COLONIAL PIPELINE CO — Safety Order

22021005NOPSO_Consent Agreement and Order_06152021_(20-188854)_text.pdf, page 1Official PDFJune 15, 2021 Mr. Joseph Blount President and Chief Executive Officer Colonial Pipeline Company 1185 Sanctuary Parkway Suite 100 Alpharetta, Georgia 30009 CPF No. 2-2021-005-NOPSO Dear Mr. Blount: Enclosed please find a Consent Order incorporating the terms of the Consent Agreement between the Pipeline and Hazardous Materials Safety Administration (PHMSA) and Colonial Pipeline Company which was executed on June 4, 2021. Service of the Consent Order and Consent Agreement by electronic mail is deemed effective upon the date of transmission, or as otherwise provided under 49 C.F.R. § 190.5. Thank you for your cooperation in this matter. Sincerely, Alan K. Mayberry Associate Administrator for Pipeline Safety Enclosure: Order and Consent Agreement cc: Mr. James Urisko, Director, Southern Region, Office of Pipeline Safety, PHMSA Mr. Mark Piazza, Manager, Pipeline Compliance and R&D, Colonial Pipeline Company Ms. Catherine Little, Troutman Pepper, Counsel for Colonial Pipeline Company CONFIRMATION OF RECEIPT REQUESTED#

22021005NOPSO_Consent Agreement and Order_06152021_(20-188854)_text.pdf, page 2U.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, ) ) ) ) ) Respondent. ) ____________________________________) CPF No. 2-2021-005-NOPSO CONSENT ORDER By letter dated March 29, 2021, the Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety, issued a Notice of Proposed Safety Order (Notice) to Colonial Pipeline Company (Colonial or Respondent). In accordance with 49 C.F.R. § 190.239, the Notice alleged that conditions existed on Respondent’s pipeline system that posed a pipeline integrity risk to public safety, property, or the environment and that the conditions potentially exist throughout the Colonial Pipeline System. The Notice proposed that Respondent take certain corrective measures to remedy the alleged conditions and ensure that the public, property, and the environment are protected from the potential risk. On April 9, 2021, pursuant to 49 C.F.R. § 190.239(b)(2), Colonial responded to the Notice by submitting a request for an informal consultation, whereupon the parties engaged in good-faith discussions that resulted in the Consent Agreement attached to this Order that settles all of the allegations in the Notice. Accordingly, the Consent Agreement is hereby approved and incorporated by reference into this Order. Colonial is hereby ordered to comply with the terms of the Consent Agreement, effective immediately. Pursuant to 49 U.S.C. 60101, et seq., failure to comply with this Consent Order may result in the assessment of civil penalties as set forth in 49 C.F.R. § 190.223. The terms and conditions of this Consent Order are effective upon service in accordance with 49 C.F.R. § 190.5. June 15, 2021 ___________________________________ __________________________ Alan K. Mayberry Date Issued Associate Administrator for Pipeline Safety#

22021005NOPSO_Consent Agreement and Order_06152021_(20-188854)_text.pdf, page 3U.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, ) ) ) ) Respondent. ) ____________________________________) CPF No. 2-2021-005-NOPSO CONSENT AGREEMENT On March 29, 2021, pursuant to 49 C.F.R. § 190.239, the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS or Agency), issued a Notice of Proposed Safety Order (Notice) to Colonial Pipeline Company (Colonial or Respondent). The Notice alleged that conditions existed on Respondent’s pipeline system that posed a pipeline integrity risk that could potentially affect public safety, property, or the environment and that the conditions potentially exist throughout the Colonial Pipeline System. Specifically, the Notice alleged that on August 14, 2020, a Colonial employee was notified by a local resident of a possible leak in Colonial’s right-of-way (ROW), approximately 100 feet north (downstream) of Huntersville-Concord Road in Huntersville, North Carolina. Upon inspection, a Colonial employee confirmed a product release visible at the ground surface that was believed to be gasoline (the Failure). The Colonial Control Center initiated a shutdown of its pipeline facilities in the area (Lines 1 and 2). Colonial notified the National Response Center (NRC) of the release (NRC Report No. 1284598) on August 14, 2020, reporting an estimated release volume of 75 barrels of gasoline. On August 15, 2020, Colonial identified the leak source to be Line 1 (gasoline service) and restarted Line 2 the same day. Colonial determined the leak originated from under a Type A sleeve repair installed in 2004, originally intended to reinforce and protect a shallow dent identified by an integrity assessment. The pipeline was initially repaired on August 19, 2020, by installing a Type B pressure containing sleeve over the prior Type A sleeve repair. Colonial restarted Line 1 on August 19, 2020, after initial repairs were completed. On September 13, 2020, Colonial submitted an initial accident report (PHMSA Form 7000.1) to PHMSA that updated the estimated release volume to 6,490 barrels of gasoline. On November 10, 2020, Colonial cut out the Type B sleeve which contained the failed section of pipe and additional sections of Line 1 on either side of the Type B sleeve repair. The cut-out section of pipe was sent to an independent laboratory for metallurgical analysis. The cut-out and welding of the replacement pipeline tie-in was witnessed by PHMSA.#

22021005NOPSO_Consent Agreement and Order_06152021_(20-188854)_text.pdf, page 4Upon identification and confirmation of the release and potential soil contamination, Colonial initiated monitoring and remediation efforts, which included installation of 167 wells (81 monitoring wells, 50 recovery wells, 11 hydraulic control wells, and 25 air sparge system wells) between August 27, 2020 and January 16, 2021. The released gasoline penetrated the soil and affected the ground water in the area.1 On February 1, 2021, Colonial submitted a supplemental report to PHMSA updating the estimated release volume to 28,571 barrels (1.2 million gallons) of gasoline. Colonial’s metallurgical analysis was received by PHMSA on March 19, 2021. The analysis identifies the primary crack growth mechanism as corrosion fatigue. At this time, Colonial has not provided any other supplemental 7000.1 reports to PHMSA regarding the estimated release volume due to the Failure. Colonial has experienced several other accidents that were not detected by its leak detection system or by Colonial personnel. For example, on September 21, 2015, a reportable accident occurred on Colonial's Line 4 hazardous liquid pipeline in Centreville, Virginia, resulting in the release of approximately 95 barrels (4,000 gallons) of gasoline. Colonial was notified by the Fairfax County Fire Marshall of a sheen on a retention pond in close proximity to Colonial’s Line 4 ROW. The cause of the leak was determined to be a crack that formed in a shallow dent on the bottom side of the pipe. In February 2016, Colonial experienced a failure in Gwinnett County, Georgia, that was discovered by a second-party contractor. According to Colonial documentation and reporting, the failure mode was fatigue cracks within an area where a dent was present with significant corrosion (up to 35%) under a Type A sleeve with shrink sleeves on the end that was installed in 2005. The final volume of release was reported to be approximately 14 barrels (588 gallons) of gasoline. On September 9, 2016, Colonial experienced a failure outside of Pelham, Alabama. Colonial was made aware of the suspected release by local governmental personnel. According to the final accident report dated May 6, 2019, Colonial reported an estimated volume released of 7,370 barrels (309,540 gallons) of gasoline. The failure mechanism was determined to be a crack in a buckle that formed due to inadequate compaction following a prior maintenance project. On April 9, 2021, Colonial responded to the Notice by timely submitting a request for an informal consultation pursuant to 49 C.F.R. § 190.239(b)(2). An informal consultation was held virtually on April 30, 2021. As a result of the informal consultation, PHMSA and Colonial (collectively, the Parties) agreed that settlement of this proceeding will avoid further administrative proceedings or litigation and will serve the public interest by promoting safety and protection of the environment. Pursuant to 49 C.F.R. Part 190, and upon consent and agreement of Colonial and PHMSA, the Parties hereby agree as follows: 1 See https://sr2448.colonialresponse.com/.#

22021005NOPSO_Consent Agreement and Order_06152021_(20-188854)_text.pdf, page 5I. General Provisions 1. Respondent acknowledges that as the operator of the Colonial Pipeline System in Texas, Louisiana, Mississippi, Alabama, Georgia, Tennessee, South Carolina, North Carolina, Virginia, Maryland, Delaware, Pennsylvania, New Jersey, and New York, Respondent and its Colonial Pipeline System are subject to the jurisdiction of the federal pipeline safety laws, 49 U.S.C. § 60101, et seq., and the regulations and administrative orders issued thereunder. For purposes of this Consent Agreement (“Agreement”), Respondent acknowledges that it received proper notice of PHMSA's action in this proceeding and that the Notice states claims upon which relief may be granted pursuant to 49 U.S.C. § 60101, et seq., and the regulations and orders issued thereunder. 2. After Colonial returns this signed Agreement to PHMSA, the Agency’s representative will present it to the Associate Administrator for Pipeline Safety, recommending that the Associate Administrator adopt the terms of this Agreement by issuing an administrative order (Consent Order or Order) incorporating the terms of this Agreement. The terms of this Agreement constitute an offer of settlement until accepted by the Associate Administrator. Once accepted, the Associate Administrator will issue a Consent Order incorporating the terms of this Agreement. 3. Respondent consents to the issuance of the Consent Order, and hereby waives any further procedural requirements with respect to its issuance. Respondent waives all rights to contest the adequacy of notice, or the validity of the Consent Order or this Agreement, including all rights to administrative or judicial hearings or appeals, except as set forth herein. 4. This Agreement shall apply to and be binding upon PHMSA and Colonial, its officers, directors, and employees, and its successors, assigns, or other entities or persons otherwise bound by law. Respondent agrees to provide a copy of this Agreement and any incorporated work plans and schedules to all of Colonial’s officers, employees, and agents whose duties might reasonably include compliance with this Agreement. 5. This Agreement constitutes the final, complete, and exclusive agreement and understanding between the Parties with respect to the settlement embodied in this Agreement. The Parties acknowledge that there are no representations, agreements, or understandings relating to settlement other than those expressly contained in this Agreement, except that the terms of this Agreement may be construed by reference to the Notice. 6. Nothing in this Agreement affects or relieves Respondent of its responsibility to comply with all applicable requirements of the federal pipeline safety laws, 49 U.S.C. § 60101, et seq., and the regulations and orders issued thereunder. Nothing in this Agreement alters PHMSA's right of access, entry, inspection, and information gathering or PHMSA's authority to bring enforcement actions against Colonial pursuant to the federal pipeline safety laws, the regulations and orders issued thereunder, or any other provision of federal or state law. 7. For all transfers of ownership or operating responsibility of Colonial’s pipeline system which occur while this Agreement is in effect, Colonial will provide a copy of this Agreement to the prospective transferee at least 30 days prior to such transfer. Colonial will#

22021005NOPSO_Consent Agreement and Order_06152021_(20-188854)_text.pdf, page 6provide written notice of the transfer to the PHMSA Southern Region Director no later than 60 days after the transfer occurs. 8. This Agreement does not waive or modify any federal, state, or local laws or regulations that are applicable to Respondent’s pipeline systems. This Agreement is not a permit, or a modification of any permit, under any federal, state, or local laws or regulations. Colonial remains responsible for achieving and maintaining compliance with all applicable federal, state, and local laws, regulations, and permits. Respondent agrees that the activities to be performed pursuant to the Work Plan may go beyond the minimum federal pipeline safety regulations. 9. This Agreement does not create rights in, or grant any cause of action to, any third party not party to this Agreement. The U.S. Department of Transportation is not liable for any injuries or damages to persons or property arising from acts or omissions of Respondent or its officers, employees, or agents carrying out the work required by this Agreement. Colonial agrees to hold harmless the U.S. Department of Transportation, its officers, employees, agents, and representatives from any and all causes of action arising from any acts or omissions of Respondent or its contractors in carrying out any work required by this Agreement. 10. This Agreement does not constitute a finding of violation of any federal law or regulation and may not be used in any civil proceeding of any kind as evidence or proof of any fact, fault or liability, or as evidence of a violation of any law, rule, regulation, or requirement, except in a proceeding to enforce the provisions of this Agreement or in future PHMSA enforcement actions. Respondent neither admits nor denies any allegation or conclusion in the Notice or this Agreement and Order, but agrees, for purposes of this Agreement and Order, to address the alleged risk condition by completing the terms of this Agreement. 11. Upon issuance of the Consent Order, the Parties agree to all terms in this Agreement and its appendices, which are incorporated herein. II. Definitions 12. The “Director” means the Director, Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety, Southern Region. The Director’s address is 230 Peachtree Street NW, Suite 2100, Atlanta, Georgia, 30303. 13. The “Failure” means the release of gasoline that occurred on Colonial’s Line 1 in Huntersville, North Carolina, which Colonial reported to the NRC on August 14, 2020. III. Corrective Measures Colonial agrees to take the following corrective measures to address the alleged risk conditions on the Colonial Pipeline System set forth in the Preliminary Findings of the Notice, as follows: 14. Remedial Work Plan. Within 120 days after the Consent Order is issued, develop and submit to the Director for approval, a written remedial work plan (Work Plan or Plan) that includes corrective measures. The Plan must include provisions to:#

22021005NOPSO_Consent Agreement and Order_06152021_(20-188854)_text.pdf, page 7i. Evaluate the effectiveness and capability of Colonial’s leak detection system on the entirety of the Colonial Pipeline System, including main lines, stub lines, and delivery lines. At a minimum, Colonial’s evaluation must consider the following factors—length and size of the pipeline, type of product carried, the swiftness of leak detection, limitations on detectable quantities, location of nearest response personnel, and leak history. This evaluation must also consider maximum operating pressure (MOP), normal operating pressures, flow rates (or throughput), and impacts from any pressure cycles or operational changes. For mainline segments that could affect high consequence areas (HCAs), Colonial’s evaluation must consider the pipeline’s proximity to the HCA and risk assessment results. ii. Based on the findings of the evaluation pursuant to paragraph i of this Item, determine corrective measures to improve the effectiveness of Colonial’s leak detection system. The corrective measures must result in improving the capability of the leak detection system to detect leaks that could potentially affect public safety, property, or the environment, similar to (but not limited to) leaks with characteristics common to those referenced above. iii. Evaluate Colonial’s written plans and procedures for inspection and maintenance that address leak detection, ROW inspection and repairs and determine the extent to which the written plans contribute to the elimination of hazardous leaks. Based on the findings, determine appropriate amendments to improve the extent to which the plans contribute to the elimination of hazardous leaks. iv. Evaluate the effectiveness of Colonial’s ROW inspection program as it pertains to leak detection. This evaluation must consider any geographic regions or features (i.e., HCAs and other sensitive areas) that may require specific or additional means of patrol. Based on the findings, determine corrective measures to improve the effectiveness of Colonial’s ROW inspection program relative to leak detection. v. Provide to the Director an inventory of all Type A sleeve repairs made on the Colonial Pipeline System. For each identified Type A sleeve, the inventory must include the most accurate information regarding, at a minimum, the installation date, a summary of the basis for the original application (i.e., remediated condition), and identification of any scheduled follow-up actions. vi. Establish a program and requirements for classifying all future repairs as temporary or permanent. The Plan must establish timeframes for the removal of any repair identified as “temporary,” or the permanent remediation of the condition requiring repair. If such designations and timeframes have been incorporated in to its programs, Colonial must submit documentation confirming the temporal disposition for repair methods deemed acceptable for all line pipe. 15. Third-party facilitator. Paragraphs i through iv of the Work Plan must be facilitated by an independent third-party approved by the Director. Documentation from the third-party facilitator must be included in each required submission to the Director.#

22021005NOPSO_Consent Agreement and Order_06152021_(20-188854)_text.pdf, page 816. Schedule. The Plan must include a proposed timeline for completion of implementation of the corrective measures identified by Item 14.i – 14.vi of the Agreement. 17. Submissions of procedures. Submit to the Director all written procedures, new or amended, that will be used to complete the requirements of the Work Plan. 18. Quarterly reports. Submit quarterly reports to the Director that: (1) include available data and evaluations conducted pursuant to the Work Plan; and (2) describe the progress of the remedial measures being undertaken. The first quarterly report shall be due 90 days from the date of the approval of the Work Plan, and thereafter on the 15th day of the last month of the calendar quarter. 19. Consent Agreement Documentation Report (CADR). When Colonial has completed all the items in this Agreement, it will submit a final CADR to the Director. This will allow the Director to conduct a thorough review of all measures identified by Colonial with regards to this Agreement prior to approving the closure of this Agreement. The intent is for the CADR to summarize all activities and documentation associated with this Agreement in one document. The CADR must include, but is not limited to: i. Table of contents; ii. Summary of the Failure, its root cause, and response activities; iii. Summary of all inspections, assessments, evaluations, and analysis required by this Agreement, including those conducted by the third-party facilitator; iv. Summary of all metallurgical testing and/or metallurgical analysis related to the Failure; v. Documentation of all corrective measures taken by Colonial to implement the Work Plan, and the results of those corrective measures; vi. Documentation of any revisions to the Work Plan; and vii. Lessons learned while completing the Work Plan. 20. Documentation of costs. It is requested that Colonial maintain documentation of the safety improvement costs associated with fulfilling this Agreement and submit the total to the Director, Southern Region, Pipeline and Hazardous Materials Safety Administration. It is requested that these costs be reported in two categories: 1) total cost associated with preparation/revision of plans, procedures, studies, and analyses; and 2) total cost associated with replacements, additions and other changes to pipeline infrastructure.#

22021005NOPSO_Consent Agreement and Order_06152021_(20-188854)_text.pdf, page 9IV. Implementation, Review, and Approval Process: 21. Respondent agrees to complete the Work Plan in accordance with the schedules set forth therein as it is approved by the Director, including revisions to the Plan. Results of measures taken in accordance with the approved Plan must be available for review by PHMSA or its representative. 22. With respect to any submission by the Respondent under the Work Plan that requires the approval of the Director, the Director may: (1) approve the submission, in whole or in part; (2) disapprove the submission on specified conditions; (3) disapprove the submission, in whole or in part; or (4) undertake any combination of the foregoing. In the event of approval in whole, in part, or upon conditions, Colonial will proceed to take all actions required by the submission as modified by the Director. In the event the Director does not approve all or any portion of a submission, the Director will provide Colonial with a written notice of the deficiencies. Respondent will correct all deficiencies within the time specified by the Director and resubmit it for approval. 23. All submittals required by the Work Plan that include decisions and determinations must also describe the options and factors considered by Colonial. 24. Respondent agrees to revise the Work Plan as necessary to incorporate new information obtained during the activities performed under the Work Plan. Respondent shall submit any such plan revisions to the Director for prior approval. 25. The Director may grant an extension of time for completion of any of the work to be performed under the Agreement or the Work Plan upon Respondent’s timely, written request that demonstrates both good cause for an extension and provides sufficient detail to enable the Director to evaluate Respondent’s request. The Director shall respond in writing to any such request. 26. After receiving and analyzing additional data in the course of this proceeding and implementation of the Work Plan, PHMSA may identify other safety measures that need to be taken. In that event, Respondent will be notified in writing of any proposed additional measures and, if necessary, amendments to the Work Plan. V. Enforcement 27. This Agreement, including all elements of the incorporated Work Plan, is subject to all enforcement authorities available to PHMSA under 49 U.S.C. § 60101, et seq., and 49 C.F.R. Part 190, including administrative civil penalties under 49 U.S.C. § 60122, of up to $200,000 (as adjusted) per violation for each day the violation continues and referral of the case to the Attorney General for judicial enforcement, if PHMSA determines that Respondent is not complying with the terms of this Agreement in accordance with determinations made by the Director, or if appealed, in accordance with decisions of the Associate Administrator. The maximum civil penalty amounts are adjusted annually for inflation. See 49 C.F.R. § 190.233.#

22021005NOPSO_Consent Agreement and Order_06152021_(20-188854)_text.pdf, page 10VI. Dispute Resolution 28. The Director and Colonial will informally attempt to resolve any disputes arising under this Agreement, including, but not limited to, any decision of the Director. If Colonial and the Director are unable to informally resolve the dispute within 15 calendar days after the dispute is first raised in writing, Colonial may submit a written request for a determination resolving the dispute from the Associate Administrator for Pipeline Safety. The written request for a determination must be provided to the Director, counsel for the Southern Region, and to the Associate Administrator no later than 10 calendar days after the 15-day deadline for informal resolution referenced in this paragraph. Along with its request, Colonial must provide the Associate Administrator with all information Colonial believes is relevant to the dispute. Determinations of the Associate Administrator under this paragraph constitute final Agency action. The existence of a dispute and PHMSA’s consideration of matters placed in dispute, will not excuse, toll, or suspend any term or timeframe for completion of any work to be performed under this Agreement during the pendency of the dispute resolution process, except as agreed upon by the Director or Associate Administrator in writing. VII. Recordkeeping and Information Disclosure 29. Unless otherwise required in this Agreement, Respondent agrees to maintain records demonstrating compliance with all requirements of this Agreement for a period of at least 5 years following completion of all work to be performed. For any reports, plans, or other deliverables required to be submitted to PHMSA pursuant to this Agreement, Respondent may assert a claim of business confidentiality or other protections applicable to the release of information by PHMSA, covering part or all of the information required to be submitted to PHMSA pursuant to this Agreement in accordance with 49 C.F.R. Part 7. Respondent must mark the claim of confidentiality in writing on each page, and include a statement specifying the grounds for each claim of confidentially. PHMSA will determine the release of any information submitted pursuant to this Agreement in accordance with 49 C.F.R. Part 7, the Freedom of Information Act, 5 U.S.C. § 552, DOT and PHMSA policies, and other applicable regulations and Executive Orders. VIII. Effective Date 30. The term “Effective Date,” as used herein, is the date on which the Consent Order is issued by the Associate Administrator, PHMSA, incorporating the terms of this Agreement. IX. Modification 31. The terms of this Agreement may be modified by mutual agreement of the Parties. Such modifications must be in writing and signed by both parties.#

22021005NOPSO_Consent Agreement and Order_06152021_(20-188854)_text.pdf, page 11X. Termination 32. This Agreement will terminate upon submission, approval where specified, and completion of the deliverables set forth in the Work Plan. XI. Ratification 33. The Parties’ undersigned representatives certify that they are fully authorized to enter into the terms and conditions of this Agreement and to execute and legally bind such party to this document. 34. The Parties hereby agree to all conditions and terms of this Agreement. For Colonial Pipeline Company: ________________________ Wes Dunbar Vice President of Operations ________________________ Date For PHMSA: _________________________ James Urisko Director, Southern Region Date#

22021005NOPSO_Closure Letter_08252025_(20-188854)_text.pdf, page 1Official PDFVIA ELECTRONIC MAIL TO: mlittle@colpipe.com; qfrazier@colpipe.com; dlangley@colpipe.com August 25, 2025 Ms. Melanie Little President, Chief Executive Officer Colonial Pipeline Company 1000 Lake Street Alpharetta, GA 30009 RE: CPF 2-2021-005-NOPSO Dear Ms. Little: On March 29, 2021, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to Colonial Pipeline Company (Colonial), a Notice of Proposed Safety Order. On June 4, 2021, PHMSA and Colonial entered into a Consent Agreement and Order. This Order included a requirement for Colonial to implement system-wide corrective actions, with regular submittals for review and approval. Based on PHMSA’s review of the documentation provided it has been determined that Colonial has complied with the terms of the Order. Accordingly, this case is now closed, and no further action is anticipated with respect to the matters involved in this case. Thank you for your cooperation in this matter. Sincerely, James A. Urisko Regional Director, Southern Region, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration#

22021005NOPSO_Notice of Proposed Safety Order_03292021_(20-188854)_text.pdf, page 1Official PDFVIA ELECTRONIC MAIL TO: jblount@colpipe.com; mpiazza@colpipe.com March 29, 2021 Mr. Joseph Blount President, Chief Executive Officer Colonial Pipeline Company 1185 Sanctuary Parkway Suite 100 Alpharetta, GA 30009-4765 CPF No. 2-2021-005-NOPSO Dear Mr. Blount: Enclosed is a Notice of Proposed Safety Order (Notice) issued in the above-referenced case. The Notice proposes that Colonial Pipeline Company take certain measures with respect to the Colonial Pipeline System to ensure pipeline safety. Your options for responding are set forth in the Notice. Service of this Notice by electronic mail is deemed effective upon the date of transmission, or as otherwise provided under 49 C.F.R. § 190.5. We look forward to a successful resolution to ensure pipeline safety. Please direct any questions on this matter to me at (404) 832-1150. Sincerely, James Urisko Director, Southern Region Pipeline and Hazardous Materials Safety Administration Enclosure: Notice of Proposed Safety Order Copy of 49 C.F.R. § 190.239 Cc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS Mr. Mark Piazza, Manager, Pipeline Compliance and R&D, Colonial Pipeline Company#

22021005NOPSO_Notice of Proposed Safety Order_03292021_(20-188854)_text.pdf, page 2DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY SOUTHERN REGION ATLANTA, GEORGIA ____________________________________ In the Matter of Colonial Pipeline Company, Respondent ) ) ) ) ) ____________________________________) CPF No. 2-2021-005-NOPSO NOTICE OF PROPOSED SAFETY ORDER Introduction and Purpose This Notice of Proposed Safety Order (NOPSO or Notice) is being issued by the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), under the authority of 49 U.S.C. § 60117. Pursuant to § 60117, PHMSA initiated an investigation of the safety of Colonial Pipeline Company’s (Colonial or the company) Pipeline System following a gasoline release in Huntersville, North Carolina on August 14, 2020 (Failure).1 PHMSA’s ongoing investigation indicates that conditions may exist on the Colonial Pipeline System that pose a pipeline integrity risk to public safety, property or the environment. The conditions that led to the Failure potentially exist throughout the Colonial Pipeline System. Further, Colonial’s inability to effectively detect and respond to this release, as well as other past releases, has potentially exacerbated the impacts of this and numerous other failures over the operational history of Colonial’s entire system. After evaluating the preliminary findings of fact described below and considering the characteristics of the Colonial Pipeline System, as well as the failure history of that system, it appears that the continued operation of the Colonial Pipeline System without corrective measures would pose a pipeline integrity risk to public safety, property, or the environment. This NOPSO notifies Colonial of the preliminary findings of the investigation, and proposes that Colonial take measures to ensure that the public, property, and the environment are protected from the potential risk. 1 Colonial became aware of the release on August 14, 2020, however, the first day of the release is unknown.#

22021005NOPSO_Notice of Proposed Safety Order_03292021_(20-188854)_text.pdf, page 32 Background On August 14, 2020 at 18:20 ET, a Colonial employee was notified by a local resident of a possible leak in Colonial’s right-of-way (ROW), approximately 100 feet north (downstream) of Huntersville-Concord Road in Huntersville, North Carolina. Upon inspection, a Colonial employee confirmed a product release visible at the ground surface at 18:42 ET near Mile Marker 980 that was believed to be gasoline. The Colonial Control Center initiated a shutdown of its pipeline facilities in the area (Lines 1 and 2) at 18:43 ET. The lines were blocked by closing valves upstream of the release location at Colonial's Charlotte Delivery Facility and downstream of the release location at the Kannapolis Station. At 19:42 ET, Colonial notified the National Response Center (NRC) of the release (NRC Report No. 1284598). Colonial reported the estimated release amount was 75 barrels. Colonial also notified the Charlotte-Mecklenburg Emergency Management Office, the U.S. Environmental Protection Agency, the North Carolina Department of Environmental Quality, and PHMSA. Colonial identified the leak source to be Line 1 on August 15, 2020 at approximately 12:00 ET. Following confirmation of the leak source, Colonial restarted Line 2 at 12:05 ET the same day. Colonial determined the leak originated from a Type A sleeve repair installed in 2004, originally intended to reinforce and protect a shallow dent identified by an integrity assessment. The leak was repaired on August 19, 2020, by installing a Type B pressure containing sleeve over the prior Type A sleeve repair. Colonial restarted Line 1 on August 19, 2020 at approximately 21:00 ET after repairs were completed. On September 13, 2020, Colonial submitted an initial accident report (PHMSA Form 7000.1) to PHMSA that updated the estimated release volume to 6,490 barrels of gasoline. On November 10, 2020, Colonial cut out the Type B sleeve and the failed section of pipe and sent them to an independent laboratory for metallurgical analysis. The cut-out and welding of the replacement pipeline tie-in was witnessed by PHMSA. On February 1, 2021, Colonial submitted a supplemental report to PHMSA updating the estimated release volume to 28,571 barrels (1.2 million gallons) of gasoline. Colonial has not provided any other reports to PHMSA regarding the estimated release volume due to the Failure. Upon identification and confirmation of the release and potential soil contamination, Colonial initiated monitoring and remediation efforts which are ongoing as of the issuance of this Notice. The preliminary findings of the PHMSA’s ongoing investigation are as follows: Preliminary Findings: • The Colonial Pipeline System consists of approximately 5,500 miles of hazardous liquid transmission pipeline within the United States, including lateral and spur lines, and fixed facilities (tanks, pump stations, etc.). The system traverses the states of Texas, Louisiana, Mississippi, Alabama, Georgia, North Carolina, South Carolina, Virginia, Maryland, Pennsylvania, New Jersey, and New York. Branches from the main lines also extend#

22021005NOPSO_Notice of Proposed Safety Order_03292021_(20-188854)_text.pdf, page 43 into Tennessee. The system delivers an average of approximately 100 million gallons of liquid petroleum products throughout the southern and eastern United States per day. • Colonial’s Line 1 Pipeline is an interstate pipeline, traversing eight states, beginning in Texas and ending in Virginia. The Line 1 portion of PHMSA inspection Unit NC-1 (Charlotte) is approximately 80 miles long, with three pump stations and as many as 25 breakout tanks. In North Carolina, Line 1 traverses five counties: Cabarrus, Cleveland, Gaston, Rowan, and Mecklenburg. • The Line 1 Pipeline is 40-inches in diameter with a 0.312-inch wall thickness, is API 5L X-60 grade, has a coal tar coating, a DSAW seam, and was manufactured in 1978 by Bethlehem Steel. It has an impressed current cathodic protection system. It transports refined products, including gasoline. The MOP is 673 psig. At the estimated time of failure, the operating pressure was 183 psig. • The Failure occurred on Line 1 in the Oehler Nature Preserve, near the intersection of Huntersville-Concord Road and Asbury Chapel Road, east of the Town of Huntersville, in Mecklenburg County, North Carolina. The Failure and resulting release was identified by local residents with access to Colonial’s ROW. • Colonial initially submitted an NRC Report (Incident Report 1284598, dated August 14, 2020) and reported an estimate of 75 barrels due to “equipment failure.” • Following confirmation of the release on August 14, 2020, Colonial submitted an initial accident report (PHMSA Form 7000.1) dated September 13, 2020, and reported an estimated release volume of 6,490 barrels. Colonial submitted a supplemental report on September 14, 2020, updating the total cost estimates with no change to estimated release volume. A second supplemental report was submitted on February 1, 2021, updating the estimated release volume to 28,571 barrels. Colonial has not provided any other reports to PHMSA regarding the estimated release volume due to the Failure. • The released gasoline penetrated the soil and affected the ground water in the area.2 Colonial installed 167 wells (81 monitoring wells, 50 recovery wells, 11 hydraulic control, and 25 air sparge system wells) between August 27, 2020 and December 23, 2020. • Preliminary findings confirmed the presence of the above-referenced Type A sleeve, the original anomaly (shallow dent), a through-wall crack that developed in the anomaly, and an electrolyte (water). Colonial’s metallurgical analysis was received by PHMSA on March 19, 2021. The analysis identifies the primary crack growth mechanism as corrosion fatigue. • PHMSA is aware that Colonial has made other repairs using Type A sleeves across the Colonial Pipeline System, and has implemented an ongoing Type A sleeve remediation 2 See https://sr2448.colonialresponse.com/.#

22021005NOPSO_Notice of Proposed Safety Order_03292021_(20-188854)_text.pdf, page 54 program intended to remove or replace existing Type A sleeves via an alternate repair method (i.e., Type B sleeve or pipe replacement). • The leak detection system used on the Colonial Pipeline System consists of a line-balance approach to track volumes transported, with regular reporting between field stations and Colonial’s control room in Alpharetta, Georgia. The process is predominantly manual, with a defined tolerance for any potential imbalance (i.e., discrepancy between stations). Colonial employs computational pipeline monitoring (CPM) on portions of the system, but not on Line 1. • On September 21, 2015, a reportable accident occurred on Colonial's Line 4 hazardous liquid pipeline in Centreville, Virginia, resulting in the release of approximately 95 barrels (4,000 gallons) of gasoline. Colonial was notified by the Fairfax County Fire Marshall of a sheen on a retention pond along Colonial’s Line 4 ROW. Line 4 is a continuation of Colonial’s Line 1. The accident occurred on a 288-mile section of Line 4 that runs between the company's Greensboro Tank Farm in Greensboro, North Carolina, and the Dorsey Tank Farm in Woodbine, Maryland. Colonial operates a parallel pipeline, Line 3, that runs approximately 30 feet apart from Line 4 at the site of the Centreville accident. The cause of the leak was determined to be a crack that formed in a shallow dent on the bottom side of the pipe. • In February 2016, Colonial experienced a failure in Gwinnett County, Georgia at Harbins Road. The release was discovered by a third-party contractor and reported to Colonial personnel. According to Colonial documentation and reporting, the failure mode was “fatigue cracks within an area where a dent was present with significant corrosion (up to 35%) under a Type A sleeve with shrink sleeves on the end that was installed in 2005.” The final volume of release was reported to be 13.71 barrels. • On September 9, 2016, Colonial experienced a failure on its Line 1 outside of Pelham, Alabama. Colonial was made aware of the suspected release by local governmental personnel. The initial estimate of the release volume was 23.8 barrels (1,000 gallons) of refined product (gasoline). According to the final accident report, dated May 6, 2019, Colonial reported an estimated volume released of 7,370 barrels (309,540 gallons). Following a prolonged response and recovery effort, the failure mechanism was determined to be a crack in a buckle that formed due to inadequate compaction following a prior repair project.3 Proposed Issuance of Safety Order Section 60117(m) of Title 49, United States Code, provides for the issuance of a safety order, after reasonable notice and the opportunity for a hearing, requiring corrective measures, which may include physical inspection, testing, repair, or other action, as appropriate. The basis for making the determination that a pipeline facility has a condition or conditions that pose a pipeline integrity 3 The failure site was the subject of an earlier recoat project by Colonial. Per Colonial’s Root Cause Failure Analysis, inadequate compaction of the backfill material contributed to movement of the pipe due to soil consolidation post-repair.#

22021005NOPSO_Notice of Proposed Safety Order_03292021_(20-188854)_text.pdf, page 65 risk to public safety, property, or the environment is set forth both in the above-referenced statute and 49 C.F.R. § 190.239, a copy of which is enclosed. After evaluating the foregoing preliminary findings of fact and considering the age of the pipe involved, the manufacturer, the hazardous nature of the product transported and the pressure required for transporting such product, the characteristics of the geographical areas where the pipeline facility is located, and the failure history of the pipeline system, including causes of those failures, it appears that the continued operation of the Colonial Pipeline System without corrective measures would pose a pipeline integrity risk to public safety, property, or the environment. The conditions described above and threats at locations of prior similar repairs potentially exist throughout the Colonial Pipeline System. Further, Colonial’s inability to effectively detect and respond to such releases has potentially exacerbated the impacts of numerous releases over the operational history of Colonial’s entire pipeline system. Accordingly, corrective measures are necessary to mitigate the pipeline integrity risk of the pipeline system to protect public safety, property, and the environment. Accordingly, PHMSA issues this Notice of Proposed Safety Order to notify Respondent of the proposed issuance of a safety order and to propose that Respondent take measures specified herein to address the potential risk. Proposed Corrective Measures Pursuant to 49 U.S.C. § 60117(m) and 49 C.F.R. § 190.239, PHMSA proposes to issue to Colonial a safety order incorporating the following remedial requirements with respect to the affected pipeline. For the purposes of this Notice, “Director” means the Director, PHMSA, Office of Pipeline Safety, Southern Region. 1. Within 90 days after the Safety Order is issued, develop and submit to the Director for approval, a written remedial work plan (Work Plan or Plan) that includes corrective measures. The Plan must include provisions to: a. Evaluate the effectiveness and capability of Colonial’s leak detection system on the entirety of the Colonial Pipeline System, including main lines, spurs, and laterals. At a minimum, Colonial’s evaluation must consider the following factors—length and size of the pipeline, type of product carried, the swiftness of leak detection, limitations on detectable quantities, location of nearest response personnel, and leak history. This evaluation must also consider MOP, normal operating pressures, flow rates (or throughput), and impacts from any pressure cycles or operational changes. For mainline segments that could affect high consequence areas (HCAs), Colonial’s evaluation must consider the pipeline’s proximity to the HCA and risk assessment results. b. Based on the findings of the evaluation pursuant to Item 1.a., determine corrective actions to improve the effectiveness of Colonial’s leak detection system. The corrective actions must result in the capability of the leak detection system to detect#

22021005NOPSO_Notice of Proposed Safety Order_03292021_(20-188854)_text.pdf, page 76 2. 3. 4. leaks that pose a pipeline integrity risk to public safety, property, or the environment, similar to (but not limited to) leaks with characteristics common to those referenced above. c. Evaluate Colonial’s written plans and procedures for inspection and maintenance and determine the extent to which the written plans contribute to the elimination of hazardous leaks. Based on the findings, determine appropriate amendments to improve the extent to which the plans contribute to the elimination of hazardous leaks. d. Evaluate the effectiveness of Colonial’s ROW inspection program. This evaluation must consider any geographic regions or features (i.e., HCAs and other sensitive areas) that may require specific or additional means of patrol. Based on the findings, determine corrective actions to improve the effectiveness of Colonial’s ROW inspection program. e. Provide to the Director a complete inventory of all Type A sleeve repairs made on the Colonial Pipeline System. For each identified Type A sleeve, the inventory must include, at a minimum, the installation date a summary of the basis for the original application (i.e., remediated condition), and confirmation of any scheduled removal/replacement. f. Establish a program and requirements for classifying all future repairs as temporary or permanent. The Plan must establish timeframes for the removal of any repair identified as “temporary,” or the permanent remediation of the condition requiring repair. Items 1.a. through 1.d. must be facilitated by an independent third-party approved by the Director. All submittals required by Item 1 that include decisions and determinations must also describe the options and factors considered, including those removed from consideration. The Plan must include a proposed timeline for completion of the actions required by Item 1 above. 5. The Director may approve Plan elements incrementally. Once approved, the Plan shall become incorporated into the Safety Order. 6. Submit to the Director all written procedures, new or amended, that will be used to complete the requirements of the Safety Order. 7. Revise the Plan as necessary to incorporate new information obtained during the evaluations and associated remedial activities. Submit any such Plan revisions to the Director for prior approval. 8. Implement the Plan as it is approved by the Director, including any revisions to the Plan. Results of actions taken in accordance with the approved Plan must be available for review by PHMSA or its representative. 9. Submit quarterly reports to the Director that: (1) include available data and results of the testing and evaluations required by the Safety Order; and (2) describe the progress#

22021005NOPSO_Notice of Proposed Safety Order_03292021_(20-188854)_text.pdf, page 87 of the repairs and other remedial actions being undertaken. The first quarterly report shall be due 90 days from the date of the Safety Order. 10. A final summary report of work performed on the above items must be submitted to the Director within 30 days of the completion of the last action performed by Colonial that is set forth in the Safety Order. 11. The Director may grant an extension of time for compliance with any of the terms of the Safety Order upon a written request timely submitted demonstrating good cause for an extension. 12. Colonial may appeal any decision of the Director to the Associate Administrator for Pipeline Safety. Decisions of the Associate Administrator shall be final. 13. It is requested that Colonial maintain documentation of the safety improvement costs associated with fulfilling this Safety Order and submit the total to the Director, Southern Region, Pipeline and Hazardous Materials Safety Administration. It is requested that these costs be reported in two categories: 1) total cost associated with preparation/revision of plans, procedures, studies and analyses, and 2) total cost associated with replacements, additions and other changes to pipeline infrastructure. The actions proposed by this Notice of Proposed Safety Order are in addition to and do not waive any requirements that apply to Respondent’s pipeline system under 49 C.F.R. Parts 190 through 199, 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. After receiving and analyzing additional data in the course of this proceeding and implementation of the Work Plan, PHMSA may identify other safety measures that need to be taken. In that event, Respondent will be notified of any proposed additional measures and, if necessary, amendments to the Work Plan or Safety Order. Response to this Notice In accordance with § 190.239, you have 30 days following receipt of this Notice to submit a written response to the official who issued the Notice. If you do not respond within 30 days, this constitutes a waiver of your right to contest this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue a Safety Order. In your response, you may notify that official that you intend to comply with the terms of the Notice as proposed, or you may request that an informal consultation be scheduled (you will also have the opportunity to request an administrative hearing before a safety order is issued). Informal consultation provides you with the opportunity to explain the circumstances associated with the risk condition(s) alleged in the notice and, as appropriate, to present a proposal for a work plan or other remedial measures, without prejudice to your position in any subsequent hearing. If you and PHMSA agree within 30 days of informal consultation on a plan and schedule for you to address each identified risk condition, we may enter into a written consent agreement (PHMSA would then issue an administrative consent order incorporating the terms of the#

22021005NOPSO_Notice of Proposed Safety Order_03292021_(20-188854)_text.pdf, page 98 agreement). If a consent agreement is not reached, or if you have elected not to request informal consultation, you may request an administrative hearing in writing within 30 days following receipt of the Notice or within 10 days following the conclusion of an informal consultation that did not result in a consent agreement, as applicable. Following a hearing, if the Associate Administrator finds the facility to have a condition that poses a pipeline integrity risk to the public, property, or the environment in accordance with § 190.239, the Associate Administrator may issue a safety order 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). In your correspondence on this matter, please refer to CPF No. 2-2021-005-NOPSO and for each document you submit, please provide a copy in electronic format whenever possible. ___________________________________ March 29, 2021 James Urisko Date issued Director, Southern Region Pipeline and Hazardous Materials Safety Administration#