COLONIAL PIPELINE CO — Warning Letter

party submissionOfficial PDF32022027WL_Operator Response to Notice_06272022_(20-173062).pdf#

32022027WL_Warning Letter_05272022_(20-173062)_text.pdf, page 1Official PDFWARNING LETTER VIA ELECTRONIC MAIL TO: jblount@colpipe.com & QFrazier@colpipe.com May 27, 2022 Joseph A. Blount President & CEO Colonial Pipeline Company 1185 Sanctuary Parkway, Suite 100 Alpharetta, GA 30009 CPF 3-2022-027-WL Dear Mr. Blount: On January 27 – November 12, 2020 , a representative of the Pipeline and Hazardous Materials Safety Administration (PHM- SA) pursuant to Chapter 601 of 49 United States Code inspected Colonial Pipeline Company’s (Colonial’s) procedures and records for Control Room Management (CRM) in Linden, NJ, Hebert, LA, Greensboro, NC, and Alpharetta, GA. This Notice is in response to PHMSA’s Control Room Management (CRM) Initiative, which is a national level program that includes inspectors from every region. As a result, you may have received this Notice from a different Regional Director than typical because the CRM Initiative inspections are currently separate from the standard inspection program. Notices and correspondence from other types of inspections will remain unchanged. As a result of the inspection, it is alleged that you have committed probable violation(s) of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected and the probable violations are:#

32022027WL_Warning Letter_05272022_(20-173062)_text.pdf, page 21. §195.446 Control room management. (a)This section applies to each operator of a pipeline facility with a controller working in a control room who monitors and controls all or part of a pipeline facility through a SCADA system. Each operator must have and follow written control room management procedures that implement the requirements of this section The procedures required by this section must be integrated, as appropriate with the operator’s written procedures required by §195.402. An operator must develop the procedures no later than August 1,1011, and must implement the procedures according to the following schedule. The procedures required by paragraphs (b), (c)(5), (d)(2) an (d)(3), (f) and (g) of this section must be implemented no later than October 1, 2011. The procedures required by paragraphs (c)(1) through (4), (d)(1), (d)(4) and € must be implemented no later than August 1, 20212. The training procures required by paragraph (h) must be implemented no later than August 1, 2012, except that any training required by another paragraph of this section must be implemented no later than the deadline for that paragraph. Colonial failed to follow their procedure ADM-CPC-006 by not completing shift turnover documentation between the morning and afternoon shift for the Greensboro Local Console for the years 2017, 2018 and 2019. This procedure supported compliance with §195.446(b)(4) and §195.446(c)(5). This console operated two 8 hour shifts from 6:00 am - 2:00 pm and 2:00pm - 10:00 pm Monday - Friday (afternoon shift times vary depending upon scheduled batch products). Personnel completed a shift change, with conversation and documentation around 2:00 pm. There is no documentation at the end of the afternoon shift for the afternoon controller pass along, without conversation, to share with the next morning controller nor on Friday afternoon for the Monday morning controller. The CRM Plan and Administrative Procedure ADM-CPC-006 requires controller to complete a shift turnover document. 2. §195.446 Control room management. (a)… (j) An operator must maintain for review during inspection: (1) Records that demonstrate compliance with the requirements of this section; Colonial did not provide records to demonstrate compliance with §195.446(h) documenting the review of the field controller training program for 2017, 2018, 2019. Colonial had separate training paths; one was for the Alpharetta Main Control Room, managed by Control Room staff and the other was for field personnel (includes field controllers), managed by HR Training. Alpharetta Main control room and field control rooms shared the same CRM plan. Accountability and responsibility for the training programs and content fell under separate organizations of which both must adhere to to §195.446 for any control room 2#

32022027WL_Warning Letter_05272022_(20-173062)_text.pdf, page 3operating under the CRM Rule related CRM Plan and procedures. The annual review of the training program content only covered the Alpharetta control room with the exception of the annual CRM Training for both Alpharetta and field controllers. While the HR Training group indicated they performed continuous training review, they were not able to provide documentation to demonstrate compliance. Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to 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. For violation occurring on or after November 2, 2015 and before November 27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum penalty not to exceed $2,090,022 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 correct the item(s) identified in this letter. Failure to do so will result in Colonial Pipeline Company being subject to additional enforcement action. No reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF 3-2022-028-WL. 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). Sincerely, Gregory A. Ochs Director, Central Region, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration cc: Quintin Frazier, Director, Pipeline Compliance QFrazier@colpipe.com 3#