{"operation":"document","citation":"CPF 220165005H","title":"COLONIAL PIPELINE CO — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-09-16","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220165005h.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220165005h.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220165005h","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220165005H","body":"Corrective Action Order involving COLONIAL PIPELINE CO. The dataset does not identify a cited regulation for this case. The case was opened on 2016-09-16 and is reported as closed as of 2020-11-17. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220165005H_Amended Corrective Action Order_10132016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220165005H/220165005H_Amended%20Corrective%20Action%20Order_10132016.pdf\n\n220165005H_Amended Corrective Action Order_10132016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220165005H/220165005H_Amended%20Corrective%20Action%20Order_10132016_text.pdf\n\n220165005H_Closure Letter_11172020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220165005H/220165005H_Closure%20Letter_11172020.pdf\n\n220165005H_Closure Letter_11172020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220165005H/220165005H_Closure%20Letter_11172020_text.pdf\n\n220165005H_Corrective Action Order_09162016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220165005H/220165005H_Corrective%20Action%20Order_09162016.pdf\n\n220165005H_Corrective Action Order_09162016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220165005H/220165005H_Corrective%20Action%20Order_09162016_text.pdf\n\n220165005H_Amended Corrective Action Order_10132016_text.pdf\n\nOctober 13, 2016\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. 2-2016-5005H\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 to the failure on its\nPipeline One (Line #1), that occurred on September 9, 2016, near Pelham, Alabama.\nService is being made by certified mail and facsimile. Service of the Amended Corrective\nAction Order by electronic transmission 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.\nThank you for your cooperation in this matter.\nSincerely,\nAlan K. Mayberry\nActing Associate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, Office of\nPipeline Safety, PHMSA\nMr. James Urisko, Regional Director, Southern Region, Office of Pipeline Safety,\nPHMSA\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)\nColonial Pipeline Company, ) CPF No. 2-2016-5005H\n)\nRespondent. )\n)\nAMENDED CORRECTIVE ACTION ORDER\nPurpose and Background:\nThis Amended Corrective Action Order (Amended CAO) is being issued under the authority of\n49 U.S.C. § 60112 to require Colonial Pipeline Company (Colonial or Respondent), to take the\nnecessary corrective action to protect the public, property, and the environment from potential\nhazards associated with the recent failure on its Colonial’s Pipeline One (Line #1).1\nOn September 9, 2016, a reportable accident occurred on Colonial’s Line #1, a hazardous liquid\npipeline in Shelby County, Alabama, approximately three miles from the town of Pelham,\nAlabama (Failure). The Failure resulted in the release of approximately 7,370 barrels (bbls) of\ngasoline into a pond (Pond #2) approximately 460 feet north of Colonial’s Line #1. Line #1\ntransports gasoline from Houston, Texas, to Greensboro, North Carolina. The Failure occurred\non a 202-mile section of Line #1 that runs from Collins, Mississippi, to Pelham, Alabama.\nColonial operates a parallel pipeline that runs adjacent to Line #1, Pipeline Two (Line #2), that is\napproximately 40 feet apart from Line #1 at the Failure Site. Line #2 transports petroleum\nproduct from Epes, Alabama, to Anderson, South Carolina.\nOn September 16, 2016, PHMSA issued a Corrective Action Order (CAO) to Colonial. The\nCAO required Colonial to shut down failed section on Line #1 and carry out mechanical and\nmetallurgical testing and failure analysis of the failed section of pipe. At the time, the location of\nthe Failure and the extent of the environmental impact were unknown. This Amended\n1 Colonial operates roughly 5,500 miles of hazardous liquid transmission pipeline within the United States. The\npipelines travel through the states of Texas, Louisiana, Mississippi, Alabama, Georgia, North and South Carolina,\nVirginia, Maryland, Pennsylvania, 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 liquid petroleum products\nthroughout the Southern and Eastern United States.\n\n\n\nCPF No. 2-2016-5005H\nPage 2\nCorrective Action Order replaces and supersedes the CAO issued to Colonial on September 16,\n1) 2016.\nPursuant to 49 U.S.C. § 60117, the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), Office of Pipeline Safety (OPS), initiated an investigation of the accident.\nThe preliminary findings in the Original CAO noted the failure and related information and\ndetails about the defect discovered as a result of the September 9, 2016 failure. Since that time,\nthe following events have occurred and certain information has been discovered or clarified:\nAmended Preliminary Findings:\nLine #1 is a 36-inch diameter hazardous liquid pipeline that runs from Houston,\nTexas, to Greensboro, North Carolina. The Failure occurred on a segment of Line\n#1 that runs from Collins, Mississippi, to Respondent’s Pelham Station, in Pelham,\nAlabama (Affected Segment). The Failure occurred at Station 5155+57 on a section\nof Line #1 that runs from Colonial’s downstream Cahaba River block valve, near\nStation 5055+00, to Colonial’s Pelham Station in Pelham, Alabama, near Station\n5545+17. A pond (Pond #2) outside the company’s right-of-way is approximately\n460 feet from the Failure Site on Line #1 (Failure Site). Two other ponds are in the\nvicinity of the failed section: Pond #1 to the south of Line #1, and Pond #3 to the\nnorth of Pond #2. All referenced ponds are man-made reclamation and evaporation\nponds used during historic rural surface strip mining.\nThe Affected Segment was constructed in 1963 and is composed of 36-inch\ndiameter, 0.281-inch wall thickness, American Petroleum Institute (API) 5L, X52\npipe. The pipe generally has asphalt enamel coating and a double-submerged arc-\nwelded (DSAW) seam type, and was manufactured by the National Tube Company.\nSeveral sections of the Affected Segment were subject to replacement and recoat\nprojects since original construction, and may have more modern pipe and/or types of\ncoating.\nPond #2 is located near Station 5154+13, on Line #1, in Shelby County, Alabama,\napproximately three miles from Pelham, Alabama. Pond #2 is bounded by Line #1\nto the south and another pond, Pond #3, to the north. Pond #3 is also a man-made\nreclamation and evaporation pond used during historic rural surface strip mining.\nFrom September 12-13, 2016, Colonial installed stopple fittings upstream and\ndownstream of the Failure location in order to begin drain-down of the line before\nexcavation of the release location. The downstream stopple was tapped and plugged\nand work continued on the upstream stopple installation. On September 14, 2016, the\nupstream stopple was completed at 1:30 AM CDT. Nitrogen injections began at\n5:00 AM CDT and initial drain-up operations were completed that evening.\nAs of 8:00 AM CDT on September 15, 2016, Colonial personnel announced that\nsampling indicated the presence of dissolved constituents in Pond #3.\n2) 3) 4) 5)\n\n\n\nCPF No. 2-2016-5005H\nPage 3\n6) 7) 8) 9) At approximately 12:30 PM CDT on September 16, 2016, Colonial officials\nannounced that its personnel had discovered a culvert below the water line in Pond\n#2. Colonial officials further noted this culvert connects to Pond #3, and that they\nbelieve the dissolved constituents flowed from Pond #2, through this culvert, into\nPond #3.\nOn September 16, 2016, the amount of product extracted from the pipe remained at\n880 bbls. Adequate pressure to evacuate the product remaining in the stoppled\nsection of the line could no longer be provided by injecting nitrogen into the line.\nAs of the 9:00 AM CDT on September 17, 2016, the amount of product extracted\nfrom the pipe was 1,073 bbls. Colonial installed a temporary pig launcher and\nreceiver in order to use a pig to remove the remaining product. Colonial used water\nto push the pig to complete the product removal effort. There was no estimate on\nvolume remaining in stoppled section of the pipe.\nOn September 20, 2016, PHMSA approved the installation of a 36-inch diameter\ntemporary 500-foot bypass line on the Isolated Segment to facilitate limited pipeline\noperation of Line #1. Specifications of the bypass pipe are as follows:\na. Grade (API): X52 and X60\nb. SMYS: 811.77 psi\nc. Wall thickness: 0.281-inch\nd. e. f. Coating Fusion Bond Epoxy and Trenton Hot Wax\nTie-in welds NDT method X-Ray.\nUpon startup of the bypass, the bypass has been operating at a 20% reduction\nfrom the highest steady-state pressure for the 90 days prior to shutdown of\nLine #1. This pressure reduction will remain in place throughout operation\nof the bypass.\n10) On September 22, 2016, at 8:45 PM CDT, the temporary bypass reached full\noperational status. Due to the artificial lighting provided by Colonial, Director\napproved a non-daylight start in a supplemental letter, dated September 21, 2016.\nColonial personnel are monitoring the security of the above-ground bypass at all\ntimes until the bypass is removed from service.\n11) On September 28, 2016, Colonial started excavation of the failed section of Line #1.\nThe failed section of Line #1 was excavated on September 29, 2016, around 1:00 PM\nCDT. A small crack was found on a buckle that had not been previously identified or\nknown by Colonial. According to Colonial, the buckle had not been identified in the\n2014 internal assessment or geometry data and, pending verification, was not present\nduring a 2015 recoat project.\n\n\n\nCPF No. 2-2016-5005H\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 this Order.\nAfter evaluating the preliminary findings in the CAO and the foregoing additional preliminary\nfindings of fact, I find that continued operation of the pipeline without corrective measures is or\nwould be hazardous to life, property, or the environment. Additionally, I have considered the\nundetermined cause of the Failure and the ongoing investigation; the location of the Failure; the\nage of the pipeline and the history of known problems or failures on pipelines being owned and\noperated by Respondent; the proximity of the pipeline to populated areas or other unusually\nsensitive ecological areas; the deceased wildlife and vegetation near the Failure Site; and the soil\nand water contamination in the vicinity of the Failure Site. I therefore find that a failure to issue\nthis Order expeditiously to require immediate corrective action would result in the likelihood of\nserious harm to life, property, or the environment.\nAccordingly, this Amendment to the Corrective Action Order mandating immediate corrective\naction is issued without prior notice and opportunity for a hearing. The terms and conditions of\nthis Amended Corrective Action Order are effective upon receipt.\nThe actions required by this Amended Corrective Action Order are in addition to the\nrequirements that apply to under the CAO issued on September 16, 2016.\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, Southern, PHMSA\n(Director). If Respondent requests a hearing, it will be held telephonically or in-person in\nSouthern Region office 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.\n\n\n\nCPF No. 2-2016-5005H\nPage 5\nRequired Corrective Actions:\nDefinitions:\nAffected Segment means the segment of Respondent’s Line #1 running from Collins, Mississippi,\nto Colonial’s Pelham Station in Pelham, Alabama.\nIsolated Segment means the segment of Respondent’s Line #1 running from Colonial’s Cahaba\nRiver block valve, near Station 4984+90, to Station 5545+17, 10.6 miles from Colonial’s Pelham\nStation in Pelham, Alabama.\nDirector means Director, Southern Region, PHMSA.\nFailure Site means the section on the Isolated Segment where the leak occurred on September 9,\n2016 at Station 5155+57.\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.\n1. Restart Plan. Prior to resuming operation of the Isolated Segment, Colonial must develop\nand submit a written Restart Plan to the Director for prior approval. This applies to the\nrestart of Line #1 upon its permanent repair, and removal of the temporary bypass.\na. The Director may approve the Restart Plan incrementally without approving the entire\nplan, but the Isolated Segment cannot resume operation until the Restart Plan is approved\nin its entirety.\nb. Once approved by the Director, the Restart Plan will be incorporated by reference into\nthis Order.\nc. The Restart Plan must include procedures for removal of the temporary bypass and\nprovide evidence that all mandated actions required for such removal have been\ncompleted.\nd. The Restart Plan must include procedures to safely return the Isolated Segment to service\nand provide evidence that all mandated actions required prior to restart are adequately\ncompleted.\ne. The Restart Plan must specify a daylight restart and must include advance\ncommunications with local emergency response officials.\nf. The Restart Plan must provide for a review of the Isolated Segment for conditions similar\nto those in which the Failure occurred. This review should include a review of Colonial’s\nconstruction, operating and maintenance (O&M) and integrity management records such\nas in-line inspection (ILI) results, hydrostatic tests, root cause failure analysis of prior\nfailures, aerial and ground patrols, corrosion, cathodic protection, excavations and pipe\nreplacements. Colonial must address any findings that require remedial measures to be\nimplemented prior to restart.\n\n\n\nCPF No. 2-2016-5005H\nPage 6\ng. The Restart Plan must include documentation of the completion of all mandated actions\nand a management of change plan to ensure that all procedural modifications are\nincorporated into Colonial’s operations and maintenance manual.\nh. The Restart Plan must provide for hydrostatic pressure testing of the replacement pipe.\ni. Within 90 days of restarting the Isolated Segment, perform an ILI to ensure that there has\nbeen no metal loss, deformation, or other damage to the Affected Pipeline.\n2. Pressure Restriction. After the removal of the temporary bypass and receiving approval\nfrom the Director to restart Line #1, Colonial must maintain a twenty percent (20%) pressure\nreduction from the highest steady state pressures recorded throughout the Affected Segment\nwithin the 90-days prior to discovery. At no point within the Affected Segment shall the\npressure exceed eighty percent (80%) of the highest steady state pressure recorded during the\n90 days prior to discovery of the Failure.\n3. Removal of Pressure Restriction.\na. Upon written request from Colonial, the Director may allow the removal or modification\nof the pressure restriction when a reliable engineering analysis demonstrates that the\npressure increase is safe, taking into consideration all known defects, anomalies,\ncompletion of the Repair Plan, and the operating parameters of the Affected Segment.\nb. The Director may allow the temporary removal or modification of the pressure\nrestrictions upon a written request from Colonial, demonstrating that temporary\nmitigative and preventive measures will be 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 operation of\nthe Affected Segment during the temporary removal or modification of the pressure\nrestriction. Appeals to determinations of the Director in this regard will be decided by the\nAssociate Administrator for Pipeline Safety.\n4. Mechanical and Metallurgical Testing. Within 45 days of excavation and exposure of the\nFailure Site, Colonial must complete mechanical and metallurgical testing, as well as a\nfailure analysis of the failed pipe, including an analysis of soil samples and any foreign\nmaterials. The testing and failure analysis must be completed by an independent laboratory\nor expert. The testing and analysis must be completed in accordance with the following\ninstructions:\na. Document the chain-of-custody when handling and transporting the failed pipe section\nand other evidence from the Failure Site;\nb. Within 10 days of removing the failed pipe, develop and submit the testing protocol and\nthe proposed testing laboratory to the Director for prior approval;\n\n\n\nCPF No. 2-2016-5005H\nPage 7\n5. 6. c. Prior to beginning the mechanical and metallurgical testing, provide the Director with the\nscheduled date, time, and location of the testing to allow for an OPS representative to\nwitness the testing;\nd. Ensure the testing laboratory distributes all reports whether draft or final in their entirety\nto the Director at the same time they are made available to Colonial; and\ne. The Director may grant an extension of time, in accordance with Item 13 Extensions of\nTime, to complete the Mechanical and Metallurgical Testing.\nRemedial Work Plan. Within 60 days of receipt of this Order, develop and submit to the\nDirector for prior approval a written Remedial Work Plan (RWP) that includes corrective\nmeasures. The RWP must fully address all known or suspected factors that caused or\ncontributed to the Failure and must include, as applicable:\na. All planned pipeline repairs or changes to operations and maintenance, personnel\nqualification or training, or corrosion control procedures or activities required to address\nall threats identified by the analysis and must contain a schedule for performing these\nrepairs or changes. Repairs of pipeline segments must comport at a minimum with the\ndeadlines set out in 49 C.F.R. § 195.452(h)(4). All conditions defined in 49 C.F.R. §\n195.452(h)(4)(i) through (iv) must be repaired. All repairs must be performed in\ncompliance with 49 C.F.R. § 195.422.\nb. The comprehensive analysis and RWP must be submitted no later than 150 days after\nexcavation of the failed pipe to the Director, Southern Region, OPS, for review and\napproval.\nc. Threats identified in areas where a pipeline failure could affect a high consequence area\nmust be properly addressed by and incorporated into Colonial’s Integrity Management\nProgram (IMP). Submit all resulting changes to your IMP no later than four months after\nthe date of this Order for the approval of the Director.\nd. The comprehensive analysis and RWP, along with any resulting changes to Colonial’s\nIMP, must be reviewed by an independent risk assessment expert prior to submission to\nthe Director, to verify that Colonial has included all known accidents and occurrences,\nhas properly identified potential and existing threats, and determined that the RWP is\nadequate to address the identified threats.\nImplementation of Work Plan. Implement the Remedial Work Plan as it is approved by the\nDirector, including any revisions to the plan.\n7. Root Cause Failure Analysis.\na. Within 90 days of excavation and exposure of the Failure Site, Colonial must complete a\nroot cause failure analysis (RCFA) and submit a final report of this RCFA to the Director.\nThe RCFA must be supplemented/facilitated by an independent third-party acceptable to\nthe Director and must document the decision making process and all factors contributing\n\n\n\n8. 9. CPF No. 2-2016-5005H\nPage 8\nto the failure. The final report must include findings and any lessons learned whether the\nfindings and any lessons learned are applicable to other locations within Colonial’s\npipeline system, and actions Colonial is taking for those other locations where the lessons\nlearned are applicable.\nb. The Director may grant an extension of time, in accordance with Item 13 Extensions of\nTime, to complete the RCFA. If an extension of time is granted, Colonial must complete\na preliminary RCFA of the Failure Site and submit a report of this preliminary RCFA to\nthe Director. The preliminary RCFA must be supplemented/facilitated by an independent\nthird-party acceptable to the Director and must document the decision making process\nand all factors contributing to the Failure including, but not limited to, manufacturing\ndefects, operational or maintenance errors, and natural disasters. The preliminary report\nmust include findings and any lessons learned whether the findings and any lessons\nlearned are applicable to other locations within Colonial’s pipeline system, and actions\nColonial is taking for those other locations where the lessons learned are applicable.\nEmergency Response Plan and Training Review. Colonial must review and assess the\neffectiveness of its emergency response plan with regards to the Failure. In its review,\nColonial should seek input local, state and federal agencies responding to release and\ninvestigating the cause of the failure. Include in the review and assessment the on-scene\nresponse and support, coordination, and communication with emergency responders and\npublic officials. Also, include a review and assessment of the effectiveness of its emergency\ntraining program. Colonial must amend its emergency response plan and emergency\ntraining, if necessary, to reflect the results of this review. The documentation of this\nEmergency Response Plan and Training Review must be available for inspection by OPS or\nprovided to the Director, if requested.\nCAO Documentation Report (CDR). Colonial must create and revise, as necessary, a CAO\nDocumentation Report (CDR). When Colonial 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 Colonial with regards to this Order prior\nto approving the closure of this Order. The intent is for the CDR to summarize all activities\nand documentation associated with this Order in one document.\na. The Director may approve the CDR incrementally without approving the entire CDR.\nb. Once approved by the Director, the CDR will be incorporated by reference into this\nOrder.\nc. The CDR must include but not be limited to:\ni. Table of Contents;\nii. Summary of the pipeline failure of September 9, 2016, and the response activities;\niii. Summary of pipe data/properties and all prior assessments of the Affected Segment;\n\n\n\nCPF No. 2-2016-5005H\nPage 9\niv. v. vi. vii. viii. ix. Summary of all tests, inspections, assessments, evaluations, and analysis required by\nthe Order;\nSummary of the Mechanical and Metallurgical Testing as required by the Order;\nSummary of the Remedial Work Plan as required by the Order;\nSummary of the RCFA with all root causes as required by the Order;\nLessons learned while completing this Order;\nA path forward describing specific actions Colonial will take on its entire pipeline\nsystem as a result of the lessons learned from work on this Order; and\nx. Appendices (if required).\nOther Requirements:\n10. Reporting. Colonial must submit quarterly 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\nquarterly report is due on January 15, 2017. The Director may change the interval for the\nsubmission of these reports.\n11. Documentation of the 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 submitted, the to-date total costs associated with: (1) preparation and revision\nof procedures, studies and analyses; (2) physical changes to pipeline infrastructure, including\nrepairs, replacements and other modifications; and (3) environmental remediation, if\napplicable.\n12. 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 the\nsubmission 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.\n13. 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 cause\nfor an extension.\nThe actions required by this Amendment to the CAO are in addition to and do not waive any\nrequirements that apply to Respondent’s pipeline system under the Original CAO, and under\n\n\n\nCPF No. 2-2016-5005H\nPage 10\n49 C.F.R. Part 195, under any other order issued to Respondent under authority of 49 U.S.C. §\n60101, et seq., or under any other provision of Federal or State law.\nRespondent may appeal any decision of the Director to the Associate Administrator for Pipeline\nSafety. Decisions of the Associate Administrator will 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. and for each document you\nsubmit, please provide a copy in electronic format whenever possible.\nThe terms and conditions of this Amended Corrective Action Order are effective upon receipt.\n__________________________________ __________________\nAlan K. Mayberry Date Issued\nActing Associate Administrator\nfor Pipeline Safety\n\n220165005H_Closure Letter_11172020_text.pdf\n\nVIA ELECTRONIC MAIL TO: jblount@colpipe.com\nNovember 17, 2020\nMr. Joseph A. Blount\nPresident & Chief Executive Officer\nColonial Pipeline Company\n1185 Sanctuary Parkway, Suite 100\nAlpharetta, GA 30009-4765\nCPF No. 2-2016-5005H\nDear Mr. Blount:\nOn September 16, 2016, the Pipeline and Hazardous Materials Safety Administration (PHMSA),\nOffice of Pipeline Safety (OPS), issued a Corrective Action Order (CAO) to Colonial Pipeline\nCompany (Colonial), relating to the September 9, 2016, Line 01 failure in Shelby County,\nAlabama, approximately three miles from Pelham, Alabama (Failure). The CAO included\nRequired Corrective Actions which required Colonial to undertake certain actions to ensure\ncompliance with the federal pipeline safety regulations. On October 13, 2016, OPS issued an\nAmended CAO which provided updated findings and revised the corrective measures Colonial\nwas ordered to take in the above-referenced case.\nIn response to the Amended CAO, Colonial made numerous submittals to OPS Southern Region,\ndocumenting its efforts toward compliance. OPS received Colonial’s final submittal\nelectronically on November 6, 2020.\nBased upon our review of documentation of actions taken, we have determined that Colonial has\ncomplied with the terms of the Amended CAO. This case is now closed and no further action is\nnecessary with respect to the matters involved in this case.\nPlease be advised that this letter refers only to the above referenced order (CPF 2-2016-5005H)\nand not to any other PHMSA cases, if any.\nSincerely,\nJames A. Urisko\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\nCc: Mr. Mark Piazza, Manager of Pipeline Compliance and R&D,\nColonial Pipeline Company\n\n220165005H_Corrective Action Order_09162016_text.pdf\n\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. 2-2016-5005H\nDear Mr. Felt:\nEnclosed is a Corrective Action Order issued in the above-referenced case, requiring Colonial\nPipeline Company to take certain corrective actions with respect to the failure on its Pipeline\nOne (Line #1), that occurred on September 9, 2016, near Pelham, Alabama.\nService is being made by certified mail and facsimile. Service of the Corrective Action Order by\nelectronic transmission is deemed complete upon transmission and acknowledgement of receipt,\nor as otherwise provided under 49 C.F.R. § 190.5. The terms and conditions of this Order are\neffective upon completion of service.\nThank you for your cooperation in this matter.\nSincerely,\nAlan K. Mayberry\nActing Associate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, Office of\nPipeline Safety, PHMSA\nMr. James Urisko, Regional Director, Southern Region, Office of Pipeline Safety,\nPHMSA\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)\nColonial Pipeline Company, ) CPF No. 2-2016-5005H\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. § 60112 to\nrequire Colonial Pipeline Company (Colonial or Respondent), to take the necessary corrective\naction to protect the public, property, and the environment from potential hazards associated with\nthe recent failure on its Colonial’s Pipeline One (Line #1).1\nOn September 9, 2016, a reportable accident occurred on Colonial’s Line #1, a hazardous liquid\npipeline in Shelby County, Alabama, approximately three miles from the town of Pelham,\nAlabama (Failure). The Failure resulted in the release of approximately 6,000 barrels of gasoline\ninto a pond (Pond #2) approximately 460 feet north of Colonial’s Line #1. Line #1 transports\ngasoline from Houston, Texas, to Greensboro, North Carolina. The Failure occurred on a section\nof Line #1 that runs from Collins, Mississippi, to Atlanta Junction Station, in Atlanta, Georgia.\nColonial operates a parallel pipeline that runs adjacent to Line #1, Pipeline Two (Line #2), that is\napproximately 40 feet apart from Line #1 at the assumed site of the Failure. Line #2 transports\npetroleum product from Epes, Alabama, to Anderson, South Carolina.\nPursuant to 49 U.S.C. § 60117, the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), Office of Pipeline Safety (OPS), initiated an investigation of the accident.\nThe preliminary findings of the ongoing investigation are as follows.\n1 Colonial operates roughly 5,500 miles of hazardous liquid transmission pipeline within the United States. The\npipelines travel through the states of Texas, Louisiana, Mississippi, Alabama, Georgia, North and South Carolina,\nVirginia, Maryland, Pennsylvania, 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 liquid petroleum products\nto businesses and communities through the Southern and Eastern United States.\n\n\n\nCPF No. 2-2016-5005H\nPage 2\nPreliminary Findings:\n1) 2) 3) 4) 5) 6) Line #1 is a 36-inch diameter hazardous liquid pipeline that runs from Houston,\nTexas, to Greensboro, North Carolina. The Failure occurred on a segment of Line\n#1 that runs from Collins, Mississippi, to Respondent’s Atlanta Junction Station, in\nAtlanta, Georgia (Affected Segment). The exact location of the Failure is unknown,2\nbut the Assumed Failure Site is on a section of Line #1 that runs from Colonial’s\nCahaba River block valve, near Mile Post (MP) 5065+11, to Colonial’s Pelham\nStation in Pelham, Alabama, near MP 5545+46. A pond (Pond 2) off of the right-of-\nway is approximately 460 feet from the Assumed Failure Site on Line #1 (Assumed\nFailure Site).\nThe Affected Segment was constructed in 1963 and is composed of 36-inch\ndiameter, 0.281-inch wall thickness, American Petroleum Institute (API) 5L, X52\npipe. The pipe has asphalt enamel coating and a double-submerged arc-welded\n(DSAW) seam type, and was manufactured by the National Tube Company.\nThe Maximum Operating Pressure (MOP) of Line #1 is 553 pounds per square inch\ngauge (“psig”), as established by hydrostatic testing in 1963. During the 30 days\nprior to the Failure, the operating pressure of Line #1 near the Assumed Failure Site\nfluctuated between 31 psig and 495 psig.3\nOn September 9, 2016, at 11:10 am Central Standard Time (CST), personnel of the\nAlabama Surface Mining Commission reported a probable leak near Line #1, in a\nright-of-way for this pipeline in a rural area. The personnel noted a strong gasoline\nodor and sheen on Pond #2, and also discovered dead vegetation near this pond.\nPond #2 is located near mile post 5163+89 (MP 5163+89), on Line #1, in Shelby\nCounty, Alabama, approximately three miles from Pelham, Alabama. Pond #2 is\nbounded by Line #1 to the south and another pond, Pond #3, to the north.\nOn September 9, 2016, beginning at 11:30 AM CST, in response to the 11:10 am\nnotification from the Alabama Surface Mining Commission,4 Respondent initiated a\nshutdown of Lines #1 and #2. This process began when Colonial’s Supervisory\nControl and Data Acquisition (SCADA) system controller remotely closed an\nautomatic valve downstream of the Assumed Failure Site, at MP 5545+47 on Line\n#1.\n2 See infra Preliminary Findings 17 – 19.\n3 PHMSA officials note the variation in operating pressure readings on Line #1 in the 30 days prior to the Failure is\na function of Colonial’s normal pipeline operations. During normal operations, pressure readings can fluctuate\ndepending on maintenance activities or required throughput of Line #1, and the referenced range is representative of\nthese operational adjustments.\n4 See supra Preliminary Finding 4.\n\n\n\nCPF No. 2-2016-5005H\nPage 3\n7) On September 9, 2016, at 12:14 PM CST, Respondent’s personnel at the Assumed\nFailure Site confirmed that gasoline had accumulated in Pond #2.\n8) On September 9, 2016, at 12:59 PM CST, Respondent notified the National\nResponse Center that gasoline had entered Pond #2 as a result of the Failure from\nLine #1.\n9) On September 9, 2016, at approximately 3:00 PM CST, Colonial personnel manually\nclosed a valve on Line #1 upstream of the Assumed Failure Site at MP 5065+11.\n10) On September 9, 2016, at 6:57 PM CST, Colonial personnel observed a total of four\ndeceased small wild animals near Pond #2 – a rabbit and three raccoons.\n11) On September 9, 2016, at 9:00 PM CST, inspectors from the Southern Region of\nPHMSA, OPS, arrived at Respondent’s Incident Command Center in Hoover,\nAlabama.\n12) On September 9, 2016, at 9:00 PM CST, officials from the Pelham, Alabama Fire\nDepartment (Fire Department) determined that the air at the Assumed Failure Site\nand at Pond #2 contained high concentrations of benzene5 and gasoline vapor.6 The\ndetected levels of benzene and gasoline vapors remained at unsafe levels at both\nlocations through September 12, 2016.\n13) On September 9, 2016, at 9:00 PM CST, due to the high concentration of benzene\nand gasoline vapor at both the Assumed Failure Site and Pond #2, Fire Department\nofficials suspended all activity and evacuated all persons from these locations until\nSeptember 12, 2016.\n14) On September 9, 2016, at 9:13 PM CST, after consulting with PHMSA, Respondent\nrestarted Line #2 upon confirming that the observed product in Pond #2 was gasoline\nfrom Line #1, and that no release had occurred on Line #2.\n15) At approximately 8:00 AM CST on September 13, 2016, Fire Department and\nColonial officials determined that after approximately 83 hours of unsafe\nconcentrations of benzene and gasoline vapors in the air at the Assumed Failure Site,\nthese concentrations had dropped to safe levels. Shortly after this determination,\nColonial and PHMSA personnel were permitted access to the Assumed Failure Site.\nHowever, at this time, Fire Department and Colonial Officials determined these\nunsafe levels of benzene and gasoline vapor were still present in the air at Pond #2.\n5 Benzene is a chemical that is a natural part of the gasoline transported in Line #1 and is highly flammable.\nFurther, inhalation of high concentrations of benzene can result in sickness or death. See Centers for Disease\nControl. https://emergency.cdc.gov/agent/benzene/basics/facts.asp (last visited September 14, 2016).\n6 U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration. 2016 Emergency\nResponse Guidebook. Guide 115 – Gases (Flammable – Included Refrigerated Liquids). Pages 170 – 171.\n\n\n\nCPF No. 2-2016-5005H\nPage 4\n16) At approximately 8:00 PM CST on September 13, 2016, Fire Department and\nColonial Officials determined that benzene and gasoline vapors had again risen to\nunsafe levels in the air at the Assumed Failure Site. Colonial Officials believed that\nthe rise in benzene and gasoline vapor levels in the air at the Assumed Failure Site\nwas caused by wind transport of benzene and gasoline vapors coming off of the\naccumulated gasoline in Pond #2.\n17) Based on the unstable and fluctuating benzen","truncated":true,"body_characters":58031}