TEXAS GAS TRANSMISSION, LLC — Notice of Amendment

party submissionOfficial PDF12025017NOA_Operator Response to Notice_09122025_(24-295935).pdf#

12025017NOA_Closure Letter_11262025_(24-295935)_text.pdf, page 1Official PDFU.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 840 Bear Tavern Road, Suite 300 West Trenton, NJ 08628 609.771.7800 VIA ELECTRONIC MAIL TO: Scott.Hallam@bwpipelines.com November 26, 2025 Mr. Scott Hallam President & Chief Executive Officer Boardwalk Pipeline Partners, LP 9 Greenway Plaza, Suite 2800 Houston, Texas 77046 CPF 1-2025-017-NOA Dear Mr. Hallam: On June 4-6, 2024, a representative from the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, conducted an on- site pipeline safety inspection of Boardwalk Pipeline Partners LP’s (Boardwalk) procedures in its Leesville and Wilfred underground gas storage facilities in Lawrence County and Sullivan County, Indiana. As a result of the inspection, Boardwalk was issued a Notice of Amendment on August 14, 2025, which proposed amendment of your procedures. Boardwalk submitted its amended procedures on September 12, 2025. 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 cc: Tina Baker, Manager, Compliance services, Tina.Baker@bwpipelines.com#

12025017NOA_Notice of Amendement_08142025_(24-295935)_text.pdf, page 1Official PDFNOTICE OF AMENDMENT VIA ELECTRONIC MAIL TO: Scott.Hallam@bwpipelines.com August 14, 2025 Mr. Scott Hallam President & Chief Executive Officer Boardwalk Pipeline Partners, LP 9 Greenway Plaza, Suite 2800 Houston, Texas 77046 CPF 1-2025-017-NOA Dear Mr. Hallam: From June 4 through June 6, 2024, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected Boardwalk Pipeline Partners LP’s (Boardwalk) procedures for its Leesville and Wilfred depleted aquifer underground natural gas storage facilities in Lawrence County and Sullivan County, Indiana. As a result of the inspection, PHMSA has identified apparent inadequacies found within Boardwalk’s plans or procedures. The items inspected, alleged inadequacies, and proposed revisions are described below: 1. § 192.12 Underground natural gas storage facilities. (a) ... (c) Procedural manuals. Each operator of a UNGSF must prepare and follow for each facility one or more manuals of written procedures for conducting operations, maintenance, and emergency preparedness and response activities under paragraphs (a) and (b) of this section. Each operator must keep records necessary to administer such procedures and review and update these manuals at intervals not exceeding 15 months, but at least once each calendar year. Each operator must keep the appropriate parts of these manuals accessible at locations where UNGSF work is being performed. Each operator must have written procedures in place before commencing operations or beginning an activity not yet implemented.#

12025017NOA_Notice of Amendement_08142025_(24-295935)_text.pdf, page 2Boardwalk’s written procedures for conducting operations, maintenance, and emergency preparedness and response activities were inadequate to assure safe operation in accordance with section 192.12(c). Specifically, Boardwalk failed to include in its manual, TL1529 Plugging and Abandoning a Well (5/31/24), a process for the determination of groundwater and hydrocarbon bearing zones and the condition of the well’s casing across those zones as required by American Petroleum Institute’s Recommended Practice 1171 (API RP 1171), section 6.7.2, and section 11.2.1 which is incorporated by reference in section 192.12(b)(2). Section 11.2.1 states that “[t]he operator shall develop and follow procedures for the construction, operation, and maintenance of natural gas storage wells and reservoirs to establish and maintain functional integrity.” Section 6.7.2 includes a maintenance requirement that states “[t]he operator shall determine the location of groundwater and hydrocarbon bearing zones (in addition to the storage zone) penetrated by the well to be abandoned, and the condition of the well’s casing and cement across those zones, to prevent communication between any of those zones during and after plugging of the well.” Therefore, Boardwalk’s written procedures for conducting operations and maintenance activities were inadequate to assure safe operation in accordance with section 192.12(c). PHMSA proposes that Boardwalk must revise its written procedures to address the deficiency outlined above. 2. § 192.12 Underground natural gas storage facilities. (a) ... (c) Procedural manuals. Each operator of a UNGSF must prepare and follow for each facility one or more manuals of written procedures for conducting operations, maintenance, and emergency preparedness and response activities under paragraphs (a) and (b) of this section. Each operator must keep records necessary to administer such procedures and review and update these manuals at intervals not exceeding 15 months, but at least once each calendar year. Each operator must keep the appropriate parts of these manuals accessible at locations where UNGSF work is being performed. Each operator must have written procedures in place before commencing operations or beginning an activity not yet implemented. Boardwalk’s written procedures for conducting operations, maintenance, and emergency preparedness and response activities under section 192.12(b) were inadequate to assure safe operation in accordance with section 192.12(c). Specifically, Boardwalk failed to have an isolation testing procedure in its manual, Underground Natural Gas Storage, 1171-9.2 Well Integrity Monitoring (5/31/24), that required personnel to confirm isolation of the well after operating the master valve and wellhead pipeline isolation valve, as required by API RP 1171, section 9.3.2, which is incorporated by reference in section 192.12(b)(2). Section 9.3.2 in API RP 1171 states that “[t]he operator shall test the operation of the master valve and wellhead pipeline isolation valve at least annually for proper function and ability to isolate the well.”#

12025017NOA_Notice of Amendement_08142025_(24-295935)_text.pdf, page 3Therefore, Boardwalk’s written procedures for conducting operations, maintenance, and emergency preparedness and response activities under section 192.12(b) were inadequate to assure safe operation in accordance with section 192.12(c). PHMSA proposes that Boardwalk must revise its procedures to address the deficiency discussed above. Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 CFR § 190.206. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement 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 section 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 CFR § 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 Boardwalk Pipeline Partners, LP 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 1-2025-017-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#