{"operation":"document","citation":"CPF 12025017NOA","title":"TEXAS GAS TRANSMISSION, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-08-14","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12025017noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12025017noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12025017noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12025017NOA","body":"Notice of Amendment involving TEXAS GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulation as 192.12(c). The case was opened on 2025-08-14 and is reported as closed as of 2025-11-26. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12025017NOA_Closure Letter_11262025_(24-295935).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025017NOA/12025017NOA_Closure%20Letter_11262025_(24-295935).pdf\n\n12025017NOA_Closure Letter_11262025_(24-295935)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025017NOA/12025017NOA_Closure%20Letter_11262025_(24-295935)_text.pdf\n\n12025017NOA_Notice of Amendement_08142025_(24-295935).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025017NOA/12025017NOA_Notice%20of%20Amendement_08142025_(24-295935).pdf\n\n12025017NOA_Notice of Amendement_08142025_(24-295935)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025017NOA/12025017NOA_Notice%20of%20Amendement_08142025_(24-295935)_text.pdf\n\n12025017NOA_Operator Response to Notice_09122025_(24-295935).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025017NOA/12025017NOA_Operator%20Response%20to%20Notice_09122025_(24-295935).pdf\n\n12025017NOA_Closure Letter_11262025_(24-295935)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and\nHazardous Materials\nSafety Administration\n840 Bear Tavern Road, Suite 300\nWest Trenton, NJ 08628\n609.771.7800\nVIA ELECTRONIC MAIL TO: Scott.Hallam@bwpipelines.com\nNovember 26, 2025\nMr. Scott Hallam\nPresident & Chief Executive Officer\nBoardwalk Pipeline Partners, LP\n9 Greenway Plaza, Suite 2800\nHouston, Texas 77046\nCPF 1-2025-017-NOA\nDear Mr. Hallam:\nOn June 4-6, 2024, a representative from the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, conducted an on-\nsite pipeline safety inspection of Boardwalk Pipeline Partners LP’s (Boardwalk) procedures in its\nLeesville and Wilfred underground gas storage facilities in Lawrence County and Sullivan County,\nIndiana. As a result of the inspection, Boardwalk was issued a Notice of Amendment on August\n14, 2025, which proposed amendment of your procedures.\nBoardwalk submitted its amended procedures on September 12, 2025. My staff reviewed the\namended procedures, and it appears that the inadequacies outlined in this Notice of Amendment\nhave been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\ncc: Tina Baker, Manager, Compliance services, Tina.Baker@bwpipelines.com\n\n12025017NOA_Notice of Amendement_08142025_(24-295935)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: Scott.Hallam@bwpipelines.com\nAugust 14, 2025\nMr. Scott Hallam\nPresident & Chief Executive Officer\nBoardwalk Pipeline Partners, LP\n9 Greenway Plaza, Suite 2800\nHouston, Texas 77046\nCPF 1-2025-017-NOA\nDear Mr. Hallam:\nFrom June 4 through June 6, 2024, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected\nBoardwalk Pipeline Partners LP’s (Boardwalk) procedures for its Leesville and Wilfred depleted\naquifer underground natural gas storage facilities in Lawrence County and Sullivan County,\nIndiana.\nAs a result of the inspection, PHMSA has identified apparent inadequacies found within\nBoardwalk’s plans or procedures. The items inspected, alleged inadequacies, and proposed\nrevisions are described below:\n1. § 192.12 Underground natural gas storage facilities.\n(a) ...\n(c) Procedural manuals. Each operator of a UNGSF must prepare\nand follow for each facility one or more manuals of written procedures\nfor conducting operations, maintenance, and emergency preparedness\nand response activities under paragraphs (a) and (b) of this section.\nEach operator must keep records necessary to administer such\nprocedures and review and update these manuals at intervals not\nexceeding 15 months, but at least once each calendar year. Each\noperator must keep the appropriate parts of these manuals accessible\nat locations where UNGSF work is being performed. Each operator\nmust have written procedures in place before commencing operations\nor beginning an activity not yet implemented.\n\n\n\nBoardwalk’s written procedures for conducting operations, maintenance, and emergency\npreparedness and response activities were inadequate to assure safe operation in accordance with\nsection 192.12(c). Specifically, Boardwalk failed to include in its manual, TL1529 Plugging and\nAbandoning a Well (5/31/24), a process for the determination of groundwater and hydrocarbon\nbearing zones and the condition of the well’s casing across those zones as required by American\nPetroleum Institute’s Recommended Practice 1171 (API RP 1171), section 6.7.2, and section\n11.2.1 which is incorporated by reference in section 192.12(b)(2).\nSection 11.2.1 states that “[t]he operator shall develop and follow procedures for the construction,\noperation, and maintenance of natural gas storage wells and reservoirs to establish and maintain\nfunctional integrity.” Section 6.7.2 includes a maintenance requirement that states “[t]he operator\nshall determine the location of groundwater and hydrocarbon bearing zones (in addition to the\nstorage zone) penetrated by the well to be abandoned, and the condition of the well’s casing and\ncement across those zones, to prevent communication between any of those zones during and after\nplugging of the well.”\nTherefore, Boardwalk’s written procedures for conducting operations and maintenance activities\nwere inadequate to assure safe operation in accordance with section 192.12(c). PHMSA proposes\nthat Boardwalk must revise its written procedures to address the deficiency outlined above.\n2. § 192.12 Underground natural gas storage facilities.\n(a) ...\n(c) Procedural manuals. Each operator of a UNGSF must prepare\nand follow for each facility one or more manuals of written procedures\nfor conducting operations, maintenance, and emergency preparedness\nand response activities under paragraphs (a) and (b) of this section.\nEach operator must keep records necessary to administer such\nprocedures and review and update these manuals at intervals not\nexceeding 15 months, but at least once each calendar year. Each\noperator must keep the appropriate parts of these manuals accessible\nat locations where UNGSF work is being performed. Each operator\nmust have written procedures in place before commencing operations\nor beginning an activity not yet implemented.\nBoardwalk’s written procedures for conducting operations, maintenance, and emergency\npreparedness and response activities under section 192.12(b) were inadequate to assure safe\noperation in accordance with section 192.12(c). Specifically, Boardwalk failed to have an isolation\ntesting procedure in its manual, Underground Natural Gas Storage, 1171-9.2 Well Integrity\nMonitoring (5/31/24), that required personnel to confirm isolation of the well after operating the\nmaster valve and wellhead pipeline isolation valve, as required by API RP 1171, section 9.3.2,\nwhich is incorporated by reference in section 192.12(b)(2).\nSection 9.3.2 in API RP 1171 states that “[t]he operator shall test the operation of the master valve\nand wellhead pipeline isolation valve at least annually for proper function and ability to isolate the\nwell.”\n\n\n\nTherefore, Boardwalk’s written procedures for conducting operations, maintenance, and\nemergency preparedness and response activities under section 192.12(b) were inadequate to assure\nsafe operation in accordance with section 192.12(c). PHMSA proposes that Boardwalk must\nrevise its procedures to address the deficiency discussed above.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 CFR § 190.206. Enclosed as part\nof this Notice is a document entitled Response Options for Pipeline Operators in Enforcement\nProceedings.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. § 552(b), along with the complete original document you must provide a second copy of\nthe document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 U.S.C. § 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under section 190.211. If you do not respond within 30 days\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis Notice without further notice to you and to issue an Order Directing Amendment. If your\nplans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend\nyour plans or procedures to correct the inadequacies (49 CFR § 190.206). If you are not contesting\nthis Notice, we propose that you submit your amended procedures to my office within 30 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that Boardwalk Pipeline Partners, LP maintain documentation of\nthe safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director,\nEastern Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 1-2025-017-NOA and, for each document you submit,\nplease provide a copy in electronic format whenever possible.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings","truncated":false,"body_characters":10383}