{"operation":"document","citation":"CPF 420075039W","title":"COLONIAL PIPELINE CO — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2007-10-12","effective_on":null,"summary":"CLOSED warning letter citing 195.452(h)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420075039w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420075039w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420075039w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420075039W","body":"Warning Letter involving COLONIAL PIPELINE CO. PHMSA's enforcement data identifies the cited regulation as 195.452(h)(2). The case was opened on 2007-10-12 and is reported as closed as of 2007-10-12. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420075039W_Warning Letter_10122007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420075039W/420075039W_Warning%20Letter_10122007.pdf\n\n420075039W_Warning Letter_10122007.pdf\n\nU.S. Department of Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n8701 South Gessner, Suite 1110\nHouston, TX 77074\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 12, 2007\nMr. Norm Szydlowski\nPresident and Chief Executive Officer\nColonial Pipeline Company\n1185 Sanctuary Parkway, Suite 100\nAlpharetta, GA 30009-4738\nCPF 4-2007-5039W\nDear Mr. Szydlowski:\nDuring the weeks of June 4th\n, 2007 and June 18th\n, 2007, representatives of the Pipeline and\nHazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United\nStates Code inspected Colonial Pipeline Company (Colonial) procedures for the Hazardous\nLiquid Pipeline Integrity Management Program (IMP) in Alpharetta, Georgia.\nAs a result of the inspection, it appears that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and\nthe probable violation is:\n1. §195.452 Pipeline integrity management in high consequence areas\n(h) What actions must an operator take to address integrity issues?\n(2) Discovery of condition. Discovery of a condition occurs when an operator\nhas adequate information about the condition to determine that the\ncondition presents a potential threat to the integrity of the pipeline. An\noperator must promptly, but no later than 180 days after an integrity\nassessment, obtain sufficient information about a condition to make that\ndetermination, unless the operator can demonstrate that the 180-day\nperiod is impracticable.\n\n\n\nFour baseline caliper-deformation in-line inspection (Ill) integrity assessments were\nreviewed that did not meet timeline requirements for discovery of a condition (Line 1\nAtlanta to Greensboro, Line 4 Greensboro to Louisa, Line 4 Louisa to Dorsey, and Line 3\nGreensboro to Dorsey). These assessments were completed well before the associated\nmetal-loss Ill. However, the dates of discovery for the caliper-deformation integrity\nassessments were based on the completion of the later metal-loss inline inspection.\nDiscovery for the conditions from the caliper-deformation integrity assessments took\n283, 288, 363 and 559 days, respectively, which is significantly longer than the required\n180 days. At the time these probable violations took place (2003 and 2004) Colonial's\nprocedures did not prevent them from not considering the 180 day time limit for each\nindividual III tool run rather than for each suite of tools. Therefore, Colonial's\nprocedures were inadequate. Colonial has since amended their procedures by adding a\nsection detailing a process that, in the event that a series of ILl tool runs is used, the 180\nday discovery period for each individual tool run is triggered based on when that specific\ntool reaches the receiver unless the specific condition being analyzed requires the data\nfrom more than one tool.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violation persists up to a maximum of $1,000,000\nfor any related series of violations. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement action\nor penalty assessment proceedings at this time. We advise you to correct the item(s) identified\nin this letter. Failure to do so will result in Colonial being subject to additional enforcement\naction.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2007-S039W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous\nMaterials Safety Administration\n2","truncated":false,"body_characters":4687}