South Bow Holding: Inheriting the Corporate Deception

Not just a holding company for an asset, South Bow Holding is fundamentally different. Shareholders hold the liability as revealed in this document, for an asset they do not really own. I promised primary documents, here is a primary document.

Here are a few things to understand about this construction audit for a pipeline built under special permit conditions:

-The Technical Fraud: The report claims raising testing voltage to 2,500 volts "eliminated" the holiday issue. While 2,500 volts is standard for testing thin-film coatings, it is completely insufficient if the coating is thick, disbonded, or improperly cured. The project, inspection teams, and contractor used paper compliance to declare the problem "eliminated" while actively lowering a sieve into the dirt.

-The Regulatory Cover-Up: The text proves that federal oversight did catch the fraud, but management actively covered it up. When the PHMSA auditor noticed raw holiday markings on the pipe, the UEI Resident Construction Supervisor (RCS) explicitly ordered in morning meetings that "the word ‘jeep’ should not be written next to marked holidays or potential holidays."  They intentionally scrubbed the physical text off the steel to blind the regulator.

-Burying Thermal Degradation: Lowering in had to be stopped because crews found burned coating from a hand-held propane torch on a pipe segment that had already been dropped into the ditch. They were actively burying thermal degradation from unapproved tools.

The picture shows how damaged coatings were not properly repaired and the Jeep was marked again but the picture was taken by me in Texas in 2013, not during the internal audit of 2009. The practices never changed.

In the  future we link documents like this... to failures.
This audit is for one mile of pipe out of thousands. 

When you read 76 digs by  South Bow since April 2025, this document helps understand the scope.

Regardless of the pointing to Keystone's Major Quality Management to CEO Russ Girling in 2011 things did not improve. To prove the point that the madness continued after i was forced out and the criminal behaviour was allowed to continue, These points are from a 2013 PHMSA warning letter,

.... special conditions indeed:

• The 72% Failure Rate Reality (September 2013 PHMSA Warning Letter): Corporate PR claimed their NDE and welding programs were world-class . In reality, federal inspectors caught them experiencing a staggering 72% weld rejection rate in a single week on the southern leg.

• The 50% Work Stoppage (September 2013 PHMSA Warning Letter): In another section, welding had to be completely shut down after 205 out of 425 physical welds failed NDE inspection

• Unqualified Labor and Procedures: PHMSA explicitly documented that TransCanada was using unapproved welding procedures and hiring completely unqualified welders who had been tested using improper, non-code-compliant protocols .

• While this Gulf Coastsection was inspected by Automated Ultrasonics, the gross inadequacy of the welding procedure in use for years was exposed . the rest of Keystone was inspected by inadequate radiography, the contractors friend for missing important repairs. I am very confident there will be girth weld leaks if the Inline Inspeciton does not radically improve.

This liability is built into Keystone pipeline and South Bow shareholders own this liability. The next question is what was Pipeline Hazardous Materials Safety Administration (PHMSA) doing while they were ignoring me,,,, probably not safety as shown next.

PHMSA professional Engineer explains how pipeline safety works from the regulatory point of view to Julie Dermansky at Desmog. It does not matter if you are pro oil and gas or pro  environmentalist, there is no selective editing,  the point is the legal justification and duty of care did not  appear to matter  much to anyone at PHMSA.
The people asking did not ask to have a pipeline, they were forced by land seizure, PHMSA did not  even demonstrate minimum levels of duty of care.