COLONIAL PIPELINE CO — Warning Letter

420155021W_Warning_10142015_text.pdf, page 1Official PDFWARNING LETTER CERTIFIED MAIL - RETURN RECEIPT REQUESTED October 14, 2015 Mr. Tim Felt President & Chief Executive Officer Colonial Pipeline Company 1185 Sanctuary Parkway, Suite 100 Alpharetta, GA 30009 CPF 4-2015-5021W Dear Mr. Felt: On January 30, 2015 Colonial Pipeline Company (Colonial) experienced an unintended release of gasoline at the Baton Rouge Junction facility in Jackson, LA. While the event did not meet the requirements for reporting to the National Response Center, it was required to be reported under Title 49 CFR 195.54. A representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant Chapter 601 of 49 United States Code investigated the incident. As a result of the investigation, it appears that you have committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and the probable violation is noted below:#

420155021W_Warning_10142015_text.pdf, page 21. §195.505 Qualification Program. Each operator shall have and follow a written qualification program. The program shall include provisions to: (b) Ensure through evaluation that individuals performing covered tasks are qualified; Colonial did not follow their written Operator Qualification program in ensuring all individuals who perform work on their pipeline facilities be qualified through the program. During the investigation that followed the accident, Colonial identified product flowed from a prover into the sump due to a vent valve left in the open position. The individual performing the line fill activities was found not to be qualified under the Colonial Operator Qualification Program to manually operate valves. Qualification records submitted to PHMSA shows this individual was later evaluated under task Colonial’s OQ Program to Task 043-0 Manually or remotely open or close valves or other equipment. Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a related series of violations. For violations occurring prior to January 4, 2012, the maximum penalty may not exceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a related series of violations. 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 identified in this letter. Failure to do so will result in Colonial 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 4-2015-5021W. 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, R. M. Seeley Director, Southwest Region Pipeline and Hazardous Materials Safety Administration 2#