# COLONIAL PIPELINE CO — Corrective Action Order

- **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:** Not available
- **summary:** CLOSED corrective action order.
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- **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.

Official case documents:

220165005H_Amended Corrective Action Order_10132016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220165005H/220165005H_Amended%20Corrective%20Action%20Order_10132016.pdf

220165005H_Amended Corrective Action Order_10132016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220165005H/220165005H_Amended%20Corrective%20Action%20Order_10132016_text.pdf

220165005H_Closure Letter_11172020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220165005H/220165005H_Closure%20Letter_11172020.pdf

220165005H_Closure Letter_11172020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220165005H/220165005H_Closure%20Letter_11172020_text.pdf

220165005H_Corrective Action Order_09162016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220165005H/220165005H_Corrective%20Action%20Order_09162016.pdf

220165005H_Corrective Action Order_09162016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220165005H/220165005H_Corrective%20Action%20Order_09162016_text.pdf

220165005H_Amended Corrective Action Order_10132016_text.pdf

October 13, 2016
VIA CERTIFIED MAIL AND FAX TO: (678) 762-2466
Mr. Tim Felt
President & Chief Executive Officer
Colonial Pipeline Company
1185 Sanctuary Parkway, Suite 100
Alpharetta, GA 30009-4765
Re: CPF No. 2-2016-5005H
Dear Mr. Felt:
Enclosed is an Amended Corrective Action Order issued in the above-referenced case, requiring
Colonial Pipeline Company to take certain corrective actions with respect to the failure on its
Pipeline One (Line #1), that occurred on September 9, 2016, near Pelham, Alabama.
Service is being made by certified mail and facsimile. Service of the Amended Corrective
Action Order by electronic transmission is deemed complete upon transmission and
acknowledgement of receipt, or as otherwise provided under 49 C.F.R. § 190.5. The terms and
conditions of this Order are effective upon completion of service.
Thank you for your cooperation in this matter.
Sincerely,
Alan K. Mayberry
Acting Associate Administrator
for Pipeline Safety
Enclosure
cc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, Office of
Pipeline Safety, PHMSA
Mr. James Urisko, Regional Director, Southern Region, Office of Pipeline Safety,
PHMSA



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
)
In the Matter of )
)
Colonial Pipeline Company, ) CPF No. 2-2016-5005H
)
Respondent. )
)
AMENDED CORRECTIVE ACTION ORDER
Purpose and Background:
This Amended Corrective Action Order (Amended CAO) is being issued under the authority of
49 U.S.C. § 60112 to require Colonial Pipeline Company (Colonial or Respondent), to take the
necessary corrective action to protect the public, property, and the environment from potential
hazards associated with the recent failure on its Colonial’s Pipeline One (Line #1).1
On September 9, 2016, a reportable accident occurred on Colonial’s Line #1, a hazardous liquid
pipeline in Shelby County, Alabama, approximately three miles from the town of Pelham,
Alabama (Failure). The Failure resulted in the release of approximately 7,370 barrels (bbls) of
gasoline into a pond (Pond #2) approximately 460 feet north of Colonial’s Line #1. Line #1
transports gasoline from Houston, Texas, to Greensboro, North Carolina. The Failure occurred
on a 202-mile section of Line #1 that runs from Collins, Mississippi, to Pelham, Alabama.
Colonial operates a parallel pipeline that runs adjacent to Line #1, Pipeline Two (Line #2), that is
approximately 40 feet apart from Line #1 at the Failure Site. Line #2 transports petroleum
product from Epes, Alabama, to Anderson, South Carolina.
On September 16, 2016, PHMSA issued a Corrective Action Order (CAO) to Colonial. The
CAO required Colonial to shut down failed section on Line #1 and carry out mechanical and
metallurgical testing and failure analysis of the failed section of pipe. At the time, the location of
the Failure and the extent of the environmental impact were unknown. This Amended
1 Colonial operates roughly 5,500 miles of hazardous liquid transmission pipeline within the United States. The
pipelines travel through the states of Texas, Louisiana, Mississippi, Alabama, Georgia, North and South Carolina,
Virginia, Maryland, Pennsylvania, New Jersey, and New York. Branches from the main lines also extend into
Tennessee. The system delivers a daily average of approximately 100 million gallons of liquid petroleum products
throughout the Southern and Eastern United States.



CPF No. 2-2016-5005H
Page 2
Corrective Action Order replaces and supersedes the CAO issued to Colonial on September 16,
1) 2016.
Pursuant to 49 U.S.C. § 60117, the Pipeline and Hazardous Materials Safety Administration
(PHMSA), Office of Pipeline Safety (OPS), initiated an investigation of the accident.
The preliminary findings in the Original CAO noted the failure and related information and
details about the defect discovered as a result of the September 9, 2016 failure. Since that time,
the following events have occurred and certain information has been discovered or clarified:
Amended Preliminary Findings:
Line #1 is a 36-inch diameter hazardous liquid pipeline that runs from Houston,
Texas, to Greensboro, North Carolina. The Failure occurred on a segment of Line
#1 that runs from Collins, Mississippi, to Respondent’s Pelham Station, in Pelham,
Alabama (Affected Segment). The Failure occurred at Station 5155+57 on a section
of Line #1 that runs from Colonial’s downstream Cahaba River block valve, near
Station 5055+00, to Colonial’s Pelham Station in Pelham, Alabama, near Station
5545+17. A pond (Pond #2) outside the company’s right-of-way is approximately
460 feet from the Failure Site on Line #1 (Failure Site). Two other ponds are in the
vicinity of the failed section: Pond #1 to the south of Line #1, and Pond #3 to the
north of Pond #2. All referenced ponds are man-made reclamation and evaporation
ponds used during historic rural surface strip mining.
The Affected Segment was constructed in 1963 and is composed of 36-inch
diameter, 0.281-inch wall thickness, American Petroleum Institute (API) 5L, X52
pipe. The pipe generally has asphalt enamel coating and a double-submerged arc-
welded (DSAW) seam type, and was manufactured by the National Tube Company.
Several sections of the Affected Segment were subject to replacement and recoat
projects since original construction, and may have more modern pipe and/or types of
coating.
Pond #2 is located near Station 5154+13, on Line #1, in Shelby County, Alabama,
approximately three miles from Pelham, Alabama. Pond #2 is bounded by Line #1
to the south and another pond, Pond #3, to the north. Pond #3 is also a man-made
reclamation and evaporation pond used during historic rural surface strip mining.
From September 12-13, 2016, Colonial installed stopple fittings upstream and
downstream of the Failure location in order to begin drain-down of the line before
excavation of the release location. The downstream stopple was tapped and plugged
and work continued on the upstream stopple installation. On September 14, 2016, the
upstream stopple was completed at 1:30 AM CDT. Nitrogen injections began at
5:00 AM CDT and initial drain-up operations were completed that evening.
As of 8:00 AM CDT on September 15, 2016, Colonial personnel announced that
sampling indicated the presence of dissolved constituents in Pond #3.
2) 3) 4) 5)



CPF No. 2-2016-5005H
Page 3
6) 7) 8) 9) At approximately 12:30 PM CDT on September 16, 2016, Colonial officials
announced that its personnel had discovered a culvert below the water line in Pond
#2. Colonial officials further noted this culvert connects to Pond #3, and that they
believe the dissolved constituents flowed from Pond #2, through this culvert, into
Pond #3.
On September 16, 2016, the amount of product extracted from the pipe remained at
880 bbls. Adequate pressure to evacuate the product remaining in the stoppled
section of the line could no longer be provided by injecting nitrogen into the line.
As of the 9:00 AM CDT on September 17, 2016, the amount of product extracted
from the pipe was 1,073 bbls. Colonial installed a temporary pig launcher and
receiver in order to use a pig to remove the remaining product. Colonial used water
to push the pig to complete the product removal effort. There was no estimate on
volume remaining in stoppled section of the pipe.
On September 20, 2016, PHMSA approved the installation of a 36-inch diameter
temporary 500-foot bypass line on the Isolated Segment to facilitate limited pipeline
operation of Line #1. Specifications of the bypass pipe are as follows:
a. Grade (API): X52 and X60
b. SMYS: 811.77 psi
c. Wall thickness: 0.281-inch
d. e. f. Coating Fusion Bond Epoxy and Trenton Hot Wax
Tie-in welds NDT method X-Ray.
Upon startup of the bypass, the bypass has been operating at a 20% reduction
from the highest steady-state pressure for the 90 days prior to shutdown of
Line #1. This pressure reduction will remain in place throughout operation
of the bypass.
10) On September 22, 2016, at 8:45 PM CDT, the temporary bypass reached full
operational status. Due to the artificial lighting provided by Colonial, Director
approved a non-daylight start in a supplemental letter, dated September 21, 2016.
Colonial personnel are monitoring the security of the above-ground bypass at all
times until the bypass is removed from service.
11) On September 28, 2016, Colonial started excavation of the failed section of Line #1.
The failed section of Line #1 was excavated on September 29, 2016, around 1:00 PM
CDT. A small crack was found on a buckle that had not been previously identified or
known by Colonial. According to Colonial, the buckle had not been identified in the
2014 internal assessment or geometry data and, pending verification, was not present
during a 2015 recoat project.



CPF No. 2-2016-5005H
Page 4
Determination of Necessity for Corrective Action Order and Right to Hearing:
Section 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action
Order, after reasonable notice and the opportunity for a hearing, requiring corrective action,
which may include the suspended or restricted use of a pipeline facility, physical inspection,
testing, repair, replacement, or other action, as appropriate. The basis for making the
determination that a pipeline facility is or would be hazardous, requiring corrective action, is set
forth both in the above-referenced statute and 49 C.F.R. § 190.233, a copy of which is enclosed.
Section 60112 and the regulations promulgated thereunder provide for the issuance of a
Corrective Action Order, without prior notice and opportunity for hearing, upon a finding that
failure to issue the Order expeditiously would result in the likelihood of serious harm to life,
property, or the environment. In such cases, an opportunity for a hearing and expedited review
will be provided as soon as practicable after the issuance of this Order.
After evaluating the preliminary findings in the CAO and the foregoing additional preliminary
findings of fact, I find that continued operation of the pipeline without corrective measures is or
would be hazardous to life, property, or the environment. Additionally, I have considered the
undetermined cause of the Failure and the ongoing investigation; the location of the Failure; the
age of the pipeline and the history of known problems or failures on pipelines being owned and
operated by Respondent; the proximity of the pipeline to populated areas or other unusually
sensitive ecological areas; the deceased wildlife and vegetation near the Failure Site; and the soil
and water contamination in the vicinity of the Failure Site. I therefore find that a failure to issue
this Order expeditiously to require immediate corrective action would result in the likelihood of
serious harm to life, property, or the environment.
Accordingly, this Amendment to the Corrective Action Order mandating immediate corrective
action is issued without prior notice and opportunity for a hearing. The terms and conditions of
this Amended Corrective Action Order are effective upon receipt.
The actions required by this Amended Corrective Action Order are in addition to the
requirements that apply to under the CAO issued on September 16, 2016.
Within 10 days of receipt of this Order, Respondent may contest its issuance obtain expedited
review either by answering in writing or requesting a hearing under 49 C.F.R. § 190.211, to be
held as soon as practicable under the terms of such regulation, by notifying the Associate
Administrator for Pipeline Safety in writing, with a copy to the Director, Southern, PHMSA
(Director). If Respondent requests a hearing, it will be held telephonically or in-person in
Southern Region office or Washington, D.C.
After receiving and analyzing additional data in the course of this investigation, PHMSA may
identify other corrective measures that need to be taken. In that event, PHMSA will notify
Respondent of any additional measures that are required and an amended Order issued, if
necessary. To the extent consistent with safety, Respondent will be afforded notice and an
opportunity for a hearing prior to the imposition of any additional corrective measures.



CPF No. 2-2016-5005H
Page 5
Required Corrective Actions:
Definitions:
Affected Segment means the segment of Respondent’s Line #1 running from Collins, Mississippi,
to Colonial’s Pelham Station in Pelham, Alabama.
Isolated Segment means the segment of Respondent’s Line #1 running from Colonial’s Cahaba
River block valve, near Station 4984+90, to Station 5545+17, 10.6 miles from Colonial’s Pelham
Station in Pelham, Alabama.
Director means Director, Southern Region, PHMSA.
Failure Site means the section on the Isolated Segment where the leak occurred on September 9,
2016 at Station 5155+57.
Pursuant to 49 U.S.C. § 60112, I hereby order Colonial to immediately take the following
corrective actions for the Affected Segment and Isolated Segment.
1. Restart Plan. Prior to resuming operation of the Isolated Segment, Colonial must develop
and submit a written Restart Plan to the Director for prior approval. This applies to the
restart of Line #1 upon its permanent repair, and removal of the temporary bypass.
a. The Director may approve the Restart Plan incrementally without approving the entire
plan, but the Isolated Segment cannot resume operation until the Restart Plan is approved
in its entirety.
b. Once approved by the Director, the Restart Plan will be incorporated by reference into
this Order.
c. The Restart Plan must include procedures for removal of the temporary bypass and
provide evidence that all mandated actions required for such removal have been
completed.
d. The Restart Plan must include procedures to safely return the Isolated Segment to service
and provide evidence that all mandated actions required prior to restart are adequately
completed.
e. The Restart Plan must specify a daylight restart and must include advance
communications with local emergency response officials.
f. The Restart Plan must provide for a review of the Isolated Segment for conditions similar
to those in which the Failure occurred. This review should include a review of Colonial’s
construction, operating and maintenance (O&M) and integrity management records such
as in-line inspection (ILI) results, hydrostatic tests, root cause failure analysis of prior
failures, aerial and ground patrols, corrosion, cathodic protection, excavations and pipe
replacements. Colonial must address any findings that require remedial measures to be
implemented prior to restart.



CPF No. 2-2016-5005H
Page 6
g. The Restart Plan must include documentation of the completion of all mandated actions
and a management of change plan to ensure that all procedural modifications are
incorporated into Colonial’s operations and maintenance manual.
h. The Restart Plan must provide for hydrostatic pressure testing of the replacement pipe.
i. Within 90 days of restarting the Isolated Segment, perform an ILI to ensure that there has
been no metal loss, deformation, or other damage to the Affected Pipeline.
2. Pressure Restriction. After the removal of the temporary bypass and receiving approval
from the Director to restart Line #1, Colonial must maintain a twenty percent (20%) pressure
reduction from the highest steady state pressures recorded throughout the Affected Segment
within the 90-days prior to discovery. At no point within the Affected Segment shall the
pressure exceed eighty percent (80%) of the highest steady state pressure recorded during the
90 days prior to discovery of the Failure.
3. Removal of Pressure Restriction.
a. Upon written request from Colonial, the Director may allow the removal or modification
of the pressure restriction when a reliable engineering analysis demonstrates that the
pressure increase is safe, taking into consideration all known defects, anomalies,
completion of the Repair Plan, and the operating parameters of the Affected Segment.
b. The Director may allow the temporary removal or modification of the pressure
restrictions upon a written request from Colonial, demonstrating that temporary
mitigative and preventive measures will be implemented prior to and during the
temporary removal or modification of the pressure restriction. The Director's
determination will be based on the failure cause and provision of evidence that
preventative and mitigative actions taken by the operator provide for the safe operation of
the Affected Segment during the temporary removal or modification of the pressure
restriction. Appeals to determinations of the Director in this regard will be decided by the
Associate Administrator for Pipeline Safety.
4. Mechanical and Metallurgical Testing. Within 45 days of excavation and exposure of the
Failure Site, Colonial must complete mechanical and metallurgical testing, as well as a
failure analysis of the failed pipe, including an analysis of soil samples and any foreign
materials. The testing and failure analysis must be completed by an independent laboratory
or expert. The testing and analysis must be completed in accordance with the following
instructions:
a. Document the chain-of-custody when handling and transporting the failed pipe section
and other evidence from the Failure Site;
b. Within 10 days of removing the failed pipe, develop and submit the testing protocol and
the proposed testing laboratory to the Director for prior approval;



CPF No. 2-2016-5005H
Page 7
5. 6. c. Prior to beginning the mechanical and metallurgical testing, provide the Director with the
scheduled date, time, and location of the testing to allow for an OPS representative to
witness the testing;
d. Ensure the testing laboratory distributes all reports whether draft or final in their entirety
to the Director at the same time they are made available to Colonial; and
e. The Director may grant an extension of time, in accordance with Item 13 Extensions of
Time, to complete the Mechanical and Metallurgical Testing.
Remedial Work Plan. Within 60 days of receipt of this Order, develop and submit to the
Director for prior approval a written Remedial Work Plan (RWP) that includes corrective
measures. The RWP must fully address all known or suspected factors that caused or
contributed to the Failure and must include, as applicable:
a. All planned pipeline repairs or changes to operations and maintenance, personnel
qualification or training, or corrosion control procedures or activities required to address
all threats identified by the analysis and must contain a schedule for performing these
repairs or changes. Repairs of pipeline segments must comport at a minimum with the
deadlines set out in 49 C.F.R. § 195.452(h)(4). All conditions defined in 49 C.F.R. §
195.452(h)(4)(i) through (iv) must be repaired. All repairs must be performed in
compliance with 49 C.F.R. § 195.422.
b. The comprehensive analysis and RWP must be submitted no later than 150 days after
excavation of the failed pipe to the Director, Southern Region, OPS, for review and
approval.
c. Threats identified in areas where a pipeline failure could affect a high consequence area
must be properly addressed by and incorporated into Colonial’s Integrity Management
Program (IMP). Submit all resulting changes to your IMP no later than four months after
the date of this Order for the approval of the Director.
d. The comprehensive analysis and RWP, along with any resulting changes to Colonial’s
IMP, must be reviewed by an independent risk assessment expert prior to submission to
the Director, to verify that Colonial has included all known accidents and occurrences,
has properly identified potential and existing threats, and determined that the RWP is
adequate to address the identified threats.
Implementation of Work Plan. Implement the Remedial Work Plan as it is approved by the
Director, including any revisions to the plan.
7. Root Cause Failure Analysis.
a. Within 90 days of excavation and exposure of the Failure Site, Colonial must complete a
root cause failure analysis (RCFA) and submit a final report of this RCFA to the Director.
The RCFA must be supplemented/facilitated by an independent third-party acceptable to
the Director and must document the decision making process and all factors contributing



8. 9. CPF No. 2-2016-5005H
Page 8
to the failure. The final report must include findings and any lessons learned whether the
findings and any lessons learned are applicable to other locations within Colonial’s
pipeline system, and actions Colonial is taking for those other locations where the lessons
learned are applicable.
b. The Director may grant an extension of time, in accordance with Item 13 Extensions of
Time, to complete the RCFA. If an extension of time is granted, Colonial must complete
a preliminary RCFA of the Failure Site and submit a report of this preliminary RCFA to
the Director. The preliminary RCFA must be supplemented/facilitated by an independent
third-party acceptable to the Director and must document the decision making process
and all factors contributing to the Failure including, but not limited to, manufacturing
defects, operational or maintenance errors, and natural disasters. The preliminary report
must include findings and any lessons learned whether the findings and any lessons
learned are applicable to other locations within Colonial’s pipeline system, and actions
Colonial is taking for those other locations where the lessons learned are applicable.
Emergency Response Plan and Training Review. Colonial must review and assess the
effectiveness of its emergency response plan with regards to the Failure. In its review,
Colonial should seek input local, state and federal agencies responding to release and
investigating the cause of the failure. Include in the review and assessment the on-scene
response and support, coordination, and communication with emergency responders and
public officials. Also, include a review and assessment of the effectiveness of its emergency
training program. Colonial must amend its emergency response plan and emergency
training, if necessary, to reflect the results of this review. The documentation of this
Emergency Response Plan and Training Review must be available for inspection by OPS or
provided to the Director, if requested.
CAO Documentation Report (CDR). Colonial must create and revise, as necessary, a CAO
Documentation Report (CDR). When Colonial has concluded all the items in this Order, it
will submit the final CDR in its entirety to the Director. This will allow the Director to
complete a thorough review of all actions taken by Colonial with regards to this Order prior
to approving the closure of this Order. The intent is for the CDR to summarize all activities
and documentation associated with this Order in one document.
a. The Director may approve the CDR incrementally without approving the entire CDR.
b. Once approved by the Director, the CDR will be incorporated by reference into this
Order.
c. The CDR must include but not be limited to:
i. Table of Contents;
ii. Summary of the pipeline failure of September 9, 2016, and the response activities;
iii. Summary of pipe data/properties and all prior assessments of the Affected Segment;



CPF No. 2-2016-5005H
Page 9
iv. v. vi. vii. viii. ix. Summary of all tests, inspections, assessments, evaluations, and analysis required by
the Order;
Summary of the Mechanical and Metallurgical Testing as required by the Order;
Summary of the Remedial Work Plan as required by the Order;
Summary of the RCFA with all root causes as required by the Order;
Lessons learned while completing this Order;
A path forward describing specific actions Colonial will take on its entire pipeline
system as a result of the lessons learned from work on this Order; and
x. Appendices (if required).
Other Requirements:
10. Reporting. Colonial must submit quarterly reports to the Director that: (1) include all
available data and results of the testing and evaluations required by this Order; and (2)
describe the progress of the repairs or other remedial actions being undertaken. The first
quarterly report is due on January 15, 2017. The Director may change the interval for the
submission of these reports.
11. Documentation of the Costs. It is requested but not required that Respondent maintain
documentation of the costs associated with implementation of this Order. Include in each
monthly report submitted, the to-date total costs associated with: (1) preparation and revision
of procedures, studies and analyses; (2) physical changes to pipeline infrastructure, including
repairs, replacements and other modifications; and (3) environmental remediation, if
applicable.
12. Approvals. With respect to each submission that under this Order requires the approval of
the Director, the Director may: (a) approve, in whole or part, the submission; (b) approve the
submission on specified conditions; (c) modify the submission to cure any deficiencies;
(d) disapprove in whole or in part, the submission, directing that Respondent modify the
submission, or (e) any combination of the above. In the event of approval, approval upon
conditions, or modification by the Director, Respondent shall proceed to take all action
required by the submission as approved or modified by the Director. If the Director
disapproves all or any portion of the submission, Respondent must correct all deficiencies
within the time specified by the Director, and resubmit it for approval.
13. Extensions of Time. The Director may grant an extension of time for compliance with any
of the terms of this Order upon a written request timely submitted demonstrating good cause
for an extension.
The actions required by this Amendment to the CAO are in addition to and do not waive any
requirements that apply to Respondent’s pipeline system under the Original CAO, and under



CPF No. 2-2016-5005H
Page 10
49 C.F.R. Part 195, under any other order issued to Respondent under authority of 49 U.S.C. §
60101, et seq., or under any other provision of Federal or State law.
Respondent may appeal any decision of the Director to the Associate Administrator for Pipeline
Safety. Decisions of the Associate Administrator will be final.
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).
Failure to comply with this Order may result in the assessment of civil penalties and in referral to
the Attorney General for appropriate relief in United States District Court pursuant to 49 U.S.C.
§ 60120.
In your correspondence on this matter, please refer to CPF No. and for each document you
submit, please provide a copy in electronic format whenever possible.
The terms and conditions of this Amended Corrective Action Order are effective upon receipt.
__________________________________ __________________
Alan K. Mayberry Date Issued
Acting Associate Administrator
for Pipeline Safety

220165005H_Closure Letter_11172020_text.pdf

VIA ELECTRONIC MAIL TO: jblount@colpipe.com
November 17, 2020
Mr. Joseph A. Blount
President & Chief Executive Officer
Colonial Pipeline Company
1185 Sanctuary Parkway, Suite 100
Alpharetta, GA 30009-4765
CPF No. 2-2016-5005H
Dear Mr. Blount:
On September 16, 2016, the Pipeline and Hazardous Materials Safety Administration (PHMSA),
Office of Pipeline Safety (OPS), issued a Corrective Action Order (CAO) to Colonial Pipeline
Company (Colonial), relating to the September 9, 2016, Line 01 failure in Shelby County,
Alabama, approximately three miles from Pelham, Alabama (Failure). The CAO included
Required Corrective Actions which required Colonial to undertake certain actions to ensure
compliance with the federal pipeline safety regulations. On October 13, 2016, OPS issued an
Amended CAO which provided updated findings and revised the corrective measures Colonial
was ordered to take in the above-referenced case.
In response to the Amended CAO, Colonial made numerous submittals to OPS Southern Region,
documenting its efforts toward compliance. OPS received Colonial’s final submittal
electronically on November 6, 2020.
Based upon our review of documentation of actions taken, we have determined that Colonial has
complied with the terms of the Amended CAO. This case is now closed and no further action is
necessary with respect to the matters involved in this case.
Please be advised that this letter refers only to the above referenced order (CPF 2-2016-5005H)
and not to any other PHMSA cases, if any.
Sincerely,
James A. Urisko
Director, Office of Pipeline Safety
PHMSA Southern Region
Cc: Mr. Mark Piazza, Manager of Pipeline Compliance and R&D,
Colonial Pipeline Company

220165005H_Corrective Action Order_09162016_text.pdf

VIA CERTIFIED MAIL AND FAX TO: (678) 762-2466
Mr. Tim Felt
President & Chief Executive Officer
Colonial Pipeline Company
1185 Sanctuary Parkway, Suite 100
Alpharetta, GA 30009-4765
Re: CPF No. 2-2016-5005H
Dear Mr. Felt:
Enclosed is a Corrective Action Order issued in the above-referenced case, requiring Colonial
Pipeline Company to take certain corrective actions with respect to the failure on its Pipeline
One (Line #1), that occurred on September 9, 2016, near Pelham, Alabama.
Service is being made by certified mail and facsimile. Service of the Corrective Action Order by
electronic transmission is deemed complete upon transmission and acknowledgement of receipt,
or as otherwise provided under 49 C.F.R. § 190.5. The terms and conditions of this Order are
effective upon completion of service.
Thank you for your cooperation in this matter.
Sincerely,
Alan K. Mayberry
Acting Associate Administrator
for Pipeline Safety
Enclosure
cc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, Office of
Pipeline Safety, PHMSA
Mr. James Urisko, Regional Director, Southern Region, Office of Pipeline Safety,
PHMSA



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
)
In the Matter of )
)
Colonial Pipeline Company, ) CPF No. 2-2016-5005H
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Respondent. )
)
CORRECTIVE ACTION ORDER
Purpose and Background:
This Corrective Action Order (Order) is being issued under the authority of 49 U.S.C. § 60112 to
require Colonial Pipeline Company (Colonial or Respondent), to take the necessary corrective
action to protect the public, property, and the environment from potential hazards associated with
the recent failure on its Colonial’s Pipeline One (Line #1).1
On September 9, 2016, a reportable accident occurred on Colonial’s Line #1, a hazardous liquid
pipeline in Shelby County, Alabama, approximately three miles from the town of Pelham,
Alabama (Failure). The Failure resulted in the release of approximately 6,000 barrels of gasoline
into a pond (Pond #2) approximately 460 feet north of Colonial’s Line #1. Line #1 transports
gasoline from Houston, Texas, to Greensboro, North Carolina. The Failure occurred on a section
of Line #1 that runs from Collins, Mississippi, to Atlanta Junction Station, in Atlanta, Georgia.
Colonial operates a parallel pipeline that runs adjacent to Line #1, Pipeline Two (Line #2), that is
approximately 40 feet apart from Line #1 at the assumed site of the Failure. Line #2 transports
petroleum product from Epes, Alabama, to Anderson, South Carolina.
Pursuant to 49 U.S.C. § 60117, the Pipeline and Hazardous Materials Safety Administration
(PHMSA), Office of Pipeline Safety (OPS), initiated an investigation of the accident.
The preliminary findings of the ongoing investigation are as follows.
1 Colonial operates roughly 5,500 miles of hazardous liquid transmission pipeline within the United States. The
pipelines travel through the states of Texas, Louisiana, Mississippi, Alabama, Georgia, North and South Carolina,
Virginia, Maryland, Pennsylvania, New Jersey, and New York. Branches from the main lines also extend into
Tennessee. The system delivers a daily average of approximately 100 million gallons of liquid petroleum products
to businesses and communities through the Southern and Eastern United States.



CPF No. 2-2016-5005H
Page 2
Preliminary Findings:
1) 2) 3) 4) 5) 6) Line #1 is a 36-inch diameter hazardous liquid pipeline that runs from Houston,
Texas, to Greensboro, North Carolina. The Failure occurred on a segment of Line
#1 that runs from Collins, Mississippi, to Respondent’s Atlanta Junction Station, in
Atlanta, Georgia (Affected Segment). The exact location of the Failure is unknown,2
but the Assumed Failure Site is on a section of Line #1 that runs from Colonial’s
Cahaba River block valve, near Mile Post (MP) 5065+11, to Colonial’s Pelham
Station in Pelham, Alabama, near MP 5545+46. A pond (Pond 2) off of the right-of-
way is approximately 460 feet from the Assumed Failure Site on Line #1 (Assumed
Failure Site).
The Affected Segment was constructed in 1963 and is composed of 36-inch
diameter, 0.281-inch wall thickness, American Petroleum Institute (API) 5L, X52
pipe. The pipe has asphalt enamel coating and a double-submerged arc-welded
(DSAW) seam type, and was manufactured by the National Tube Company.
The Maximum Operating Pressure (MOP) of Line #1 is 553 pounds per square inch
gauge (“psig”), as established by hydrostatic testing in 1963. During the 30 days
prior to the Failure, the operating pressure of Line #1 near the Assumed Failure Site
fluctuated between 31 psig and 495 psig.3
On September 9, 2016, at 11:10 am Central Standard Time (CST), personnel of the
Alabama Surface Mining Commission reported a probable leak near Line #1, in a
right-of-way for this pipeline in a rural area. The personnel noted a strong gasoline
odor and sheen on Pond #2, and also discovered dead vegetation near this pond.
Pond #2 is located near mile post 5163+89 (MP 5163+89), on Line #1, in Shelby
County, Alabama, approximately three miles from Pelham, Alabama. Pond #2 is
bounded by Line #1 to the south and another pond, Pond #3, to the north.
On September 9, 2016, beginning at 11:30 AM CST, in response to the 11:10 am
notification from the Alabama Surface Mining Commission,4 Respondent initiated a
shutdown of Lines #1 and #2. This process began when Colonial’s Supervisory
Control and Data Acquisition (SCADA) system controller remotely closed an
automatic valve downstream of the Assumed Failure Site, at MP 5545+47 on Line
#1.
2 See infra Preliminary Findings 17 – 19.
3 PHMSA officials note the variation in operating pressure readings on Line #1 in the 30 days prior to the Failure is
a function of Colonial’s normal pipeline operations. During normal operations, pressure readings can fluctuate
depending on maintenance activities or required throughput of Line #1, and the referenced range is representative of
these operational adjustments.
4 See supra Preliminary Finding 4.



CPF No. 2-2016-5005H
Page 3
7) On September 9, 2016, at 12:14 PM CST, Respondent’s personnel at the Assumed
Failure Site confirmed that gasoline had accumulated in Pond #2.
8) On September 9, 2016, at 12:59 PM CST, Respondent notified the National
Response Center that gasoline had entered Pond #2 as a result of the Failure from
Line #1.
9) On September 9, 2016, at approximately 3:00 PM CST, Colonial personnel manually
closed a valve on Line #1 upstream of the Assumed Failure Site at MP 5065+11.
10) On September 9, 2016, at 6:57 PM CST, Colonial personnel observed a total of four
deceased small wild animals near Pond #2 – a rabbit and three raccoons.
11) On September 9, 2016, at 9:00 PM CST, inspectors from the Southern Region of
PHMSA, OPS, arrived at Respondent’s Incident Command Center in Hoover,
Alabama.
12) On September 9, 2016, at 9:00 PM CST, officials from the Pelham, Alabama Fire
Department (Fire Department) determined that the air at the Assumed Failure Site
and at Pond #2 contained high concentrations of benzene5 and gasoline vapor.6 The
detected levels of benzene and gasoline vapors remained at unsafe levels at both
locations through September 12, 2016.
13) On September 9, 2016, at 9:00 PM CST, due to the high concentration of benzene
and gasoline vapor at both the Assumed Failure Site and Pond #2, Fire Department
officials suspended all activity and evacuated all persons from these locations until
September 12, 2016.
14) On September 9, 2016, at 9:13 PM CST, after consulting with PHMSA, Respondent
restarted Line #2 upon confirming that the observed product in Pond #2 was gasoline
from Line #1, and that no release had occurred on Line #2.
15) At approximately 8:00 AM CST on September 13, 2016, Fire Department and
Colonial officials determined that after approximately 83 hours of unsafe
concentrations of benzene and gasoline vapors in the air at the Assumed Failure Site,
these concentrations had dropped to safe levels. Shortly after this determination,
Colonial and PHMSA personnel were permitted access to the Assumed Failure Site.
However, at this time, Fire Department and Colonial Officials determined these
unsafe levels of benzene and gasoline vapor were still present in the air at Pond #2.
5 Benzene is a chemical that is a natural part of the gasoline transported in Line #1 and is highly flammable.
Further, inhalation of high concentrations of benzene can result in sickness or death. See Centers for Disease
Control. https://emergency.cdc.gov/agent/benzene/basics/facts.asp (last visited September 14, 2016).
6 U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration. 2016 Emergency
Response Guidebook. Guide 115 – Gases (Flammable – Included Refrigerated Liquids). Pages 170 – 171.



CPF No. 2-2016-5005H
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16) At approximately 8:00 PM CST on September 13, 2016, Fire Department and
Colonial Officials determined that benzene and gasoline vapors had again risen to
unsafe levels in the air at the Assumed Failure Site. Colonial Officials believed that
the rise in benzene and gasoline vapor levels in the air at the Assumed Failure Site
was caused by wind transport of benzene and gasoline vapors coming off of the
accumulated gasoline in Pond #2.
17) Based on the unstable and fluctuating benzen
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