{"operation":"document","citation":"PHMSA-2009-0390","title":"Colonial Pipeline Company — Pipeline Special Permit","source_type":"permit","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2019-11-25","effective_on":"2019-11-25","summary":"PHMSA-2009-0390, issued 2019-11-25 for Colonial Pipeline Company's hazardous liquid system.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2009-0390.json","markdown":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2009-0390.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2009-0390","source_url":"https://www.regulations.gov/docket/PHMSA-2009-0390","body":"PHMSA pipeline special permit PHMSA-2009-0390. Operator: Colonial Pipeline Company. System: Hazardous Liquid. Issue date: 2019-11-25.\n\n<<<PAGE 1>>>\n\nC\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nNOV 25\nMr. Joseph A. Blount, Jr.\nPresident & CEO\nColonial Pipeline Company\n1185 Sanctuary Parkway, Suite 100\nAlpharetta, GA 30009\nDocket No. PHMSA-2009-0390\nDear Mr. Blount:\nOn November 17, 2009, Colonial Pipeline Company (Colonial) applied to the Pipeline and\nHazardous Materials Safety Administration (PHMSA) for a special permit PHMSA-2009-0390,\nfor relief of pressure testing record keeping requirements. The special permit waives compliance\nwith 49 Code of Federal Regulations 195.3 10, for the two (2) pipeline special permit segments\ntotaling 74.684 miles of the 40-inch diameter Line 01 Pipeline.\nThe special permit segments are defined as 64.450 miles of the Line 01 Pipeline located in\nAcadia, St. Landry, Point Coupee, and West Feliciana Parishes, Louisiana (special permit\nsegment 1) and 10.234 miles of the Line 01 Pipeline located in Fulton, DeKaib, and Gwinnett\nCounties, Georgia (special permit segment 2).\nPHMSA grants this special permit (enclosed) based on a review of Colonial's application letter,\nsupporting attachments, and the required integrity inspections and documentation required by the\nspecial permit conditions. The special permit allows Colonial to continue to operate the Line 01\nPipeline at a maximum operating pressure of 574 pounds per square inch gauge sig) in special\npermit segment 1 and 743 psig in special permit segment 2. The special permit requires Colonial\nto comply with certain conditions designed to maintain pipeline safety.\nMy staff would be pleased to discuss this special permit or any other regulatory matter with\nColonial. Ms. Sentho White, Director of Engineering and Research Division, may be contacted\nat 202-366-2415, on matters specific to this special permit.\nSincerely,\nAssociate Administrator for Pipeline Safety\nEnclosure: Special Permit- PHMSA-2009-0390\n\n<<<PAGE 1>>>\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nSpecial Permit Analysis and Findings\nSpecial Permit Information:\nDocket Number: PHMSA- 2009-0390\nPipeline Operator: Colonial Pipeline Company\nOperator ID#: 2552\nDate Requested: November 17, 2009\nDate Granted: November 25, 2019\nCode Section(s): 49 CFR 195.310\nPurpose:\nThe Pipeline and Hazardous Materials Safety Administration (PHMSA) provides this\ninformation to describe the facts of the subject special permit application submitted by Colonial\nPipeline Company (Colonial), to discuss any relevant public comments received with respect to\nthe application, to present the engineering and safety analysis of the special permit application,\nand to make findings regarding whether the requested special permit should be granted and if so\nunder what conditions. Colonial requested that PHMSA waive compliance from 49 Code of\nFederal Regulations (CFR) 195.310 for two (2) special permit segments which includes 74.684\nmiles of 40-inch diameter hazardous liquid pipeline.\nSpecial Permit Request:\nOn November 17, 2009, Colonial applied to PHMSA for a special permit seeking relief from the\nFederal pipeline safety regulations in 49 CFR 195.310 for two (2) segments of the Colonial Line\n01 hazardous liquid pipeline system, where Colonial has failed to retain certain hydrostatic\npressure test records. The application for a special permit is to waive the requirement to have\nretained the pressure recording charts and certain other pressure test data. The two (2) hazardous\nliquid pipeline special permit segments of Colonial’s 40-inch diameter Line 01 were constructed\nand placed in operation between 1976 and 1978. Line 01 is an interstate pipeline that consists of\nDocket Number: PHMSA- 2009-0390 – Colonial Pipeline – Line 01 Pipeline Special Permit Analysis and Findings – Loss of Test Records\nPage 1 of 19\n\n<<<PAGE 2>>>\n\n1,049 miles of 40-inch and 36-inch diameter steel pipeline that primarily transports gasoline\nfrom refineries in Houston, Texas to Greensboro, North Carolina.\nSpecial Permit Segments:\n• Special permit segment 1 – 64.45 miles1 of 40-inch diameter Line 01 from Church Point\nStation to Baton Rouge Junction in Louisiana. 27.949 miles of the 64.45-mile special permit\nsegment 1 is a pipeline segment that could affect a high consequence area (HCA). Special\npermit segment 1 begins at Colonial Survey Station (SS) 4976+11 and ends at SS 5+32\n(equation involved) located in Acadia, St. Landry, Point Coupee, and West Feliciana\nParishes, Louisiana.\n Colonial states in the special permit application,\n“The MOP, established by\nhydrostatic test pressures for the pipeline segment is 574 pounds per square inch\n(psi).”\n Line 01 is comprised of 40-inch diameter API 5L X60, X52, and X42 grades steel\npipe with wall thicknesses ranging from 0.312 to 0.500 inches.\n• Special permit segment 2 - 10.234 miles2 of 40-inch Line 01 from the Chattahoochee River\nto the Georgia Highway 141 in Georgia. The entire 10.234-mile special permit segment 2 is\na pipeline segment that could affect an HCA. Special permit segment 2 begins at Colonial\nSS 951+65 and ends at SS 1492+76 located in Fulton, DeKalb, and Gwinnett Counties in\nGeorgia.\n Colonial states in the Final Environmental Assessment and Finding of No Significant\nImpact document, “The MOP, established by design test pressures, for this\npipeline segment is 743 psi.”\n Line 01 is comprised of 40-inch diameter API 5L X60 and X42 grade steel pipe\nwith wall thicknesses ranging from 0.344 to 0.500 inches.\n1 Colonial’s special permit application referenced 66.372 miles of Line 01 from Church Point Station to Baton\nRouge Junction in Louisiana. Colonial maintains hydrostatic pressure testing records for 1.922 miles of that\npipeline segment. For that reason, Colonial is no longer requesting a special permit for that mileage, but rather is\nrequesting a special permit for 64.45 miles of Line 01 from Church Point to Baton Rouge Junction in Louisiana.\n2 Within special permit segment 2, one (1) pipe replacement has been completed and Colonial maintains the\nassociated hydrostatic pressure tests records.\nDocket Number: PHMSA- 2009-0390 – Colonial Pipeline – Line 01 Pipeline Special Permit Analysis and Findings – Loss of Test Records\nPage 2 of 19\n\n<<<PAGE 3>>>\n\nColonial’s Integrity Findings:\nSpecial Permit Segment 1:\nSpecial permit segment 1 primarily runs through rural southwest Louisiana, with 27.949 miles\nlocated in an area that could affect an HCA in accordance with 49 CFR 195.450 – Definitions\nand 195.452 – Pipeline Integrity Management in High Consequence Areas.\nSince 1988, Colonial has assessed special permit segment 1 routinely using a variety of\ninline inspection (ILI) technologies. ILI inspections were performed on special permit\nsegment 1 in 1988, 1993, 1995, 2001, 2004, 2009, 2013 and 2015 using magnetic flux and\ndeformation tools and/or crack tools. These inspections revealed only one (1) immediate\nanomaly (in 2012) and no 60-day anomalies. All anomalies (including some 180-day and\nother anomalies) were timely remediated, in accordance with Colonial's integrity\nmanagement (IM) and maintenance procedures. Since 2010, Colonial has performed\nannual cathodic protection (CP) surveys of special permit segment 1 to identify\ndeficiencies in CP and confirm adequate corrosion protection. No deficiencies have been\nidentified, with the exception of certain readings in 2010 which were subsequently\nconfirmed to be invalid. In 2017, Colonial employed SmartBall leak detection technology\non special permit segment 1 and no acoustical anomalies were detected.\nSpecial permit segment 1 has had no manufacturing related leaks in its history. It has\nexperienced a total of five (5) leaks of which only one was on the pipeline, the remaining\nfour (4) were valve and equipment related. The pipeline leak was found to be located at a\nbuckle with a fatigue crack that survived the original hydrostatic testing.\nSpecial Permit Segment 2:\nSpecial permit segment 2 is in the high population area (HPA) of north metropolitan Atlanta,\nGeorgia. The total segment length of 10.234 miles is located such that it could affect an HCA in\naccordance with 49 CFR 195.450 – Definitions and 195.452 – Pipeline Integrity Management in\nHigh Consequence Areas.\nSince 1988, Colonial has assessed special permit segment 2 routinely using a variety of ILI\ntechnologies. Inspections were performed in 1988, 1993, 1998, 2003, 2008, 2012 and 2017\nusing magnetic flux and deformation tools and/or crack tools. ILI inspections revealed no\nDocket Number: PHMSA- 2009-0390 – Colonial Pipeline – Line 01 Pipeline Special Permit Analysis and Findings – Loss of Test Records\nPage 3 of 19\n\n<<<PAGE 4>>>\n\nimmediate anomalies and only four 60-day anomalies. All anomalies (including some 180-day\nand other anomalies) were timely remediated, in accordance with Colonial's IM and maintenance\nprocedures. Similar to special permit segment 1, Colonial has been performing annual CP\nsurveys of special permit segment 2 to identify deficiencies in CP and confirm adequate\ncorrosion protection since the mid-1990s. No deficiencies have been identified since 2012 and\nthose that were identified have since been addressed. In 2017, Colonial employed SmartBall\nleak detection technology on special permit segment 2 and no acoustical anomalies were\ndetected.\nSpecial permit segment 2 has had no manufacturing related leaks in its history. It has\nexperienced two (2) leaks from other causes: one (1) attributable to a buckle (caused by\nthird-party activities) with a fatigue crack that was not present during original hydrostatic\ntesting, and the other was related to a valve fitting.\nColonial’s Pressure Test Records:\nColonial has indicated to PHMSA that its historical hydrostatic pressure test records for the\nspecial permit segments 1 and 2 were kept in hard copy, consistent with industry practice in the\nlate 1970s. Certain pressure recording charts and calibration data from the original construction\nhydrostatic testing of the special permit segments, however, were inadvertently lost over time.\nUpon identifying this potential issue, Colonial stated that it undertook an intensive and\nexhaustive records review beginning in the 1990s. In 2008, Colonial discussed the pressure test\nrecords review results with PHMSA. Colonial followed those discussions with its special permit\napplication in November 2009. Since submitting the special permit application, Colonial has\ncontinued to have discussions with PHMSA on this issue.\nIn its special permit application Colonial states that, “The Maximum Operating Pressure (MOP)\nfor these line sections [special permit segment 1 and special permit segment 2] were originally\ndetermined based on successful pressure tests performed and documented in conformance with\nall requirements of 49 CFR Part 195, Subpart E – Pressure Testing.” While Colonial can no\nlonger locate the original pressure recording charts and associated data, they have presented\ndocumentation (in Colonial’s opinion) to support that the pressure tests were completed.\nMoreover, they have “… performed engineering and integrity reviews of these two-line segments\nDocket Number: PHMSA- 2009-0390 – Colonial Pipeline – Line 01 Pipeline Special Permit Analysis and Findings – Loss of Test Records\nPage 4 of 19\n\n<<<PAGE 5>>>\n\nto confirm that they can be safely operated at the current established MOP.” Colonial states the\n“[…] primary basis for this confirmation is that sufficient evidence has been found to prove that\nthe hydrostatic tests were conducted consistent with Subpart E of Part 195.” In essence, it is\nColonial’s position that this is a records retention issue only.\nPHMSA’s Findings in Reviewing Colonial’s Application, Documentation, and Past\nEnforcement History:\n• Colonial has known about their lack of test records and non-compliance with 49 CFR\n§195.310(b) since July 27, 1990, and has waited almost 19 years to rectify the situation\nthrough a special permit request to PHMSA.\n• Special permit segment 1 document dated May 24, 1977, written by Mr. J.L. Merchant,\nColonial’s Manager of Engineering, indicates that a test was conducted at 855 psi which\nwas below design pressure of 882 psi, and eventually used to establish maximum\noperating pressure (MOP). Colonial did not submit to PHMSA any documentation of a\nretest.3 The documentation submitted does not confirm that a test was conducted in 1976\nor a retest was conducted on the pipeline, and if a re-test was not conducted, why.4\n• Special permit segment 2 notarized statements by Mr. N. J. Edmonds, Colonials’\nManager of Operations Planning & Pipeline Control during the hydrostatic pressure\ntesting, and Mr. Sam Kelly, an employee of third-party contractor, Michael Curran &\nAssociates, who oversaw the hydrostatic testing, were provided in 1990 and 2008 to\nColonial. The notarized statements have conflicting test date intervals, whether there was\na rupture in the test section, and one of them would not even have been on the job site\nbased on their statements. The notarized statements of Mr. Kelly and Mr. Edmonds\nconflict with documentation submitted by Colonial indicating that the test began around\nJuly 22, 1978, with a failure on that day.\n3 Colonial states in the environmental assessment (EA) submitted to PHMSA in April 2018 –\n“The MOP,\nestablished by hydrostatic test pressures, for the pipeline segment is 574 psi. The upstream pump station\ndischarge control pressure setting is 570 psi with a high line shutdown at 600 psi.”\n4 In 2018, Colonial replied to PHMSA that the pipeline was apparently never retested and to maintain the overall\nline segment MOP below 684 psi (80% of 855 psi) the lowest MOP needed to be 574 psi (due to elevation\nchanges) establishing the Church Point Station discharge control pressure to be 570 psi.\nDocket Number: PHMSA- 2009-0390 – Colonial Pipeline – Line 01 Pipeline Special Permit Analysis and Findings – Loss of Test Records\nPage 5 of 19\n\n<<<PAGE 6>>>\n\n• Colonial did not submit any inspection logs showing pressures at the test site, pressure\ncharts, pressure logs, or temperature charts that indicate when tested, the test interval, and\nthe test pressure of a successful test on special permit segments 1 and 2.\nPHMSA Documentation Reviews:\nRepresentatives from Colonial met with the Director, PHMSA Southern Region, and PHMSA\nregional staff on several occasions in 2008 and 2009 to discuss and review Colonial’s records\nrelated to pressure tests on the applicable pipeline special permit segments. A summary of\ndocuments reviewed by PHMSA’s Southern Region staff, as referenced in Colonial’s application\nletter of November 17, 2009, is as follows:\nSpecial permit segment 1 – documents submitted by Colonial:\n1. Line 01 hydraulic gradient at current equipment settings for display with MOP for 40-\ninch diameter Line 01, Church Point to Baton Rouge with injection at Krotz Springs;\n2. Payment records for contractor performing the hydrostatic pressure test on 40-inch\ndiameter Line 01, Church Point to Baton Rouge;\n3. Memo dated May 24, 1977, identifying a hydrostatic test pressure of 855 psi from J. L.\nMerchant, Colonial Manager of Engineering at that time;\n4. Field notes labeled “Hydro Test 1976” from Hebert Station to Baton Rouge for Spreads\n1, 2, and 3;\n5. Line No. 01, dated February 15, 1980, from location Church Point Station to location\nFelixville Station, control engineer’s analysis of pipe data, maximum operating pressure,\nhydrostatic test information and critical elevation checks;\n6. Hydrostatic Test Records Team spread sheet listing of test sections with engineering\nstationing and minimum and maximum test pressures; and\n7. Summary of pressure tests performed upstream and downstream of Line 01, Church Point\nto Baton Rouge.\nDocket Number: PHMSA- 2009-0390 – Colonial Pipeline – Line 01 Pipeline Special Permit Analysis and Findings – Loss of Test Records\nPage 6 of 19\n\n<<<PAGE 7>>>\n\nSpecial permit segment 2 – documents submitted by Colonial:\n1. Line 01 hydraulic gradient at current equipment settings for display with MOP data for\n40-inch diameter, Line 01, Atlanta to Dacula;\n2. Payment records for contractor performing the hydrostatic test on 40-inch diameter, Line\n01, Spread 1A, Chattahoochee River to Georgia Highway 141;\n3. Spread 1A, Test Section 4 (Chattahoochee River to Georgia Highway 141), pressure test\nprocedure diagram and test design showing the test pressures, station numbers, and\nelevations;\n4. Detailed water management plan and drawings for the hydrostatic testing inclusive of\nwater chemistry analytical results;\n5. Testimonies from N. J. Edmonds, Colonial Manager of Operations Planning & Pipeline\nControl, and Sam A. Kelly, Supervisor for Michael Curran & Associates (hydrostatic\ntesting contractor), that the hydrostatic test was performed;\n6. Hydrostatic Test Records Team spreadsheet listing of test sections with engineering\nstationing and minimum and maximum test pressure; and\n7. Summary of pressure tests performed upstream and downstream of Spread 1A, Test\nSection 4 (Chattahoochee River to Georgia Highway 141).\nGeneral Information for both Special Permit Segments 1 and 2 – documents submitted by\nColonial:\n1. Construction specifications for each authorization for expenditure (AFE);\n2. Hydrostatic test records for the adjacent segments;\n3. IM Program (IMP) baseline and reassessments information along with inline inspection\n(ILI) data prior to the IMP Rule;\n4. Pipeline inspection records documenting appropriate repairs for all discovered defects;\n5. Pipeline manufacturing data; and\n6. Leak history documentation.\nDocket Number: PHMSA- 2009-0390 – Colonial Pipeline – Line 01 Pipeline Special Permit Analysis and Findings – Loss of Test Records\nPage 7 of 19\n\n<<<PAGE 8>>>\n\nBased on PHMSA’s review of Colonial’s documents, it is unclear whether Colonial performed\ncomplete hydrostatic pressure tests of the subject segments and, if so, whether such tests were\nadequate in pressure, test time interval, and if there were test failures. The hydrostatic pressure\ntests cannot be confirmed by PHMSA based upon the following:\nSpecial permit segment 1:\n1. Line 01 hydraulic gradient at the current equipment settings for display with MOP for 40-\ninch diameter Line 01, Church Point to Baton Rouge, Louisiana, with injection at Krotz\nSprings, Louisiana;\n• PHMSA Review: This operating and hydraulic gradient data does not confirm\nthat a test was conducted in 1976 on the pipeline, 40-inch diameter Line 01. The\ndocument submitted has no test information to confirm that a test was conducted\nnor does it contain field inspection reports that confirm a test was conducted.\n2. Payment records for contractor performing the hydrostatic pressure test on 40-inch\ndiameter Line 01, Church Point to Baton Rouge;\n• PHMSA Review: The financial records indicate that the construction contractor,\nFord, Bacon & Davis, was paid in 1976 for services which included “testing.”\nWhile the type of testing is not specified on the invoice, the only testing included\nin the scope of work was hydrostatic testing. The original invoice was sent to J.\nL. Merchant, Colonial’s Manager of Engineering.\n• The financial records indicate that the construction contractor was paid, but does\nnot confirm that a test was conducted in 1976 on the pipeline.\n3. Memo dated May 24, 1977, identifying a hydrostatic test pressure of 855 psi from J. L.\nMerchant, Colonial Manager of Engineering at that time;\n• PHMSA Review: The memo dated May 24, 1977, by Mr. J.L. Merchant,\nColonial's Manager of Engineering, indicates that a test was conducted, and states\n\"A review of the Spread 3 hydrostatic test reports…\" In addition, the memo\nstates that the pipeline was tested in a certain area at 855 psi (below its required\ndesign pressure of 882 psi) and \"arrangements are now being made to conduct the\nnew hydrostatic test.\" The memo noted that until a retest has been completed, the\nDocket Number: PHMSA- 2009-0390 – Colonial Pipeline – Line 01 Pipeline Special Permit Analysis and Findings – Loss of Test Records\nPage 8 of 19\n\n<<<PAGE 9>>>\n\npipeline in that area will be operated at lower maximum discharge pressure\nconsidering the lower test pressure in that area. Colonial did not submit to\nPHMSA any documentation of a retest. The documentation submitted does not\nconfirm that an original test was conducted in 1976 or that a retest was conducted\non the pipeline, and if a retest was not conducted, why.\n4. Field notes labeled “Hydro Test 1976” from Hebert Station to Baton Rouge for Spreads\n1, 2, and 3;\n• PHMSA Review: Colonial submitted some rough field pressure notes that have\nno date or author, and do not include the entire pipeline segment.\n5. Line No. 01, dated 2-15-80, from Church Point Station to Felixville Station, control\nengineer’s analysis of pipe data, maximum operating pressure, hydrostatic test\ninformation and critical elevation checks;\n• PHMSA Review: Colonial’s documentation that was submitted to PHMSA is a\ncontrol center engineer’s analysis dated February 15, 1980. The document does\nnot contain the author’s name/signature, source of information, and test records.\n6. Hydrostatic Test Records Team spread sheet listing of test sections with engineering\nstationing and minimum and maximum test pressures; and\n• PHMSA Review: Colonial’s documentation did not include any test records. The\ndocumentation was a summary indicating that tests were conducted in the interval\nof November 6 through December 1, 1976, with a hydrostatic pressure test\ndescription and minimum and maximum pressures. For mile posts 4976+55 to\n5976+62 (covering special permit segment 1), the maximum pressure listed is\n859 psi and the minimum pressure is listed as 855 psi. This document does not\ncontain the author’s name/signature, date, source of information, and test records.\n7. Summary of pressure tests performed upstream and downstream of Line 01, Church Point\nto Baton Rouge.\n• PHMSA Review: The document submitted has no test information to confirm\nthat a test was conducted. There are no document authors with signature, dates,\ntimes, pressures logs, charts, stationing, or elevations on this document.\nDocket Number: PHMSA- 2009-0390 – Colonial Pipeline – Line 01 Pipeline Special Permit Analysis and Findings – Loss of Test Records\nPage 9 of 19\n\n<<<PAGE 10>>>\n\nSpecial permit segment 2:\n8. Line 01 hydraulic gradient at current equipment settings for display with MOP data for\n40-inch diameter Line 01, Atlanta to Dacula, Georgia;\n• PHMSA Review: The documents submitted by Colonial show the “Hydrostatic\nTest Analysis” for Line 01, Chattahoochee River to GA 141 (which includes the\nspecial permit segment 2). The documents submitted by Colonial have no test\ninformation to confirm that a test was conducted. There are no document authors\nwith signature, dates, times, pressures logs, charts, stationing, or elevations on this\ndocument. The documents are dated March 6, 2009, well after the 1978 pipeline\ninstallation timing.\n9. Payment records for contractor performing the hydrostatic test on 40-inch diameter Line\n01, Spread 1A, Chattahoochee River to Georgia Highway 141;\n• PHMSA Review: The documents indicate that Colonial paid for services\nrendered associated with the performance of the hydrostatic testing. The\ndocuments submitted have no test information to confirm that a test was\nconducted. There are no document authors with signature, dates, times, pressures\nlogs, charts, stationing, or elevations on this document.\n10. The Spread 1A, Test Section 4 (Chattahoochee River to Georgia Highway 141) pressure\ntest procedure diagram and test design showing the test pressures, station numbers and\nelevations;\n• PHMSA Review: Colonial submitted field notes outlining the hydrostatic test\nprocedure inclusive of design and diagrams showing test pressures, stationing,\nand elevations. The information was signed and dated, but did not include any\ntest records. The signature date was April 20, 1978.\n11. Detailed water management plan and drawings for the hydrostatic testing inclusive of\nwater chemistry analytical results;\nDocket Number: PHMSA- 2009-0390 – Colonial Pipeline – Line 01 Pipeline Special Permit Analysis and Findings – Loss of Test Records\nPage 10 of 19\n\n<<<PAGE 11>>>\n\n• PHMSA Review: Colonial submitted water samples of water sources for the\nhydrostatic test. Water samples were taken at the Chattahoochee River on March\n28, 1978, and June 29, 1978.\n12. Testimonies from N. J. Edmonds, Colonial Manager of Operations Planning & Pipeline\nControl, and Sam A. Kelly, Supervisor for Michael Curran & Associates (hydrostatic\ntesting contractor), that the hydrostatic test was performed;\n• PHMSA Review:\nMr. N. J. Edmonds’ signed memo dated July 27, 1990, stated that he was on the\npipeline segment construction from March 15, 1978, to July 30, 1978. Mr.\nEdmonds did not indicate that he conducted the test, nor did he include any test\ndocumentation or daily inspector records. Mr. Edmunds did state that he did not\nrecall any failures occurring during the hydrostatic tests on AFE 2333, Spread\n1-A.\nMr. Sam Kelly’s signed memo dated April 3, 2008, stated that the hydrotesting of\nColonial’s Spread 1-A (segment from Chattahoochee River to Georgia Highway\n141) occurred in early August 1978, and he recalled overseeing the actual testing.\nMr. Kelly remembered preparing the test documentation and delivering it to a\nColonial inspector for delivery to Mr. N. J. Edmonds. The Colonial inspector\ninadvertently dropped the records in the mud and Mr. Edmunds returned them to\nMichael Curran & Associates to clean up the records and prepare a hydrostatic\ntest report.\n13. Hydrostatic Test Records Team spreadsheet listing of test sections with engineering\nstationing and minimum and maximum test pressure; and\n• PHMSA Review: Colonial’s documentation did not include any test records or\ninspector daily reports to document the test (date of test, test pressure, test\nduration) and any leaks or failures during the test.\n14. Summary of pressure tests performed upstream and downstream of Spread 1A, Test\nSection 4 (Chattahoochee River to Georgia Highway 141).\nDocket Number: PHMSA- 2009-0390 – Colonial Pipeline – Line 01 Pipeline Special Permit Analysis and Findings – Loss of Test Records\nPage 11 of 19\n\n<<<PAGE 12>>>\n\n• PHMSA Review: Colonial submitted a document indicating that the test began\naround July 22, 1978, with a failure on that day. Colonial’s document states that\nthe failure was repaired on July 23, 1978, and a successful test is believed to have\nbeen completed sometime after completion of the repair on July 23, 1978, and\nprior to commencement of the testing of Sections 2 and 3, which began on July\n25, 1978. This document conflicts with the statements of Mr. Sam Kelly and Mr.\nN.J. Edmonds above, Item 12, on the timing of the test and whether there was a\nfailure during the test.\nPublic Notice:\nOn January 26, 2010, PHMSA published a notice of this special permit request in the Federal\nRegister (75 FR 4136). The notice provided a thirty (30) day comment period regarding the\nspecial permit request, ending February 25, 2010. PHMSA did not receive any comments on\nColonial’s special permit request.\nOn August 23, 2019, PHMSA published the special permit request in the Federal Register (84\nFR 44350) and the public comment period ended on September 23, 2019, with all comments\nreceived through September 26, 2019, being reviewed and considered. PHMSA did not receive\nany comments on Colonial’s special permit request. The special permit application from\nColonial, pipeline route maps, public comments, environmental assessment, and special permit\nconditions are available in Docket No. PHMSA-2009-0390 at: www.regulations.gov.\nPHMSA Overall Response and Considerations of Public Safety Concerns:\nPHMSA did not receive any public stakeholder comments on the docket, emails sent to PHMSA,\nor any phone calls received through September 26, 2019, concerning the Colonial 40-inch\ndiameter Line 01 pipeline special permit request.\nAnalysis:\nPHMSA developed the special conditions to achieve an equivalent or higher level of safety by\nsignificantly decreasing the likelihood of a release of hazardous liquids in the special permit\nsegments 1 and 2. The special permit conditions include: ILI (smart pigging), CP inspections\nand defined repair criteria (reducing the risk of failure due to mechanical damage and corrosion);\nincreased line of sight markers (reducing the risk of in-service mechanical damage), equipment\nDocket Number: PHMSA- 2009-0390 – Colonial Pipeline – Line 01 Pipeline Special Permit Analysis and Findings – Loss of Test Records\nPage 12 of 19\n\n<<<PAGE 13>>>\n\nand valves for remote monitoring and control to detect and shut off product flow when a large\nvolume leak or rupture is detected.\nPast Enforcement History – January 1, 2009 through September 26, 2019:\nA review of PHMSA enforcement actions against Colonial from January 1, 2009, through\nSeptember 26, 2019, shows the following enforcement actions against Colonial. The existence\nof these actions requires substantial justification to warrant granting this special permit.\nBelow is a listing of PHMSA closed enforcement matters of all types in all PHMSA Regions for\nColonial from January 1, 2009 through September 26, 2019 (excluded withdrawn matters):\n• Letters of Concern or Warning - 5 matters\n• Notices of Amendment, Probable Violations, or Corrective Action Orders – 14 matters\n• Civil Penalties - $326,700 Proposed, $146,400 Assessed; $117,100 Collected\nColonial Pipeline - Total Number of Enforcement Cases –\nJanuary 1, 2009 through September 26, 2019\nTotal\nCase\nCorrective\nNotices of\nNotices of\nSafety\nWarning\nLetters\nNumber\nStatus\nAction\nAmendment\nProbable\nOrders\nLetters\nof\nof Cases\nOrders\nViolation\nConcern\nCLOSED 0 3 7 0 5 0 15\nOPEN 2 0 2 0 0 0 4\nGrand\nTotal 2 3 9 0 5 0 19\nCivil Penalty Status\nProposed Assessed Awaiting Order Withdrawn/Reduced Collected\n$326,700 $146,400 $67,000 $113,300 $117,100\nOperational Integrity Compliance:\nPHMSA has developed special permit conditions to ensure that integrity threats to the pipeline in\nthe special permit segments 1 and 2 are addressed in the operator’s O&M plan (O&M\nprocedures and specifications). PHMSA carefully designed a comprehensive set of conditions\nthat Colonial is required to implement for the special permit to be granted for loss of records to\nDocket Number: PHMSA- 2009-0390 – Colonial Pipeline – Line 01 Pipeline Special Permit Analysis and Findings – Loss of Test Records\nPage 13 of 19\n\n<<<PAGE 14>>>\n\nmeet 49 CFR §195.310(b) of special permit segments 1 and 2 totaling 74.684 miles of 40-inch\ndiameter pipeline. The special permit conditions are to find and mitigate integrity threats to\nspecial permit segments 1 and 2 as summarized below:\nSummary of Special Permit Conditions:\n1) Maximum Operating Pressure Limitations: Colonial must continue to operate special\npermit segment 1 at or below its existing maximum operating pressure (MOP) of 574\npounds per square inch gauge (psig) and must continue to operate special permit segment\n2 at or below its existing MOP of 743 psig. Special permit segments 1 and 2 must be\npressure tested to meet 49 CFR Part 195, Subpart E within two (2) years of the granting\nof this special permit and the appropriate records must be retained. If Colonial elects to\nnot pressure test special permit segments 1 and 2, then Special Permit Conditions 2\nthrough 19 must be fully implemented within two (2) years of the grant of this special\npermit.\n2) Integrity Management Program: Within six (6) months of the grant of this special\npermit, Colonial must incorporate special permit segments 1 and 2 into its written\nintegrity management program (IMP) as a hazardous liquid pipeline that could affect an\nHCA in accordance with 49 CFR 195.452. Colonial must follow and implement the\nrequirements of 49 CFR 195.452 and these special permit conditions in evaluating the\nintegrity of special permit segments 1 and 2.\n3) Close Interval Surveys: Within one (1) year of the grant of this special permit, Colonial\nmust perform a close interval survey (CIS) on special permit segments 1 and 2. A CIS\nneed not be performed if Colonial has performed a CIS on the Line 01 pipeline along the\nentire length of each special permit segment less than five (5) years prior to the grant of\nthis special permit.\n4) Close Interval Survey – Reassessment Interval: Colonial must perform a Close\nInterval Survey (CIS) and remediate any areas where CP levels are determined not to be\nadequate per 49 CFR 195, Subpart H within special permit segments 1 and 2 at least\nonce every five (5) calendar years, not to exceed 68 months.\nDocket Number: PHMSA- 2009-0390 – Colonial Pipeline – Line 01 Pipeline Special Permit Analysis and Findings – Loss of Test Records\nPage 14 of 19\n\n<<<PAGE 15>>>\n\n5) Coating Condition Evaluation: Within one (1) year of the grant of this special permit,\nColonial must perform a detailed evaluation of the pipeline coating system and remediate\nareas where coating degradation poses a corrosion threat on the pipeline within special\npermit segments 1 and 2.\n6) O&M Manual – Reassessment Intervals: Within six (6) months of the grant of this\nspecial permit, Colonial must amend its written O&M manual to require ILI inspection\nand reassessment intervals of the Line 01 pipeline for special permit segments 1 and 2 at\na frequency consistent with 49 CFR 195.452, but at least once every five (5) calendar\nyears at reassessment intervals not exceeding 68 months.\n7) In-Line Inspection Initial Assessment:\na. Colonial must perform ILI threat assessments along the entire length of special\npermit segments 1 and 2 using ILI tools (high resolution magnetic flux leakage\n(HR-MFL); HR-geometry or HR-deformation tools; and ultrasonic crack\ndetection) and must remediate discovered conditions in accordance with\nCondition 16 of this permit.\nb. If ILI assessments have not been run within five (5) years of this special permit\nusing ILI tools (high resolution magnetic flux leakage (HR-MFL); HR-geometry\nor HR-deformation tools; and ultrasonic crack detection), Colonial must complete\nILI tool inspections on the special permit segments within one (1) year of\nissuance of this special permit.\n8) ILI Reassessment Intervals: Colonial must schedule ILI reassessment dates for the\nspecial permit segments in accordance with 49 CFR 195.452 by adding the required time\ninterval to the previous assessment date, but may not exceed a “five (5) year not to\nexceed 68-months” reassessment interval.\n9) Damage Prevention Best Practices: Colonial must incorporate the applicable best\npractices of the Common Ground Alliance (CGA) into its damage prevention program\nwithin the special permit segments.\n10) Field Activity Notice to PHMSA: Colonial must give notice to the Director, PHMSA\nSouthern Region, within 14 days of discovery resulting from an ILI to enable PHMSA to\nDocket Number: PHMSA- 2009-0390 – Colonial Pipeline – Line 01 Pipeline Special Permit Analysis and Findings – Loss of Test Records\nPage 15 of 19\n\n<<<PAGE 16>>>\n\nobserve the excavations relating to Conditions 16 - Anomaly Evaluation and Repair,\nand Condition 18 - Casings, of field activities in the special permit inspection areas.\n11) Annual Reports to PHMSA: Colonial must report annually on pipeline threat findings\nto PHMSA.\n12) Cathodic Protection Test Station – Location: At least one (1) cathodic protection (CP)\npipe-to-soil test station must be located within each HCA with a maximum spacing\nbetween test stations of one (1) mile within the special permit segments 1 and 2.\n13) Cathodic Protection Test Station - Remediation: If any annual CP test station reading\nwithin the special permit segments 1 and 2 fall below 49 CFR Part 195, Subpart H\nrequirements, remediation must occur within six (6) months of the test station reading\nand must include a CIS 100 feet upstream and 100 feet downstream of the test station to\nverify that the cause of the deficiency has been mitigated.\n14) Interference Currents Control: Colonial must address induced alternating current\n(AC) from parallel electric transmission lines and other sources that may affect the\npipeline in the special permit segments 1 and 2.\n15) Field Coating: Colonial currently has the coating data for the pipe in special permit\nsegments 1 and 2. If Colonial identifies through subsequent inspections that a different\ncoating exists or is known to shield CP for girth weld joints, then Colonial must take\nspecial care to check for cracking.\n16) Anomaly Evaluation and Repair: Anomaly response and repair for the Colonial Line\n01 Pipeline within special permit segments 1 and 2 must be conducted as required by 49\nCFR 195.452(h) and the additional evaluation and remediation criteria in the special\npermit conditions regardless of HCA5 status. The required timing for excavation,\ninvestigation, and remediation of anomalies based on ILI data or excavation results must\nbe in accordance with 49 CFR 195.452(h), and must incorporate the appropriate design\nfactors and wall loss criteria in the anomaly repair criteria. All cracks over 50% wall\n5 HCAs in the special permit segments 1 and 2 must have anomalies evaluated and repaired based upon the most\nstringent requirements of: this special permit; 49 CFR Part 195.452, or Colonial’s Integrity Management Plan.\nDocket Number: PHMSA- 2009-0390 – Colonial Pipeline – Line 01 Pipeline Special Permit Analysis and Findings – Loss of Test Records\nPage 16 of 19\n\n<<<PAGE 17>>>\n\nthickness and less than 1.39 failure pressure ratio must be remediated. All dents over 1%\nmust have an “engineering critical assessment.\n”\n17) Girth Welds: Colonial must provide records to PHMSA to demonstrate the girth welds\non special permit segments 1 and 2 were non-destructively tested (NDT) at the time of\nconstruction or demonstrate the sound of the girth welds through integrity and operational\nevaluations.\n18) Casings: Colonial must identify all shorted casings (metallic or electrolytic) within\nspecial permit segments 1 and 2 no later than six (6) months after the grant of this\nspecial permit and classify any shorted casings as either having a “metallic short” (the\ncarrier pipe and the casing are in metallic contact) or an “electrolytic short” (the casing is\nfilled with an electrolyte) using a commonly accepted method such as the Panhandle\nEastern, Pearson, DCVG, ACVG or AC Attenuation. A casing survey and shorted casing\nassessment need not be performed if Colonial has performed a casing survey and shorted\ncasing assessment on the Line 01 Pipeline along the entire length of special permit\nsegments 1 and 2 less than one (1) year prior to the grant of this special permit. If factors\n“beyond Colonial’s control” prevent the completion of shorted casing evaluation and\nappropriate remediation within six (6) months of the short identification, then the\nevaluation and appropriate remediation must be completed as soon as practicable and a\nletter justifying the delay and providing the anticipated date of completion must be\nsubmitted to the Director, PHMSA Southern Region.\n19) Pipe Seam Evaluations: Colonial must identify any pipe in special permit segments 1\nand 2 that may be susceptible to pipe seam issues because of the vintage of the pipe, the\nmanufacturing process of the pipe, or other issues.\n20) Special Permit Segment Specific Conditions: Colonial must comply with the following\nrequirements.\na. Depth of Cover: Colonial must conduct depth of cover surveys in special permit\nsegments 1 and 2 to confirm that pipeline cover meets 49 CFR 195.248 and\nremediate based upon findings.\nb. Line-of-sight Markers: Colonial must install and maintain line-of-sight markers\non the pipeline in the special permit segments except in agricultural areas or large\nDocket Number: PHMSA- 2009-0390 – Colonial Pipeline – Li","truncated":true,"body_characters":44195}