# COLONIAL PIPELINE CO — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 22024011NOPV
- **title:** COLONIAL PIPELINE CO — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** current
- **official:** true
- **published on:** 2024-06-18
- **effective on:** Not available
- **summary:** OPEN notice of probable violation citing 194.121(b)(6), 195.222(b), 195.402(a), 195.412(a), 195.414(a), 195.452(j)(5)(i), 195.571, 195.573(c).
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-22024011nopv.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-22024011nopv
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/22024011NOPV
**body:**

Notice of Probable Violation involving COLONIAL PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 194.121(b)(6),  195.222(b),  195.402(a),  195.412(a),  195.414(a),  195.452(j)(5)(i),  195.571,  195.573(c). The case was opened on 2024-06-18 and is reported as open. Proposed civil penalty: $52,800. Assessed civil penalty: $52,800. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

22024011NOPV_Final Order_08062025_(22-235530).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024011NOPV/22024011NOPV_Final%20Order_08062025_(22-235530).pdf

22024011NOPV_Final Order_08062025_(22-235530)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024011NOPV/22024011NOPV_Final%20Order_08062025_(22-235530)_text.pdf

22024011NOPV_Operators Response to Notice_08062024_(22-235530).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024011NOPV/22024011NOPV_Operators%20Response%20to%20Notice_08062024_(22-235530).pdf

22024011NOPV_PCP PCO (AMENDED)_07092024_(22-235530).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024011NOPV/22024011NOPV_PCP%20PCO%20(AMENDED)_07092024_(22-235530).pdf

22024011NOPV_PCP PCO (AMENDED)_07092024_(22-235530)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024011NOPV/22024011NOPV_PCP%20PCO%20(AMENDED)_07092024_(22-235530)_text.pdf

22024011NOPV_PCP PCO_06182024_(22-235530).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024011NOPV/22024011NOPV_PCP%20PCO_06182024_(22-235530).pdf

22024011NOPV_PCP PCO_06182024_(22-235530)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/22024011NOPV/22024011NOPV_PCP%20PCO_06182024_(22-235530)_text.pdf

22024011NOPV_Final Order_08062025_(22-235530)_text.pdf

August 6, 2025
VIA ELECTRONIC MAIL TO: MLittle@colpipe.com
Ms. Melanie Little
President, Chief Executive Officer
Colonial Pipeline Company
P.O. Box 1624
Alpharetta, GA 30009-9934
Re: CPF No. 2-2024-011-NOPV
Dear Ms. Little:
Enclosed please find the Final Order issued in the above-referenced case. It makes a finding of
violation and assesses a civil penalty of $52,800. PHMSA acknowledges receipt of payment of
the full penalty amount, by wire transfer, dated August 16, 2024. When the terms of the
compliance order are completed, as determined by the Director, Southern Region, this enforcement
action will be closed. Service of the Final Order by e-mail is effective upon the date of
transmission and acknowledgement of receipt as provided under 49 CFR § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Linda Daugherty
Acting Associate Administrator
for Pipeline Safety
Enclosure
cc: James Urisko, Director, Southern Region, Office of Pipeline Safety
Adam Wolfe, Vice President, Operations, Colonial Pipeline Company,
awolfe@colpipe.com



Quintin Frazier, Director, Pipeline Compliance, Colonial Pipeline Company,
qfrazier@colpipe.com
Denise Langley, Senior Compliance Specialist, Colonial Pipeline Company,
dlangley@colpipe.com
CONFIRMATION OF RECEIPT REQUESTED



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 Co., ) CPF No. 2-2024-011-NOPV
)
)
)
Respondent. )
____________________________________)
FINAL ORDER
From February 14, 2022 through February 17, 2023, pursuant to 49 U.S.C. § 60117,
representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office
of Pipeline Safety (OPS), conducted an on-site pipeline safety inspection of the facilities and
records of Colonial Pipeline Company (Colonial or Respondent) in New Jersey, Maryland, Texas,
Georgia, Louisiana, North Carolina, Tennessee, Mississippi, South Carolina, Alabama, and New
York.
As a result of the inspection, the Director, Southern Region, OPS (Director), issued to Respondent,
by letter dated June 18, 2024, a Notice of Probable Violation, Proposed Civil Penalty, and
Proposed Compliance Order. On July 9, 2024, the Director issued to Respondent an Amended
Notice of Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order (Notice)
which corrected certain discrepancies in the calculation of the proposed civil penalty. In
accordance with 49 C.F.R. § 190.207, the Notice proposed finding that Colonial had violated 49
C.F.R. § 195.571, proposed assessing a civil penalty of $52,800 for the alleged violation, and
proposed ordering Respondent to take certain measures to correct the alleged violation. The Notice
also included an additional seven warning items pursuant to 49 C.F.R. § 190.205, which warned
Respondent to correct the probable violations or face possible future enforcement action.
Colonial responded to the Notice by letter dated August 6, 2024 (Response). Colonial did not
contest the allegation of violation, offered additional information in response to the Notice, and
requested that one of the warning items be withdrawn. On August 16, 2024, Colonial paid the
proposed civil penalty of $52,800.



FINDING OF VIOLATION
In its Response, Colonial did not contest the allegation in the Notice that it violated 49 CFR Part
195, as follows:
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.571, which states:
§ 195.571 What criteria must I use to determine the adequacy of cathodic
protection?
Cathodic protection required by this subpart must comply with one or more
of the applicable criteria and other considerations for cathodic protection
contained paragraphs 6.2.2, 6.2.3, 6.2.4, 6.2.5 and 6.3 in NACE SP 0169
(incorporated by reference, see § 195.3).
The Notice alleged that Respondent violated 49 CFR § 195.571 by failing to demonstrate that it
complied with applicable criteria for cathodic protection. Specifically, the Notice alleged that
Colonial did not comply with the criteria and other considerations for cathodic protection as
required in Paragraph 6.2.2 of NACE SP 0169, incorporated by reference per § 195.3.
Respondent did not contest this allegation of violation.1 In its Response, Colonial provided
additional information about its cathodic protection testing procedures and asserted the violation
did not increase the risk of a release from external corrosion.
Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 CFR
§ 195.571 by failing to demonstrate that it complied with applicable criteria for cathodic
protection.
This finding of violation will be considered a prior offense in any subsequent enforcement action
taken against Respondent.
ASSESSMENT OF PENALTY
Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty exceeding
$200,000 per violation for each day of the violation, with a maximum administrative civil penalty
exceeding $2,000,000 for any related series of violations.2
In determining the amount of a civil penalty under 49 U.S.C. § 60122 and 49 C.F.R. § 190.225, I
must consider the following criteria: the nature, circumstances, and gravity of the violation,
including adverse impact on the environment; the degree of Respondent’s culpability; the history
of Respondent’s prior offenses; any effect that the penalty may have on its ability to continue doing
business; the good faith of Respondent in attempting to comply with the pipeline safety
1 Respondent stated that it “does not contest ANOPV Item Nos. 1-7, including the PCO and the civil penalty amount
associated with ANOPV Item No. 1.” Response at 1.
2 These amounts are adjusted annually for inflation. See 49 C.F.R. § 190.223 for adjusted amounts.



regulations; and self-disclosure or actions to correct a violation prior to discovery by PHMSA. In
addition, I may consider the economic benefit gained from the violation without any reduction
because of subsequent damages, and such other matters as justice may require. The Notice
proposed a total civil penalty of $52,800 for the violation cited above.
Item 1: The Notice proposed a civil penalty of $52,800 for Respondent’s violation of 49 CFR
§ 195.571, for failing to demonstrate that it complied with applicable criteria for cathodic
protection. Colonial neither contested the allegation nor presented any evidence or argument
justifying a reduction in or elimination of the proposed penalty. Accordingly, having reviewed the
record and considered the assessment criteria, I assess Respondent a civil penalty of $52,800 for
violation of 49 CFR § 195.571.
In summary, having reviewed the record and considered the assessment criteria for each of the
Items cited above, I assess Respondent a total civil penalty of $52,800, which was paid in full by
wire transfer on August 16, 2024.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Item 1 in the Notice for violation of 49
CFR § 195.571. Under 49 U.S.C. § 60118(a), each person who engages in the transportation of
hazardous liquids or who owns or operates a pipeline facility is required to comply with the
applicable safety standards established under chapter 601. Pursuant to the authority of 49 U.S.C.
§ 60118(b) and 49 CFR § 190.217, Respondent is ordered to take the following actions to ensure
compliance with the pipeline safety regulations applicable to its operations:
1. With respect to the violation of § 195.571 (Item 1):
a. Colonial must revise its written plans and procedures to incorporate the
criteria described in Paragraph 6.2.2 of the NACE SP 0169 standard.
Specifically, revised procedures must account for voltage drop in order to
demonstrate that Colonial has met the requirements of the -0.850V and/or
100mV criteria. Colonial must submit its revised written plans and
procedures to the Director, PHMSA’s Office of Pipeline Safety (OPS),
Southern Region (Director), within 30 days of receipt of the Final Order
for approval.
b. Colonial must apply its approved procedure and conduct pipe-to-soil
surveys at the Port Arthur Products Junction and the Herbert Pump
Station. The results of this survey must be submitted to the Director
within 60 days of receipt of the written plans and procedures approval.
c. If any deficiencies are noted during the survey described above, where the
criteria described in Paragraph 6.2.2 of the NACE SP 0169 standard
and/or Colonial’s approved procedures are not met, Colonial must submit
an Action Plan to correct the deficiencies for approval to the Director
within 90 days of receipt of the written plans and procedures approval.
The Action Plan must include a time-to-completion for any required
actions.
d. Colonial must submit the results of the Action Plan to the Director within



10 days of its completion in accordance with the approved time-to-
completion. The results of the Action Plan must include a post-action
pipe-to-soil survey of the deficient areas that demonstrate Colonial has
met the requirements of Paragraph 6.2.2 of the NACE SP 0169 standard
and/or Colonial’s approved procedures.
The Director may grant an extension of time to comply with any of the required items upon a
written request timely submitted by the Respondent and demonstrating good cause for an
extension.
PHMSA requests that Respondent maintain documentation of the safety improvement costs
associated with fulfilling this Compliance Order and submit the total to the Director. 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.
Failure to comply with this Order may result in the administrative assessment of civil penalties
exceeding $200,000, as adjusted for inflation (see 49 CFR § 190.223 for adjusted amounts), for
each violation for each day the violation continues or in referral to the Attorney General for
appropriate relief in a district court of the United States.
WARNING ITEMS
With respect to Items 2, 3, 4, 5, 6, 7, and 8, the Notice alleged probable violations of Part 195, but
identified them as warning items pursuant to § 190.205. The warnings were for:
49 C.F.R. § 195.222(b)(1) (Item 2) ─ Respondent’s alleged use of a welder to
perform a welding process when the welder did not engage in welding with that
process within the preceding 6 months;
49 C.F.R. § 194.121(b)(6) (Item 3) ─ Respondent’s alleged failure to
immediately modify its response plan to address a new or different operating
condition and submit the change to PHMSA within 30 days;
49 C.F.R. § 195.402(a) (Item 4) ─ Respondent’s alleged failure to follow its
manual of written procedures in conducting normal operations and maintenance
activities;
49 C.F.R. § 195.412(a) (Item 5) ─ Respondent’s alleged failure to inspect the
surface condition on or adjacent to each pipeline right-of-way using an
appropriate means of traversing the right-of-way;
49 C.F.R. § 195.573(c) (Item 6) ─ Respondent’s alleged failure to electrically
check for the proper performance of each rectifier at least six times each calendar
year, but with intervals not exceeding 2 ½ months;



49 C.F.R. § 195.452(j)(5)(i) (Item 7) ─ Respondent’s alleged failure to meet the
regulatory requirements for conducting an In-Line Inspection (ILI) as a means of
assessing the integrity of line pipe.
If OPS finds a violation of any of these items in a subsequent inspection, Respondent may be
subject to future enforcement action.
The Notice also included a warning item (Item 8) which alleged that Colonial violated 49 C.F.R.
§ 195.414(a) because it could not provide documentation to support that it had inspected all
potentially affected pipeline facilities to detect conditions that could adversely affect the safe
operation of that pipeline following an extreme weather event. In its Response, Colonial requested
withdrawal of Item 8, because, upon receiving the Post-Inspection Preliminary Findings Report, it
located inspection records associated with Hurricane Ian and provided those records to PHMSA.
In a recommendation for final action submitted pursuant to § 190.209(b)(7), the Director
recommended withdrawing the warning item. Accordingly, I hereby order that Item 8 be
withdrawn.
Under 49 C.F.R. § 190.243, Respondent may submit a Petition for Reconsideration of this Final
Order to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey
Avenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to the Office of
Chief Counsel, PHMSA, at the same address. The written petition must be received no later than
20 days after receipt of the Final Order by Respondent. Any petition submitted must contain a
statement of the issue(s) and meet all other requirements of 49 C.F.R. § 190.243. The filing of a
petition automatically stays the payment of any civil penalty assessed. The other terms of the
order, including corrective action, remain in effect unless the Associate Administrator, upon
request, grants a stay. The terms and conditions of this Final Order are effective upon service in
accordance with 49 C.F.R. § 190.5.
___________________________________ __________________________
Linda Daugherty Date Issued
Acting Associate Administrator
for Pipeline Safety

22024011NOPV_PCP PCO (AMENDED)_07092024_(22-235530)_text.pdf

AMENDED NOTICE OF PROBABLE VIOLATION
PROPOSED CIVIL PENALTY
and
PROPOSED COMPLIANCE ORDER
VIA ELECTRONIC MAIL TO: mlittle@colpipe.com; qfrazier@colpipe.com;
dlangley@colpipe.com
July 9, 2024
Ms. Melanie Little
President, Chief Executive Officer
Colonial Pipeline Company
P.O. Box 1624
Alpharetta, GA 30009-9934
CPF 2-2024-011-NOPV
Dear Ms. Little:
From February 14, 2022 to February 17, 2023, representatives of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter
601 of 49 United States Code (U.S.C.), inspected Colonial Pipeline Company’s (Colonial)
procedures, records, and facilities in New Jersey, Maryland, Texas, Georgia, Louisiana, North
Carolina, Tennessee, Mississippi, South Carolina, Alabama, and New York.
As a result of the inspection, it is alleged that Colonial committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). This amended Notice
replaces the Notice that was previously issued on June 18, 2024. The items inspected and the
probable violations are:
1. § 195.571 What criteria must I use to determine the adequacy of cathodic protection?



Cathodic protection required by this subpart must comply with one or more of the
applicable criteria and other considerations for cathodic protection contained
paragraphs 6.2.2, 6.2.3, 6.2.4, 6.2.5 and 6.3 in NACE SP 0169 (incorporated by
reference, see § 195.3).
Colonial failed to meet 49 C.F.R. § 195.571 because it did not demonstrate that it complied
with applicable criteria for cathodic protection. Specifically, Colonial did not comply with
the criteria and other considerations for cathodic protection as required in Paragraph 6.2.2 of
NACE SP 0169, incorporated by reference per § 195.3.
During PHMSA’s inspection, Colonial presented its 2019-2022 annual pipe-to-soil corrosion
control survey records for facilities near the Port Arthur Products Junction and Herbert Pump
Station. Section 6.2.2 of NACE SP 0169 prescribes the criteria by which adequate cathodic
protection of a metallic piping system can be demonstrated. Colonial accepts either
the -.850V or 100mV polarization criteria, as described in Section 6.2 of NACE SP 0169.
The referenced NACE standard requires, “[a] minimum of 100mV of cathodic polarization
between the structure surface and a stable reference electrode contacting the electrolyte”
when relying on the 100mV polarization criteria. This necessitates a native pipe-to-soil
reference measurement. No records presented to PHMSA included native a pipe-to-soil
measurement, thus failing to demonstrate adequate implementation of the 100mV
polarization criteria.
Furthermore, for use of the -.850V criteria, the referenced NACE standard requires that
“voltage drops other than those across the structure-to-electrolyte boundary must be
considered.” Per Colonial records, voltage drops other than those across the structure-to-
electrolyte boundary had only been considered and documented for the following:
• 105 of 1293 records at the Port Arthur Products Junction.
• 160 of 315 records at the Herbert Pump Station.
Colonial did not provide any explanation of how voltage drop in locations with no record
was considered when relying on the -.850V criteria.
2. § 195.222 Welders and welding operators: Qualification of welders and welding
operators.
(a) ….
(b) No welder or welding operator may weld with a welding process unless, within
the preceding 6 calendar months, the welder or welding operator has -
(1) Engaged in welding with that process; and
(2) Had one weld tested and found acceptable under section 9 or Appendix A of API
Std 1104 (incorporated by reference, see § 195.3).
Colonial failed to meet 49 C.F.R. § 195.222(b)(1) because it allowed a welder to perform a
welding process when the welder did not engage in welding with that process within the
preceding 6 months.
During PHMSA’s inspection, Colonial presented continuity log records for welders working
on the Project Kingfish Construction Project. PHMSA’s review of the referenced logs
revealed welds performed on September 30, 2013, November 21, 2013, and May 26, 2014,



3. with the same welder identified as having performed the September 2013 and May 2014
welds. Documentation of the November 2013 weld, however, did not identify the welder via
name or by any other means. Consequently, Colonial was unable to confirm that the same
welder completed all three referenced welds. The duration between the September 30, 2013,
and May 26, 2014, welds was 7 months and 26 days, exceeding the 6-calendar month
requirement. Colonial did provide documentation confirming that it had retested the welder
on that welding process.
§ 194.121 Response plan review and update procedures.
(a) ….
(b) If a new or different operating condition or information would substantially affect
the implementation of a response plan, the operator must immediately modify its
response plan to address such a change and, within 30 days of making such a change,
submit the change to PHMSA. Examples of changes in operating conditions that would
cause a significant change to an operator's response plan are:
(1) ….
(6) The qualified individual;
Colonial failed to meet 49 C.F.R. § 194.121(b)(6) because it did not immediately modify its
response plan to address a new or different operating condition and submit the change to
PHMSA within 30 days. Specifically, Colonial did not update its facility response plan with a
new qualified individual.
During the inspection, PHMSA personnel reviewed Colonial’s Southeast District Incident
Command Plan (ICP). Section 1.6.1 of the Southeast District ICP identified the Primary
Qualified Individual and Alternate Qualified Individual for each of Colonial’s District
Response Zones. At the time of PHMSA’s inspection, the 2022 Southeast District ICP, dated
May 5, 2022, listed the Northeast District’s Primary Qualified Individual as an employee no
longer with Colonial.
4. § 195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a manual
of written procedures for conducting normal operations and maintenance activities and
handling abnormal operations and emergencies. This manual shall be reviewed at
intervals not exceeding 15 months, but at least once each calendar year, and
appropriate changes made as necessary to ensure that the manual is effective. This
manual shall be prepared before initial operations of a pipeline system commence, and
appropriate parts shall be kept at locations where operations and maintenance
activities are conducted.
Colonial failed to meet 49 C.F.R. § 195.402(a) because it did not follow its manual of written
procedures in conducting normal operations and maintenance activities. Specifically,
Colonial did not perform a 10% partial valve operation for multiple valves as required by its
procedures.
Colonial procedure, titled “Maintenance Procedure – Main-Lateral Line Valve Inspection,”
dated May 23, 2021, prescribed actions to be taken when performing a valve inspection.
Section 1.1 of the referenced procedure requires “the valve to be operated by opening or



5. 6. closing the valve 10% of travel if the valve is to be closed or opened more than 10% of
travel.” At PHMSA’s request, Colonial personnel provided work orders documenting
maintenance of several valves required per § 195.420. Each work order included a data entry
line with the description “Travel Tested 10% (Yes, No).” On 94 valve inspections from 2019
to 2022, Colonial entered “N” in response to the travel testing, indicating that the travel test
had not been completed.
At the time of PHMSA’s inspection, Colonial personnel stated that they did not perform the
10% partial operation due to the valves in question being cycled for regular operational
purposes. Colonial personnel could not provide documentation that demonstrated when those
valves were operated for regular operational purposes.
§ 195.412 Inspection of rights-of-way and crossings under navigable waters.
(a) Each operator shall, at intervals not exceeding 3 weeks, but at least 26 times each
calendar year, inspect the surface conditions on or adjacent to each pipeline right-of-
way. Methods of inspection include walking, driving, flying or other appropriate means
of traversing the right-of-way.
Colonial failed to meet 49 C.F.R. § 195.412(a) because it did not inspect the surface
condition on or adjacent to each pipeline right-of-way using an appropriate means of
traversing the right-of-way.
During a field inspection near Crotwell Road, northwest of Leesburg, Georgia, PHMSA
personnel noticed a portion of the right-of-way that had tree canopy obstructing the
right-of-way from an aerial view. Colonial uses aerial patrol exclusively in this area.
Colonial personnel stated that they had been in contact with the landowner and the landowner
refused to remove the tree farm from the right-of-way. The obstructed aerial view of the
pipeline prevents the aerial patrol pilot from adequately observing potential dead vegetation
or leaking product during the required patrols.
§ 195.573 What must I do to monitor external corrosion control?
(a) ….
(c) Rectifiers and other devices. You must electrically check for proper performance
each device in the first column at the frequency stated in the second column:



7. Colonial failed to meet 49 C.F.R. § 195.573(c) because it did not electrically check for the
proper performance of each rectifier at least six times each calendar year, but with intervals
not exceeding 2 ½ months.
During its inspection, PHMSA reviewed records related to rectifier inspections in the
Nashville area. PHMSA’s review revealed that six of these rectifiers had been inspected with
intervals exceeding 2 ½ months. The rectifiers and dates are as follows:
• Rectifier 0504709: 03/01/2019 to 06/27/2019 - 119 days (3 months, 27 days)
• Rectifier 0504393: 03/01/2019 to 06/26/2019 - 118 days (3 months, 26 days)
• Rectifier 0504170: 01/04/2019 to 06/25/2019 - 173 days (5 months, 22 days)
• Rectifier 0505424: 03/01/2019 to 07/03/2019 - 125 days (4 months, 3 days)
• Rectifier 0603382: 05/13/2019 to 12/17/2019 - 219 days (7 months, 5 days)
• Rectifier 0603411: 01/24/2019 to 04/23/2019 - 90 days (3 months)
Colonial acknowledged that there were instances in 2019 where rectifiers were not
electrically checked for proper performance. Colonial stated that “personnel and system
inadequacies were identified during internal evaluations in 2020 and mitigative measures
were completed in 2021.”
§ 195.452 Pipeline integrity management in high consequence areas.
(a) ….
(j) What is a continual process of evaluation and assessment to maintain a pipeline's
integrity? -
(1) ….
(5) Assessment methods. An operator must assess the integrity of the line pipe by any
of the following methods. The methods an operator selects to assess low frequency
electric resistance welded pipe or lap welded pipe susceptible to longitudinal seam
failure must be capable of assessing seam integrity and of detecting corrosion and
deformation anomalies.
(i) In-Line Inspection tool or tools capable of detecting corrosion and deformation
anomalies, including dents, gouges, and grooves. For pipeline segments that are
susceptible to cracks (pipe body and weld seams), an operator must use an in-line
inspection tool or tools capable of detecting crack anomalies. When performing an
assessment using an In-Line Inspection tool, an operator must comply with §
195.591;
Colonial failed to meet 49 C.F.R. § 195.452(j)(5)(i) because it did not meet the regulatory
requirements for conducting an In-Line Inspection (ILI) as a means of assessing the integrity
of line pipe. Specifically, Colonial failed to ensure that ILI analysts had sufficient records
demonstrating compliance with the training recommendations of the ANSI/ASNT ILI-PQ
standard, as required by § 195.591.
On August 6, 2020, Colonial contracted an ILI vendor to complete an Ultrasonic Testing
(UT) wall thickness ILI run on Line 576-04 from Hartsfield West Junction to Airport in
Atlanta, Georgia. After completion of the run, two individuals at the vendor performed an
analysis of the data to determine if any anomalies were present in Line 576-04. The



8. individuals were listed as a Level II and Level III analyst, respectively. Records of their
education, experience, and training revealed the following deficiencies:
• Level II Analyst: At the time of the inspection, this individual had 141 hours of
training documented. The ANSI/ASNT ILI-PQ standard recommends a minimum of
160 training hours for a UT Compression Wave Level II analyst.
• Level III Analyst: At the time of the inspection, this individual had 496 hours of
training documented. The ANSI/ASNT ILI-PQ standard recommends a minimum of
500 training hours for a UT Compression Wave Level II analyst.
Furthermore, Colonial does not maintain the qualification records for ILI analysts. Colonial
relies on the ILI Vendor to maintain qualification records and will contact the vendor as
necessary to obtain the record. Operators are required to maintain records that demonstrate
compliance with Subpart F, pursuant to § 195.452(l).
§ 195.414 Inspections of pipelines in areas affected by extreme weather and natural
disasters.
(a) General. Following an extreme weather event or natural disaster that has
the likelihood of damage to infrastructure by the scouring or movement of the soil
surrounding the pipeline, such as a named tropical storm or hurricane; a flood that
exceeds the river, shoreline, or creek high-water banks in the area of the pipeline; a
landslide in the area of the pipeline; or an earthquake in the area of the pipeline, an
operator must inspect all potentially affected pipeline facilities to detect conditions that
could adversely affect the safe operation of that pipeline.
Colonial failed to meet 49 C.F.R. § 195.414(a) because it could not provide documentation to
support that it had inspected all potentially affected pipeline facilities to detect conditions
that could adversely affect the safe operation of that pipeline following an extreme weather
event.
When asked by PHMSA, Colonial personnel could not provide pre- or post-storm
documentation for Hurricane Ian. Hurricane Ian made landfall near Georgetown, South
Carolina, on September 30, 2022, as a Category 1 Hurricane. Colonial personnel stated that
ground and aerial patrols were conducted, but Colonial could not provide documentation for
those patrols.
Proposed Civil Penalty
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$266,015 per violation per day the violation persists, up to a maximum of $2,660,135 for a
related series of violations. For violation occurring on or after January 6, 2023, and before
December 28, 2023, the maximum penalty may not exceed $257,664 per violation per day the
violation persists, up to a maximum of $2,576,627 for a related series of violations. For violation
occurring on or after March 21, 2022, and before January 6, 2023, the maximum penalty may not
exceed $239,142 per violation per day the violation persists, up to a maximum of $2,391,412 for
a related series of violations. For violation occurring on or after May 3, 2021, and before March
21, 2022, the maximum penalty may not exceed $225,134 per violation per day the violation
persists, up to a maximum of $2,251,334 for a related series of violations. For violation



occurring on or after January 11, 2021, and before May 3, 2021, the maximum penalty may not
exceed $222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for
a related series of violations. For violation occurring on or after July 31, 2019, and before
January 11, 2021, the maximum penalty may not exceed $218,647 per violation per day the
violation persists, up to a maximum of $2,186,465 for a related series of violations. For violation
occurring on or after November 27, 2018, and before July 31, 2019, the maximum penalty may
not exceed $213,268 per violation per day, with a maximum penalty not to exceed $2,132,679.
We have reviewed the circumstances and supporting documentation involved for the above
probable violations and recommend that you be preliminarily assessed a civil penalty of $ 52,800
as follows:
Item number
PENALTY
1
$ 52,800
Warning Items
With respect to Items 2,3,4,5,6,7, and 8, we have reviewed the circumstances and supporting
documents involved in this case and have decided not to conduct additional enforcement action
or penalty assessment proceedings at this time. We advise you to promptly correct these items.
Failure to do so may result in additional enforcement action.
Proposed Compliance Order
With respect to Item 1 pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous Materials
Safety Administration proposes to issue a Compliance Order to Colonial Pipeline Company.
Please refer to the Proposed Compliance Order, which is enclosed and made a part of this
Notice.
Response to this Notice
This amended Notice is issued in accordance with 49 C.F.R. § 190.207(c). Any response you
may have submitted to the original Notice is no longer applicable. You must respond as set forth
below.
Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators
in Enforcement Proceedings. Please refer to this document and note the response options. All
material you submit in response to this enforcement action may be 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).
Following the receipt of this Notice, you have 30 days to submit written comments, or request a
hearing under 49 CFR § 190.211. If you do not respond within 30 days of receipt of this Notice,
this constitutes a waiver of your right to contest the allegations in 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 Final Order. If you are responding to this Notice, we propose that
you submit your correspondence to my office within 30 days from receipt of this Notice. This
period may be extended by written request for good cause.



In your correspondence on this matter, please refer to CPF 2-2024-011-NOPV and, for each
document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
James A. Urisko
Director, Southern Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
Enclosures: Proposed Compliance Order
Response Options for Pipeline Operators in Enforcement Proceedings



PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety
Administration (PHMSA) proposes to issue to Colonial Pipeline Company (Colonial) a
Compliance Order incorporating the following remedial requirements to ensure the compliance
of Colonial with the pipeline safety regulations:
A. In regard to Item 1 of the Notice pertaining to Colonial’s failure to demonstrate that it
met applicable criteria in Paragraph 6.2.2 of NACE SP 0169:
1. Colonial must revise its written plans and procedures to incorporate the criteria
described in Paragraph 6.2.2 of the NACE SP 0169 standard. Specifically, revised
procedures must account for voltage drop in order to demonstrate that Colonial has
met the requirements of the -0.850V and/or 100mV criteria. Colonial must submit its
revised written plans and procedures to the Director, PHMSA’s Office of Pipeline
Safety (OPS), Southern Region (Director), within 30 days of receipt of the Final
Order for approval.
2. Colonial must apply its approved procedure and conduct pipe-to-soil surveys at the
Port Arthur Products Junction and the Herbert Pump Station. The results of this
survey must be submitted to the Director within 60 days of receipt of the written
plans and procedures approval.
3. If any deficiencies are noted during the survey described above, where the criteria
described in Paragraph 6.2.2 of the NACE SP 0169 standard and/or Colonial’s
approved procedures are not met, Colonial must submit an Action Plan to correct the
deficiencies for approval to the Director within 90 days of receipt of the written plans
and procedures approval. The Action Plan must include a time-to-completion for any
required actions.
4. Colonial must submit the results of the Action Plan to the Director within 10 days of
its completion in accordance with the approved time-to-completion. The results of the
Action Plan must include a post-action pipe-to-soil survey of the deficient areas that
demonstrate Colonial has met the requirements of Paragraph 6.2.2 of the NACE SP
0169 standard and/or Colonial’s approved procedures.
B. It is requested that Colonial maintain documentation of the safety improvement cost
associated with fulfilling this Compliance Order and submit the total to the Director. 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.
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