{"operation":"document","citation":"CPF 220205003M","title":"COLONIAL PIPELINE CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-12-15","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(c)(3), 195.589(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220205003m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220205003m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220205003m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220205003M","body":"Notice of Amendment involving COLONIAL PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 195.402(c)(3),  195.589(c). The case was opened on 2020-12-15 and is reported as closed as of 2022-03-09. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220205003M_Closure Letter_03092022_(18-162643S).pdf: https://primis.phmsa.dot.gov/enforcement-documents/220205003M/220205003M_Closure%20Letter_03092022_(18-162643S).pdf\n\n220205003M_Closure Letter_03092022_(18-162643S)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220205003M/220205003M_Closure%20Letter_03092022_(18-162643S)_text.pdf\n\n220205003M_Notice of Amendment_12152020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220205003M/220205003M_Notice%20of%20Amendment_12152020.pdf\n\n220205003M_Notice of Amendment_12152020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220205003M/220205003M_Notice%20of%20Amendment_12152020_text.pdf\n\n220205003M_Notice of Amendment_12152020_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 15, 2020\nMr. Joseph Blount\nPresident & Chief Executive Officer\nColonial Pipeline Company\n1185 Sanctuary Parkway\nSuite 100\nAlpharetta, GA 30009\nCPF 2-2020-5003M\nDear Mr. Blount:\nBetween January 14, 2019, and February 7, 2020, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) inspected Colonial Pipeline Company’s (Colonial)\nwritten procedures covering its pipeline system in Alabama, Georgia, Louisiana, Mississippi,\nNorth Carolina, South Carolina, Tennessee, and Texas, pursuant to Chapter 601 of 49 United\nStates Code (U.S.C.).\nBased on the inspection, PHMSA has identified apparent inadequacies within Colonial’s plans or\nprocedures, as described below:\n1. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) …\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n. . . .\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\n\n\n\n2. Two (2) Colonial procedures reviewed during the inspection were inadequate to assure safe\noperation of a pipeline facility because they omitted key steps for personnel to perform\nwhile conducting inspections of overpressure safety devices required by § 195.428(a). The\nprocedures which omitted key steps were the Equipment Maintenance Procedure: Pressure\nSwitches – System Integrity, EM-6.1-SI, Rev. 10 (“EM-6.1-SI”) and the Equipment\nMaintenance Procedure: Pressure Relief Valves, EM-6.6-SI, Rev. 12 (“EM-6.6-SI”).\nAt the time of PHMSA’s Colonial Procedure EM-6.1-SI, covering inspection and\nmaintenance of pressure switches, omitted steps requiring Colonial personnel to reset the\ninhibitor alarm after conducting routine inspection and maintenance on pressure switches.\nColonial personnel acknowledged during the inspection, on September 25, 2019, that failure\nto reset the inhibitor alarm after routine inspection and maintenance may pose a safety or\nintegrity threat.\nFurther, at the time of PHMSA’s inspection, Colonial Procedure EM-6.6-SI, covering\ninspection and maintenance of pressure relief valves, omitted the step of resetting the control\nroom lockout that is required when inspecting and maintaining certain relief valves. During\nPHMSA’s inspection, Colonial personnel acknowledged that failure to perform a reset of the\ncontrol room lockout after routine inspection and maintenance may pose a safety or integrity\nthreat.\nIn a December 23, 2019, communication, Colonial stated that “[t]hese steps are covered in\nother operations manual and processes” and that Colonial will not make revisions to\nEM-6.1-SI and EM-6.6-SI at this time.\nWhile both EM-6.1-SI and EM-6.6-SI have a section for “References,” at the time of\nPHMSA’s inspection, neither procedure directed Colonial personnel to read or refer to any\nspecific, incorporated “References” requiring them to reset the inhibitor alarm or control\nroom lockout, as referenced above.\n§ 195.589 What corrosion control information do I have to maintain?\n(a) …\n(c) You must maintain a record of each analysis, check, demonstration, examination,\ninspection, investigation, review, survey, and test required by this subpart in sufficient\ndetail to demonstrate the adequacy of corrosion control measures or that corrosion\nrequiring control measures does not exist. You must retain these records for at least 5\nyears, except that records related to §§195.569, 195.573(a) and (b), and 195.579(b)(3)\nand (c) must be retained for as long as the pipeline remains in service.\nColonial’s written procedure for stray currents was inadequate to assure safe operation of a\npipeline facility because it did not require Colonial personnel to maintain a record of each\nanalysis, check, demonstration, examination, inspection, investigation, review, survey, and\ntest required by this subpart in sufficient detail to demonstrate the adequacy of corrosion\ncontrol measures or that corrosion requiring control measures did not exist.\nFor pipelines exposed to stray currents, § 195.577 requires Colonial to develop a program to\nidentify, test for, and minimize the detrimental effects of stray currents. Colonial’s\nprocedures for stray current testing are found in its Maintenance Procedure: Inspect and\nTest Cathodic Protection Electrical Isolation (“Isolation Test Procedure”), Rev. 1.\nAt the time of PHMSA’s inspection, the above-referenced Isolation Test Procedure did not\nrequire personnel to maintain a record of each test. For both aboveground and underground\nisolation devices, the referenced procedure directed personnel that “IF necessary,\n2\n\n\n\nDOCUMENT inspection and test results in field log and/or data logger AND ENTER data\ninto Corrosion Prevention database” (Emphasis added). The procedure was inadequate\nbecause it did not adequately identify when the records were required to be maintained.\nMoreover, the tests required by § 195.577 are tests required by Subpart H, and thus, per §\n195.589(c), a record of each test is required.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised 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).\nFollowing the receipt of this Notice, Colonial has 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If Colonial does not respond within 30\ndays of receipt of this Notice, this constitutes a waiver of its right to contest the allegations in\nthis Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged\nin this Notice without further notice to Colonial and to issue an Order Directing Amendment. If\nColonial’s plans or procedures are found inadequate as alleged in this Notice, Colonial may be\nordered to amend its plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If\nColonial is not contesting this Notice, PHMSA proposes that Colonial submit its amended\nprocedures to PHMSA’s Office of Pipeline Safety, Southern Region, within 45 days of receipt of\nthis Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in any amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that Colonial Pipeline Company maintain documentation of the\nsafety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Director, Office of Pipeline\nSafety, PHMSA Southern Region. In correspondence concerning this matter, please refer to CPF\n2-2020-5003M and, for each document you submit, please provide a copy in electronic format\nwhenever possible.\nSincerely,\nJames A. Urisko\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n3\n\n220205003M_Closure Letter_03092022_(18-162643S)_text.pdf\n\nDELIVERY METHOD – VIA FEDERAL EXPRESS\nMarch 9, 2022\nMr. Joseph Blount\nPresident & Chief Executive Officer\nColonial Pipeline Company\n1185 Sanctuary Parkway\nSuite 100\nAlpharetta, GA 30009\nCPF 2-2020-5003M\nDear Mr. Blount:\nBetween January 14, 2009, and February 7, 2020, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) inspected Colonial Pipeline Company’s (Colonial)\nwritten procedures covering its pipeline system in Alabama, Georgia, Louisiana, Mississippi,\nNorth Carolina, South Carolina, Tennessee, and Texas. pursuant to Chapter 601 of 49 United\nStates Code. As a result of the inspection, Colonial was issued a Notice of Amendment (NOA)\non December 15, 2020, which proposed amendments of Colonial’s procedures.\nColonial submitted its amended procedures on February 12, 2021 and on February 21, 2022.\nPHMSA has reviewed the amended procedures, and it appears that the inadequacies outlined in\nthe NOA have been corrected.\nThis letter is to inform you no further action is necessary, and this case is now closed.\nPlease be advised that this letter refers only to the referenced case (CPF 2-2020-5003M) and not\nto any other PHMSA cases, if any.\nSincerely,\nJames A. Urisko\nDirector, Office of Pipeline Safety\nPHMSA Southern Region","truncated":false,"body_characters":10086}