# EASTERN SHORE NATURAL GAS CO — Notice of Amendment

**Citation:** CPF 12023024NOA  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2023-03-16

CLOSED notice of amendment citing 192.631(e)(5).

## Document text

Notice of Amendment involving EASTERN SHORE NATURAL GAS CO. PHMSA's enforcement data identifies the cited regulation as 192.631(e)(5). The case was opened on 2023-03-16 and is reported as closed as of 2023-06-01. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

12023024NOA_Closure Letter_06012023_(22-246392).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023024NOA/12023024NOA_Closure%20Letter_06012023_(22-246392).pdf

12023024NOA_Closure Letter_06012023_(22-246392)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023024NOA/12023024NOA_Closure%20Letter_06012023_(22-246392)_text.pdf

12023024NOA_Notice of Amendment_03162023_(22-246392).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023024NOA/12023024NOA_Notice%20of%20Amendment_03162023_(22-246392).pdf

12023024NOA_Notice of Amendment_03162023_(22-246392)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023024NOA/12023024NOA_Notice%20of%20Amendment_03162023_(22-246392)_text.pdf

12023024NOA_Operator Response to Notice_04062023_(22-246392).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12023024NOA/12023024NOA_Operator%20Response%20to%20Notice_04062023_(22-246392).pdf

12023024NOA_Notice of Amendment_03162023_(22-246392)_text.pdf

NOTICE OF AMENDMENT
OVERNIGHT EXPRESS DELIVERY
March 16, 2023
Mr. Jeff Householder
President and Chief Executive Officer
Eastern Shore Natural Gas Co
500 Energy Lane, Suite 200
Dover, Delaware 19901
CPF 1-2023-024-NOA
Dear Mr. Householder:
From September 26 to September 29, 2022, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code
(U.S.C.) inspected Eastern Shore Natural Gas Co’s (Eastern Shore) procedures for Control Room
Management in Dover, DE.
As a result of the inspection, PHMSA has identified the apparent inadequacy found within Eastern
Shore’s plans or procedures. The item inspected and the inadequacy is described below:
1. 49 C.F.R. § 192.631 Control Room Management
(a) …
(e) Alarm management. Each operator using a SCADA system must
have a written alarm management plan to provide for effective
controller response to alarms. An operator's plan must include
provisions to:
(1) …
(5) Monitor the content and volume of general activity being
directed to and required of each controller at least once each calendar
year, but at intervals not to exceed 15 months, that will assure
controllers have sufficient time to analyze and react to incoming
alarms; and



Eastern Shore’s written control room management procedures were inadequate. Specifically,
Eastern Shore’s Control Room Management Plan, dated 05-14-2014 (CRM Plan) and its SCADA
Alarm Management Plan, dated 06-08-2021 (Alarm Plan) lacked sufficient details pursuant to
compliance with § 192.631(e)(5).
During the inspection, the PHMSA inspector reviewed Eastern Shore’s CRM Plan and Alarm Plan.
The CRM Plan stated in part:
“(5) Monitor the content and volume of general activity (alarms).
The content and volume of alarms received in Gas Control shall be reviewed by the
Gas Control Manager and/or System Planning and Process Controls Manager at
least once each calendar year, but at intervals not to exceed 15 months.”
While the CRM Plan reflects the language found in § 192.631(e)(5), it did not include details on
how Eastern Shore will complete and document this required assessment. The Alarm Plan also
referenced this review but did not provide additional details on how this task will be completed
and documented.
Therefore, Eastern Shore’s written control room management procedures were inadequate
pursuant to § 192.631(e)(5). Eastern Shore must revise its procedures to address this deficiency.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as
part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance
Proceedings.
Please refer to this document and note the response options. 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).
Following the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under §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 an Order Directing Amendment. If your plans or
procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans
or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this
Notice, we propose that you submit your amended procedures to my office within 30 days of
receipt of this Notice. This period may be extended by written request for good cause. Once the
inadequacies identified herein have been addressed in your amended procedures, this enforcement
action will be closed.



It is requested (not mandated) that Eastern Shore Natural Gas Co maintain documentation of the
safety improvement costs associated with fulfilling this Notice of Amendment
(preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director,
Eastern Region, Pipeline and Hazardous Materials Safety Administration. In correspondence
concerning this matter, please refer to CPF 1-2023-024-NOA and, for each document you submit,
please provide a copy in electronic format whenever possible.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings

12023024NOA_Closure Letter_06012023_(22-246392)_text.pdf

OVERNIGHT EXPRESS DELIVERY
June 1, 2023
Mr. Jeff Householder
President and Chief Executive Officer
Eastern Shore Natural Gas Co
500 Energy Lane, Suite 200
Dover, Delaware 19901
CPF 1-2023-024-NOA
Dear Mr. Householder:
From September 26 to September 29, 2022, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code
(U.S.C.) inspected Eastern Shore Natural Gas Co’s (Eastern Shore) procedures for Control Room
Management in Dover, DE. As a result of the inspection, Eastern Shore was issued a Notice of
Amendment on March 16, 2023, which proposed amendment of your procedures.
Eastern Shore submitted its amended procedures on April 6, 2023. My staff reviewed the amended
procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been
corrected.
This letter is to inform you no further action is necessary and this case is now closed. Thank you
for your cooperation.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/12023024NOA>
- Source ID: `phmsa-enforcement`
- SHA-256: `cc5a502ad45c2987419a328dc6ffd7b1c92919c3c9923570d5bae54459c4dd3d`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T23:36:02.766Z
- Document slug: `phmsa-enforcement-12023024noa`

### Source metadata

```json
{
  "cpf": "12023024NOA",
  "operator": "EASTERN SHORE NATURAL GAS CO",
  "region": "Eastern",
  "pipelineType": "INTERSTATE GAS TRANSMISSION",
  "caseStatus": "CLOSED",
  "citedSections": [
    "192.631(e)(5)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 5,
  "attachments": [
    {
      "name": "12023024NOA_Closure Letter_06012023_(22-246392).pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/12023024NOA/12023024NOA_Closure%20Letter_06012023_(22-246392).pdf",
      "bytes": 355773,
      "category": "agency_document"
    },
    {
      "name": "12023024NOA_Closure Letter_06012023_(22-246392)_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/12023024NOA/12023024NOA_Closure%20Letter_06012023_(22-246392)_text.pdf",
      "bytes": 82567,
      "category": "agency_document"
    },
    {
      "name": "12023024NOA_Notice of Amendment_03162023_(22-246392).pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/12023024NOA/12023024NOA_Notice%20of%20Amendment_03162023_(22-246392).pdf",
      "bytes": 592659,
      "category": "agency_document"
    },
    {
      "name": "12023024NOA_Notice of Amendment_03162023_(22-246392)_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/12023024NOA/12023024NOA_Notice%20of%20Amendment_03162023_(22-246392)_text.pdf",
      "bytes": 115916,
      "category": "agency_document"
    },
    {
      "name": "12023024NOA_Operator Response to Notice_04062023_(22-246392).pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/12023024NOA/12023024NOA_Operator%20Response%20to%20Notice_04062023_(22-246392).pdf",
      "bytes": 449390,
      "category": "party_submission"
    }
  ],
  "extractedAgencyDocumentCount": 2,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "EASTERN SHORE NATURAL GAS CO"
}
```
