# COLONIAL PIPELINE CO — Warning Letter

**Citation:** CPF 120185020W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2018-09-13

CLOSED warning letter citing 195.430(a).

## Document text

Warning Letter involving COLONIAL PIPELINE CO. PHMSA's enforcement data identifies the cited regulation as 195.430(a). The case was opened on 2018-09-13 and is reported as closed as of 2018-09-13. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120185020W_Warning Letter_09132018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120185020W/120185020W_Warning%20Letter_09132018.pdf

120185020W_Warning Letter_09132018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120185020W/120185020W_Warning%20Letter_09132018_text.pdf

120185020W_Warning Letter_09132018_text.pdf

WARNING LETTER
OVERNIGHT EXPRESS DELIVERY
September 13, 2018
Joseph A. Blount, Jr.
President and Chief Executive Officer
Colonial Pipeline Company
1185 Sanctuary Parkway, Suite 100
Alpharetta, GA 30009
CPF 1-2018-5020W
Dear Mr. Blount:
From June 20-22, 2017, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), Office of Pipeline Safety (OPS) pursuant to Chapter 601 of 49 United
States Code (U.S.C.) inspected Colonial Pipeline Company’s (Colonial) Dorsey Junction facility
in Woodbine, Maryland.
As a result of the inspection, it is alleged that Colonial has committed probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and
the probable violation is:
1. § 195.430 Firefighting Equipment.
Each operator shall maintain adequate firefighting equipment at each pump station
and breakout tank area. The equipment must be—
(a) In proper operating condition at all times;
Colonial did not maintain its firefighting equipment in proper operating condition at all times at
the breakout tank area in Dorsey Junction facility.
According to Colonial’s Fire Prevention & Response Plan Dorsey Junction 2/1/2014 (FPRP), on
page 11, under section D. Site Features & On-site Resources, “Dorsey Junction’s current fire
protection system consists of an underground firewater piping system terminating in hydrants
throughout the tank area.” At the time of the inspection, Colonial did not have records to
demonstrate that it maintained its fire protection system for the last 10 years. In addition, Colonial



CPF 1-2018-5020W
stated that the underground firewater piping had deteriorated and would not be able to transport
water to the breakout tank area to fight an incipient fire. Colonial had no other firefighting
equipment at the breakout tank area. Furthermore, Colonial had a fire pump that drafted water
from a pond, and which was connected to the underground firewater piping, but was no longer
operable since 2012.
Nevertheless, Colonial had a documented plan with local emergency response agencies and
contracted firefighting firms to provide expertise, equipment, tools, and materials to control and
extinguish non-incipient fires, in the FPRP. However, Colonial indicated that the local fire
department determined that it needed a hose to reach the tank area from the pond in 2015.
Based on the foregoing information, Colonial could not ensure that it had firefighting equipment,
in proper operating condition at all times, to fight all types of fires at its breakout tank area in
accordance with § 195.430(a).
Colonial informed the PHMSA inspector that it anticipates having a fire protection system installed
and operational in late 2018.
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$209,002 per violation per day the violation persists, up to a maximum of $2,090,022 for a related
series of violations. For violations occurring prior to November 2, 2015, the maximum penalty
may not exceed $200,000 per violation per day, with a maximum penalty not to exceed $2,000,000
for a related series of violations. We have reviewed the circumstances and supporting documents
involved in this case, and have decided not to conduct additional enforcement action or penalty
assessment proceedings at this time. We advise you to correct the item identified in this letter.
Failure to do so will result in Colonial being subject to additional enforcement action.
Please be advised that all material you submit in response to this enforcement action is subject to
being made publicly available. If you believe that any portion of your responsive material qualifies
for confidential treatment under 5 U.S.C. 552(b), along with the complete original document you
must provide a second copy of the document with the portions you believe qualify for confidential
treatment redacted and an explanation of why you believe the redacted information qualifies for
confidential treatment under 5 U.S.C. 552(b).
No reply to this letter is required. If you choose to reply, please submit all correspondence in this
matter to Robert Burrough, Director, PHMSA Eastern Region, 820 Bear Tavern Road, Suite 103,
West Trenton, NJ 08628. Please refer to CPF 1-2018-5020W on each document you submit, and
whenever possible provide a signed PDF copy in electronic format. Smaller files may be emailed
to robert.burrough@dot.gov. Larger files should be sent on a CD accompanied by the original
paper copy to the Eastern Region Office.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
120185020W_Warning Letter_09132018_text
Page 2 of 2

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/120185020W>
- Source ID: `phmsa-enforcement`
- SHA-256: `16eef0549c45a6c4e0d0aa0ae0632a3c5da1c84586cfdeae91e27962e9f3ece5`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-23T19:01:56.267Z
- Document slug: `phmsa-enforcement-120185020w`

### Source metadata

```json
{
  "cpf": "120185020W",
  "operator": "COLONIAL PIPELINE CO",
  "region": "Eastern",
  "pipelineType": "INTERSTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "195.430(a)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 2,
  "attachments": [
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      "name": "120185020W_Warning Letter_09132018.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/120185020W/120185020W_Warning%20Letter_09132018.pdf",
      "bytes": 193573,
      "category": "agency_document"
    },
    {
      "name": "120185020W_Warning Letter_09132018_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/120185020W/120185020W_Warning%20Letter_09132018_text.pdf",
      "bytes": 368877,
      "category": "agency_document"
    }
  ],
  "extractedAgencyDocumentCount": 1,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "COLONIAL PIPELINE CO"
}
```
