# Failure Report- Explorer Pipeline Co 8/17/09

- **operation:** document
- **citation:** PHMSA FIR, Explorer Pipeline Co, 2009-08-17
- **title:** Failure Report- Explorer Pipeline Co 8/17/09
- **source type:** incident
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2010-11-10
- **effective on:** 2009-08-17
- **summary:** Explorer Pipeline Co; Hazardous Liquid; OK; failure 2009-08-17; apparent cause: Corrosion External.
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- **source url:** https://www.phmsa.dot.gov/safety-reports/failure-report-explorer-pipeline-co-81709
**body:**

<<<PAGE 1>>>

Memorandum
U. S. Department
of Transportation
Pipeline and
Hazardous Materials
Safety Administration
Date: November 2, 2010
To: R. M. Seeley, Regional Director, Southwest Region
From: Gene Roberson, General Engineer
Subject: Incident Report: Explorer Pipeline
OPID: 4805 Unit No.: 2494
Date of incident: August 17, 2009
Atoka County, OK.
NRC Report # 915209
ODES Report # 20090261
Summary:
At approximately 5:45 pm CST, August 17, 2009, Explorer Pipeline Company
(Explorer) identified a product release on their Greenville, TX – Glenpool, OK 28-inch
OD pipeline in Atoka County, OK. Explorer’s aerial patrol observed an area of dead
vegetation at Mile Post (MP) 398.7 on the ROW, and ground crews confirmed the
indication of a release from the odor of petroleum products in the area. The pipeline
was shut in immediately, and crews mobilized to excavate the pipeline for confirmation
of the release and repair of the pipeline. The section of the pipeline where the release
occurred has an MOP of 751 psig and was operating at 129 psig when the release was
confirmed. Records indicate the highest operating pressure for the previous 30 days
was 682 psig. Upon excavation a 2% dent with metal loss was found on the bottom of
the pipe (6 o’clock position) with product being released. Explorer made a temporary
repair of the location by installing a PLIDCO Repair Sleeve over the area until a
permanent repair could be made. The pipeline was returned to service at a reduced
pressure, pending scheduling of a shutdown to allow a permanent repair to be
completed. Fifty (50) barrels (bbls) of diesel fuel were estimated to have been released
as a result of this accident, and none was recovered.
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During the week of October 26, 2009 the pipeline was shut in, and a permanent repair
was made by installing a section of new pipe in the area of the release. A 10-foot
section of pipe containing the failure was then transported to the DNV Columbus Inc.
laboratory facility in Dublin, Ohio, for a metallurgical failure investigation. The pipe
section in which the release occurred is 28-inch OD, 0.281-inch nominal wall thickness
(wt), API 5L X52 line pipe with double submerged arc welded (DSAW) longitudinal
seams. The pipe was manufactured in 1971 by STELCO Corporation. The
metallurgical analysis determined the probable cause of the release to be through wall
cracking consistent with near-neutral pH stress corrosion cracking (SCC).
At the time of the release, Explorer was in the process of re-evaluating previous in-line
inspection tool (ILI) log run data from 2007 and 2008 ILI runs and performing 58
additional verification digs associated with this segment of pipeline, and no SCC was
identified in these excavations. Specifically, there were 4 additional locations that had
ILI data characteristics similar to the anomaly at the release location, and these 4 “dent-
like” locations were excavated and examined. None of the 4 additional excavation sites
contained SCC.
As a result of the accident, Explorer hired vendors to support additional data analysis,
excavations, and inspections. In all previous excavations on this pipeline segment,
SCC has only been identified in the presence of deformation anomalies (dents);
therefore, post accident activities were tailored to address SCC within dents.
Explorer’s program for identifying sites of possible SCC in dents had focused on dents
> 2% OD in depth, but the dent at the failure site was less than 2%. Therefore, ILI tool
data was analyzed for all areas where dents were present in areas of metal loss. The
analysis identified 328 locations for evaluation, and 15 sites were identified for further
examination. The excavations performed did not reveal any additional locations with
SCC present.
Background:
The PHMSA inspection unit in which the release occurred (SMART # 2494) has a
history of failures due to SCC in 2004 and in 2007 resulting in a Corrective Action
Order (CAO) being issued to Explorer (CPF 4-2007-5021H). CPF 4-2007-5021H was
closed on 09/01/2009.
System description:
Explorer Pipeline Company owns and operates a 1400-mile pipeline system
transporting primarily gasoline, fuel oil and jet fuel from Gulf Coast refineries and
import facilities in Texas and Louisiana into the Midwestern United States. The system
was constructed in 1971. The main line pipe size is 28-inch OD from Port Arthur,
Texas, to Glenpool, Oklahoma (southern line segment) and 24-inch OD from Glenpool
to Hammond, Indiana (northern line segment). There are 20 pump stations located
throughout the system, which has a current total line capacity of 560,000 barrels per
day on the southern segment and 350,000 barrels per day on the northern segment.
Explorer's pipeline operations are monitored and controlled from the Explorer Control
Center located in the Tulsa Headquarters office.
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The release occurred in PHMSA Inspection Unit 2494 – Central District. The pipeline
unit travels from Greenville, TX to Glenpool, OK, to the OK-MO State line near Joplin,
MO and consists of 31 tanks and 432 miles of pipeline. The main line was installed in
1971 consisting of 28-inch OD, 0.280/0.312-inch wt, API 5L X-52, DSAW
longitudinal seam line pipe from STELCO. The line has coal tar enamel external
coating.
Findings:
The line pipe in which the release occurred was evaluated during the installation of the
PLIDCO sleeve. Evidence of a dent with metal loss was present but no further details
were obtainable at that time. On October 26, 2009 the section of pipe containing the
probable leak was removed from the Explorer system and transported to DNV
Columbus for metallurgical analysis. The metallurgical analysis determined the
probable cause of the release to be through wall cracking consistent with near-neutral
pH SCC.
Conclusions:
Stress corrosion cracking in the Greenville to Glenpool segment of pipeline has only
been found to date in conjunction with external dents/deformation of the pipe.
Appendices:
• Appendix A – NRC # 915209
• Appendix B – PHMSA F 7000.1 - ODES #20090261
• Appendix C – DNV Metallurgical Report ENAUS813BPADG
Privileged and Confidential
• Appendix D – DNV Incident Summary ANEUS822TARP
Privileged and Confidential
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Appendix A
NRC Report
915209

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Page 1 of 2
NATIONAL RESPONSE CENTER 1-800-424-8802
*** For Public Use ***
Information released to a third party shall comply with any
applicable federal and/or state Freedom of Information and Privacy Laws
Incident Report # 915209
INCIDENT DESCRIPTION
*Report taken at 18:58 on 17-AUG-09
Incident Type: PIPELINE
Incident Cause: UNKNOWN
Affected Area:
The incident was discovered on 17-AUG-09 at 17:45 local time.
Affected Medium: SOIL SOIL
____________________________________________________________________________
SUSPECTED RESPONSIBLE PARTY
Organization: EXPLORER PIPELINE
TULSA , OK 74101
Type of Organization: PRIVATE ENTERPRISE
____________________________________________________________________________
INCIDENT LOCATION
1/2 MILE NORTH 1/2 MILE WEST County: ATOKA
INTERSECTION OF OVERLAND TRAIL AND
BUTTERFIELD
City: CANEY, OKLAHOMA State: OK
Distance from City: 10.5 MILES
Direction from City: WNW
Latitude: 34° 17' 34" N
Longitude: 096° 20' 50" W
Section: 15 Township: 3S Range: 9E MP 398.8 GREENVILLE TO GLENPOOL 28 NE/4 SW/4
S15 R3S T9E ATOKA COUNTY,
____________________________________________________________________________
RELEASED MATERIAL(S)
CHRIS Code: ODS Official Material Name: OIL: DIESEL
Also Known As: FUEL OIL - DIESEL 2
Qty Released: 0 UNKNOWN AMOUNT
____________________________________________________________________________
DESCRIPTION OF INCIDENT
REPORTING A PIPELINE RELEASE. NO FREE PRODUCT AT THIS TIME. NO IMPACT TO WATER.
DEAD VEGETATION ON ROW AND SMELL OF PETROLEUM PRODUCT IN SOIL. EXCAVATION AND
ENVIRONMENTAL CONTRACTORS ON SITE IN ADDITION TO COMPANY PERSONNEL. WILL BEGIN
EXCAVATION TONIGHT TO DETERMINE THE EXTENT OF OF INCIDENT. REPORTING AT THIS TIME
DUE TO COSTS EXPECTED TO EXCEED $50,000. NO VOLUME ESTIMATE AVAILABLE.
____________________________________________________________________________
INCIDENT DETAILS
Pipeline Type: TRANSMISSION
DOT Regulated: YES
Pipeline Above/Below Ground: BELOW
Exposed or Under Water: NO
Pipeline Covered: UNKNOWN
____________________________________________________________________________
DAMAGES
Fire Involved: NO Fire Extinguished: UNKNOWN
INJURIES: NO Hospitalized: Empl/Crew: Passenger:
FATALITIES: NO Empl/Crew: Passenger: Occupant:
EVACUATIONS: NO Who Evacuated: Radius/Area:
Damages: YES $50000
Length of Direction of
Closure Type Description of Closure Closure Closure
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Air: N
Road: N Major
Artery: N
Waterway: N
Track: N
Passengers Transferred: NO
Environmental Impact: YES/VEGETATION
Media Interest: NONE Community Impact due to Material:
____________________________________________________________________________
REMEDIAL ACTIONS
EXCAVATION AND ENVIRONMENTAL CONTRACTORS ON-SITE.
Release Secured: YES
Release Rate:
Estimated Release Duration:
____________________________________________________________________________
WEATHER
Weather: PARTLY CLOUDY, 90ºF Wind speed: 15 MPH Wind direct
____________________________________________________________________________
ADDITIONAL AGENCIES NOTIFIED
Federal: N/A
State/Local: OKLAHOMA CORPORATION COMMISSION
State/Local On Scene: N/A
State Agency Number: N/A
____________________________________________________________________________
NOTIFICATIONS BY NRC
USCG ICC (ICC ONI)
17-AUG-09 19:34
COLORADO INFO ANALYSIS CENTER (FUSION CENTER)
17-AUG-09 19:34
DOT CRISIS MANAGEMENT CENTER (MAIN OFFICE)
17-AUG-09 19:34
U.S. EPA VI (MAIN OFFICE)
17-AUG-09 19:38
NATIONAL INFRASTRUCTURE COORD CTR (MAIN OFFICE)
17-AUG-09 19:34
NOAA RPTS FOR OK (MAIN OFFICE)
17-AUG-09 19:34
OFC OF ENV SVC CHEROKEE NATIONS OK (MAIN OFFICE)
17-AUG-09 19:34
PIPELINE & HAZMAT SAFETY ADMIN (OFFICE OF PIPELINE SAFETY (AUTO))
17-AUG-09 19:34
PIPELINE & HAZMAT SAFETY ADMIN (OFFICE OF PIPELINE SAFETY WEEKDAYS (VERBAL))
17-AUG-09 19:39
DEQ OKLAHOMA (MAIN OFFICE)
17-AUG-09 19:34
WEB REPORT (WEB REPORT SUBMITTER)
17-AUG-09 19:34
____________________________________________________________________________
ADDITIONAL INFORMATION
///////WEB REPORT//////
___________________________________________________________________________
*** END INCIDENT REPORT # 915209 ***
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Appendix B
ODES Report
2009 0261

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NOTICE: This report is required by 49 CFR Part 195. Failure to report can result in a civil penalty not to exceed $25,000 for each violation for each day that such violation persists except that the maximum civil penalty shall not exceed $500,000 as provided in 49 USC 60122 Form Approved
OMB No. 2137-0047
U.S. Department of Transportation
Research and Special Programs
Administration
ACCIDENT REPORT – HAZARDOUS LIQUID
PIPELINE SYSTEMS
Report Date
No.
(DOT Use Only)
INSTRUCTIONS
Important: Please read the separate instructions for completing this form before you begin. They clarify the
information requested and provide specific examples. If you do not have a copy of the instructions,
you can obtain one from the Office Of Pipeline Safety Web Page at http://ops.dot.gov.
PART A – GENERAL REPORT INFORMATION
Original Report Supplemental Report Final Report
1. a. Operator's OPS 5-digit Identification Number (if known) / ____________/
2. b. If Operator does not own the pipeline, enter Owner’s OPS 5-digit Identification Number (if known) / ___ /
c. Name of Operator ______________________________________________________________________________________
d. Operator street address _______________________________________________________________________________
e. Operator address ______________________________________________________________________________________
City, County, State and Zip Code
IMPORTANT: IF THE SPILL IS SMALL, THAT IS, THE AMOUNT IS AT LEAST 5 GALLONS BUT IS LESS THAN 5 BARRELS,
COMPLETE THIS PAGE ONLY, UNLESS THE SPILL IS TO WATER AS DESCRIBED IN 49 CFR §195.52(A)(4) OR IS OTHERWISE
REPORTABLE UNDER §195.50 AS REVISED IN CY 2001.
2. Time and date of the accident
/ / / / / / / /
hr. month day year
3. Location of accident
(If offshore, do not complete a through d. See Part C.1)
a. Latitude: _____ Longitude:
__________
(if not available, see instructions for how to provide specific location)
b. _________________________________________________
City, and County or Parish
c. _________________________________________________
State and Zip Code
d. Mile post/valve station or survey station no.
(whichever gives more accurate location)
_________________________________
4. Telephone report
/ / / / / / / /
NRC Report Number month day year
5. Losses (Estimated)
Public/Community Losses reimbursed by operator:
Public/private property damage $_______________
Cost of emergency response phase $_______________
Cost of environmental remediation $_______________
Other Costs $_______________
(describe) _____________________________________
Operator Losses:
Value of product lost $_______________
Value of operator property damage $_______________
Other Costs $_______________
(describe) _____________________________________
Total Costs $_______________
6. Commodity Spilled Yes No
(If Yes, complete Parts a through c where applicable)
a. Name of commodity spilled ___________________________
b. Classification of commodity spilled:
HVLs /other flammable or toxic fluid which is a gas at ambient conditions
CO2 or other non-flammable, non-toxic fluid which is a gas at ambient conditions
Gasoline, diesel, fuel oil or other petroleum product which is a liquid at ambient conditions
Crude oil
c. Estimated amount of commodity
involved :
Barrels
Gallons (check only if spill is
less than one barrel)
Amounts:
Spilled : ____________
Recovered: ____________
CAUSES FOR SMALL SPILLS ONLY (5 gallons to under 5 barrels) : (For large spills [5 barrels or greater] see Part H)
Corrosion Natural Forces Excavation Damage Other Outside Force Damage
Material and/or Weld Failures Equipment Incorrect Operation Other
PART B – PREPARER AND AUTHORIZED SIGNATURE
(type or print) Preparer's Name and Title Preparer's E-mail Address Area Code and Telephone Number
Area Code and Facsimile Number
Authorized Signature (type or print) Name and Title Date Area Code and Telephone Number
Form RSPA F 7000-1 ( 01-2001 ) Page 1 of 4
OPS Data Facsimile

<<<PAGE 9>>>

PART C – ORIGIN OF THE ACCIDENT (Check all that apply)
1. Additional location information
a. Line segment name or ID _______________________
b. Accident on Federal land other than Outer Continental
Shelf Yes No
c. Is pipeline interstate? Yes No
Offshore: Yes No (complete d if offshore)
d. Area ___________________ Block # ______________
State / / or Outer Continental Shelf
2. Location of system involved (check all that apply)
Operator’s Property
Pipeline Right of Way
High Consequence Area (HCA)?
Describe HCA____________________________________
3. Part of system involved in accident
Above Ground Storage Tank
Cavern or other below ground storage facility
Pump/meter station; terminal/tank farm piping and
equipment, including sumps
Other Specify: _________________________________
Onshore pipeline, including valve sites
Offshore pipeline, including platforms
If failure occurred on Pipeline, complete items a - g:
4. Failure occurred on
Body of Pipe Pipe Seam Scraper Trap
Pump Sump Joint
Component Valve Metering Facility
Repair Sleeve Welded Fitting Bolted Fitting
Girth Weld
Other (specify)
Year the component that failed was installed: / /
5. Maximum operating pressure (MOP)
a. Estimated pressure at point and time of accident:
____ PSIG
b. MOP at time of accident:
___________PSIG
c. Did an overpressurization occur relating to the accident?
Yes No
a. Type of leak or rupture
Leak: Pinhole Connection Failure (complete sec. H5)
Puncture, diameter (inches) _________
Rupture: Circumferential – Separation
Longitudinal – Tear/Crack, length (inches) __________
Propagation Length, total, both sides (feet) _________
N/A
Other _______________________________
b.Type of block valve used for isolation of immediate section:
Upstream: Manual Automatic Remote Control
Check Valve
Downstream: Manual Automatic Remote Control
Check Valve
c. Length of segment isolated _______ ft
d. Distance between valves _______ ft
e. Is segment configured for internal inspection tools? Yes No
f. Had there been an in-line inspection device run at the point of
failure? Yes No Don’t Know
Not Possible due to physical constraints in the system
g. If Yes, type of device run (check all that apply)
High Resolution Magnetic Flux tool Year run: ______
Low Resolution Magnetic Flux tool Year run: ______
UT tool Year run: ______
Geometry tool Year run: ______
Caliper tool Year run: ______
Crack tool Year run: ______
Hard Spot tool Year run: ______
Other tool Year run: ______
PART D – MATERIAL SPECIFICATION PART E – ENVIRONMENT
1. Nominal pipe size (NPS) / / in.
2. Wall thickness / / in.
3. Specification SMYS / /
4. Seam type
5. Valve type
6. Manufactured by in year / /
1. Area of accident In open ditch
Under pavement Above ground
Underground Under water
Inside/under building Other ____________
2. Depth of cover: inches
PART F – CONSEQUENCES
1. Consequences (check and complete all that apply)
a. Fatalities Injuries c. Product ignited Yes No d. Explosion Yes No
Number of operator employees: _______ _______ e. Evacuation (general public only) / / people
Contractor employees working for operator: _______ _______ Reason for Evacuation:
General public: _______ _______ Precautionary by company
Totals: _______ _______ Evacuation required or initiated by public official
b. Was pipeline/segment shutdown due to leak? Yes No f. Elapsed time until area was made safe:
If Yes, how long? ______ days ______ hours _____ minutes / / hr. / / min.
2. Environmental Impact
a. Wildlife Impact: Fish/aquatic Yes No e. Water Contamination: Yes No (If Yes, provide the following)
Birds Yes No Amount in water _________ barrels
Terrestrial Yes No Ocean/Seawater No Yes
b. Soil Contamination Yes No Surface No Yes
If Yes, estimated number of cubic yards: _________
Groundwater No Yes
c. Long term impact assessment performed: Yes No Drinking water No Yes (If Yes, check below.)
d. Anticipated remediation Yes No Private well Public water intake
If Yes, check all that apply: Surface water Groundwater Soil Vegetation Wildlife
Form RSPA F 7000-1 ( 01-2001 ) OPS Data Facsimile
Page 2 of 4

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PART G – LEAK DETECTION INFORMATION
1. Computer based leak detection capability in place? 2. Was the release initially detected by? (check one): Yes No
CPM/SCADA-based system with leak detection
Static shut-in test or other pressure or leak test
Local operating personnel, procedures or equipment
Remote operating personnel, including controllers
Air patrol or ground surveillance
A third party Other (specify) _________________
3. Estimated leak duration days ____ hours ____
PART H – APPARENT CAUSE
Important: There are 25 numbered causes in this Part H. Check the box corresponding to the
primary cause of the accident. Check one circle in each of the supplemental categories
corresponding to the cause you indicate. See the instructions for guidance.
H1 – CORROSION
1. External Corrosion
2. Internal Corrosion
(Complete items a – e
where applicable.) b. Visual Examination
Localized Pitting
General Corrosion
Other ____________________
a. Pipe Coating
c. Cause of Corrosion
Bare
Galvanic Atmospheric
Coated
Stray Current Microbiological
Cathodic Protection Disrupted
Stress Corrosion Cracking
Selective Seam Corrosion
Other ____________________
d. Was corroded part of pipeline considered to be under cathodic protection prior to discovering accident?
No Yes, Year Protection Started: / /
e. Was pipe previously damaged in the area of corrosion?
No Yes => Estimated time prior to accident: / / years / / months Unknown
H2 – NATURAL FORCES
3. Earth Movement => Earthquake Subsidence Landslide Other
4. Lightning
5. Heavy Rains/Floods => Washouts Flotation Mudslide Scouring Other
6. Temperature => Thermal stress Frost heave Frozen components Other
7. High Winds
H3 – EXCAVATION DAMAGE
8. Operator Excavation Damage (including their contractors/Not Third Party)
9. Third Party (complete a-f)
a. Excavator group
General Public Government Excavator other than Operator/subcontractor
b. Type: Road Work Pipeline Water Electric Sewer Phone/Cable
Landowner-not farming related Farming Railroad
Other liquid or gas transmission pipeline operator or their contractor
Nautical Operations Other ________
c. Excavation was: Open Trench Sub-strata (boring, directional drilling, etc…)
d. Excavation was an ongoing activity (Month or longer) Yes No e. Did operator get prior notification of excavation activity?
If Yes, Date of last contact /_________/
Yes; Date received: / / mo. / / day / ______/ yr. No
Notification received from: One Call System Excavator Contractor Landowner
f. Was pipeline marked as result of location request for excavation? No i. Temporary markings: Flags Stakes Paint
ii. Permanent markings:
iii. Marks were (check one) : Accurate Not Accurate
iv. Were marks made within required time? Yes No
H4 – OTHER OUTSIDE FORCE DAMAGE
10. Fire/Explosion as primary cause of failure => Fire/Explosion cause: Man made Natural
11. Car, truck or other vehicle not relating to excavation activity damaging pipe
12. Rupture of Previously Damaged Pipe
13. Vandalism
Yes (If Yes, check applicable items i - iv)
Form RSPA F 7000-1 ( 01-2001 ) Page 3 of 4
OPS Data Facsimile

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H5 – MATERIAL AND/OR WELD FAILURES
Material
14. Body of Pipe => Dent Gouge Bend Arc Burn Other
15. Component => Valve Fitting Vessel Extruded Outlet Other
16. Joint => Gasket O-Ring Threads Other
Weld
17. Butt => Pipe Fabrication Other
18. Fillet => Branch Hot Tap Fitting Repair Sleeve Other
19. Pipe Seam => LF ERW DSAW Seamless Flash Weld
HF ERW SAW Spiral Other
Complete a-g if you indicate any cause in part H5.
a. Type of failure:
Construction Defect => Poor Workmanship Procedure not followed Poor Construction Procedures
Material Defect
b. Was failure due to pipe damage sustained in transportation to the construction or fabrication site? Yes No
c. Was part which leaked pressure tested before accident occurred? Yes, complete d-g No
d. Date of test: / / yr. / / mo. / / day
e. Test medium: Water Inert Gas Other
f. Time held at test pressure: / / hr.
g. Estimated test pressure at point of accident: PSIG
H6 – EQUIPMENT
20. Malfunction of Control/Relief Equipment => Control valve Instrumentation SCADA Communications
Block valve Relief valve Power failure Other
21. Threads Stripped, Broken Pipe Coupling => Nipples Valve Threads Dresser Couplings Other
22. Seal Failure => Gasket O-Ring Seal/Pump Packing Other
H7 – INCORRECT OPERATION
23. Incorrect Operation
a. Type: Inadequate Procedures Inadequate Safety Practices Failure to Follow Procedures
Other _______________________________________
b. Number of employees involved who failed a post-accident test: drug test: / / alcohol test /_________/
H8 – OTHER
24. Miscellaneous, describe:
25. Unknown
Investigation Complete Still Under Investigation (submit a supplemental report when investigation is complete)
PART I – NARRATIVE DESCRIPTION OF FACTORS CONTRIBUTING TO THE EVENT (Attach additional sheets as necessary)
Form RSPA F 7000-1 (01-2001 ) Page 4 of 4
OPS Data Facsimile

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Appendix C
Metallurgical Report
Privileged and Confidential

<<<PAGE 13>>>

•
DNV
DET NORSKE VERITAS
Final Report
Metallurgical Analysis of 28-Inch
Diameter Double Submerged
Arc-Welded Longitudinal Seam
Explorer Pipeline Company
Tulsa, Oklahoma
Report No./DNV Reg No.: ENAUS813BPADG (EP008510)
December 31, 2009
Privileged and Confidential

<<<PAGE 14>>>

Appendix D
Incident Summary
Privileged and Confidential

<<<PAGE 15>>>

DNV
Det Norske Veritas
Final Report
Atoka MP 398 Incident Summary
Explorer Pipeline Company
Tulsa, Oklahoma
Report No./DNV Reg. No.: ANEUS822TARP (20100728) - Version 1
August 02, 2010
Privileged and Confidential
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