# DIXIE PIPELINE COMPANY LLC — Notice of Amendment

**Citation:** CPF 220105003M  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2010-03-22

CLOSED notice of amendment citing 195.402(e)(8), 195.403(b)(1).

## Document text

Notice of Amendment involving DIXIE PIPELINE COMPANY LLC. PHMSA's enforcement data identifies the cited regulations as 195.402(e)(8),  195.403(b)(1). The case was opened on 2010-03-22 and is reported as closed as of 2011-04-06. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

220105003M_closure letter_04062011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220105003M/220105003M_closure%20letter_04062011.pdf

220105003M_closure letter_04062011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220105003M/220105003M_closure%20letter_04062011_text.pdf

220105003M_NOA_03222010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220105003M/220105003M_NOA_03222010.pdf

220105003M_NOA_03222010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220105003M/220105003M_NOA_03222010_text.pdf

220105003M_operator response_05032010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220105003M/220105003M_operator%20response_05032010.pdf

220105003M_operator response_11102010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220105003M/220105003M_operator%20response_11102010.pdf

220105003M_Order Directing Amendment_01312011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220105003M/220105003M_Order%20Directing%20Amendment_01312011.pdf

220105003M_Order Directing Amendment_01312011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220105003M/220105003M_Order%20Directing%20Amendment_01312011_text.pdf

220105003M_closure letter_04062011_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
April 6, 2011
Mr. Kevin Bodenhamer
Senior Vice President of Liquid Pipeline Operations
Dixie Pipeline Company
1100 Louisiana Street
Houston, Texas 77002-5227
CPF 2-2010-5003M
Dear Mr. Bodenhamer:
On January 31, 2011, the Pipeline and Hazardous Materials Safety Administration (PHMSA)
issued to Dixie Pipeline Company (Dixie) an Order Directing Amendment (Order), which
required Dixie to amend certain procedures.
Dixie submitted its amended procedures on March 25, 2011, and then modified its response
on March 31, 2011, after a discussion with a PHMSA senior engineer. We have reviewed the
amended procedures and have determined that Dixie has complied with the terms of the
Order. No further action is necessary with regards to the Order and this case is now closed.
Please be advised that this letter refers only to CPF 2-2010-5003M and not to any other
PHMSA pending cases. Also be advised that nothing herein states or implies that the Dixie
Pipeline Company pipeline system meets the requirements of the federal pipeline safety laws
or regulations. The pipeline system remains subject to inspection by PHMSA.
Sincerely,
Wayne T. Lemoi
Director, PHMSA Southern Region
Office of Pipeline Safety

220105003M_Order Directing Amendment_01312011_text.pdf

JAN 31 2011
Mr. Jim Collingsworth
President
Dixie Pipeline Company
1100 Louisiana Street
Houston, Texas 77002-5227
Re: CPF No. 2-2010-5003M
Dear Mr. Collingsworth:
Enclosed please find the Order Directing Amendment issued in the above-referenced case. It
makes findings of inadequate procedures and requires that Dixie Pipeline Company amend
certain of its operations, maintenance and emergencies procedures. When the terms of the
Order are completed, as determined by the Director, Southern Region, this enforcement action
will be closed. Service of the Final Order by certified mail is deemed effective upon the date of
mailing, or as otherwise provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Wayne T. Lemoi, Director, Southern Region, PHMSA
CERTIFIED MAIL - RETURN RECEIPT REQUESTED [7005 1160 0001 0041 3535]



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
)
In the Matter of )
)
DIXIE PIPELINE COMPANY, ) CPF No. 2 -2010-5003M
)
Respondent. )
____________________________________)
ORDER DIRECTING AMENDMENT
On October 14-16, October 19-22, and November 9-10, 12-13 and 16-19, 2009, pursuant to 49
U.S.C. § 60117, a representative of the Pipeline and Hazardous Materials Safety Administration
(PHMSA), Office of Pipeline Safety (OPS), conducted an on-site pipeline safety inspection of
Dixie Pipeline Company’s (Dixie or Respondent) procedures in Milner, Georgia; Petal,
Mississippi; and Lexington, South Carolina. Dixie is a subsidiary of Enterprise Products
Operating, LLC. Dixie operates approximately 1,300 miles of pipeline transporting propane to
customers in the southeastern United States.
As a result of the inspection, the Director, Southern Region, OPS (Director), issued to
Respondent, by letter dated March 22, 2010, a Notice of Amendment (Notice). The Notice
alleged inadequacies in Dixie’s Operations, Maintenance and Emergencies Manual and
proposed, in accordance with 49 C.F.R. § 190.237, that Respondent amend its Emergency
Response Plan (ERP) procedures to comply with the provisions of 49 C.F.R. § 195.402.
Dixie responded to the Notice by letter dated May 3, 2010 (Response). Respondent adequately
described the steps that it would take to correct the inadequacies outlined in Item 2 of the Notice.
However, Dixie’s response still failed to address all of the inadequacies in Item 1 of the Notice.
The Director responded to Dixie by letter dated July 13, 2010 to request that Respondent
resubmit adequate procedures to comply with Item 1 of the Notice. Dixie responded by letter
dated October 6, 2010. Dixie requested and was granted an extension of time until November
15, 2010 to resubmit its amended procedures.
Respondent resubmitted its amended procedures for Item 1 of the Notice on November 10, 2010.
Dixie’s modified procedures still failed to address all of the inadequacies described in the Notice.
In its Responses, the company did not contest the allegations that its procedures were inadequate.
Accordingly, based on a review of all the evidence, I find that Respondent has corrected the
identified inadequacies in Item 2 of the Notice. However, I find that Respondent’s procedures in
response to Item 1 of the Notice are inadequate as described below:



2
− Dixie modified Section 3.5.3.4 of its ERP to include a provision for the use of
air modeling. Although Dixie included the possible use of an air modeling
program, it placed this responsibility on the local emergency response agency
or a Hazmat contractor.
− Dixie’s modified procedures also included a drawing (Drawing 1) showing an
“IMMEDIATE PRECAUTIONARY AREA - ISOLATE ZONE BASED ON DOT
ERG” and an “INITIAL DOWNWIND EVACATION/HAZARD AREA,” which is
an illustration representing the isolation and evacuation areas to consider.
While it refers to the DOT ERG, the procedure did not provide guidance on
using the drawing, such as the width of the area downwind to be evacuated.
− Dixie included the DOT ERG as a resource in its modified procedures for use
during the “initial response phase.
” While the value of the DOT ERG is
acknowledged, it is not a replacement or supplement for a pipeline operator's
emergency response procedures.
Accordingly, I find that Respondent’s procedures are inadequate to assure safe operation of its
pipeline system. Pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237, Dixie is ordered to
make the following changes to its procedures. Respondent must:
1. Amend its written procedures to address how Dixie will determine the initial extent
and location of a vapor cloud formed during a release from its pipeline so that Dixie
can begin air monitoring from a safe area.
2. Amend its procedures to address the identification of factors that would affect the
vapor cloud, as well as guidance on how the factors will be considered in making
vapor cloud determinations.
3. Amend its procedures to include the use of vapor dispersion modeling software,
formulas, or techniques with appropriate factors to determine the vapor cloud and
safe areas from which monitoring can begin.
4. Submit the amended procedures to the Director within 30 days following receipt of
this Order.
The Director may grant an extension of time to comply with any of the required items upon a
written request timely submitted by the Respondent and demonstrating good cause for an
extension.
The terms and conditions of this Order Directing Amendment are effective upon receipt.
Failure to comply with this Order may result in administrative assessment of civil penalties not
to exceed $100,000 for each violation for each day the violation continues or in referral to the
Attorney General for appropriate relief in a district court of the United States.



3
Under 49 C.F.R. § 190.215, Respondent has a right to submit a Petition for Reconsideration of
this Final Order. The petition must be sent to: Associate Administrator, Office of Pipeline
Safety, PHMSA, 1200 New Jersey Avenue, SE, East Building, 2nd Floor, Washington, DC
20590, with a copy sent to the Office of Chief Counsel, PHMSA, at the same address. PHMSA
will accept petitions received no later than 20 days after receipt of service of this Final Order by
the Respondent, provided they contain a brief statement of the issue(s) and meet all other
requirements of 49 C.F.R. § 190.215. Unless the Associate Administrator, upon request, grants a
stay, the terms and conditions of this Final Order are effective upon service in accordance with
49 C.F.R. § 190.5.
___________________________________ __________________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/220105003M>
- Source ID: `phmsa-enforcement`
- SHA-256: `1e51c818a3005150e90a8ee299e5e29a04654dc1c8df8c801586ee46886fa875`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T19:16:35.307Z
- Document slug: `phmsa-enforcement-220105003m`

### Source metadata

```json
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  "cpf": "220105003M",
  "operator": "DIXIE PIPELINE COMPANY LLC",
  "region": "Southern",
  "pipelineType": "INTERSTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "195.402(e)(8)",
    "195.403(b)(1)"
  ],
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  "jurisdiction": "US",
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}
```
