{"operation":"document","citation":"CPF 12021077CAO","title":"COLLINS PIPELINE CO — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2021-12-30","effective_on":null,"summary":"OPEN corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021077cao.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021077cao.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12021077cao","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12021077CAO","body":"Corrective Action Order involving COLLINS PIPELINE CO. The dataset does not identify a cited regulation for this case. The case was opened on 2021-12-30 and is reported as open. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12021077CAO_Corrective Action Order_12302021_(21-232095).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021077CAO/12021077CAO_Corrective%20Action%20Order_12302021_(21-232095).pdf\n\n12021077CAO_Corrective Action Order_12302021_(21-232095)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021077CAO/12021077CAO_Corrective%20Action%20Order_12302021_(21-232095)_text.pdf\n\n12021077CAO_Corrective Action Order_12302021_(21-232095)_text.pdf\n\nDecember 30, 2021\nVIA ELECTRONIC MAIL TO: tom.nimbley@pbfenergy.com\nMr. Thomas Nimbley\nChairman and Chief Executive Officer\nPBF Energy, Inc.\n1 Sylvan Way, Second Floor\nParsippany, NJ 07054\nCPF No. 1-2021-077-CAO\nDear Mr. Nimbley:\nEnclosed please find a Corrective Action Order (CAO) issued by the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), in the above-\nreferenced case. It requires Collins Pipeline Company, LLC (Respondent), a subsidiary of PBF\nEnergy, Inc., to take certain corrective actions with respect to a rupture that occurred on its 16-inch\nMeraux Pipeline near the Mississippi River Gulf Outlet levee in St. Bernard Parish, Louisiana.\nService of the CAO by electronic mail is deemed complete upon transmission and\nacknowledgement of receipt, or as otherwise provided under 49 C.F.R. § 190.5. The terms and\nconditions of this Order are effective upon completion of service.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure: CAO\ncc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS\nMr. Robert Burrough, Director, Eastern Region, OPS\nMr. Christopher Carrington, Environmental Manager, PBF Energy, Inc.,\nchristopher.carrington@pbfenergy.com\nMr. Thomas J. McLane, Director, Regulatory Compliance, PBF Logistics, LP,\nthomas.mclane@pbfenergy.com\nCONFIRMATION OF RECEIPT REQUESTED\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 )\n)\n)\nCollins Pipeline Company, LLC,\na subsidiary of PBF Energy, Inc.,\n)\n)\n)\nRespondent. )\n____________________________________)\nCPF No. 1-2021-077-CAO\nCORRECTIVE ACTION ORDER\nPurpose and Background\nThis Corrective Action Order (CAO or Order) is being issued by the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), under the authority\nof 49 U.S.C. § 60112 to require Collins Pipeline Company, LLC (Collins or Respondent), a\nsubsidiary of PBF Energy, Inc.,1 to take the necessary corrective actions to protect the public,\nproperty, and the environment from potential hazards associated with the December 27, 2021\nrupture of its 16-inch hazardous liquid pipeline near the Mississippi River Gulf Outlet (MRGO)\nlevee in St. Bernard Parish, Louisiana (Accident).\nAt approximately 09:30 Central Standard Time (CST) on December 27, 2021, Collins personnel\nshut in the Meraux Pipeline after reportedly observing pressure gauges and flow meter\nmeasurements that indicated there was a leak. At approximately 17:30 CST, Collins personnel\nvisually confirmed that its 16-inch Meraux Pipeline ruptured, resulting in a release of low sulfur\ndiesel that surfaced in a field approximately 5 miles from PBF Energy, Inc.’s Chalmette\nRefinery2 in St. Bernard Parish in southeastern Louisiana.\nCollins initially estimated the failed pipeline released approximately 200-300 barrels (BBLs) of\nlow sulfur diesel, producing an approximately 10-yard by 30-yard pool of diesel in a field near\ntwo ponds. Collins updated the estimated loss to 7,200 BBLs based on supervisory control and\ndata acquisition (SCADA) information and drain down volume on December 28, 2021. The\n1 PBF Energy, Inc. is an independent petroleum refiner and supplier of unbranded transportation fuels, heating oil,\npetrochemical feedstocks, lubricants, and other petroleum products in the United States. PBF Energy, Inc. owns and\noperates six domestic oil refineries and related assets with a combined processing capacity, known as throughput, of\nover 1,000,000 bpd. See PBF Energy website, available at https://www.pbfenergy.com/refineries/ (last accessed\nDecember 28, 2021).\n2 The Meraux Pipeline is downstream of the Chalmette Refinery.\n\n\n\nCPF No. 1-2021-077-CAO\nPage 2\nrelease contaminated the soil of the field and 1,200 BBLs were recovered, collectively, from the\ntwo ponds.\nPrior to the rupture, the Meraux Pipeline operated at a reduced maximum operating pressure\n(MOP) of approximately 1398 pounds per square inch gauge (psig) due to the Respondent’s\ndiscovery of two metal loss anomalies in October 2020. The failure occurred at mile post 3.79,\nthe location of one of the two anomalies, which had not yet been repaired. The cause of the\nfailure is currently unknown.\nCollins deployed personnel to the site to run a containment and preventative boom to ensure that\nadditional product did not reach the two ponds. Collins personnel also mobilized equipment to\nremove product and contaminated soil from the environment. The Louisiana Department of\nEnvironmental Quality (DEQ) and the Louisiana Department of Wildlife and Fisheries\nresponded to the Accident. PHMSA’s Accident Investigation Division (AID) also deployed and\narrived onsite at 07:00 CST on December 29, 2021.\nPursuant to 49 U.S.C. § 60117, PHMSA initiated an investigation of the Accident. The\npreliminary findings of the Agency’s ongoing investigation are as follows:\nPreliminary Findings\n At approximately 09:30 CST on December 27, 2021, Collins personnel observed\npressure gauges and flow meter measurements that indicated there was a leak on its\n16-inch Meraux Pipeline. Immediately thereafter, the pipeline was shut in.\n At approximately 17:30 CST on December 27, 2021, 8 hours later, Collins personnel\nvisually confirmed that the Meraux Pipeline ruptured, resulting in a release of low\nsulfur diesel.\n Collins reported the Accident to the National Response Center (NRC) at 18:16 CST\non December 27, 2021 (NRC Report No. 1325365), indicating it released an\nunknown amount of low sulfur diesel into soil, nearly nine hours after shutting in the\npipeline.\n Collins initially reported a release of approximately 200-300 BBLs of low sulfur\ndiesel, producing a 10-yard by 30-yard pool in a field on the onshore side of a\nconcrete barrier wall near the MRGO levee, approximately 5 miles from Chalmette\nRefinery in St. Bernard Parish in southeastern Louisiana and 3.79 miles downstream\nof the Meraux pump station. As of December 28, 2021, the estimated loss of low\nsulfur diesel was increased to 7,200 BBLs based on SCADA information and drain\ndown volume.\n The failure site is located at the anomaly at mile post 3.79. It is 3.79 miles from the\nMeraux pump station and approximately 5 miles from Chalmette Refinery in St.\nBernard Parish.\n\n\n\nCPF No. 1-2021-077-CAO\nPage 3\n There were no fires, injuries, fatalities, or evacuations associated with the Accident.\n State and federal agencies responded, including the Louisiana DEQ and the Louisiana\nDepartment of Wildlife and Fisheries. PHMSA’s AID also deployed and arrived\nonsite at 07:00 CST on December 29, 2021.\n Clean up operations are underway. Private oil spill response organizations under\ncontract with Collins are onsite. Collins personnel began containment and\nremediation work on December 27, 2021. On December 29, 2021 Collins began\nexcavation of the affected pipe. Cannons are in place to deter wildlife from the site.\n The Meraux Pipeline is a 16-inch, 124.52-mile interstate pipeline, beginning at the\noutlet of the Meraux pump station in St. Bernard Parish, Louisiana and ending at the\nT&M Terminal in Collins, Mississippi. The Meraux Pipeline traverses high\nconsequence areas (HCA), as defined in 49 C.F.R. § 195.450. Approximately 72\nmiles of the Meraux Pipeline is designated as an HCA due to its proximity to an\nunusually sensitive area (USA) drinking water resource, as defined in 49 C.F.R. §\n195.6(a), and approximately 105 miles is designated as an HCA due to its proximity\nto an USA ecological resource, as defined in 49 C.F.R. § 195.6(b).\n The failure is located within an HCA, only a few hundred feet from the Mississippi\nRiver.\n Construction of the Meraux Pipeline started in 1970 and was completed in 1979. It\nhas a 16-inch nominal diameter with 0.344-inch wall thickness. The pipeline consists\nof X-52 grade seamless pipe. The pipe coating type is somastic (asphalt, asbestos\nfiber, sand, and a mineral filler) and has an impressed cathodic protection system.\n Prior to the rupture, the Meraux Pipeline operated at a reduced MOP of 1398 psig.\nAs of December 29, 2021, the Meraux Pipeline’s actual operating pressure prior to\nthe Accident has not been determined.\n On October 15, 2020, an ultrahigh-resolution magnetic flux leakage inline inspection\n(MFL- ILI) tool run was completed on the pipeline by a third-party vendor. The\nOctober 15, 2020 MFL-ILI survey results (hereafter, MFL-ILI) indicated an area of\ninteracting external pitting 266-inches long by 25-inches wide near the failure\nlocation. The anomaly with the most metal loss within the area of interacting pitting\nwas an apparent 75 percent metal loss anomaly near the MRGO levee at mile post\n3.79 (MRGO levee anomaly). In accordance with 49 C.F.R. § 195.452(h)(4)(i)(A), a\n75 percent metal loss meets the immediate repair criteria when including tool\ntolerance. However, after the Respondent’s field evaluation of other anomalies\nnearby in 2021, the MFL-ILI was reevaluated by the vendor and the anomaly was re-\ngraded to 66 percent deep, meeting the criteria for a 180-day repair in accordance\nwith 49 C.F.R. § 195.452(h)(4)(iii).\n\n\n\nCPF No. 1-2021-077-CAO\nPage 4\n The MFL-ILI indicated another anomaly, which after the Respondent’s field\nverification was determined to be internal metal loss due to a manufacturing defect\nmeasured at 56 percent in depth. This anomaly was repaired with a full encirclement\nsleeve in December 2020.\n Collins instituted a temporary pressure reduction from 1440 psig to 1402 psig on\nNovember 11, 2020 using pressure recalculations based on the MFL-ILI identified\nmetal loss. In accordance with 49 C.F.R. § 191.23, Collins filed a Safety Related\nCondition report with PHMSA on November 16, 2020. A further pressure reduction\nto 1398 psig was initiated on November 11, 2021, due to the MRGO levee anomaly\nnot being remediated within the regulatory required time frame of 180 days. Because\nthe pressure reduction exceeded 365 days, Collins filed an Integrity Management\nNotification for the MRGO levee anomaly on November 11, 2021, as required by 49\nC.F.R. § 195.452(h)(1)(ii). The failure occurred on or near the MRGO levee\nanomaly.\n The pipeline remains shut down and shut in. The operator is in the process of\nrecovering product from the failure site.\n The root cause of the Accident remains unconfirmed at this time. However,\npreliminary reports indicate that the probable cause is likely localized corrosion and\nmetal loss.\nDetermination of Necessity for Corrective Action Order and Right to Hearing\nSection 60112 of title 49, United States Code, authorizes PHMSA to determine that a pipeline\nfacility is or would be hazardous to life, property, or the environment and if there is a likelihood\nof serious harm, to expeditiously order the operator of the facility to take necessary corrective\naction, including suspended or restricted use of the facility, physical inspection, testing, repair,\nreplacement, or other appropriate action. An order issued expeditiously must provide an\nopportunity for a hearing as soon as practicable after the order is issued.\nIn deciding whether to issue an order, PHMSA must consider the following, if relevant: (1) the\ncharacteristics of the pipe and other equipment used in the pipeline facility, including the age,\nmanufacture, physical properties, and method of manufacturing, constructing, or assembling the\nequipment; (2) the nature of the material the pipeline facility transports, the corrosive and\ndeteriorative qualities of the material, the sequence in which the material is transported, and the\npressure required for transporting the material; (3) the aspects of the area in which the pipeline\nfacility is located, including climatic and geologic conditions and soil characteristics; (4) the\nproximity of the area in which the hazardous liquid pipeline facility is located to environmentally\nsensitive areas; (5) the population density and population and growth patterns of the area in\nwhich the pipeline facility is located; (6) any recommendation of the National Transportation\nSafety Board made under another law; and (7) any other factors PHMSA may consider as\nappropriate.\n\n\n\nCPF No. 1-2021-077-CAO\nPage 5\nAfter evaluating the foregoing preliminary findings of fact, and having considered the\ncharacteristics of the pipeline, including the size of the corrosion area identified in the MFL-ILI\n(interacting external pitting 266-inches long by 25-inches wide); the location of another anomaly\nat mile post 52.17, which was identified in the MFL-ILI and initially met the condition for an\nimmediate repair, and was subsequently repaired with a full encirclement sleeve; the Accident’s\nlocation in an HCA near the MRGO levee and the Mississippi River; the hazardous nature of the\nmaterial (diesel) transported; the uncertainty as to the root cause of the Accident; the length of\ntime it took Collins to identify the leak; the sensitive environmental areas in the vicinity of the\npipeline; ongoing impacts to the environment and wildlife; and the risk of additional, related\naccidents, I find that continued operation of the Affected Pipeline, as defined below, without\ncorrective measures is or would be hazardous to life, property, or the environment, and that\nfailure to issue this Order expeditiously would result in the likelihood of serious harm.\nAccordingly, this Order mandating immediate corrective action is issued expeditiously without\nprior notice and opportunity for a hearing. The terms and conditions of this Order are effective\nupon receipt.\nWithin 10 days of receipt of this Order, Respondent may request a hearing, to be held as soon as\npracticable, by notifying the Associate Administrator for Pipeline Safety in writing, with a copy\nto the Director, Eastern Region, PHMSA. If a hearing is requested, it will be held in accordance\nwith 49 C.F.R. § 190.211.\nAfter receiving and analyzing additional data in the course of this investigation, PHMSA may\nidentify other corrective measures that need to be taken. Respondent will be notified of any\nadditional measures required and, if appropriate, PHMSA will consider amending this Order. To\nthe extent consistent with safety, Respondent will be afforded notice and an opportunity for a\nhearing prior to the imposition of any additional corrective measures.\nRequired Corrective Actions\nDefinitions:\nAffected Pipeline – The “Affected Pipeline” means the Collins Meraux Pipeline, which is\napproximately 124.52 miles long, beginning at the outlet of the Meraux pump station in St.\nBernard Parish, Louisiana and ending at the T&M Terminal in Collins, Mississippi.\nIsolated Segment – The \"Isolated Segment\" means the 9.49 miles of the Meraux Pipeline,\nbeginning at the Meraux pump station in St. Bernard Parish, Louisiana and ending at Valve 2\nnear mile post 9.5 in Orleans Parish, Louisiana.\nDirector – PHMSA, OPS Eastern Region\nPursuant to 49 U.S.C. 60112, I hereby order Collins to immediately take the following corrective\nactions:\n\n\n\nCPF No. 1-2021-077-CAO\nPage 6\n1. 2. 3. Shutdown of the Isolated Segment. The Isolated Segment is currently out of service. The\nIsolated Segment must remain shut-in and may not be operated until authorized to be\nrestarted by the Director in accordance with the terms of this Order.\nOperating Pressure Restriction. Collins must reduce and maintain a twenty percent (20%)\npressure reduction in the actual operating pressure along the entire length of the Affected\nPipeline such that the operating pressure along the Affected Pipeline will not exceed eighty\npercent (80%) of the actual operating pressure in effect immediately prior to the failure.\na. This pressure restriction is to remain in effect until written approval to increase the\npressure or approval to return the pipeline to its pre-failure operating pressure is\nobtained from the Director.\nb. Within 15 days of receipt of this Order, Collins must provide the Director the actual\noperating pressures of each pump station and each main line pressure transmitter on the\nAffected Pipeline at the time of failure and the reduced pressure restriction set-points at\nthese same locations.\nc. This pressure restriction requires any relevant remote or local alarm limits, software\nprogramming set-points or control points, and mechanical over-pressure devices to be\nadjusted accordingly.\nd. When determining the pressure restriction set-points, Collins must take into account\nany in-line inspection (ILI) features or anomalies present in the Affected Pipeline to\nprovide for continued safe operation while further corrective actions are completed.\ne. Collins must review the pressure restriction monthly by analyzing the operating\npressure data, taking into account any ILI features or anomalies present in the Affected\nPipeline. Collins must immediately reduce the operating pressure further to maintain\nthe safe operations of the Affected Pipeline, and notify the Director to revise the\nremedial work plan (Item 9 below), if warranted by the monthly review. Further,\nCollins must submit the results of the monthly review to the Director including, at a\nminimum, the current discharge set-points (including any additional pressure\nreductions), and any pressure exceedance at discharge set-points. Submittals must be\nmade quarterly, in accordance with Item 16 below.\nMechanical and Metallurgical Testing. Within 45 days of receipt of this Order, Collins\nmust complete mechanical and metallurgical testing and failure analysis of the failed pipe,\nincluding an analysis of soil samples and any foreign materials. Mechanical and\nmetallurgical testing must be conducted by an independent third-party acceptable to the\nDirector. The independent third-party must document its analysis and evaluation of the\nfailed pipe and any other factors that contributed to the failure of the pipe. Collins must\ncomplete the testing and analysis as follows:\na. Document the chain-of-custody when handling and transporting the failed pipe\nsection and other evidence from the failure site.\nb. c. Within 10 days of receipt of this Order, develop and submit the testing protocol and\nthe proposed testing laboratory to the Director for prior approval.\nPrior to beginning the mechanical and metallurgical testing, provide the Director with\n\n\n\nCPF No. 1-2021-077-CAO\nPage 7\n4. 5. 6. 7. 8. the scheduled date, time, and location of the testing to allow for an OPS\nrepresentative to witness the testing.\nd. Ensure the testing laboratory distributes all reports whether draft or final in their\nentirety to the Director at the same time they are made available to Collins.\nInstrumented Leakage Survey. Within 30 days of receipt of this Order, Collins must\nperform an aerial or ground instrumented leakage survey of the Affected Pipeline. Collins\nmust investigate all leak indications and remedy all leaks discovered. Collins must submit\ndocumentation of this survey to the Director within 45 days of receipt of this Order.\nRecords Verification. As recommended in PHMSA Advisory Bulletin 2012-06, Collins\nmust verify the records for the Affected Pipeline to confirm the MOP. Collins must submit\ndocumentation of this record verification to the Director within 45 days of receipt of this\nOrder.\nReview of Prior Inline Inspection (ILI) Results. Within 30 days of receipt of this Order,\nCollins must conduct a review of any previous ILI results of the Affected Pipeline. In its\nreview, Collins must re-evaluate all ILI results from the past 10 calendar years, including a\nreview of the ILI vendors' raw data and analysis. Collins must determine whether any\nfeatures were present in the failed pipe joints from the Accident and any other pipe\nremoved. Collins must also determine if any features with similar characteristics are\npresent elsewhere on the Affected Pipeline. Collins must submit documentation of this ILI\nreview to the Director within 60 days of receipt of this Order as follows:\na. b. List all ILI tool runs, tool types, and the calendar years of the tool runs.\nList, describe (type, size, wall loss, etc.), and identify the specific location of all ILI\nfeatures present in the failed joint and other pipe removed.\nc. List, describe (type, size, wall loss, etc.), and identify the specific location of all ILI\nfeatures with similar characteristics present elsewhere on the Affected Pipeline.\nd. Explain the process used to review the ILI results and the results of the reevaluation.\nEmergency Response Plan and Training Review. Collins must review and assess the\neffectiveness of its emergency response plan with regards to the failure. Collins must\ninclude in the review and assessment the on-scene response and support, coordination, and\ncommunication with emergency responders and public officials. Also, Collins must\ninclude a review and assessment of the effectiveness of its emergency training program.\nCollins must amend its emergency response plan and emergency training, if necessary, to\nreflect the results of this review. Further, as part of this review, Collins must review\ncontroller response to all alarms prior to, and following, confirmation of the rupture.\nCollins must also review the controllers’ coordination and communications with internal\nand external stakeholders prior to and throughout this accident response. Documentation of\nthis Emergency Response Plan and Training Review and any amended plans must be\nprovided to the Director within 120 days of receipt of this Order.\nRoot Cause Failure Analysis. Within 120 days following receipt of this Order, an\nindependent third-party, retained by Collins and approved by the Director, must complete a\nroot cause failure analysis (RCFA) and submit a final report of this RCFA to the Director.\n\n\n\nCPF No. 1-2021-077-CAO\nPage 8\nThe RCFA must document Collins’ decision-making process prior to the Accident and\nevaluate all factors contributing to the failure. The final report must include findings and\nany lessons learned and whether the findings and lessons learned are applicable to other\nlocations within Collins’ pipeline system.\n9. Remedial Work Plan (RWP).\na. b. c. Within 120 days following receipt of this Order, Collins must submit a remedial work\nplan (RWP) to the Director for approval.\nThe Director may approve the RWP incrementally without approving the entire RWP.\nOnce approved by the Director, the RWP will be incorporated by reference into this\nOrder.\nd. The RWP must specify the tests, inspections, assessments, evaluations, and remedial\nmeasures Collins will use to verify the integrity of the Affected Pipeline. It must\naddress all known or suspected factors and causes of the Accident. Collins must\nconsider the risks and consequences of another failure to develop a prioritized\nschedule for RWP-related work along the Affected Pipeline.\ne. The RWP must:\ni. ii. Identify pipe in the Affected Pipeline with characteristics similar to the\ncontributing factors identified for the Accident.\nIncorporate all data necessary to review the failure history (in service and pressure\ntest failures) of the Affected Pipeline, such as the locations, dates, and causes of\nleaks and failures.\niii. iv. v. Integrate the results of the metallurgical testing, root cause failure analysis, and\nother corrective actions required by this Order with all relevant pre-existing\noperational and assessment data for the Affected Pipeline. Pre-existing\noperational data includes, but is not limited to, design, construction, operations,\nmaintenance, testing, repairs, prior metallurgical analyses, and any third-party\nconsultation information. Pre-existing assessment data includes, but is not limited\nto, ILI tool runs, hydrostatic pressure testing, direct assessments, close interval\nsurveys, and DCVG/ACVG surveys.\nDetermine if conditions similar to those contributing to the Accident are likely to\nexist elsewhere on the Affected Pipeline.\nConduct additional field tests, inspections, assessments, and evaluations to\ndetermine whether, and to what extent, the conditions associated with the\nAccident and other failures from the failure history (see (e)(ii) above) or any other\nintegrity threats are present elsewhere on the Affected Pipeline. At a minimum,\nthis process must consider all failure causes and specify the use of one or more of\nthe following:\n1) ILI tools that are technically appropriate for assessing the pipeline system\nbased on the cause of Accident and that can reliably detect and identify\nanomalies;\n2) Hydrostatic pressure testing;\n\n\n\nCPF No. 1-2021-077-CAO\nPage 9\nf. g. 3) Close-interval surveys;\n4) Cathodic protection surveys, to include interference surveys in coordination\nwith other utilities (e.g. underground utilities, overhead power lines, etc.) in\nthe area;\n5) Coating surveys;\n6) Stress corrosion cracking surveys;\n7) Selective seam corrosion surveys; and\n8) Other tests, inspections, assessments, and evaluations appropriate for the\nfailure causes.\nvi. Describe the inspection and repair criteria Collins will use to prioritize, excavate,\nevaluate, and repair anomalies, imperfections, and other identified integrity\nthreats. Include a description of how any defects will be graded and a schedule\nfor repairs or replacement.\nvii. Based on the known history and condition of the Affected Pipeline, describe the\nmethods Collins will use to repair, replace, or take other corrective measures to\nremediate the conditions associated with the Accident and to address other known\nintegrity threats along the Affected Pipeline. The repair, replacement, or other\ncorrective measures must meet the criteria specified in (e)(vi) above.\nviii. Implement continuing long-term periodic testing and integrity verification\nmeasures to ensure the ongoing safe operation of the Affected Pipeline\nconsidering the results of the analyses, inspections, evaluations, and corrective\nmeasures undertaken pursuant to the Order.\nInclude a proposed schedule for completion of the RWP.\nCollins must revise the RWP as necessary to incorporate new information obtained\nduring the failure investigation and remedial activities, to incorporate the results of\nactions undertaken pursuant to this Order, and to incorporate modifications required by\nthe Director.\nh. Submit any plan revisions to the Director for prior approval.\ni. ii. The Director may approve plan revisions incrementally.\nAll revisions to the RWP after it has been approved and incorporated by reference\ninto this Order will be fully described and documented in the CAO\nDocumentation Report, submitted under Item 10 below.\ni. Implement the RWP as it is approved by the Director, including any revisions to the\nplan.\n10. CAO Documentation Report (CDR). Collins must create and revise, as necessary, a CAO\nDocumentation Report (CDR). When Collins has concluded all the items in this Order it\nwill 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 Collins with regards to this Order prior\nto 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.\n\n\n\nCPF No. 1-2021-077-CAO\nPage 10\na. b. The Director may approve the CDR incrementally without approving the entire CDR.\nOnce approved by the Director, the CDR will be incorporated by reference into this\nOrder.\nc. The CDR must include, but is not necessarily limited to, the following:\ni. Table of Contents;\nii. iii. Summary of the Accident and the response activities;\nSummary of pipe data, material properties and all prior assessments of the\nAffected Pipeline;\niv. Summary of all tests, inspections, assessments, evaluations, and analysis required\nby the Order;\nv. vi. vii. Summary of the mechanical and metallurgical testing as required by the Order;\nSummary of the RCFA with all root causes as required by the Order;\nDocumentation of all actions taken by Collins to implement the RWP, the results\nof those actions, and the inspection and repair criteria used;\nviii. Documentation of any revisions to the RWP including those necessary to\nincorporate the results of actions undertaken pursuant to this Order and whenever\nnecessary to incorporate new information obtained during the failure investigation\nand remedial activities;\nix. x. Lessons learned while completing this Order;\nA path forward describing specific actions Collins will take on its entire pipeline\nsystem as a result of the lessons learned from work on this Order; and\nxi. Appendices (if required).\n11. Restart Plan. No restart of the Affected Pipeline may occur, unless and until a written\nRestart Plan has been submitted and approval had been granted by the Director, and which\nis to be subject to the following:\na. b. The Director may approve the Restart Plan incrementally without approving the\nentire plan, but the Isolated Segment cannot resume operation until the Restart Plan is\napproved in its entirety.\nOnce approved by the Director, the Restart Plan will be incorporated by reference\ninto this Order.\nc. The Restart Plan must provide for adequate patrolling of the Isolated Segment during\nthe restart process and must include incremental pressure increases during start up,\nwith each increment to be held for at least two hours.\nd. The Restart Plan must include sufficient surveillance of the pipeline during each\npressure increment to ensure that no leaks are present when operation of the line\nresumes.\ne. The Restart Plan must specify a day-light restart and include advance\ncommunications with local emergency response officials.\n\n\n\nCPF No. 1-2021-077-CAO\nPage 11\nf. The Restart Plan must provide for a review of the Isolated Segment for conditions\nsimilar to those of the failure including a review of construction, operating and\nmaintenance (O&M) and integrity management records such as ILI results,\nhydrostatic tests, root cause failure analysis of prior failures, aerial and ground\npatrols, corrosion, cathodic protection, excavations, and pipe replacements. Collins\nmust address any findings that require remedial measures to be implemented prior to\nrestarting operation of the Isolated Segment.\ng. The Restart Plan must also include documentation of the completion of all mandated\nactions, and a management of change plan to ensure that all procedural modifications\nare incorporated into Collins’ O&M procedures manual.\nh. The Restart Plan must provide for hydrostatic pressure testing of the Isolated\nSegment.\n12. Return to Service. After the Director approves the Restart Plan, Collins may return the\nIsolated Segment to service but the operating pressure must not exceed the pressure\nrestrictions in accordance with Item 2 above.\n13. Removal of Pressure Restriction.\na. b. The Director may allow the removal or modification of the pressure restriction upon a\nwritten request from Collins demonstrating that restoring the pipeline to its pre-failure\noperating pressure is justified based on a reliable engineering analysis showing that\nthe pressure increase is safe considering all known defects, anomalies, and operating\nparameters of the pipeline.\nThe Director may allow the temporary removal or modification of the pressure\nrestrictions upon a written request from Collins demonstrating that temporary\nmitigative and preventive measures are implemented prior to and during the\ntemporary removal or modification of the pressure restriction. The Director's\ndetermination will be based on the failure cause and provision of evidence that\npreventative and mitigative actions taken by the operator provide for the safe\noperation of the Affected Pipeline during the temporary removal or modification of\nthe pressure restriction. Appeals to determinations of the Director in this regard will\nbe decided by PHMSA’s Associate Administrator for Pipeline Safety.\nOther Requirements:\n14. Approvals. With respect to each submission that under this Order requires the approval of\nthe Director, the Director may: (a) approve, in whole or part, the submission; (b) approve\nthe submission on specified conditions; (c) modify the submission to cure any deficiencies;\n(d) disapprove in whole or in part, the submission, directing that Respondent modify the\nsubmission, or (e) any combination of the above. In the event of approval, approval upon\nconditions, or modification by the Director, Respondent 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 the submission, Respondent must correct all deficiencies\nwithin the time specified by the Director, and resubmit it for approval.\n\n\n\nCPF No. 1-2021-077-CAO\nPage 12\n15. Extensions of Time. The Director may grant an extension of time for compliance with any\nof the terms of this Order upon a written request timely submitted demonstrating good\ncause for an extension.\n16. Reporting. Submit quarterly reports to the Director that: (1) include all available data and\nresults of the testing and evaluations required by this Order; and (2) describe the progress\nof the repairs or other remedial actions being undertaken. The first quarterly report is due\non March 31, 2022. The Director may change the interval for the submission of these\nreports.\n17. Documentation of the Costs. It is requested but not required that Respondent maintain\ndocumentation of the costs associated with implementation of this Corrective Action Order.\nInclude in each monthly report submitted, the to-date total costs associated with: (1)\npreparation and revision of procedures, studies, and analyses; (2) physical changes to\npipeline infrastructure, including repairs, replacements, and other modifications; and (3)\nenvironmental remediation, if applicable.\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).\nIn your correspondence on this matter, please refer to “CPF No. 1-2021-077-CAO” and for each\ndocument you submit, please provide a copy in electronic format whenever possible. The\nactions required by this Order are in addition to and do not waive any requirements that apply to\nRespondent’s pipeline system under 49 C.F.R. Parts 190 through 199, under any other order\nissued to Respondent under authority of 49 U.S.C. Chapter 601, or under any other provision of\nfederal or state law.\nRespondent may appeal in writing any decision of the Director to the Associate Administrator\nfor Pipeline Safety. Decisions of the Associate Administrator shall be final.\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\n49 U.S.C. § 60120.\nThe terms and conditions of this Order are effective upon service in accordance with 49 C.F.R.\n§ 190.5.\nDecember 30, 2021\n_________________________________ ________________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety","truncated":false,"body_characters":36142}