{"operation":"document","citation":"CPF 120085002","title":"COLONIAL PIPELINE CO — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-04-07","effective_on":null,"summary":"CLOSED notice of probable violation citing 195.202.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120085002.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120085002.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120085002","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120085002","body":"Notice of Probable Violation involving COLONIAL PIPELINE CO. PHMSA's enforcement data identifies the cited regulation as 195.202. The case was opened on 2008-04-07 and is reported as closed as of 2012-01-27. Proposed civil penalty: $70,000. Assessed civil penalty: $70,000. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120085002_Closure Letter_01272012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120085002/120085002_Closure%20Letter_01272012.pdf\n\n120085002_Closure Letter_01272012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120085002/120085002_Closure%20Letter_01272012_text.pdf\n\n120085002_FinalOrder_03212011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120085002/120085002_FinalOrder_03212011.pdf\n\n120085002_FinalOrder_03212011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120085002/120085002_FinalOrder_03212011_text.pdf\n\n120085002_NOPV PCP PCO_04072008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120085002/120085002_NOPV%20PCP%20PCO_04072008.pdf\n\n120085002_nopv pcp pco_04072008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120085002/120085002_nopv%20pcp%20pco_04072008_text.pdf\n\n120085002_Operator Response_05092008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120085002/120085002_Operator%20Response_05092008.pdf\n\n120085002_FinalOrder_03212011_text.pdf\n\nMAR 21 2011\nMr. Tim Felt\nPresident and Chief Executive Officer\nColonial Pipeline Company\n1185 Sanctuary Parkway, Suite 100\nAlpharetta, GA 30009-4738\nRe: CPF No. 1-2008-5002\nDear Mr. Felt:\nEnclosed please find the Final Order issued in the above-referenced case. It makes findings of\nviolation, assesses a civil penalty of $70,000, and specifies actions that need to be taken by\nColonial Pipeline Company to comply with the pipeline safety regulations. The penalty payment\nterms are set forth in the Final Order. When the civil penalty has been paid and the terms of the\ncompliance order are completed, as determined by the Director, Eastern Region, this\nenforcement action will be closed. Service of the Final Order by certified mail is deemed\neffective upon the date of mailing, or as otherwise provided under 49 C.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Mr. Byron Coy, Director, Eastern Region, PHMSA\nCERTIFIED MAIL – RETURN RECEIPT REQUESTED[7005 1160 0001 0041 3603]\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n______________________________\n)\nIn the Matter of )\n)\nColonial Pipeline Company, ) CPF No. 1-2008-5002\n)\nRespondent. )\n______________________________)\nFINAL ORDER\nBetween February and April 2007, pursuant to 49 U.S.C. § 60117, a representative of the\nVirginia State Corporation Commission (VA SCC), as agent for the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), conducted an on-\nsite pipeline safety inspection of Colonial Pipeline Company’s (Colonial or Respondent) pipeline\nextension project near Dulles International Airport in Virginia. Respondent owns and operates\napproximately 5,519 miles of hazardous liquid pipeline which deliver petroleum products to 12\nstates and the District of Columbia.\n1\nAs a result of the inspection, the Director, Eastern Region, OPS (Director), issued to Respondent,\nby letter dated April 7, 2008, a Notice of Probable Violation, Proposed Civil Penalty, and\nProposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice\nproposed finding that Colonial had violated 49 C.F.R. § 195.202 and assessing a total civil\npenalty of $70,000 for the alleged violations. The Notice also proposed that Respondent take\ncertain measures to correct the alleged violations.\nColonial responded to the Notice by letter dated May 9, 2008 (Response). Respondent did not\ndispute the allegations but requested that the proposed civil penalty be reduced. The company\ndid not request a hearing and therefore has waived its right to one.\nFINDINGS OF VIOLATION\nIn its Response, Colonial did not contest the allegations in the Notice that it violated 49 C.F.R.\nPart 195, as follows:\n1 http://www.colpipe.com/ab_main.asp (last accessed February 25, 2011).\n\n\n\n2\nItem 1A: The Notice alleged that Respondent violated 49 C.F.R. § 195.202, which states:\n§ 195.202 Compliance with specifications or standards.\nEach pipeline system must be constructed in accordance with\ncomprehensive written specifications or standards that are consistent with\nthe requirements of this part.\nThe Notice alleged that Respondent violated 49 C.F.R. § 195.202 by failing to construct its\npipeline extension project in accordance with comprehensive written specifications consistent\nwith the requirements of 49 C.F.R. Part 195. Specifically, it alleged that Respondent failed to\nproperly ground certain detector equipment used to check for “holidays” or breaks in the anti-\ncorrosion coating on the pipe. The manufacturer of the instrument stated in its operating manual\nthat “a good ground return system for both the pipe and the detector will always provide the best\nand photographed Colonial personnel using the detector without properly grounding it. As a\nresult, the company missed several coating holidays. Colonial did not dispute this allegation.\nAccordingly, based upon a review of all of the evidence, I find that Respondent violated 49\ncomprehensive written specifications for grounding the holiday detector.\nand most reliable inspection.”2 However, on April 11, 2007, the VA SCC inspector observed\nC.F.R. § 195.202 by failing to construct its pipeline extension project in accordance with\nItem 1B: The Notice alleged that Respondent further violated 49 C.F.R. § 195.202 by failing to\nconstruct its pipeline extension project in accordance with comprehensive written specifications\nconsistent with the requirements of 49 C.F.R. Part 195. Specifically, it alleged that Respondent\nfailed to follow certain coating repair procedures specified by the manufacturer. The\nmanufacturer set forth specific procedures for replacing the coating. However, on February 27,\n2007, the VA SCC inspector observed Respondent’s contractor applying the coating repair\nmaterial incorrectly and not in conformance with the manufacturer’s specifications. The\ninspector informed Colonial personnel of the proper procedure for applying the coating repair,\ndiscussed the repairs with Colonial’s regulatory manager, provided photographs documenting the\nimproper repairs, and supplied Colonial with an additional copy of the manufacturer’s repair\nprocedures. However, on March 7, 2007, the inspector again observed the contractor improperly\napplying the coating repair. Subsequent tests performed on the coating confirmed that the\nrepairs did not bond properly to the pipeline. Respondent did not dispute this allegation.\nAccordingly, based upon a review of all of the evidence, I find that Respondent violated 49\nC.F.R. § 195.202 by failing to construct its pipeline extension project in accordance with\ncomprehensive written specifications for applying the pipeline coating repair.\nThese findings of violation will be considered prior offenses in any subsequent enforcement\naction taken against Respondent.\n2 Pipeline Safety Violation Report, April 7, 2008 (Violation Report) (on file with PHMSA).\n\n\n\n3\nASSESSMENT OF PENALTY\nUnder 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed\n$100,000 per violation for each day of the violation, up to a maximum of $1,000,000 for any\nrelated series of violations.\nIn determining the amount of the civil penalty under 49 U.S.C. § 60122 and 49 C.F.R. § 190.225,\nI must consider the following criteria: the nature, circumstances, and gravity of the violation,\nincluding adverse impact on the environment; the degree of Respondent’s culpability; the history\nof Respondent’s prior offenses; the Respondent’s ability to pay the penalty and any effect that\nthe penalty may have on its ability to continue doing business; and the good faith of Respondent\nin attempting to comply with the pipeline safety regulations. In addition, I may consider the\neconomic benefit gained from the violation without any reduction because of subsequent\ndamages, and such other matters as justice may require. The Notice proposed a total civil\npenalty of $70,000 for the violations cited above.\nWith respect to Items 1A and 1B, the Notice proposed a civil penalty of $35,000 for each\nviolation of 49 C.F.R. § 195.202. The Dulles pipeline extension project is located in a high\nconsequence area (HCA) and failure to follow holiday detector and coating procedures could\ncause a future release of product. This line carries jet fuel, creating additional concerns for the\nsafety of the surrounding public.\nAlthough Respondent did not dispute the violations, it requested a reduction of the $70,000 total\ncivil penalty. The company argued that a reduction was appropriate on account of its “good\nfaith” in correcting the violations in both Items 1A and 1B, at the time of the inspection or before\nthe Notice was issued. In addition, Respondent argued that the company would incur additional\ncosts in completing the Compliance Order that were unnecessary. Therefore, Colonial asserted\nthat a civil penalty, in addition to the costs it would incur in satisfying the Compliance Order,\nwould be excessive.\nI am not convinced that a reduction in the proposed civil penalty is warranted. With respect to\nItem 1A, the facts are not in dispute. The violations of § 195.202 were observed at the time of\nthe inspection. Due to the Respondent’s failure to comply with § 195.202, company personnel\nmissed coating holidays. These holidays would have remained undetected if the inspector had\nnot required Respondent to re-examine the pipe. Holidays cannot be remediated if they are\noverlooked during construction and can accelerate corrosion and lead to the subsequent failure of\nthe pipeline. Although Colonial has now located and repaired the previously undetected holidays\nat the direction of the inspector, this is what any reasonable and prudent operator would be\nexpected to do. This action does not constitute a pre-violation “good faith” attempt to achieve\ncompliance that, at times, may warrant mitigation of a proposed penalty. On the contrary,\nColonial has an obligation to comply with the pipeline safety regulations without the necessity of\nan inspector’s visit.\nIn addition, this particular pipeline extension project is located in an HCA, a factor that actually\nincreases the gravity of the offense because it carries a heightened risk of potential\nenvironmental and public safety harm in the event of an accident. Finally, Colonial has had a\n\n\n\n4\nprior history of related violations for failure to prepare and follow its manual for operations,\nmaintenance and emergencies.3 assessment criteria, I assess Respondent a civil penalty of $35,000 for Item 1A.\nAccordingly, having reviewed the record and considered the\nWith respect to Item 1B, the VA SCC inspector personally observed the violations and notified\nRespondent of the improper coating repairs on February 27, 2007. However, on March 7, 2007,\ncompany personnel were still applying the coating repair incorrectly, putting the safety of the\npipeline at risk. Maintaining and adhering to written specifications ensures that construction\nactivities are performed in a consistent manner, with all personnel cognizant of the applicable\nrequirements. Colonial had ample opportunity in this case to correct the repair concerns after the\ninspector’s first visit and yet its personnel continued to apply the coating incorrectly. As noted\nabove, Colonial has an obligation to comply with the pipeline safety regulations without the\nnecessity of an inspector’s visit. The proposed civil penalty is appropriate for this type of\nviolation, particularly in terms of the culpability of Respondent’s personnel and the location of\nthe construction project in an HCA. Accordingly, having reviewed the record and considered the\nassessment criteria, I assess Respondent a civil penalty of $35,000 for Item 1B.\nIn summary, having reviewed the record and considered the assessment criteria for each of the\nItems cited above, I assess Respondent a total civil penalty of $70,000 for violating 49 C.F.R.\n§ 195.202 (Items 1A and 1B).\nPayment of the civil penalty must be made within 20 days of service. Federal regulations\n(49 C.F.R. § 89.21(b)(3)) require this payment be made by wire transfer, through the Federal\nReserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed\ninstructions are contained in the enclosure. Questions concerning wire transfers should be\ndirected to: Financial Operations Division (AMZ-341), Federal Aviation Administration, Mike\nMonroney Aeronautical Center, P.O. Box 269039, Oklahoma City, OK 73125. The Financial\nDivision’s telephone number is (405) 954-8893.\nFailure to pay the $70,000 civil penalty will result in accrual of interest at the current annual rate\nin accordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to\nthose same authorities, a late penalty charge of six percent (6%) per annum will be charged if\npayment is not made within 110 days of service. Furthermore, failure to pay the civil penalty\nmay result in referral of the matter to the Attorney General for appropriate action in a United\nStates District Court.\nCOMPLIANCE ORDER\nThe Notice proposed a compliance order with respect to Items 1A and 1B in the Notice for\nviolations of 49 C.F.R. § 195.202. Under 49 U.S.C. § 60118(a), each person who engages in the\ntransportation of hazardous liquids or who owns or operates a pipeline facility is required to\ncomply with the applicable safety standards established under chapter 601. Pursuant to the\n3 See, In the Matter of Colonial Pipeline Company, Final Order, CPF No. 1-2002-5009 (December 10, 2003)\n(available at www.phmsa.dot.gov/pipeline/enforcement); See, In the Matter of Colonial Pipeline Company, Final\nOrder, CPF No. 2-2004-5005 (October 18, 2004) (available at www.phmsa.dot.gov/pipeline/enforcement).\n\n\n\n5\nauthority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the\nfollowing actions to ensure compliance with the pipeline safety regulations applicable to its\noperations:\n1. Conduct a close-interval survey (CIS) and a Direct Current Voltage Gradient (DCVG)\nsurvey or an Alternating Current Voltage Gradient (ACVG) survey of the pipeline to\ncheck for coating holidays. A CIS and a DCVG or ACVG of the pipeline should take\ninto consideration any effects of ground stabilization from the time the pipeline was\nbackfilled.\n2. Excavate and examine all survey indications that correspond to possible large coating\nholidays using the assessment protocols in the table below to correct any undetected\ncoating damage. Subsequent surveys should show no large coating holidays remaining\nafter the initial assessment.\n3. Evaluate DCVG or ACVG coating survey results as follows:\n• The threshold survey indication values are 50% IR for DCVG and 70dBµV for\nACVG. These values represent the severe category in the severity classification used\nto characterize survey indications in the GTI ECDA Protocol Rev 4.\nGTI ECDA Protocol Rev 4 Severity Table\nSeverity of Measurement Amplitude Change of\nIndication (In Units of Measurement Resolution\nsee Table 4.4.2)\nTool MINOR MODERATE SEVERE\nCIS\n(impressed current system)\nSmall Dips,\non & off\npotentials\nboth are\nmore\nnegative than\n-0.850 V\nMedium Dips,\non potential\nmore negative\nthan -0.850 V\noff potential\nnot more\nnegative than\n-0.850 V\nLarge Dips,\non & off\npotentials,\nboth not\nmore\nnegative\nthan -0.850\nV\nDCVG 1-35% 35-50% 50-100%\nPCM 1(EM, AC Atten.) 1-30% 30-50% 50-100%\nPCM A-Frame (ACVG) 30-50 dBµV 50-70 dBµV\n> 70 dBµV\n(2 ft intervals\naround\ndefect)\n• Colonial will submit a proposed remediation plan to PHMSA for indications found\nabove the threshold values.\n• Colonial will conduct a calibration dig on at least one anomaly that is classified as\nminor and moderate to ensure findings that are not in the remediation plan are not\ndetrimental to the pipeline.\n4. Monitor current cathodic protection requirements to determine if there are other coating\nissues with the pipeline. Any significant change in cathodic protection requirements,\n\n\n\n6\nsuch as a 10% to 20% overall increase, will trigger a follow-up investigation. Test\nstations will be available to facilitate monitoring.\n5. Submit to PHMSA a summary report, with coating evaluation survey results and\nexcavation/remediation results.\n6. All the above-mentioned remedial items must be completed within 120 days of receipt of\nthe Final Order.\n7. Colonial Pipeline is requested to maintain documentation of the safety improvement costs\nassociated with fulfilling this Compliance Order and submit the total to Byron Coy, PE,\nDirector, Eastern Region, Pipeline and Hazardous Materials Safety Administration, 820\nBear Tavern Road, West Trenton, New Jersey 08628. Costs should be reported in two\ncategories: 1) total cost associated with preparation/revision of plans, procedures, studies\nand analyses, and 2) total cost associated with replacements, additions and other changes\nto pipeline infrastructure.\nThe Director may grant an extension of time to comply with any of the required items upon a\nwritten request timely submitted by the Respondent and demonstrating good cause for an\nextension.\nFailure to comply with this Order may result in the administrative assessment of civil penalties\nnot to exceed $100,000 for each violation for each day the violation continues or in referral to the\nAttorney General for appropriate relief in a district court of the United States.\nUnder 49 C.F.R. § 190.215, Respondent has a right to submit a Petition for Reconsideration of\nthis Final Order. The petition must be sent to: Associate Administrator, Office of Pipeline\nSafety, PHMSA, 1200 New Jersey Avenue, SE, East Building, 2nd Floor, Washington, DC\n20590, with a copy sent to the Office of Chief Counsel, PHMSA, at the same address. PHMSA\nwill accept petitions received no later than 20 days after receipt of service of this Final Order by\nthe Respondent, provided they contain a brief statement of the issue(s) and meet all other\nrequirements of 49 C.F.R. § 190.215. The filing of a petition automatically stays the payment of\nany civil penalty assessed. Unless the Associate Administrator, upon request, grants a stay, all\nother terms and conditions of this Final Order are effective upon service in accordance with 49\nC.F.R. § 190.5.\n___________________________________ __________________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n120085002_Closure Letter_01272012_text.pdf\n\nU.S. Department 820 Bear Tavern Road, Suite 103\nOf Transportation West Trenton, NJ 08628\nPipeline and 609.989.2171\nHazardous Materials\nSafety Administration\nOvernight Express Mail\nJanuary 27, 2012\nDoug A. Belden\nVice President and General Manager-Operations\nColonial Pipeline Company\n1185 Sanctuary Parkway, Suite 100\nAlpharetta, Georgia 30009\nCPF 1-2008-5002\nDear Mr. Belden:\nOn March 21, 2011, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to\nColonial Pipeline Company (Colonial) a Final Order in the above-referenced case. This Order included a\nCompliance Order and Civil Penalty assessment. The Compliance Order set forth remedial requirements to\nensure pipeline safety.\nColonial submitted a draft report of effort regarding this Order to PHMSA on July 22, 2011. Subsequently,\non January 17, 2012, Colonial submitted a final summary report that demonstrated compliance with all the\nrequirements outlined in the Compliance Order.\nA Virginia State Corporation Commission (VA SCC) Inspector, as an agent for PHMSA, observed portions\nof the Close Interval Survey (CIS) that Colonial performed in accordance with this Order. The VA SCC also\nreviewed Colonial’s final summary report submission.\nBased on our review of the documentation provided and confirmation of payment of the civil penalty, it has\nbeen determined that Colonial has complied with the terms of this Order.\nAccordingly, this case is now closed and no further action is contemplated with respect to the matters\ninvolved in this case. Thank you for your cooperation in this matter.\nSincerely,\nByron Coy, PE\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n\n120085002_nopv pcp pco_04072008_text.pdf\n\nO\nU. S. Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n409 3rd Street, SW, Suite 300\nWashington, DC 20024\nNOTICE OF PROBABLE VIOLATION\nPROPOSED CIVIL PENALTY\nand\nPROPOSED COMPLIANCE ORDER\nCERTIFIED MAIL - RETURN RECEIPT RE UESTED\nApril 7, 2008\nMr. Norman J. Szydlowski\nPresident and Chief Executive Officer\nColonial Pipeline Company\n1185 Sanctuary Parkway, Suite 100\nAlpharetta, GA 30004-4738\nCPF 1-2008-5002\nDear Szydlowski:\nFrom February through April 2007, representatives from the Virginia State Corporation\nCommission (VA SCC) acting as Agents of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Colonial\nPipeline's (Colonial) approximately 2. 5 mile pipeline extension construction project to the\nDulles International Airport in Virginia.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violations are:\n\n\n\n1. $195. 202 Compliance with specifications or standards\nEach pipeline system must be constructed in accordance with comprehensive\nwritten specifications or standards that are consistent with the requirements of this\npart.\n1A. On April 11, 2007 at the Dulles Pipeline Expansion Project, the VA SCC inspector observed\nand documented that the contractor for Colonial was not properly grounding the holiday detector\nwhen examining the pipe coating for holidays.\nThe holiday detector instrument used for the project required proper grounding in order to detect\nholidays in the pipeline coating. Re-examination of the pipe revealed holidays initially\nundetected that were subsequently repaired.\n1B. On February 27, 2007 the VA SCC inspector observed and documented at the Dulles\nPipeline Expansion Project that the contractor for Colonial was not following the proper coating\nrepair procedures as specified by the coating repair manufacturer. This was observed again on\nMarch 7, 2007.\nAfter bringing this concern to the Colonial Construction Manager's attention on March 1, 2007,\nthe VA SCC inspector again on March 7, 2007 observed incorrect coating repair procedures\nbeing performed by the contractor for Colonial. In addition, Colonial did not include the repair\nmethod being used in their written procedures for the Dulles Pipeline Expansion Project. Tests\nperformed on the pipeline coating to determine the integrity of the coating repairs showed that\nthe repairs did not bond properly to the pipe.\nPro osed Civil Penalt\nUnder 49 United States Code, $ 60122, you are subject to a civil penalty not to exceed $100, 000\nfor each violation for each day the violation persists up to a maximum of $1, 000, 000 for any\nrelated series of violations. The Compliance Officer has reviewed the circumstances and\nsupporting documentation involved in the above probable violations and has recommended that\nyou be preliminarily assessed a civil penalty of $70, 000 as follows:\nItem number\n1A\n1B\nPENALTY\n$35, 000\n$35, 000\n\n\n\nPro osed Com liance Order\nWith respect to items 1A and 1B pursuant to 49 United States Code ( 60118, the Pipeline and\nHazardous Materials Safety Administration proposes to issue a Compliance Order to Colonial.\nPlease refer to the Proposed Compliance Order, which is enclosed and made a part of this\nNotice.\nRes onse to this Notice\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline Operators\nin Compliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U. S. C. 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U. S. C. 552(b). If you do not respond within 30 days\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis Notice without further notice to you and to issue a Final Order.\nIn your correspondence on this matter, please refer to CPF 1-2008-5002 and for each document\nyou submit, please provide a copy in electronic format whenever possible.\nSincerely,\n~ Byron E. Coy, P. E.\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosures: Proposed Compliance Order\nResponse Options for Pipeline Operators in Compliance Proceedings\n\n\n\nPROPOSED COMPLIANCE ORDER\nPursuant to 49 United States Code ) 60118, the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) proposes to issue to Colonial Pipeline a Compliance Order\nincorporating the following remedial requirements to ensure the compliance of Colonial Pipeline\nwith the pipeline safety regulations:\n1. In regard to Item Number 1A and 1B of the Notice pertaining to compliance with\nspecifications or standards:\n~ Conduct a close-interval survey (CIS) and a Direct Current Voltage Gradient\n(DCVG) survey or an Alternating Current Voltage Gradient (ACVG) survey of the\npipeline to check for coating holidays. A CIS and a DCVG/ACVG of the pipeline\nshould take into consideration any effects of ground stabilization from the time the\npipeline was backfilled.\n~ Excavate and examine all survey indications that correspond to possible large coating\nholidays (severe per GTI ECDA Protocol Rev 4 Severity table below), to correct any\nundetected coating damage. Subsequent surveys should show no large coating\nholidays remaining after the initial assessment.\n~ Evaluate DCVG or ACVG coating survey results as follows:\n0 The threshold survey indication values are 50% IR for DCVG\nand 70dBpV for ACVG. These values represent the severe\ncategory in the severity classification used to characterize survey\nindications in the GTI External Corrosion Direct Assessment\n(ECDA) Protocol Rev 4.\nGTI ECDA Protocol Rev 4 Severity Table\nCIS\n(impressed\ncurrent\nsystem)\nSmall Dips,\non & off\npotentials\nboth are\nmore\nnegative than\n-0. 850 V\nMedium Dips,\non potential\nmore negative\nthan -0. 850 V\noff potential\nnot more\nnegative than\n-0. 850 V\nLarge Dips,\non & off\npotentials,\nboth not\nmore\nnegative\nthan -0. 850\nv\nDCVG 1-35% 35-50% 50-100%\nPCM ~(EM,\nAC Atten. 1-30% 30-50% 50-100%\nPCM A-\nFrame\n(ACVG)\n3p 5Q dB V ) 70 dBpV\n5p 7Q dB V (2 ft intervals\naround\ndefect\n\n\n\no Colonial will submit a proposed remediation plan to PHMSA for\nindications found above the threshold values.\no Colonial will conduct a calibration dig on at least one anomaly\nthat is classified as minor and moderate, to ensure findings not in\nthe remediation plan are not detrimental to the pipeline.\n~ Monitor CP current requirements to determine if there are other coating\nissues with the pipeline. Any significant change in CP requirements,\nsuch as 10% to 20% overall increase, will trigger a follow up\ninvestigation. Test stations will be available to facilitate monitoring.\n~ Submit to PHMSA a summary report with coating evaluation survey\nresults and excavation/remediation results.\nAll the above mentioned remedial items must be completed within 120 days of\nreceipt of a Final Order,\nColonial Pipeline shall maintain documentation of the safety improvement costs\nassociated with fulfilling this Compliance Order and submit the total to Byron\nCoy, PE, Director, Eastern Region, Pipeline and Hazardous Materials Safety\nAdministration. Costs shall be reported in two categories: 1) total cost associated\nwith preparation/revision of plans, procedures, studies and analyses, and 2) total\nin &astructure.cost associated with replacements, additions and other changes to pipeline","truncated":false,"body_characters":28624}