COLONIAL PIPELINE CO — Warning Letter

120185020W_Warning Letter_09132018_text.pdf, page 1Official PDFWARNING LETTER OVERNIGHT EXPRESS DELIVERY September 13, 2018 Joseph A. Blount, Jr. President and Chief Executive Officer Colonial Pipeline Company 1185 Sanctuary Parkway, Suite 100 Alpharetta, GA 30009 CPF 1-2018-5020W Dear Mr. Blount: From June 20-22, 2017, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected Colonial Pipeline Company’s (Colonial) Dorsey Junction facility in Woodbine, Maryland. As a result of the inspection, it is alleged that Colonial has committed probable violation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and the probable violation is: 1. § 195.430 Firefighting Equipment. Each operator shall maintain adequate firefighting equipment at each pump station and breakout tank area. The equipment must be— (a) In proper operating condition at all times; Colonial did not maintain its firefighting equipment in proper operating condition at all times at the breakout tank area in Dorsey Junction facility. According to Colonial’s Fire Prevention & Response Plan Dorsey Junction 2/1/2014 (FPRP), on page 11, under section D. Site Features & On-site Resources, “Dorsey Junction’s current fire protection system consists of an underground firewater piping system terminating in hydrants throughout the tank area.” At the time of the inspection, Colonial did not have records to demonstrate that it maintained its fire protection system for the last 10 years. In addition, Colonial#

120185020W_Warning Letter_09132018_text.pdf, page 2CPF 1-2018-5020W stated that the underground firewater piping had deteriorated and would not be able to transport water to the breakout tank area to fight an incipient fire. Colonial had no other firefighting equipment at the breakout tank area. Furthermore, Colonial had a fire pump that drafted water from a pond, and which was connected to the underground firewater piping, but was no longer operable since 2012. Nevertheless, Colonial had a documented plan with local emergency response agencies and contracted firefighting firms to provide expertise, equipment, tools, and materials to control and extinguish non-incipient fires, in the FPRP. However, Colonial indicated that the local fire department determined that it needed a hose to reach the tank area from the pond in 2015. Based on the foregoing information, Colonial could not ensure that it had firefighting equipment, in proper operating condition at all times, to fight all types of fires at its breakout tank area in accordance with § 195.430(a). Colonial informed the PHMSA inspector that it anticipates having a fire protection system installed and operational in late 2018. Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $209,002 per violation per day the violation persists, up to a maximum of $2,090,022 for a related series of violations. For violations occurring prior to November 2, 2015, the maximum penalty may not exceed $200,000 per violation per day, with a maximum penalty not to exceed $2,000,000 for a related series of violations. We have reviewed the circumstances and supporting documents involved in this case, and have decided not to conduct additional enforcement action or penalty assessment proceedings at this time. We advise you to correct the item identified in this letter. Failure to do so will result in Colonial being subject to additional enforcement action. Please 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). No reply to this letter is required. If you choose to reply, please submit all correspondence in this matter to Robert Burrough, Director, PHMSA Eastern Region, 820 Bear Tavern Road, Suite 103, West Trenton, NJ 08628. Please refer to CPF 1-2018-5020W on each document you submit, and whenever possible provide a signed PDF copy in electronic format. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should be sent on a CD accompanied by the original paper copy to the Eastern Region Office. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration 120185020W_Warning Letter_09132018_text Page 2 of 2#