# COLONIAL PIPELINE CO — Warning Letter

**Citation:** CPF 420075039W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2007-10-12

CLOSED warning letter citing 195.452(h)(2).

## Document text

Warning Letter involving COLONIAL PIPELINE CO. PHMSA's enforcement data identifies the cited regulation as 195.452(h)(2). The case was opened on 2007-10-12 and is reported as closed as of 2007-10-12. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420075039W_Warning Letter_10122007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075039W/420075039W_Warning%20Letter_10122007.pdf

420075039W_Warning Letter_10122007.pdf

U.S. Department of Transportation
Pipeline and
Hazardous Materials Safety
Administration
8701 South Gessner, Suite 1110
Houston, TX 77074
WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
October 12, 2007
Mr. Norm Szydlowski
President and Chief Executive Officer
Colonial Pipeline Company
1185 Sanctuary Parkway, Suite 100
Alpharetta, GA 30009-4738
CPF 4-2007-5039W
Dear Mr. Szydlowski:
During the weeks of June 4th
, 2007 and June 18th
, 2007, representatives of the Pipeline and
Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United
States Code inspected Colonial Pipeline Company (Colonial) procedures for the Hazardous
Liquid Pipeline Integrity Management Program (IMP) in Alpharetta, Georgia.
As a result of the inspection, it appears that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and
the probable violation is:
1. §195.452 Pipeline integrity management in high consequence areas
(h) What actions must an operator take to address integrity issues?
(2) Discovery of condition. Discovery of a condition occurs when an operator
has adequate information about the condition to determine that the
condition presents a potential threat to the integrity of the pipeline. An
operator must promptly, but no later than 180 days after an integrity
assessment, obtain sufficient information about a condition to make that
determination, unless the operator can demonstrate that the 180-day
period is impracticable.



Four baseline caliper-deformation in-line inspection (Ill) integrity assessments were
reviewed that did not meet timeline requirements for discovery of a condition (Line 1
Atlanta to Greensboro, Line 4 Greensboro to Louisa, Line 4 Louisa to Dorsey, and Line 3
Greensboro to Dorsey). These assessments were completed well before the associated
metal-loss Ill. However, the dates of discovery for the caliper-deformation integrity
assessments were based on the completion of the later metal-loss inline inspection.
Discovery for the conditions from the caliper-deformation integrity assessments took
283, 288, 363 and 559 days, respectively, which is significantly longer than the required
180 days. At the time these probable violations took place (2003 and 2004) Colonial's
procedures did not prevent them from not considering the 180 day time limit for each
individual III tool run rather than for each suite of tools. Therefore, Colonial's
procedures were inadequate. Colonial has since amended their procedures by adding a
section detailing a process that, in the event that a series of ILl tool runs is used, the 180
day discovery period for each individual tool run is triggered based on when that specific
tool reaches the receiver unless the specific condition being analyzed requires the data
from more than one tool.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed
$100,000 for each violation for each day the violation persists up to a maximum of $1,000,000
for any 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(s) identified
in this letter. Failure to do so will result in Colonial being subject to additional enforcement
action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 4-2007-S039W. 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).
Sincerely,
R. M. Seeley
Director, Southwest Region
Pipeline and Hazardous
Materials Safety Administration
2

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/420075039W>
- Source ID: `phmsa-enforcement`
- SHA-256: `8ff4092facf156052a6e13f423c57c4420b45104a281adb341fe8d7d2fcd0b5f`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T16:24:40.081Z
- Document slug: `phmsa-enforcement-420075039w`

### Source metadata

```json
{
  "cpf": "420075039W",
  "operator": "COLONIAL PIPELINE CO",
  "region": "Southwest",
  "pipelineType": "INTERSTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "195.452(h)(2)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 1,
  "attachments": [
    {
      "name": "420075039W_Warning Letter_10122007.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/420075039W/420075039W_Warning%20Letter_10122007.pdf",
      "bytes": 84445,
      "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"
}
```
