# COLONIAL PIPELINE CO — Notice of Probable Violation

- **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:** Not available
- **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.

Official case documents:

120085002_Closure Letter_01272012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120085002/120085002_Closure%20Letter_01272012.pdf

120085002_Closure Letter_01272012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120085002/120085002_Closure%20Letter_01272012_text.pdf

120085002_FinalOrder_03212011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120085002/120085002_FinalOrder_03212011.pdf

120085002_FinalOrder_03212011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120085002/120085002_FinalOrder_03212011_text.pdf

120085002_NOPV PCP PCO_04072008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120085002/120085002_NOPV%20PCP%20PCO_04072008.pdf

120085002_nopv pcp pco_04072008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120085002/120085002_nopv%20pcp%20pco_04072008_text.pdf

120085002_Operator Response_05092008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120085002/120085002_Operator%20Response_05092008.pdf

120085002_FinalOrder_03212011_text.pdf

MAR 21 2011
Mr. Tim Felt
President and Chief Executive Officer
Colonial Pipeline Company
1185 Sanctuary Parkway, Suite 100
Alpharetta, GA 30009-4738
Re: CPF No. 1-2008-5002
Dear Mr. Felt:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation, assesses a civil penalty of $70,000, and specifies actions that need to be taken by
Colonial Pipeline Company to comply with the pipeline safety regulations. The penalty payment
terms are set forth in the Final Order. When the civil penalty has been paid and the terms of the
compliance order are completed, as determined by the Director, Eastern 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. Byron Coy, Director, Eastern Region, PHMSA
CERTIFIED MAIL – RETURN RECEIPT REQUESTED[7005 1160 0001 0041 3603]



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
______________________________
)
In the Matter of )
)
Colonial Pipeline Company, ) CPF No. 1-2008-5002
)
Respondent. )
______________________________)
FINAL ORDER
Between February and April 2007, pursuant to 49 U.S.C. § 60117, a representative of the
Virginia State Corporation Commission (VA SCC), as agent for the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), conducted an on-
site pipeline safety inspection of Colonial Pipeline Company’s (Colonial or Respondent) pipeline
extension project near Dulles International Airport in Virginia. Respondent owns and operates
approximately 5,519 miles of hazardous liquid pipeline which deliver petroleum products to 12
states and the District of Columbia.
1
As a result of the inspection, the Director, Eastern Region, OPS (Director), issued to Respondent,
by letter dated April 7, 2008, a Notice of Probable Violation, Proposed Civil Penalty, and
Proposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice
proposed finding that Colonial had violated 49 C.F.R. § 195.202 and assessing a total civil
penalty of $70,000 for the alleged violations. The Notice also proposed that Respondent take
certain measures to correct the alleged violations.
Colonial responded to the Notice by letter dated May 9, 2008 (Response). Respondent did not
dispute the allegations but requested that the proposed civil penalty be reduced. The company
did not request a hearing and therefore has waived its right to one.
FINDINGS OF VIOLATION
In its Response, Colonial did not contest the allegations in the Notice that it violated 49 C.F.R.
Part 195, as follows:
1 http://www.colpipe.com/ab_main.asp (last accessed February 25, 2011).



2
Item 1A: The Notice alleged that Respondent violated 49 C.F.R. § 195.202, which states:
§ 195.202 Compliance with specifications or standards.
Each pipeline system must be constructed in accordance with
comprehensive written specifications or standards that are consistent with
the requirements of this part.
The Notice alleged that Respondent violated 49 C.F.R. § 195.202 by failing to construct its
pipeline extension project in accordance with comprehensive written specifications consistent
with the requirements of 49 C.F.R. Part 195. Specifically, it alleged that Respondent failed to
properly ground certain detector equipment used to check for “holidays” or breaks in the anti-
corrosion coating on the pipe. The manufacturer of the instrument stated in its operating manual
that “a good ground return system for both the pipe and the detector will always provide the best
and photographed Colonial personnel using the detector without properly grounding it. As a
result, the company missed several coating holidays. Colonial did not dispute this allegation.
Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49
comprehensive written specifications for grounding the holiday detector.
and most reliable inspection.”2 However, on April 11, 2007, the VA SCC inspector observed
C.F.R. § 195.202 by failing to construct its pipeline extension project in accordance with
Item 1B: The Notice alleged that Respondent further violated 49 C.F.R. § 195.202 by failing to
construct its pipeline extension project in accordance with comprehensive written specifications
consistent with the requirements of 49 C.F.R. Part 195. Specifically, it alleged that Respondent
failed to follow certain coating repair procedures specified by the manufacturer. The
manufacturer set forth specific procedures for replacing the coating. However, on February 27,
2007, the VA SCC inspector observed Respondent’s contractor applying the coating repair
material incorrectly and not in conformance with the manufacturer’s specifications. The
inspector informed Colonial personnel of the proper procedure for applying the coating repair,
discussed the repairs with Colonial’s regulatory manager, provided photographs documenting the
improper repairs, and supplied Colonial with an additional copy of the manufacturer’s repair
procedures. However, on March 7, 2007, the inspector again observed the contractor improperly
applying the coating repair. Subsequent tests performed on the coating confirmed that the
repairs did not bond properly to the pipeline. Respondent did not dispute this allegation.
Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49
C.F.R. § 195.202 by failing to construct its pipeline extension project in accordance with
comprehensive written specifications for applying the pipeline coating repair.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
2 Pipeline Safety Violation Report, April 7, 2008 (Violation Report) (on file with PHMSA).



3
ASSESSMENT OF PENALTY
Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed
$100,000 per violation for each day of the violation, up to a maximum of $1,000,000 for any
related series of violations.
In determining the amount of the civil penalty under 49 U.S.C. § 60122 and 49 C.F.R. § 190.225,
I must consider the following criteria: the nature, circumstances, and gravity of the violation,
including adverse impact on the environment; the degree of Respondent’s culpability; the history
of Respondent’s prior offenses; the Respondent’s ability to pay the penalty and any effect that
the penalty may have on its ability to continue doing business; and the good faith of Respondent
in attempting to comply with the pipeline safety regulations. In addition, I may consider the
economic benefit gained from the violation without any reduction because of subsequent
damages, and such other matters as justice may require. The Notice proposed a total civil
penalty of $70,000 for the violations cited above.
With respect to Items 1A and 1B, the Notice proposed a civil penalty of $35,000 for each
violation of 49 C.F.R. § 195.202. The Dulles pipeline extension project is located in a high
consequence area (HCA) and failure to follow holiday detector and coating procedures could
cause a future release of product. This line carries jet fuel, creating additional concerns for the
safety of the surrounding public.
Although Respondent did not dispute the violations, it requested a reduction of the $70,000 total
civil penalty. The company argued that a reduction was appropriate on account of its “good
faith” in correcting the violations in both Items 1A and 1B, at the time of the inspection or before
the Notice was issued. In addition, Respondent argued that the company would incur additional
costs in completing the Compliance Order that were unnecessary. Therefore, Colonial asserted
that a civil penalty, in addition to the costs it would incur in satisfying the Compliance Order,
would be excessive.
I am not convinced that a reduction in the proposed civil penalty is warranted. With respect to
Item 1A, the facts are not in dispute. The violations of § 195.202 were observed at the time of
the inspection. Due to the Respondent’s failure to comply with § 195.202, company personnel
missed coating holidays. These holidays would have remained undetected if the inspector had
not required Respondent to re-examine the pipe. Holidays cannot be remediated if they are
overlooked during construction and can accelerate corrosion and lead to the subsequent failure of
the pipeline. Although Colonial has now located and repaired the previously undetected holidays
at the direction of the inspector, this is what any reasonable and prudent operator would be
expected to do. This action does not constitute a pre-violation “good faith” attempt to achieve
compliance that, at times, may warrant mitigation of a proposed penalty. On the contrary,
Colonial has an obligation to comply with the pipeline safety regulations without the necessity of
an inspector’s visit.
In addition, this particular pipeline extension project is located in an HCA, a factor that actually
increases the gravity of the offense because it carries a heightened risk of potential
environmental and public safety harm in the event of an accident. Finally, Colonial has had a



4
prior history of related violations for failure to prepare and follow its manual for operations,
maintenance and emergencies.3 assessment criteria, I assess Respondent a civil penalty of $35,000 for Item 1A.
Accordingly, having reviewed the record and considered the
With respect to Item 1B, the VA SCC inspector personally observed the violations and notified
Respondent of the improper coating repairs on February 27, 2007. However, on March 7, 2007,
company personnel were still applying the coating repair incorrectly, putting the safety of the
pipeline at risk. Maintaining and adhering to written specifications ensures that construction
activities are performed in a consistent manner, with all personnel cognizant of the applicable
requirements. Colonial had ample opportunity in this case to correct the repair concerns after the
inspector’s first visit and yet its personnel continued to apply the coating incorrectly. As noted
above, Colonial has an obligation to comply with the pipeline safety regulations without the
necessity of an inspector’s visit. The proposed civil penalty is appropriate for this type of
violation, particularly in terms of the culpability of Respondent’s personnel and the location of
the construction project in an HCA. Accordingly, having reviewed the record and considered the
assessment criteria, I assess Respondent a civil penalty of $35,000 for Item 1B.
In summary, having reviewed the record and considered the assessment criteria for each of the
Items cited above, I assess Respondent a total civil penalty of $70,000 for violating 49 C.F.R.
§ 195.202 (Items 1A and 1B).
Payment of the civil penalty must be made within 20 days of service. Federal regulations
(49 C.F.R. § 89.21(b)(3)) require this payment be made by wire transfer, through the Federal
Reserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed
instructions are contained in the enclosure. Questions concerning wire transfers should be
directed to: Financial Operations Division (AMZ-341), Federal Aviation Administration, Mike
Monroney Aeronautical Center, P.O. Box 269039, Oklahoma City, OK 73125. The Financial
Division’s telephone number is (405) 954-8893.
Failure to pay the $70,000 civil penalty will result in accrual of interest at the current annual rate
in accordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to
those same authorities, a late penalty charge of six percent (6%) per annum will be charged if
payment is not made within 110 days of service. Furthermore, failure to pay the civil penalty
may result in referral of the matter to the Attorney General for appropriate action in a United
States District Court.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Items 1A and 1B in the Notice for
violations of 49 C.F.R. § 195.202. Under 49 U.S.C. § 60118(a), each person who engages in the
transportation of hazardous liquids or who owns or operates a pipeline facility is required to
comply with the applicable safety standards established under chapter 601. Pursuant to the
3 See, In the Matter of Colonial Pipeline Company, Final Order, CPF No. 1-2002-5009 (December 10, 2003)
(available at www.phmsa.dot.gov/pipeline/enforcement); See, In the Matter of Colonial Pipeline Company, Final
Order, CPF No. 2-2004-5005 (October 18, 2004) (available at www.phmsa.dot.gov/pipeline/enforcement).



5
authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the
following actions to ensure compliance with the pipeline safety regulations applicable to its
operations:
1. Conduct a close-interval survey (CIS) and a Direct Current Voltage Gradient (DCVG)
survey or an Alternating Current Voltage Gradient (ACVG) survey of the pipeline to
check for coating holidays. A CIS and a DCVG or ACVG of the pipeline should take
into consideration any effects of ground stabilization from the time the pipeline was
backfilled.
2. Excavate and examine all survey indications that correspond to possible large coating
holidays using the assessment protocols in the table below to correct any undetected
coating damage. Subsequent surveys should show no large coating holidays remaining
after the initial assessment.
3. Evaluate DCVG or ACVG coating survey results as follows:
• The threshold survey indication values are 50% IR for DCVG and 70dBµV for
ACVG. These values represent the severe category in the severity classification used
to characterize survey indications in the GTI ECDA Protocol Rev 4.
GTI ECDA Protocol Rev 4 Severity Table
Severity of Measurement Amplitude Change of
Indication (In Units of Measurement Resolution
see Table 4.4.2)
Tool MINOR MODERATE SEVERE
CIS
(impressed current system)
Small Dips,
on & off
potentials
both are
more
negative than
-0.850 V
Medium Dips,
on potential
more negative
than -0.850 V
off potential
not more
negative than
-0.850 V
Large Dips,
on & off
potentials,
both not
more
negative
than -0.850
V
DCVG 1-35% 35-50% 50-100%
PCM 1(EM, AC Atten.) 1-30% 30-50% 50-100%
PCM A-Frame (ACVG) 30-50 dBµV 50-70 dBµV
> 70 dBµV
(2 ft intervals
around
defect)
• Colonial will submit a proposed remediation plan to PHMSA for indications found
above the threshold values.
• Colonial will conduct a calibration dig on at least one anomaly that is classified as
minor and moderate to ensure findings that are not in the remediation plan are not
detrimental to the pipeline.
4. Monitor current cathodic protection requirements to determine if there are other coating
issues with the pipeline. Any significant change in cathodic protection requirements,



6
such as a 10% to 20% overall increase, will trigger a follow-up investigation. Test
stations will be available to facilitate monitoring.
5. Submit to PHMSA a summary report, with coating evaluation survey results and
excavation/remediation results.
6. All the above-mentioned remedial items must be completed within 120 days of receipt of
the Final Order.
7. Colonial Pipeline is requested to maintain documentation of the safety improvement costs
associated with fulfilling this Compliance Order and submit the total to Byron Coy, PE,
Director, Eastern Region, Pipeline and Hazardous Materials Safety Administration, 820
Bear Tavern Road, West Trenton, New Jersey 08628. Costs should be reported in two
categories: 1) total cost associated with preparation/revision of plans, procedures, studies
and analyses, and 2) total cost associated with replacements, additions and other changes
to pipeline infrastructure.
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.
Failure to comply with this Order may result in the 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.
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. The filing of a petition automatically stays the payment of
any civil penalty assessed. Unless the Associate Administrator, upon request, grants a stay, all
other 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

120085002_Closure Letter_01272012_text.pdf

U.S. Department 820 Bear Tavern Road, Suite 103
Of Transportation West Trenton, NJ 08628
Pipeline and 609.989.2171
Hazardous Materials
Safety Administration
Overnight Express Mail
January 27, 2012
Doug A. Belden
Vice President and General Manager-Operations
Colonial Pipeline Company
1185 Sanctuary Parkway, Suite 100
Alpharetta, Georgia 30009
CPF 1-2008-5002
Dear Mr. Belden:
On March 21, 2011, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to
Colonial Pipeline Company (Colonial) a Final Order in the above-referenced case. This Order included a
Compliance Order and Civil Penalty assessment. The Compliance Order set forth remedial requirements to
ensure pipeline safety.
Colonial submitted a draft report of effort regarding this Order to PHMSA on July 22, 2011. Subsequently,
on January 17, 2012, Colonial submitted a final summary report that demonstrated compliance with all the
requirements outlined in the Compliance Order.
A Virginia State Corporation Commission (VA SCC) Inspector, as an agent for PHMSA, observed portions
of the Close Interval Survey (CIS) that Colonial performed in accordance with this Order. The VA SCC also
reviewed Colonial’s final summary report submission.
Based on our review of the documentation provided and confirmation of payment of the civil penalty, it has
been determined that Colonial has complied with the terms of this Order.
Accordingly, this case is now closed and no further action is contemplated with respect to the matters
involved in this case. Thank you for your cooperation in this matter.
Sincerely,
Byron Coy, PE
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration

120085002_nopv pcp pco_04072008_text.pdf

O
U. S. Department
of Transportation
Pipeline and
Hazardous Materials Safety
Administration
409 3rd Street, SW, Suite 300
Washington, DC 20024
NOTICE OF PROBABLE VIOLATION
PROPOSED CIVIL PENALTY
and
PROPOSED COMPLIANCE ORDER
CERTIFIED MAIL - RETURN RECEIPT RE UESTED
April 7, 2008
Mr. Norman J. Szydlowski
President and Chief Executive Officer
Colonial Pipeline Company
1185 Sanctuary Parkway, Suite 100
Alpharetta, GA 30004-4738
CPF 1-2008-5002
Dear Szydlowski:
From February through April 2007, representatives from the Virginia State Corporation
Commission (VA SCC) acting as Agents of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Colonial
Pipeline's (Colonial) approximately 2. 5 mile pipeline extension construction project to the
Dulles International Airport in Virginia.
As a result of the inspection, it appears that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the
probable violations are:



1. $195. 202 Compliance with specifications or standards
Each pipeline system must be constructed in accordance with comprehensive
written specifications or standards that are consistent with the requirements of this
part.
1A. On April 11, 2007 at the Dulles Pipeline Expansion Project, the VA SCC inspector observed
and documented that the contractor for Colonial was not properly grounding the holiday detector
when examining the pipe coating for holidays.
The holiday detector instrument used for the project required proper grounding in order to detect
holidays in the pipeline coating. Re-examination of the pipe revealed holidays initially
undetected that were subsequently repaired.
1B. On February 27, 2007 the VA SCC inspector observed and documented at the Dulles
Pipeline Expansion Project that the contractor for Colonial was not following the proper coating
repair procedures as specified by the coating repair manufacturer. This was observed again on
March 7, 2007.
After bringing this concern to the Colonial Construction Manager's attention on March 1, 2007,
the VA SCC inspector again on March 7, 2007 observed incorrect coating repair procedures
being performed by the contractor for Colonial. In addition, Colonial did not include the repair
method being used in their written procedures for the Dulles Pipeline Expansion Project. Tests
performed on the pipeline coating to determine the integrity of the coating repairs showed that
the repairs did not bond properly to the pipe.
Pro osed Civil Penalt
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. The Compliance Officer has reviewed the circumstances and
supporting documentation involved in the above probable violations and has recommended that
you be preliminarily assessed a civil penalty of $70, 000 as follows:
Item number
1A
1B
PENALTY
$35, 000
$35, 000



Pro osed Com liance Order
With respect to items 1A and 1B pursuant to 49 United States Code ( 60118, the Pipeline and
Hazardous Materials Safety Administration proposes to issue a Compliance Order to Colonial.
Please refer to the Proposed Compliance Order, which is enclosed and made a part of this
Notice.
Res onse to this Notice
Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators
in Compliance Proceedings. Please refer to this document and note the response options. 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). If you do not respond within 30 days
of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this
Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in
this Notice without further notice to you and to issue a Final Order.
In your correspondence on this matter, please refer to CPF 1-2008-5002 and for each document
you submit, please provide a copy in electronic format whenever possible.
Sincerely,
~ Byron E. Coy, P. E.
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
Enclosures: Proposed Compliance Order
Response Options for Pipeline Operators in Compliance Proceedings



PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code ) 60118, the Pipeline and Hazardous Materials Safety
Administration (PHMSA) proposes to issue to Colonial Pipeline a Compliance Order
incorporating the following remedial requirements to ensure the compliance of Colonial Pipeline
with the pipeline safety regulations:
1. In regard to Item Number 1A and 1B of the Notice pertaining to compliance with
specifications or standards:
~ Conduct a close-interval survey (CIS) and a Direct Current Voltage Gradient
(DCVG) survey or an Alternating Current Voltage Gradient (ACVG) survey of the
pipeline to check for coating holidays. A CIS and a DCVG/ACVG of the pipeline
should take into consideration any effects of ground stabilization from the time the
pipeline was backfilled.
~ Excavate and examine all survey indications that correspond to possible large coating
holidays (severe per GTI ECDA Protocol Rev 4 Severity table below), to correct any
undetected coating damage. Subsequent surveys should show no large coating
holidays remaining after the initial assessment.
~ Evaluate DCVG or ACVG coating survey results as follows:
0 The threshold survey indication values are 50% IR for DCVG
and 70dBpV for ACVG. These values represent the severe
category in the severity classification used to characterize survey
indications in the GTI External Corrosion Direct Assessment
(ECDA) Protocol Rev 4.
GTI ECDA Protocol Rev 4 Severity Table
CIS
(impressed
current
system)
Small Dips,
on & off
potentials
both are
more
negative than
-0. 850 V
Medium Dips,
on potential
more negative
than -0. 850 V
off potential
not more
negative than
-0. 850 V
Large Dips,
on & off
potentials,
both not
more
negative
than -0. 850
v
DCVG 1-35% 35-50% 50-100%
PCM ~(EM,
AC Atten. 1-30% 30-50% 50-100%
PCM A-
Frame
(ACVG)
3p 5Q dB V ) 70 dBpV
5p 7Q dB V (2 ft intervals
around
defect



o Colonial will submit a proposed remediation plan to PHMSA for
indications found above the threshold values.
o Colonial will conduct a calibration dig on at least one anomaly
that is classified as minor and moderate, to ensure findings not in
the remediation plan are not detrimental to the pipeline.
~ Monitor CP current requirements to determine if there are other coating
issues with the pipeline. Any significant change in CP requirements,
such as 10% to 20% overall increase, will trigger a follow up
investigation. Test stations will be available to facilitate monitoring.
~ Submit to PHMSA a summary report with coating evaluation survey
results and excavation/remediation results.
All the above mentioned remedial items must be completed within 120 days of
receipt of a Final Order,
Colonial Pipeline shall maintain documentation of the safety improvement costs
associated with fulfilling this Compliance Order and submit the total to Byron
Coy, PE, Director, Eastern Region, Pipeline and Hazardous Materials Safety
Administration. Costs shall be reported in two categories: 1) total cost associated
with preparation/revision of plans, procedures, studies and analyses, and 2) total
in &astructure.cost associated with replacements, additions and other changes to pipeline
- **truncated:** false
- **body characters:** 28624