{"operation":"document","citation":"CPF 22024010NOA","title":"COLONIAL PIPELINE CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-07-15","effective_on":null,"summary":"CLOSED notice of amendment citing 195.452(f)(5), 195.505(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-22024010noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-22024010noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-22024010noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/22024010NOA","body":"Notice of Amendment involving COLONIAL PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 195.452(f)(5),  195.505(b). The case was opened on 2024-07-15 and is reported as closed as of 2025-06-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n22024010NOA_Closure Letter_06022025_(22-235530).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024010NOA/22024010NOA_Closure%20Letter_06022025_(22-235530).pdf\n\n22024010NOA_Closure Letter_06022025_(22-235530)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024010NOA/22024010NOA_Closure%20Letter_06022025_(22-235530)_text.pdf\n\n22024010NOA_Notice of Amendment_07152024_(22-235530).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024010NOA/22024010NOA_Notice%20of%20Amendment_07152024_(22-235530).pdf\n\n22024010NOA_Notice of Amendment_07152024_(22-235530)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024010NOA/22024010NOA_Notice%20of%20Amendment_07152024_(22-235530)_text.pdf\n\n22024010NOA_Closure Letter_06022025_(22-235530)_text.pdf\n\nVIA ELECTRONIC MAIL TO: mlittle@colpipe.com; qfrazier@colpipe.com;\ndlangley@colpipe.com\nJune 2, 2025\nMs. Melanie Little\nPresident, Chief Executive Officer\nColonial Pipeline Company\nP.O. Box 1624\nAlpharetta, GA 30009-9934\nRE: CPF 2-2024-010-NOA\nDear Ms. Little:\nOn February 14, 2022, to February 17, 2022, a representative from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,\nconducted an on-site pipeline safety inspection of Colonial Pipeline Company’s procedures,\nrecords, and facilities in New Jersey, Maryland, Texas, Georgia, Louisiana, North Carolina,\nTennessee, South Carolina, Mississippi, Alabama, and New York. On July 15, 2024, pursuant to\n49 CFR § 190.206, PHMSA issued a Notice of Amendment which proposed amendment of\nColonial Pipeline Company’s procedures.\nColonial Pipeline Company submitted its amended procedures on May 20, 2025. PHMSA has\nreviewed the amended procedures, and it appears that the inadequacies outlined in the Notice of\nAmendment have been corrected.\nThis letter is to inform you that no further action is necessary, and this case is now closed.\nThank you for your cooperation.\nSincerely,\nJames A. Urisko\nDirector, Southern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\n\n22024010NOA_Notice of Amendment_07152024_(22-235530)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: mlittle@colpipe.com; qfrazier@colpipe.com;\ndlangley@colpipe.com\nJuly 15, 2024\nMs. Melanie Little\nPresident, Chief Executive Officer\nColonial Pipeline Company\nP.O. Box 1624\nAlpharetta, GA 30009-9934\nCPF 2-2024-010-NOA\nDear Ms. Little:\nFrom February 14, 2022, to February 17, 2023, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code\n(U.S.C.), inspected Colonial Pipeline Company’s (Colonial) procedures, records, and facilities in\nNew Jersey, Maryland, Texas, Georgia, Louisiana, North Carolina, Tennessee, Mississippi,\nSouth Carolina, Alabama, and New York.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within\nColonial’s plans or procedures. The items inspected and the inadequacies are described below:\n1. §195.452 Pipeline integrity management in high consequence areas\n(a) ….\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must continually\nchange the program to reflect operating experience, conclusions drawn from results of\nthe integrity assessments, and other maintenance and surveillance data, and evaluation\nof consequences of a failure on the high consequence area. An operator must include, at\nminimum, each of the following elements in its written integrity management program:\n(1) ….\n(5) A continual process of assessment and evaluation to maintain a pipeline's integrity\n(see paragraph (j) of this section)….\n\n\n\n2. Colonial failed to meet 49 C.F.R. §195.452(f)(5) because it did not include in its written\nintegrity management program a sufficient process of assessment and evaluation to maintain\na pipeline’s integrity using In-Line Inspection (ILI) assessments, pursuant to §§\n195.452(j)(5)(i) and 195.591. Specifically, Colonial did not specify which ILI tool analyst\nqualification levels, as described in ANSI/ANST ILI-PQ-2005, are required to analyze the\nILI data.\n49 C.F.R. § 195.591 specifically requires that “When conducting in-line inspection of\npipelines required by this part, each operator must comply with the requirements and\nrecommendations of API Std 1163, Inline Inspection Systems Qualification Standard…” API\nStandard 1163, Second Edition, April 2013 (API 1163), Annex C, Section C.1.13 states, “In\naddition, the operator should also discuss analyst’s qualifications (Level 1, Level 2, or Level\n3) for whom should perform the analysis.” API 1163 references ANSI/ANST ILI-PQ-2005 in\nsection 2.\nColonial’s Integrity Management Program, Appendix L, titled ILI Technical Specification,\nlast revised in 2018, prescribed the responsibilities of Colonial and in-line inspection vendors\nwhen conducting in-line inspection surveys of Colonial’s pipelines. Section 5 of this\ndocument, titled “Personnel and Equipment Qualifications,” specified that “Personnel and\nequipment used to perform in-line inspections and analyze the results shall be qualified\naccording to ASNT ILI-PQ, In-line Inspection Personnel Qualification and Certification.”\nNo additional information was presented in this document that describes to which level those\npersonnel must be qualified. The ANSI/ANST ILI-PQ-2005 standard does not prescribe\nminimum qualification levels for acceptance by operators.\n§ 195.452 Pipeline integrity management in high consequence areas.\n(a) ….\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must continually\nchange the program to reflect operating experience, conclusions drawn from results of\nthe integrity assessments, and other maintenance and surveillance data, and evaluation\nof consequences of a failure on the high consequence area. An operator must include, at\nminimum, each of the following elements in its written integrity management program:\n(1) ….\n(5) A continual process of assessment and evaluation to maintain a pipeline's integrity\n(see paragraph (j) of this section);\nColonial failed to meet 49 C.F.R. § 195.452(f)(5) because its procedures did not establish a\ncontinual process of assessment and evaluation to maintain a pipeline’s integrity.\nSpecifically, Colonial’s procedures did not specify a means for how Colonial will \"otherwise\naccept\" an ILI tool run that did not meet the program's 100% of pipe wall inspection\nthreshold.\nAppendix L of Colonial’s Integrity Management Program, titled “ILI Technical\nSpecification,” last revised in 2018, prescribed the responsibilities of Colonial personnel and\nin-line inspection vendors in conducting in-line inspection surveys of Colonial’s pipelines.\nSection 9 of Appendix L, titled “Acceptance Criteria,” specified that “Unless otherwise\naccepted by the COMPANY [Colonial], the inspection survey shall be deemed acceptable\nonly when 100 percent of the pipe wall has been inspected and the data is sufficient to meet\n\n\n\nthe performance specification.” Colonial procedure(s) did not elaborate on what situations\nwould be otherwise acceptable.\n3. § 195.505 Qualification program.\nEach operator shall have and follow a written qualification program. The program\nshall include provisions to:\n(a) ….\n(b) Ensure through evaluation that individuals performing covered tasks are qualified;\nColonial failed to meet 49 C.F.R. § 195.505(b) because its procedures are not adequate to\nensure through evaluation that individuals performing covered tasks are qualified.\nColonial Procedure NOP-ROW-001, titled “Right-of-Way Procedure, Exposed Piping,”\ndated December 13, 2022, prescribed guidelines for response to unintentionally exposed\npipe. This procedure did not require that personnel who examine exposed portions of buried\npipelines are qualified to do so. This procedure also allowed personnel who are not qualified\nto conduct coating inspections to determine severity before the appropriate department\n(Corrosion Control) is notified of the exposure. Consequently, if an unqualified individual\ndetermines the coating is in “good” condition, no corrosion control measures are\nimplemented.\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\nEnforcement Proceedings.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. § 552(b), along with the complete original document you must provide a second copy of\nthe document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment\nunder 5 U.S.C. § 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under § 190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis Notice without further notice to you and to issue an Order Directing Amendment. If your\nplans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend\nyour plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not\ncontesting this Notice, we propose that you submit your amended procedures to my office within\n90 days of receipt of this Notice. This period may be extended by written request for good\ncause. Once the inadequacies identified herein have been addressed in your amended\nprocedures, this enforcement action will be closed.\nIt is requested that Colonial Pipeline Company maintain documentation of the safety\n\n\n\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to the Director, Southern Region, Pipeline and Hazardous\nMaterials Safety Administration. In correspondence concerning this matter, please refer to\nCPF 2-2024-010-NOA and, for each document you submit, please provide a copy in electronic\nformat whenever possible.\nSincerely,\nJames A. Urisko\nDirector, Southern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings","truncated":false,"body_characters":11109}