{"operation":"document","citation":"CPF 120155018H","title":"COLONIAL PIPELINE CO — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-09-29","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120155018h.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120155018h.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120155018h","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120155018H","body":"Corrective Action Order involving COLONIAL PIPELINE CO. The dataset does not identify a cited regulation for this case. The case was opened on 2015-09-29 and is reported as closed as of 2020-07-16. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120155018H_Amended Corrective Action Order_10222015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120155018H/120155018H_Amended%20Corrective%20Action%20Order_10222015.pdf\n\n120155018H_Amended Corrective Action Order_10222015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120155018H/120155018H_Amended%20Corrective%20Action%20Order_10222015_text.pdf\n\n120155018H_Closure Letter_07162020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120155018H/120155018H_Closure%20Letter_07162020.pdf\n\n120155018H_Closure Letter_07162020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120155018H/120155018H_Closure%20Letter_07162020_text.pdf\n\n120155018H_Corrective Action Order_09292015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120155018H/120155018H_Corrective%20Action%20Order_09292015.pdf\n\n120155018H_Corrective Action Order_09292015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120155018H/120155018H_Corrective%20Action%20Order_09292015_text.pdf\n\n120155018H_Amended Corrective Action Order_10222015_text.pdf\n\nOctober 22, 2015\nVIA CERTIFIED MAIL AND FAX TO: (678) 762-2466\nMr. Tim Felt\nPresident & Chief Executive Officer\nColonial Pipeline Company\n1185 Sanctuary Parkway, Suite 100\nAlpharetta, GA 30009-4765\nRe: CPF No. 1-2015-5018H\nDear Mr. Felt:\nEnclosed is an Amended Corrective Action Order issued in the above-referenced case, requiring\nColonial Pipeline Company to take certain corrective actions with respect the failure of its Line\n#4 pipeline on September 21, 2015, in Centreville, Virginia. The amended order replaces and\nsupersedes the original Corrective Action Order issued to Colonial on September 29, 2015.\nService is being made by certified mail, electric transmission, and facsimile. Service of the\nAmended Corrective Action Order by electronic transmission is deemed complete upon\ntransmission and acknowledgement of receipt, or as otherwise provided under 49 C.F.R. § 190.5.\nThe terms and conditions of this Order are effective upon completion of service.\nThank you for your cooperation in this matter.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Mr. Byron Coy, P.E., Regional Director, Eastern Region, OPS\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nColonial Pipeline Company, ) CPF No. 1-2015-5018H\n)\n)\n)\nRespondent. )\n____________________________________)\nAMENDED CORRECTIVE ACTION ORDER\nPurpose and Background:\nThis Amended Corrective Action Order (Order) is being issued, under the authority of 49 U.S.C.\n§ 60112, to require Colonial Pipeline Company (Colonial or Respondent), to take the necessary\ncorrective action to protect the public, property, and the environment from potential hazards\nassociated with the recent failure on Colonial’s Line #4 pipeline.\nOn September 21, 2015, a reportable accident occurred on Colonial’s Line #4 hazardous liquid\npipeline in Centreville, Virginia, resulting in the release of approximately 4,000 gallons of\ngasoline (Failure). This pipeline transports petroleum products from Houston, Texas, to Linden,\nNew Jersey. The accident occurred on a 288-mile section of Line #4 that runs between the\ncompany’s Greensboro Tank Farm in Greensboro North Carolina, and the Dorsey Tank Farm in\nWoodbine, Maryland. Colonial operates a parallel pipeline, known as Line #3 that runs thirty\nfeet apart from Line #4 at the site of the accident (Leak Site). Based on a visual inspection of the\npipe, a leak occurred at a crack within a dent that was discovered on the bottom of Line #4. The\nroot cause of the release has not yet been determined. Pursuant to 49 U.S.C. § 60117, the\nPipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety\n(OPS), initiated an investigation of the accident.\nOn September 29, 2015 PHMSA issued a Corrective Action Order to Colonial. This Amended\nCorrective Action Order replaces and supersedes the CAO issued to Colonial on September 29,\n2015.\nThe preliminary findings of the ongoing investigation are as follows.\nPreliminary Findings:\n1. Colonial operates roughly 5,500 miles of hazardous liquid transmission pipeline within\nthe United States. The pipelines travel through the states of Texas, Louisiana,\n\n\n\nCPF No: 1-2015-5018H\nPage 2\nMississippi, Alabama, Georgia, North and South Carolina, Virginia, Maryland,\nPennsylvania, New Jersey, and New York. Branches from the main lines also extend into\nTennessee. The system delivers a daily average of approximately 100 million gallons of\nliquid petroleum products to businesses and communities throughout the Southern and\nEastern United States.1\n2. The section of Line #4 at the Leak Site was constructed in 1963 and is composed of 32-\ninch diameter, 0.281” wall thickness (generally), API-5L, X52 pipe, has asphalt enamel\ncoating and a double-submerged arc-welded (DSAW) seam type, manufactured by\nNational Tube Company.\n3. The Maximum Operating Pressure (MOP) of the section of Line #4 at the Leak Site is\n657 psig, as established by hydrostatic testing in 1963. At the time of the Failure, the\nhighest steady state operating pressure of Line #4 at the Leak Site, during the 60 days\nprior to the Failure on September 21, 2015 was 283 psig.\n4. In response to reports from local residents of a gasoline odor near a retention pond\napproximately 1,000 feet from Lines #3 and #4 in Centreville, Virginia, on the morning\nof September 21, 2015, the Fairfax County Fire Department and Fairfax County Fire\nMarshall responded to the site of the retention pond.\n5. Due to the reports of gasoline odor near the site of the retention pond in Centreville,\nVirginia, as well as the activity on the part of the Fairfax County Fire Department and\nFairfax County Fire Marshall near this site, officials from Colonial arrived at this site by\nthe evening of September 21, 2015. After arriving, these officials discovered large\nquantities of gasoline in the storm water system leading to the retention pond.\n6. At 9:00 pm on September 21, 2015, Colonial acted to immediately isolate Lines 3 and 4\nby closing remote-operated valves at the Chantilly, Virginia Station (downstream), and\nRemington, Virginia Station (upstream).\n2\n7. At approximately 1:30 pm on September 22, 2015, an OPS investigator arrived at the\nLeak Site. A representative of the Virginia State Corporation Commission, in its capacity\nas interstate agent for PHMSA (VA-SCC) arrived at the Leak Site later in the afternoon\non September 22, 2015.\n8. On September 22, 2015, the National Transportation Safety Board (NTSB) informed the\nDirector, Eastern Region, PHMSA, that NTSB officials were going to visit the Leak Site\non September 23, 2015.\n9. On September 22, 2015, at 1:32 am , Colonial made a report to the National Response\nCenter (NRC Report No. 1129084), noting a sheen and odor of gasoline in the retention\npond approximately 3,000 feet from Lines #3 and #4 in Centreville, Virginia.\n10. On September 22, 2015 Colonial conducted an investigation by digging test holes around\nLines #3 and #4 in order to identify the source of the leak. Colonial personnel later\ndiscovered a crack within a dent on the bottom of Line #4.\n1 Colonial Pipeline Company. Website: http://www.colpipe.com/home/about-colonial (last visited September 29,\n2015).\n2 The isolation valves are separated by a distance of approximately 27 miles.\n\n\n\nCPF No: 1-2015-5018H\nPage 3\n11. On September 23, 2015, officials from the NTSB arrived at the Leak Site. On this date,\nthe NTSB also informed the Director that it was also launching an investigation into the\nFailure.\n12. On September 23, 2015, at 4:23 pm, Colonial made a follow-up notification to the NRC\n(“Report No. 1129221). Colonial recovered approximately 2,000 gallons of the estimated\n4,000 gallons released. As a precaution, three restaurants were closed by the Fairfax\nCounty Fire Marshal. The release caused significant soil contamination in the vicinity of\nthe Leak Site and nearby storm water drainage piping and retention ponds.\n13. The accident occurred within a High Consequence Area (HCA). There were no reported\ninjuries or fatalities, and the released gasoline failed to ignite.\n14. Based on a visual examination of the pipeline at the Leak Site, gasoline was released\nfrom a crack within a shallow dent located on the bottom of the pipe. However, the\nspecific cause of the failure is still undetermined and the investigation is ongoing. The\npipe at the Leak Site was excavated and examined on September 23, 2015. The Non-\nDestructive Examination (NDE) inspection and sleeve repair were made the following\nday on September 24, 2015, with final inspection and certification of welds on September\n25, 2015.\n15. Colonial had most recently identified the dent at the Leak Site and a similar dent 69 feet\nfrom the Leak Site during a 2013 in-line inspection (2013 ILI). During the 2013 ILI, it\nwas determined that neither dent required repair or excavation, as both were less than two\npercent of the pipe diameter. On September 24, 2015, Colonial excavated the site of the\nsecond dent and confirmed that it did not appear to have any cracks or appear to be\nleaking.\n16. Colonial installed a repair sleeve at the Leak Site. Colonial has indicated that it intends\nto remove the section of pipe containing the defect now under the repair sleeve for NTSB\ntesting and analysis in an attempt to learn more about the metallurgy and failure\nmechanisms.\n17. On September 25, 2015, following satisfactory installation of the B-Sleeve, the Director\napproved the temporary re-start of Line #4, which included a 20% reduction in operating\npressure at the leak location, resulting in a temporary maximum pressure at this location\nof 223 psig.\n18. Colonial and the Director agreed that as part of the temporary restart, Line #4 must be\nimmediately shut down upon any sign of significant or unexplained pressure loss in Line\n#4 or leakage at the Leak Site. If any leaks occur, all pumps would be shut down and the\nline blocked on each side of the Leak Site.\n19. The Director further directed, and Colonial agreed, that until the CAO was issued,\nColonial is to maintain a 24 hour on-site presence at the excavation site, construct a\ntemporary chain-link fence around the excavation and set a jersey-type barrier between\nthe nearby dead-end street and the excavation site. Colonial also agreed to provide\nongoing forecast information to PHMSA and VA-SCC about planned site work and\nprovide an opportunity for inspections and compliance oversight.\n\n\n\nCPF No: 1-2015-5018H\nPage 4\nDetermination of Necessity for Corrective Action Order and Right to Hearing:\nSection 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action\nOrder, after reasonable notice and the opportunity for a hearing, requiring corrective action,\nwhich may include the suspended or restricted use of a pipeline facility, physical inspection,\ntesting, repair, replacement, or other action, as appropriate. The basis for making the\ndetermination that a pipeline facility is or would be hazardous, requiring corrective action, is set\nforth both in the above-referenced statute and 49 C.F.R. § 190.233, a copy of which is enclosed.\nSection 60112 and the regulations promulgated thereunder provide for the issuance of a\nCorrective Action Order, without prior notice and opportunity for hearing, upon a finding that\nfailure to issue the Order expeditiously would result in the likelihood of serious harm to life,\nproperty, or the environment. In such cases, an opportunity for a hearing and expedited review\nwill be provided as soon as practicable after the issuance of the Order.\nAfter evaluating the foregoing preliminary findings of fact, I find that continued operation of the\n“Affected Segment,” as defined below, without corrective measures is or would be hazardous to\nlife, property, or the environment. Additionally, having considered the nature of the Failure; the\nunexplained existence of a dent in the pipeline 69 feet north of the joint of pipe that failed; the\nlocation of the Failure in an HCA and the resulting soil and water contamination in the vicinity\nof the Failure Site; the age of the pipeline; and the undetermined cause of the Failure, I find that\nfailure to issue this Order expeditiously would result in the likelihood of serious harm to life,\nproperty, or the environment.\nAccordingly, this Corrective Action Order mandating immediate corrective action is issued\nwithout prior notice and opportunity for a hearing. The terms and conditions of this Order are\neffective upon receipt.\nWithin 10 days of receipt of this Order, Respondent may contest its issuance obtain expedited\nreview either by answering in writing or requesting a hearing under 49 C.F.R. § 190.211, to be\nheld as soon as practicable under the terms of such regulation, by notifying the Associate\nAdministrator for Pipeline Safety in writing, with a copy to the Director, Eastern Region,\nPHMSA (Director). If Respondent requests a hearing, it will be held telephonically or in-person\nin the Eastern Region or Washington, D.C.\nAfter receiving and analyzing additional data in the course of this investigation, PHMSA may\nidentify other corrective measures that need to be taken. In that event, PHMSA will notify\nRespondent of any additional measures that are required and an amended Order issued, if\nnecessary. To the extent consistent with safety, Respondent will be afforded notice and an\nopportunity for a hearing prior to the imposition of any additional corrective measures.\nRequired Corrective Actions:\nPursuant to 49 U.S.C. § 60112, I hereby order Colonial to immediately take the following\ncorrective actions for the Affected Segment and Isolated Segment of Line #4:\nDefinitions\nThe term “Affected Segment” means approximately 288 miles of Colonial’s Line #4 between the\nGreensboro, North Carolina Tank Farm, and the Dorsey Tank Farm in Woodbine, Maryland.\n\n\n\nCPF No: 1-2015-5018H\nPage 5\nThe term “Isolated Segment” means the segment of Line #4 that is approximately 3.6 miles long\nand runs between the Compton Road Valve 10545+13 (upstream of leak) and Chantilly Junction\nMP 244 (downstream of leak) in or near Centreville, Virginia.\nThe term “Director” means the Director, Eastern Region, PHMSA.\nThe term “Failure Site” means refers to the location of the Isolated Segment that runs across the\nLeak Site, which is located at MP 241.\nCorrective Actions\n1. 2. 3. 4. 5. 6. Repair Plan. Colonial must establish a plan to make a permanent repair at the Failure\nSite in accordance with applicable pipeline safety regulations. The plan must be\nsubmitted to the Director for prior approval. As noted above, while B-Sleeves are\npermanent repairs, Colonial is removing the B-Sleeve in this particular instance for\nNTSB testing and analysis in an attempt to learn more about the metallurgy and failure\nmechanisms.\nPressure Restriction. The operating pressure may not exceed 223 psig under steady state\nconditions, which is 80% of the highest steady state operating pressure at the Leak Site in\nthe 60 days prior to the Failure on September 21, 2015. According to Colonial, hydraulic\nanalysis shows that under transient conditions the pressure at the Leak Site could reach\n284 psig.\nRemoval of Pressure Restriction. Upon written request from Colonial, the Director may\nallow the removal or modification of the pressure restriction when a reliable engineering\nanalysis demonstrates that the pressure increase is safe, taking into consideration all\nknown defects, anomalies, completion of the Repair Plan, and the operating parameters\nof the pipeline.\nTemporary Removal or Modification. The Director may allow the pressure restrictions to\nbe temporarily removed or modified upon written application from Colonial. In order to\njustify such a removal or modification, Colonial must demonstrate that mitigative and\npreventive measures will have been implemented prior to and during the temporary\nremoval or modification of the pressure restriction. Colonial may appeal any\ndetermination under this Paragraph to the Associate Administrator for Pipeline Safety.\nRecords Verification. Colonial shall verify the records for the Affected Segment to\nconfirm the MOP. Colonial must submit documentation of this record verification to the\nDirector within 45 days of receipt of this Order.3\nReview of Prior ILI Results.\nColonial must conduct a preliminary review of the results for any previous ILI run\nconducted on the Affected Segment to determine if any features with similar\ncharacteristics are present elsewhere on the Affected Segment. Colonial must complete\nthe review within 15 days of receipt of this Order and must submit documentation of this\nreview to the Director within 30 days of receipt of this Order.\nColonial must then conduct a detailed integrating review of the raw data for any previous\nILI runs conducted on the Affected Segment since the line was constructed to determine\n3 See PHMSA Advisory Bulletin 2012-06.\n\n\n\nCPF No: 1-2015-5018H\nPage 6\nwhether any features were present in the failed pipe joint, and to determine if any features\nwith similar characteristics are present elsewhere on the Affected Segment. This detailed\nreview must include a review of the ILI vendors’ raw data and an analysis by an\nindependent third party approved by PHMSA who is not the same vendor that initially\nevaluated the ILI results. Documentation of this detailed review must include the\nfollowing:\na) A list of all ILI tool runs, tool types, and the dates of the completion of the tool\nruns.\nb) c) d) A list describing the type, size, wall loss, etc., and the specific location of all ILI\nMOP-impacting, crack, dent, or other integrity-impacting features present in the\nfailed joint and/or pipe in the Affected Segment.\nA list describing the (type, size, wall loss, etc.), and the specific location of all ILI\nfeatures with similar characteristics present elsewhere on the Affected Segment.\nAn explanation of the process used to review the ILI results and the results of the\nre-evaluation.\nDocumentation of this detailed review must be submitted to the Director within 90 days\nof receipt of this Order.\n7. Mechanical and Metallurgical Testing. Mechanical and metallurgical testing, including\nfailure analysis, will be done by the NTSB in accordance with NTSB procedures and\nprotocols. In the event that the NTSB does not perform these functions, the Operator will\nbe responsible for completing all testing and analysis. Details of this analysis will be\ndefined if the NTSB does not perform the analysis.\n8. Root Cause Failure Analysis. The NTSB will perform a root cause failure analysis\n(RCFA) to determine the cause of the Failure. In the event that the NTSB does not\nperform these functions, the Operator must perform and complete a RCFA and submit a\nfinal report of this RCFA to the Director. Details of the RCFA will be defined if the\nNTSB does not perform these tasks.\n9. Emergency Response Plan and Training Review. Colonial must review and assess the\neffectiveness of its emergency response plan with regards to the Failure. Include in the\nreview and assessment the on-scene response and support, coordination, and\ncommunication with emergency responders and public officials. Also, include a review\nand assessment of the effectiveness of its emergency training program. Colonial must\namend its emergency response plan and emergency training, if necessary, to reflect the\nresults of this review. The documentation of this plan and review must be available for\ninspection by OPS or provided to the Director, if requested.\n10. Public Awareness Program Review. Colonial must review and assess the effectiveness of\nits Public Awareness Program within 90 days following receipt of this Order. Colonial\nmust amend its program, if necessary, to reflect the results of this review.\nDocumentation of this review must be made available to OPS upon request and to the\nDirector.\n11. Remedial Work Plan (RWP).\na) Within 90 days following receipt of this Order, Colonial must submit a RWP to the\nDirector for approval.\n\n\n\nb) c) d) e) CPF No: 1-2015-5018H\nPage 7\nThe Director may approve the RWP incrementally without approving the entire\nRWP.\nOnce approved by the Director, the RWP will be incorporated by reference into this\nOrder.\nThe RWP must specify the tests, inspections, assessments, evaluations, and\nremedial measures Colonial will use to verify the integrity of the Affected Segment.\nIt must address all known or suspected factors contributing to the Failure. Colonial\nshould consider both the risk of another failure and the consequence of another\nfailure to develop a prioritized schedule for RWP related work along the Affected\nSegment.\nThe RWP must include a procedure or process to:\n1. Identify pipe in the Affected Segment with characteristics similar to the\ncontributing factors identified for the Failure.\n2. Gather all data necessary to review the failure history (in service and pressure\ntest failures) of the Affected Segment and to prepare a written report containing\nall the available information such as the locations, dates, and causes of leaks and\nfailures.\n3. 4. 5. Integrate the results of the metallurgical testing, suspected cause, and other\ncorrective actions required by this Order with all relevant pre-existing\noperational and assessment data for the Affected Segment. Pre-existing\noperational data includes, but is not limited to, construction, operations,\nmaintenance, testing, repairs, prior metallurgical analyses, and any third party\nconsultation information. Pre-existing assessment data includes, but is not\nlimited to, ILI tool runs, hydrostatic pressure testing, direct assessments, close\ninterval surveys, and DCVG/ACVG surveys.\nDetermine if conditions similar to those contributing to the Failure are likely to\nexist elsewhere on the Affected Segment.\nConduct additional field tests, inspections, assessments, and/or evaluations to\ndetermine whether, and to what extent, the conditions associated with the\nFailure and other failures from the operating history or any other integrity\nthreats are present elsewhere on the Affected Segment. At a minimum, this\nprocess must consider all failure causes and specify the use of one or more of\nthe following:\na. ILI tools that are technically appropriate for assessing the pipeline system\nbased on the suspected cause of failure and that can reliably detect and\nidentify anomalies;\nb. Hydrostatic pressure testing;\nc. Close-interval surveys;\nd. Cathodic protection surveys, to include interference surveys in\ncoordination with other utilities (e.g. underground utilities, overhead\npower lines, etc.) in the area;\ne. Coating surveys;\n\n\n\nCPF No: 1-2015-5018H\nPage 8\nf. Stress corrosion cracking surveys;\ng. h. Selective seam corrosion surveys; and\nOther tests, inspections, assessments, and evaluations appropriate for the\nfailure causes.\n6. Describe the inspection and repair criteria Colonial will use to prioritize,\nexcavate, evaluate, and repair anomalies, imperfections, and other identified\nintegrity threats. Include a description of how any defects will be graded and a\nschedule for repairs or replacement.\n7. Ensure long-term periodic testing and integrity verification measures are\ndescribed in maintenance procedures and incorporated in their integrity\nmanagement program; to ensure the ongoing safe operation of the Affected\nSegment considering the results of the analyses, inspections, evaluations, and\ncorrective measures undertaken pursuant to this Order.\n8. 9. Include a proposed schedule for completion of the RWP.\nColonial must revise the RWP as necessary to incorporate new information\nobtained during the failure investigation and remedial activities, to incorporate\nthe results of actions undertaken pursuant to this Order, and/or to incorporate\nmodifications required by the Director.\na. Submit any plan revisions to the Director for prior approval.\nb. The Director may approve plan revisions incrementally.\nc. Any and all revisions to the RWP after it has been approved and\nincorporated by reference into this Order will be fully described and\ndocumented in the CAO Documentation Report (CDR).\n10. Implement the RWP as it is approved by the Director, including any revisions to\nthe plan.\n12. CAO Documentation Report. Colonial must create and revise, as necessary, a CAO\nDocumentation Report (CDR). When Colonial has concluded all the items in this Order\nit will submit the final CDR in its entirety to the Director. This will allow the Director to\ncomplete a thorough review of all actions taken by Colonial with regards to this Order\nprior to approving the closure of this Order. The intent is for the CDR to summarize all\nactivities and documentation associated with this Order in one document.\na. The Director may approve the CDR incrementally without approving the entire\nCDR.\nb. Once approved by the Director, the CDR will be incorporated by reference into\nthis Order.\nc. The CDR must include, but not be limited to:\ni. A Table of Contents;\nii. A summary of the Failure events and the response activities;\niii. A summary of pipe data/properties and all prior assessments of the\n\n\n\nCPF No: 1-2015-5018H\nPage 9\niv. v. vi. vii. viii. ix. Affected Segment;\nA summary of all tests, inspections, assessments, evaluations, and analysis\nrequired by this Order;\nA summary of the Mechanical and Metallurgical Testing as required by\nthis Order;\nDocumentation of all actions taken by Colonial to implement the RWP,\nthe results of those actions, and the inspection and repair criteria used;\nDocumentation of any revisions to the RWP, including those necessary to\nincorporate the results of actions undertaken pursuant to this Order and\nwhenever necessary to incorporate new information obtained during the\nfailure investigation and remedial activities;\nLessons learned while completing this Order;\nA path forward describing specific actions Colonial will take on its entire\npipeline system as a result of the lessons learned from work on this Order;\nand\nx. Appendices (if required).\nOther Requirements:\n1. Reporting.\nMonthly - Colonial must submit monthly reports to the Director that: (1) include all\navailable data and results of the testing and evaluations required by this Order; and (2)\ndescribe the progress of the repairs or other remedial actions being undertaken. The first\nmonthly report is due November 1, 2015, for the month of October 2015.\nQuarterly – Colonial must also submit quarterly reports to the Director. The first\nquarterly report is due on January 5, 2016, for the period October 1, 2015, through\nDecember 31, 2015.\nMonthly reports will be due 5 days after the first of each month. Quarterly reports will be\ndue 10 days after the first of each month.\na. For example, the first monthly report will cover the time period from October 1,\n2015, through October 31, 2015, and is due by November 5, 2015.\nb. The first quarterly report will cover the time period from October 1, 2015 to\nDecember 31, 2015, and is due by January 10, 2016.\nThe requirement for monthly and quarterly report submittals will terminate upon closure\nof the Amended Corrective Action Order. The Director may change the interval for the\nsubmission of these reports.\n2. Documentation of Costs. It is requested but not required that Respondent maintain\ndocumentation of the costs associated with implementation of this Order. Include in each\nmonthly report the to-date total costs associated with: (1) preparation and revision of\nprocedures, studies and analyses; (2) physical changes to pipeline infrastructure,\nincluding repairs, replacements and other modifications; and (3) environmental\nremediation, if applicable.\n\n\n\nCPF No: 1-2015-5018H\nPage 10\n3. Approvals. With respect to each submission requiring the approval of the Director, the\nDirector may: (a) approve the submission in whole or in part; (b) approve the submission\non specified conditions; (c) modify the submission to cure any deficiencies; (d)\ndisapprove the submission in whole or in part and direct Respondent to modify the\nsubmission; or (e) any combination of the above. In the event of approval, approval upon\nconditions, or modification by the Director, Colonial shall proceed to take all action\nrequired by the submission, as approved or modified by the Director. If the Director\ndisapproves all or any portion of a submission, Respondent must correct all deficiencies\nwithin the time specified by the Director and resubmit it for approval.\n4. Extensions of Time. The Director may grant an extension of time for compliance with\nany of the terms of this Order upon a written request timely submitted and demonstrating\ngood cause for an extension.\nThe actions required by this Order are in addition to and do not waive any requirements that\napply to Respondent’s pipeline system under 49 C.F.R. Part 195, under any other order issued to\nRespondent under authority of 49 U.S.C. § 60101, et seq., or under any other provision of\nFederal or State law.\nRespondent may appeal any decision of the Director to the Associate Administrator for Pipeline\nSafety. Decisions of the Associate Administrator shall be final.\nBe advised 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).\nFailure to comply with this Order may result in the assessment of civil penalties and in referral to\nthe Attorney General for appropriate relief in United States District Court pursuant to 49 U.S.C.\n§ 60120.\nIn your correspondence on this matter, please refer to CPF No. 1-2015-5018H and for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nThe terms and conditions of this Amended Corrective Action Order are effective upon receipt.\n__________________________________ ________________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n120155018H_Closure Letter_07162020_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nJuly 16, 2020\nMr. Joseph Blount\nPresident & CEO\nColonial Pipeline Company\n1185 Sanctuary Parkway, Suite 100\nAlpharetta, Georgia 30009\nCPF 1-2015-5018H\nDear Mr. Blount:\nOn October 22, 2015, the Pipeline and Hazardous Materials Safety Administration (PHMSA)\nissued an Amended Corrective Action Order (ACAO) with regard to a pipeline failure accident of\nColonial Pipeline Company (Colonial). The ACAO included a list of various required Corrective\nActions.\nWe have received an email and ACAO Documentation Report dated March 31, 2020, from a\nrepresentative of Colonial. The Documentation Report was submitted as part of the final\nCorrective Action deliverable. Simultaneously, the correspondence requested closure of the\nACAO.\nBased on our review of the documentation, it has been determined that Colonial Pipeline has\ncomplied with the terms of the Order.\nThis letter is to inform you no further action is necessary, and this case is now closed. Thank you\nfor your cooperation in this matter.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n\n120155018H_Corrective Action Order_09292015_text.pdf\n\nSeptember 29, 2015\nVIA CERTIFIED MAIL AND FAX TO: (678) 762-2466\nMr. Tim Felt\nPresident & Chief Executive Officer\nColonial Pipeline Company\n1185 Sanctuary Parkway, Suite 100\nAlpharetta, GA 30009-4765\nRe: CPF No. 1-2015-5018H\nDear Mr. Felt:\nEnclosed is a Corrective Action Order issued in the above-referenced case. It requires Colonial\nPipeline Company to take certain corrective actions with respect to its Line #4 pipeline that\nfailed on September 23, 2015, in Centreville, Virginia. Service is being made by certified mail\nand facsimile. Service of the Corrective Action Order by electronic transmission is deemed\ncomplete upon transmission and acknowledgement of receipt, or as otherwise provided under\n49 C.F.R. § 190.5. The terms and conditions of this Order are effective upon completion of\nservice.\nThank you for your cooperation in this matter.\nSincerely,\nLinda Daugherty\nActing Associate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Mr. Byron Coy, Regional Director, Eastern Region, OPS\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nColonial Pipeline Company, ) CPF No. 1-2015-5018H\n)\n)\n)\nRespondent. )\n____________________________________)\nCORRECTIVE ACTION ORDER\nPurpose and Background:\nThis Corrective Action Order (“Order”) is being issued, under the authority of 49 U.S.C. §\n60112, to require Colonial Pipeline Company (“Colonial or Respondent”), to take the necessary\ncorrective action to protect the public, property, and the environment from potential hazards\nassociated with the recent failure on Colonial’s Line #4 pipeline.\nOn September 23, 2015, a reportable accident occurred on Colonial’s Line #4 hazardous liquid\npipeline in Centreville, Virginia, resulting in the release of approximately 4,000 gallons of\ngasoline (“Failure”). This pipeline transports petroleum product from Houston, Texas, to\nLinden, New Jersey. The accident occurred on a 285-mile section of Line #4 that runs from\nGreensboro Station, Greensboro, North Carolina, to Dorsey Junction Station in Sykesville,\nMaryland. Colonial operates a parallel pipeline, known as Line #3, that runs thirty feet apart\nfrom Line #4 at the site of the accident (“Leak Site”). Based on a visual inspection of the pipe, a\nleak occurred as the result of a crack within a dent that was discovered on the bottom of Line #4.\nThe root cause of the release has not yet been determined. Pursuant to 49 U.S.C. § 60117, the\nPipeline and Hazardous Materials Safety Administration (“PHMSA”), Office of Pipeline Safety\n(OPS), initiated an investigation of the accident. The preliminary findings of the ongoing\ninvestigation are as follows.\nPreliminary Findings:\n• Colonial operates roughly 5,500 miles of hazardous liquid transmission pipeline within\nthe United States. The pipelines travel through the states of Texas, Louisiana,\nMississippi, Alabama, Georgia, North and South Carolina, Virginia, Maryland,\nPennsylvania, New Jersey, and New York. Branches from the main lines also extend into\nTennessee. The system delivers a daily average of approximately 100 million gallons of\n\n\n\nCPF No: 1-2015-5018H\nPage 2\nliquid petroleum products to businesses and communities throughout the Southern and\nEastern United States.1\n• The section of Line #4 at the Leak Site was constructed in 1963 and is composed of 32-\ninch diameter, 0.281” wall thickness (generally), API-5L, X52 pipe, has asphalt enamel\ncoating and DSAW seam type, and is high-frequency electric resistance welded (“HF\nERW”) pipe manufactured by National Tube Company.\n• The Maximum Operating Pressure (MOP) of the section of Line #4 at the Leak Site is\n657 psig, as established by hydrostatic testing in 1963. At the time of the Failure, the\nactual operating pressure of the Affected Segment was 283 psig.\n• In response to reports from local residents of gasoline odor near a retention pond\napproximately 1,000 feet from Lines #3 and #4 in Centreville, Virginia, on the morning\nof September 21, 2015, the Fairfax County Fire Department and Fairfax County Fire\nMarshall responded to the site of the retention pond.\n• Due the reports of gasoline odor near the site of the retention pond in Centreville,\nVirginia, as well as the activity on the part of the Fairfax County Fire Department and\nFairfax County Fire Marshall near this site, officials from Colonial arrived at this site by\nthe evening of September 21, 2015. After arriving, these officials discovered large\nquantities of gasoline in the storm water system leading to the retention pond.\n• At 9:00 pm on September 21, 2015 Colonial acted to immediately isolate Lines 3 and 4\nby closing remote operated valves at Greensboro, North Carolina, and Sykesville,\nMaryland.\n2\n• At approximately 1:30 pm on September 22, 2015 an OPS investigator arrived at the\nLeak Site. A representative of the Virginia State Corporation Commission, in its capacity\nas interstate agent for PHMSA (“VA-SCC”) arrived at the Leak Site later in the afternoon\non September 22, 2015.\n• On September 22, 2015 the National Transportation Safety Board (“NTSB”) informed\nthe Director, Eastern Region, PHMSA, that NTSB officials were going to visit the Leak\nSite on September 23, 2015.\n• On the September 23, 2015, officials from the NTSB arrived at the Leak Site. On this\ndate the NTSB also informed the Director that it was also launching an investigation into\nthe Failure.\n• On September 23, 2015, at 4:23 pm, Colonial made a report to the National Response\nCenter (NRC Report No. 1129084), noting a sheen and odor of gasoline in the retention\npond approximately 1,000 feet from Lines #3 and #4 in Centreville, Virginia.\n1 Colonial Pipeline Company. Website: http://www.colpipe.com/home/about-colonial (last visited September 29,\n2015).\n2 The isolation valves are separated by a distance of approximately 280 miles; additional manual valves were closed\nto further isolate the failure point.\n\n\n\nCPF No: 1-2015-5018H\nPage 3\n• Colonial conducted an investigation by digging test holes around Lines #3 and #4 in\norder to identify the source of the leak. Colonial personnel later discovered a crack\nwithin a dent on the bottom of Line #4. There were no reported injuries or fatalities, and\nthe released gasoline failed to ignite. Colonial recovered approximately 2,000 gallons of\nthe estimated 4,000 gallons released. As a precaution, a small strip mall and a restaurant\nin the vicinity of the release were evacuated. The release caused significant soil\ncontamination in the vicinity of Line #3, Line #4, and nearby storm water drainage piping\nand retention ponds. The accident occurred within a High Consequence Area (HCA).\n• Based on a visual examination of the pipeline at the Leak Site, gasoline was released\nfrom a crack within a shallow dent located on the bottom of the pipe. However, the\nspecific cause of the failure is still undetermined and the investigation is ongoing. The\npipe at the Leak Site was excavated and examined on September 25, 2015.\n• Colonial identified the dent at the Leak Site and a similar dent 65 feet from the Leak Site\nduring a 2010 in-line inspection (2010 ILI). During the 2010 ILI, it was determined that\nneither dent required repair or excavation, as both were less than two percent of the pipe\ndiameter. On September 24, 2015, Colonial excavated the site of the second dent and\nconfirmed that it did not appear to have any cracks or appear to be leaking.\n• Colonial applied a B-Sleeve at the leak site as a temporary measure, and planned to cut\nout a section of Line #4 at the Leak Site in the coming weeks.\n• On September 25, 2015, following satisfactory installation of the B-Sleeve, the Director\napproved the temporary re-start for Line #4, which included a 20% reduction in operating\npressure at the leak location, resulting in a temporary maximum pressure at this location\nof 223 psig.\n• Colonial and the director agreed that as part of the temporary re-start, Line #4 must be\nimmediately shutdown upon any sign of significant or unexplained pressure loss in Line\n#4 ","truncated":true,"body_characters":58724}