HTML Preview Construction Safety Warning Letter page number 1.
WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
September 10, 2013
Mr. Vern Meier
Vice President, Field Operations
TC Oil Pipeline Operations, Inc.
717 Texas Ave.
Houston, TX 77002
CPF 4-2013-5017W
Dear Mr. Meier:
During the months of June and July 2013, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected the construction of the
Keystone Gulf Coast Project.
As a result of the inspection, it appears that you have committed probable violations of the Pipeline Safety
Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable violations are:
1. §195.246 Installation of pipe in a ditch.
(a) All pipe installed in a ditch must be installed in a manner that minimized the introduction of
secondary stresses and the possibility of damage to the pipe
Transcanada did not assure that its Keystone Pipeline was installed in the ditch in a manner that minimizes the
possibility of damage to the pipe. During the field inspections, PHMSA witnessed and examined anomaly
investigations being conducted by Transcanada due to the results of a deformation tool run. The deformation tool
identified dents on the pipe that appear to be caused by secondary stresses on the pipe. Several anomaly reports
state that foam pillows and rocky terrain were present at the dig sites which may attribute to the dents on the pipe.
During the field inspections the PHMSA inspector verified the locations of several dents which were located in
the same vicinity as the foam pillow supports.
Transcanada’s TES-PROJ-LPCS-US Onshore Liquid Pipeline Construction Specification, Section 22.4 states
“when foam pillows are installed, approved fill will be supplied to provide a uniform support along the underside
of the pipe.” Assuring a uniform fill underneath the pipe at all foam pillow locations will minimize external
stresses on the pipe. In addition, Section 22.5 states that “rock, stone laden soil, or frozen material shall not be
backfilled into the trench until the pipe has been surrounded by stone free soil.”