{"operation":"document","citation":"CPF 420165025M","title":"TC OIL PIPELINE OPERATIONS INC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-07-28","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(a), 195.410(a)(1), 195.434.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420165025m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420165025m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420165025m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420165025M","body":"Notice of Amendment involving TC OIL PIPELINE OPERATIONS INC. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.410(a)(1),  195.434. The case was opened on 2016-07-28 and is reported as closed as of 2019-07-09. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420165025M_Closure Letter_07092019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165025M/420165025M_Closure%20Letter_07092019.pdf\n\n420165025M_Closure Letter_07092019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165025M/420165025M_Closure%20Letter_07092019_text.pdf\n\n420165025M_Notice of Amendment_07282016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165025M/420165025M_Notice%20of%20Amendment_07282016.pdf\n\n420165025M_Notice of Amendment_07282016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165025M/420165025M_Notice%20of%20Amendment_07282016_text.pdf\n\n420165025M_Closure Letter_07092019_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJuly 9, 2019\nPaul Miller\nExecutive Vice-President and President Liquids Pipelines\nTC Oil Pipeline Operations, Inc.\n450 1st Street S.W.\nCalgary, Alberta, Canada T2P5H1\nCPF 4-2016-5025M\nDear Mr. Miller:\nFrom May 3, 2016 to May 4, 2016, pursuant to 49 U.S.C. § 60117, a representative of the Pipeline\nand Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),\nconducted an inspection of TC Oil Pipeline Operations, Inc., a subsidiary of TransCanada\nCorporation (TransCanada or Respondent), including its written procedures and records for the\npipeline facilities of the Gulf Coast Pipeline. TransCanada owns and operates the Keystone\nPipeline System, including the Gulf Coast Pipeline. As a result of the inspection, TransCanada\nwas issued a Notice of Amendment (Notice) on July 28, 2016.\nTransCanada responded to the Notice by letter dated August 30, 2016 (Response), and submitted\nrevised procedures. TransCanada submitted its amended procedures with revision history for their\nOM manual on February 27, 2017.\nMy staff reviewed the amended procedures, and it appears that the inadequacies outlined in this\nOrder of Directing Amendment have been corrected. This letter is to inform you no further action\nis necessary and this case is now closed. Thank you for your cooperation.\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\n\n420165025M_Notice of Amendment_07282016_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJuly 28, 2016\nMr. Vern Meier\nVice President Field Operations\nTC Oil Pipeline Operations, Inc.\n717 Texas Avenue\nHouston, TX 77002\nCPF 4-2016-5025M\nDear Mr. Meier:\nOn May 3-4, 2016, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nprocedures at pump station facility in Liberty County, TX and various mainline valve (MLV)\nstations along pipeline route from Liberty County, TX to Houston Tank Terminal in Houston,\nTX.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within\nTC’s plans or procedures as described below:\n1. §195.402 Procedural manual for operations, maintenance, and emergencies\n(a) General. Each operator shall prepare and follow for each pipeline system a manual\nof written procedures for conducting normal operations and maintenance activities\nand handling abnormal operations and emergencies. This manual shall be reviewed\nat intervals not exceeding 15 months, but at least once each calendar year, and\nappropriate changes made as necessary to insure that the manual is effective. This\nmanual shall be prepared before initial operations of a pipeline system commence,\nand appropriate parts shall be kept at locations where operations and maintenance\nactivities are conducted.\n\n\n\n§195.434 Signs\n(a) Each operator must maintain signs visible to the public around each pumping\nstation and breakout tank area. Each sign must contain the name of the operator\nand a telephone number (including area code) where the operator can be reached at\nall times.\nThe operator’s current procedure (TransCanada O&M Manual – U.S. Hazardous Liquids\nPipelines, 195.434 Signs, Section 3 and 4) is not adequate for signs. The Operator must amend\ntheir procedures to address the requirements of §195.434. More specifically, TransCanada must\nstate how compliance will be achieved including the placement and spacing of the signs.\n2. §195.402 Procedural manual for operations, maintenance, and emergencies\n(a) General. Each operator shall prepare and follow for each pipeline system a manual\nof written procedures for conducting normal operations and maintenance activities\nand handling abnormal operations and emergencies. This manual shall be reviewed\nat intervals not exceeding 15 months, but at least once each calendar year, and\nappropriate changes made as necessary to insure that the manual is effective. This\nmanual shall be prepared before initial operations of a pipeline system commence,\nand appropriate parts shall be kept at locations where operations and maintenance\nactivities are conducted.\n§195.410 Line markers\n(a) Except as provided in paragraph (b) of this section, each operator shall place and\nmaintain line markers over each buried pipeline in accordance with the following:\n(1) Markers must be located at each public road crossing, at each railroad crossing,\nand in sufficient number along the remainder of each buried line so that its location\nis accurately known.\nThe operator’s current procedure (TransCanada O&M Manual – U.S. Hazardous Liquids\nPipelines, 195.410 Line Markers, Section 3) need to include detail procedures for line markers\naddressing the requirements in Appendix U, PHMSA Special Conditions #19a and #40.\nTransCanada agreed to comply with these special conditions and must include the requirements\nin their O&M procedures, including additional protective marking when the 48-inches of cover\nare not maintained and line-of-sight marking where required by the conditions.\nAppendix U, PHMSA Special Conditions:\n\n\n\n19) Depth of Cover: Keystone shall construct the pipeline with soil cover at a minimum depth of\nforty-eight (48) inches in all areas, except in consolidated rock. The minimum depth in consolidated\nrock areas is thirty-six (36) inches. Keystone shall maintain a depth of cover of 48 inches in\ncultivated areas and a depth of 42 inches in all other areas. In cultivated areas where conditions\nprevent the maintenance of forty-eight (48) inches of cover, Keystone must employ additional\nprotective measures to alert the public and excavators to the presence of the pipeline. The additional\nmeasures shall include:\na) Placing warning tape and additional line-of-sight pipeline markers along the affected pipeline\nsegment,\n40) Pipeline Markers: Keystone must install and maintain line-of-sight markings on the 22 pipeline\nexcept in agricultural areas or large water crossings such as lakes where line of sight signage is not\npractical. The marking of pipelines may also be subject to environmental permits and local\nrestrictions. Additional markers must be placed along the pipeline in areas where the pipeline is\nburied less than forty-eight (48) inches. Keystone must replace removed or damaged line-of-sight\nmarkers, during pipeline patrols and maintenance on the right-of-way. Keystone, at a minimum, must\nidentify and replace any missing or damaged line-of-sight markers during pipeline patrols\n(Condition 41). If pipeline patrolling for Condition 41 is performed via aerial patrolling and cannot\nconsistently identify areas with missing or damaged line-of-sight markers, then Keystone must on a\ncalendar year basis, not to exceed fifteen (15) months, conduct ground patrols.\nIt is requested (not mandated) that TC Oil Pipeline Operations, Inc. maintain documentation of\nthe safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to R. M. Seeley, Director,\nSouthwest Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 4-2016-5025M and, for each document you submit,\nplease provide a copy in electronic format whenever possible.\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings","truncated":false,"body_characters":8540}