The following text provides partial conclusions from the Executive Summary of the PHMSA report in normal text, and objections are provided in italicized text.
- 'During PHMSA's on site investigation, a bulge on the bottom of the pipe located upstream (north side) of the elbow was identified.'
- From the RSI report: "Ovalities are generally not viewed as an integrity threat by the industry".
- 'The downstream portion of the pipeline, approximately 30-feet south of the ruptured girth weld, was observed to have raised up 6 to 8 inches from its original position while it was being excavated after the rupture. '
- As noted herein, large stresses are needed for such buckling. To believe that adding and compacting dirt in the trench to bend the pipeline upward is unreasonable.
- 'The observed ovality, the bulge, and the pipe rising indicate excessive stress was present on the pipeline as a result of external loading.'
- An outward bulge in the pipeline was caused by a water hammer explosion. From the RSI report, 'The post-construction settlement or gap under the pipeline can explain the out-of-roundness of the elbow. However, this scenario does not explain the [buckle] as the amount of compressive stress at the elbow is not excessive.'
- 'This stress has been determined sufficient to initiate cracking of the failed girth weld.'
- The RSI report clearly stated that a 60-ton load on the pipeline was considered to determine an excessive hypothetical load. Water hammer cracked the weld.
- 'PHMSA attributes the primary source of external loading, and therefore bending stress, was due to inadequate soil compaction during the backfill process following the fitting replacement in 2010.'
- The RSI report does not support this conclusion.
- Per RSI, 'A more likely scenario is that a combination of several factors led to the overstress of the elbow.'
- The exact cause of pipeline bursting was unknown.

Figure 9. Oil pipeline water hammer model (Walters and Leishear, by permission of ASME).
(Image by ASME) Details DMCA
Water Hammer Modeling
In the absence of Keystone data, a different model provides insights into oil pipeline water hammers ("When the Joukowsky Equation Does Not Predict Maximum Water Hammer Pressures", click here). For a 31.1 mile long, 39.37 inch diameter pipeline, the pressure rose 343 psi from 963 psi when a downstream valve was closed (Figure 9). Considering the Leishear Stress Theory, the effective total pressure was near the range of 1649 psi to 2335 psi. Such water hammer pressures can create significant damage, even though computer modeling would be required to refine this pressure estimate.
Essential Water Hammer Analysis Required
Water hammers are the most probable cause of this Keystone pipeline failure. The bogus soil weight failure assumption does not explain the intricacies of the Keystone oil pipeline failure. Water hammer explains all observed damage.
Without doubt, a comprehensive water hammer evaluation - to include power outage effects - is required for the 2022, Kansas, Keystone pipeline failure. Along with other recommendations, I advised PHMSA in 2022 to require 'investigators to analyze water hammers and water hammer fatigue for the Keystone oil spill', and 'stop hammering pipelines to stop pipeline oil spills' (click here). As long as government agencies refuse to accept new science, oil spills will continue to flow throughout our country.
Even so, water hammers are the most probable cause of this Keystone pipeline failure. The bogus soil weight failure assumption does not explain the Keystone oil pipeline failure.
Disclaimer
This Op Ed presents the probable failure mechanism for the Keystone pipeline failure - however - significant information concerning water hammer and heavily redacted information are withheld from the public. Such information is essential for analysis and details of this analysis could be swayed.
Communications
The following letter was sent to PHMSA. Based on past experience, a response was not expected and was not received.
Keystone Pipeline Oil Spill Report Flaws
There are fundamental flaws in the PHMSA report for the Keystone pipeline oil spill. See "The 2022, Kansas, Keystone Pipeline Oil Spill Coverup". Comments?
(Article changed on Jan 06, 2026 at 12:01 AM EST)
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