# GULF SOUTH PIPELINE COMPANY, LLC — Safety Order

- **operation:** document
- **citation:** CPF 220151001S
- **title:** GULF SOUTH PIPELINE COMPANY, LLC — Safety Order
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2015-03-27
- **effective on:** Not available
- **summary:** CLOSED safety order.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-220151001s.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-220151001s.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-220151001s
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/220151001S
**body:**

Safety Order involving GULF SOUTH PIPELINE COMPANY, LLC. The dataset does not identify a cited regulation for this case. The case was opened on 2015-03-27 and is reported as closed as of 2024-02-09. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

220151001S_Closure Letter_02092024_(15-149704S).pdf: https://primis.phmsa.dot.gov/enforcement-documents/220151001S/220151001S_Closure%20Letter_02092024_(15-149704S).pdf

220151001S_Closure Letter_02092024_(15-149704S)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220151001S/220151001S_Closure%20Letter_02092024_(15-149704S)_text.pdf

220151001S_Consent Agreement_06052015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220151001S/220151001S_Consent%20Agreement_06052015.pdf

220151001S_Consent Agreement_06052015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220151001S/220151001S_Consent%20Agreement_06052015_text.pdf

220151001S_Consent Order_07232015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220151001S/220151001S_Consent%20Order_07232015.pdf

220151001S_Consent Order_07232015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220151001S/220151001S_Consent%20Order_07232015_text.pdf

220151001S_nopso_03272015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220151001S/220151001S_nopso_03272015.pdf

220151001S_nopso_03272015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220151001S/220151001S_nopso_03272015_text.pdf

220151001S_Consent Order_07232015_text.pdf

July 23, 2015
Mr. Richard Keyser
Vice President
Gulf South Pipeline Company, LP
9 Greenway Plaza, Suite 2800
Houston, TX 77046
Re: CPF No. 2-2015-1001S
Dear Mr. Keyser:
Enclosed please find a Consent Order incorporating the terms of the Consent Agreement that you
signed on June 9, 2015. Service of the Consent Order and Consent Agreement by certified mail
is deemed effective upon the date of mailing, or as otherwise provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Wayne T. Lemoi, Director, Office of Pipeline Safety, Southern Region, PHMSA
CERTIFIED MAIL - RETURN RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
)
In the Matter of )
)
Gulf South Pipeline Company, LP ) CPF No. 2-2015-1001S
)
Respondent. )
____________________________________)
CONSENT ORDER
By letter dated March 27, 2015, the Pipeline and Hazardous Materials Safety Administration
(PHMSA) Office of Pipeline Safety issued a Notice of Proposed Safety Order (Notice) to Gulf
South Pipeline Company, LP (Respondent or Gulf South) in this case.
In accordance with 49 C.F.R. § 190.239, the Notice alleged that conditions exist on Gulf South’s
Index 130 and Index 129 transmission pipelines in Mississippi, Louisiana, and Texas that pose a
pipeline integrity risk to public safety, property, or the environment.
In response to the Notice, Respondent requested an informal consultation. Respondent and
PHMSA engaged in good faith settlement discussions resulting in the Consent Agreement
attached to this Order that settles all of the allegations in the Notice.
Accordingly, the foregoing Consent Agreement is hereby approved and incorporated by
reference into this Order. The Respondent is hereby ordered to comply with the terms of the
Consent Agreement, effective immediately.
Pursuant to 49 U.S.C. 60101 et seq., failure to comply with this Consent Order may result in the
assessment of civil penalties of up to $200,000 per violation per day, or in the referral of the case
for judicial enforcement. The terms and conditions of this Consent Order are effective upon
service in accordance with 49 C.F.R. § 190.5.
___________________________________ __________________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety



CERTIFIED MAIL - RETURN RECEIPT REQUESTED
June 5, 2015
Mr. Richard Keyser
Vice President
Gulf South Pipeline Company, LP
9 Greenway Plaza, Suite 2800
Houston, TX 77046
CPF 2-2015-1001S
Dear Mr. Keyser:
Enclosed for your signature is a Consent Agreement between the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety, Southern Region and
Gulf South Pipeline Company, LP in accordance with §190.(b)(2). Once signed by both
parties the Associate Administrator for Pipeline Safety will issue a Consent Order,
incorporating the terms of the agreement, in lieu of the Safety Order proposed by the Southern
Region via the Notice of Proposed Safety Order referenced above.
Please sign the Consent Agreement and return the signed original to me. If you have any
questions on this matter or any other pipeline safety issue please call me at (404) 832-1160.
Sincerely,
Wayne T. Lemoi
Director, Office of Pipeline Safety
PHMSA Southern Region
Enclosure: Consent Agreement



DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
Southern Region
Atlanta, GA 30303
____________________________________
In the Matter of )
)
)
Gulf South Pipeline Company, LP )
Respondent )
____________________________________)
) CPF 2-2015-1001S
CONSENT AGREEMENT
On March 27, 2015, the Pipeline and Hazardous Materials Safety Administration (PHMSA),
U.S. Department of Transportation, issued to Gulf South Pipeline Company, LP1 (Gulf South or
Respondent) a Notice of Proposed Safety Order (Notice). The Notice alleged that conditions
exist on Gulf South’s Index 130 and Index 129 transmission pipelines in Mississippi, Louisiana,
and Texas that pose a pipeline integrity risk to public safety, property, or the environment.
The Notice also proposed that Respondent take certain corrective measures if necessary to
correct the alleged conditions and ensure that the public, property, and the environment are
protected from the potential risk.
Gulf South responded to the Notice by letter dated April 13, 2015 (Response). Respondent
acknowledged receipt of the proposed safety order and requested an informal consultation,2
which was held June 4, 2015, via teleconference with the Office of Pipeline Safety, Southern
Region, Atlanta, Georgia.
During the informal consultation, PHMSA and Gulf South agreed that settlement of this
proceeding will avoid further administrative proceedings or litigation and that entry into this
Consent Agreement is the most appropriate means of resolving the Notice; therefore, pursuant to
49 C.F.R. Part 190, without adjudication of any issue of fact or law, and upon consent and
agreement of Respondent and PHMSA ("the Parties"), the Parties agree as follows:
I. General Provisions
1. Respondent acknowledges that as operator of the pipeline, Respondent and its pipeline
system are subject to the jurisdiction of the Federal pipeline safety laws, 49 U.S.C. § 60101
et seq., and the regulations and administrative orders issued thereunder. For purposes of this
1 Gulf South is a subsidiary of Boardwalk Pipeline Partners.
2 Gulf South's Response is incorporated into this Consent Agreement in whole (see attached).



2
Consent Agreement, Respondent acknowledges that it received proper notice of PHMSA's action
in this proceeding and that the Notice states claims upon which relief may be granted pursuant to
49 U.S.C. 60101 et seq. and the regulations and orders issued thereunder.
2. Respondent does not admit or deny any allegation or conclusion in the Notice but agrees,
for purposes of this Consent Agreement, that the condition identified in the Notice exists and
agrees to address it by completing the actions specified in Section II of this agreement
(“Corrective Measures”). These actions, including any work plans and schedules, shall be
incorporated into this agreement. This Consent Agreement does not constitute a finding of
violation of any Federal law or regulation and therefore may not be used in any civil proceeding
of any kind as evidence or proof of any fact, fault or liability, or as evidence of the violation of
any law, rule, regulation or requirement, except in a proceeding to enforce the provisions of this
agreement or in future PHMSA enforcement actions.
3. After Respondent returns this signed agreement, PHMSA's representative will present it to
the Associate Administrator for Pipeline Safety (“Associate Administrator”) recommending that
the Associate Administrator adopt the terms of this agreement by issuing an administrative order
(Consent Order) incorporating the terms of this Consent Agreement. The terms of this agreement
constitute an offer of settlement until accepted by the Associate Administrator.
4. Respondent consents to the issuance of the Consent Order, and hereby waives any further
procedural requirements with respect to its issuance. Respondent waives all rights to contest the
adequacy of notice, or the validity of the Consent Order or this Consent Agreement, including all
rights to administrative or judicial hearings or appeals.
5. This Consent Agreement shall apply to and be binding upon PHMSA, and upon
Respondent, its officers, directors, and employees, and its successors, assigns, or other entities or
persons otherwise bound by law. Respondent agrees to provide a copy of this agreement and any
incorporated work plans and schedules to all of Respondent's officers, employees, and agents
whose duties might reasonably include compliance with this agreement.
6. For all transfers of ownership or operating responsibility of Respondent’s pipeline,
Respondent must provide a copy of this Consent Agreement to the prospective transferee at least
30 days prior to such transfer and simultaneously provide written notice of the prospective
transfer to the PHMSA Regional Director who issued the Notice.
7. This Consent Agreement constitutes the final, complete and exclusive agreement and
understanding between the Parties with respect to the settlement embodied in this agreement, and
the Parties acknowledge that there are no representations, agreements or understandings related
to the settlement other than those expressly contained in this agreement, except that the terms of
this agreement may be construed by reference to the Notice.
8. Nothing in this Consent Agreement affects or relieves Respondent of its responsibility to
comply with all applicable requirements of the Federal pipeline safety laws, 49 U.S.C. § 60101
et seq., and the regulations and orders issued thereunder. Nothing in this agreement alters
PHMSA's right of access, entry, inspection, and information gathering or PHMSA's authority to
bring enforcement actions against Respondent pursuant to the Federal pipeline safety laws, the
regulations and orders issued thereunder, or any other provision of Federal or State law.
9. This Consent Agreement does not waive or modify any Federal, State, or local laws or
regulations that are applicable to Respondent's pipeline systems. This agreement is not a permit,



3
or a modification of any permit, under any Federal, State, or local laws or regulations.
Respondent remains responsible for achieving and maintaining compliance with all applicable
Federal, State, and local laws, regulations and permits.
10. This Consent Agreement does not create rights in, or grant any cause of action to, any third
party not party to this agreement. The U.S. Department of Transportation is not liable for any
injuries or damages to persons or property arising from acts or omissions of Respondent or its
officers, employees, or agents carrying out the work required by this agreement. The U.S.
Department of Transportation, its officers, employees, agents, and representatives are not liable
for any cause of action arising from any acts or omissions of Respondent or its contractors in
carrying out any work required by this agreement.
II. Corrective Measures
11. Terms & Definitions
a. Affected Pipelines means Gulf South’s:
− Index 130 - approximately 212.9 miles from Marchand Junction (mile post 83.5) in
Ascension Parish, LA to Kosciusko (mile post 296.4) in Leake County, Mississippi;
and,
− Index 129 - approximately 385.6 miles from the Edna Compression Station (mile
post 58.8) in Jackson County, Texas to the Sterlington Compression Station (mile
post 444.4) in Ouachita Parish Louisiana.
− Affected Pipelines only include the valve sections of Index 130 and Index 129 that
contain Indicated Hard Spots (defined below).
b. Type “A” sleeves means non-pressure contacting sleeves installed on the Affected
Pipelines over Indicated Hard Spots.
Type “B” sleeves means pressure contacting sleeves installed on the Affected Pipelines
over Indicated Hard Spots.
Indicated Hard Spots means those hard spots on the Affected Pipelines with a Brinell
hardness value of 300 or greater, that are two (2) inches or greater in any direction, and
which are reinforced with Type A sleeves. Indicated Hard Spots have been identified
by Gulf South and are shown by valve section in the attached Exhibit A.
Director means Director, Office of Pipeline Safety, PHMSA Southern Region, Atlanta,
Georgia.
12. Within 30 days from the issuance of the Consent Order, Gulf South is to maintain a
pressure restriction on both Affected Pipelines of no greater than 550 psig.
f. The pressure restrictions require any relevant remote or local alarm limits, software
programming set-points or control points, and mechanical over-pressure devices to be
adjusted accordingly.
The pressure restrictions are to remain in effect in each valve section until all Type “A”
sleeves in that particular valve section have been removed or remediated in accordance
with the Remedial Work Plan described in Item 15 below, or otherwise properly
addressed using a method selected by Gulf South in consultation with PHMSA, and
c. d. e. g.



4
written approval to remove and/or modify the pressure restrictions is obtained from the
Director.
h. The Director can allow the permanent removal and/or modification of the pressure
restriction on either or both Affected Pipelines or for segments of either or both Affected
Pipelines upon a written request from Gulf South demonstrating that the corrective
measures described in the Remedial Work Plan (see Item 15 below) have been
completed.
i. The Director may allow the temporary removal and/or modification of the pressure
restriction on either or both Affected Pipelines or for segments of either or both Affected
Pipelines upon a written request from Gulf South demonstrating that preventive and
mitigative measures have been implemented and will remain in place during the
temporary removal and/or modification of the pressure restriction. The Director's
determination will be based on the evidence that preventative and mitigative actions
taken by the Respondent provide for the safe operation of the pipeline(s) or pipeline
segment(s) during the temporary removal and/or modification of the pressure
restriction.
13. j. The Director may allow the temporary or permanent removal and/or modification of
the pressure restriction on either or both Affected Pipelines or for segments of either or
both Affected Pipelines upon a written request from Gulf South demonstrating that
restoring the pipeline(s) or pipeline segment(s) to normal operating pressure is justified
based on a reliable engineering analysis showing that the pressure increase is safe
considering all known defects, anomalies, and operating parameters of the pipeline.
k. Appeals to determinations of the Director in this regard will be decided by the
Associate Administrator for Pipeline Safety.
Gulf South is to complete mechanical and metallurgical testing and failure analysis to:
l. Determine the cause of the failure on the Index 130, including an analysis of the Type
“A” sleeve which also failed on the Index 130.
m. Determine a safe operating pressure using fracture mechanics modeling for all Type
“A” sleeves that will remain on the Affected Pipelines after remediation.
n. Analyze three (3) additional Type “A” sleeves on the Index 130 from the Caney Creek
block valve (mile post 255.8) to the Fannin block valve (mile post 248.9).
o. Use the data to further validate the fracture mechanics modeling, and to analyze how
the workmanship on the Type “A” sleeve may have contributed to the pipeline failure.
14. The mechanical and metallurgical testing and failure analysis must be completed and
submitted to the Director on or before September 30, 2015, or 30 days after issuance of the
Consent Order, whichever occurs last. Ensure that each testing laboratory distributes all reports
whether draft or final in their entirety to the Director at the same time they are made available to
Gulf South.
15. Within 60 days from the issuance of this Order, Gulf South must submit a Remedial Work
Plan (RWP) to the Director for review and approval. The RWP must include a proposed
schedule for completion of the RWP and must require Gulf South to accomplish the following:



5
16. p. Remove or reinforce with a pressure containing Type “B” sleeve all Indicated Hard
Spots on both Affected Pipelines that are currently reinforced with Type “A” sleeves,
and which are located within High Consequence Areas (HCAs), Class 3 locations,
and/or within 660 feet of a habitable structure by not later than December 31, 2015.
q. Identify all the remaining Indicated Hard Spots reinforced with Type “A” sleeves (i.e.
those not removed or reinforced with a Type “B” sleeve as explained above) on both
the Affected Pipelines by mile post, station, GPS, wheel count or other stationing
method.
r. Establish a written procedure to identify within 12 calendar months any remaining
Indicated Hard Spot(s) on both Affected Pipelines reinforced with a Type “A” sleeve
(i.e. a hard spot not removed or reinforced with a Type “B” sleeve as explained above)
that becomes located within an HCA, Class 3 locations, or within 660 feet of a
habitable structure in the future due to development, an increase in population density,
or any other cause.
s. Remove or reinforce with a pressure containing Type “B” sleeve any remaining
Indicated Hard Spot on both Affected Pipelines reinforced with a Type “A” sleeve (i.e.
one not removed or reinforced with a Type “B” sleeve as explained above) if the
Indicated Hard Spot becomes located within an HCA, Class 3 location area, or within
660 feet of a habitable structure within 24 months.
The Director may approve the RWP incrementally without approving the entire RWP.
t. Once approved by the Director, the RWP will be incorporated by reference into this
Order.
u. v. Gulf South will implement the RWP as it is approved by the Director.
Gulf South must revise the RWP as necessary to incorporate new information obtained
during the failure investigation and remedial activities, to incorporate the results of
actions undertaken pursuant to this Safety Order, and/or to incorporate modifications
required by the Director. Submit any such plan revisions to the Director for review and
approval. The Director may approve plan revisions incrementally. Once approved, the
Amended RWP and all revisions will become incorporated into the Consent Order.
17. The Director may grant an extension of time for compliance with any of the terms of the
Consent Order upon a written request timely submitted demonstrating good cause for an
extension.
18. Gulf South may appeal any decision of the Director to the Associate Administrator for
Pipeline Safety. Decisions of the Associate Administrator shall be final.
19. Beginning 60 days after the Consent Order’s issuance, Gulf South is to prepare and submit
monthly progress reports to the Director. These reports should include documentation of the
costs associated with implementing the Corrective Measures and include sufficient detail to
allow the Director to track the progress of the project and to provide the Director (or his
designated representatives) an opportunity to observe and inspect future field activities as they
occur.



6
20. Gulf South agrees to maintain documentation of the costs associated with implementing the
Corrective Measures set forth in the Notice and to submit such costs to the Director with the
monthly progress reports described in the Notice.
III. Review and Approval Process
21. With respect to any submission under Section II of this Consent Agreement that requires
the approval of the Director, the Director may: (a) approve, in whole or in part, the submission,
(b) approve the submission on specified conditions, (c) disapprove, in whole or in part, the
submission, or (d) any combination of the foregoing. If the Director approves, approves in part,
or approves with conditions, Respondent will take all action as approved by the Director, subject
to Respondent's right to invoke the dispute resolution procedures in Section IV with respect to
any conditions the Director identifies. If the Director disapproves all or any portion of the
submission, the Director will provide Respondent with a written notice of the deficiencies.
Respondent will correct all deficiencies within the time specified by the Director and resubmit it
for approval.
IV. Dispute Resolution
22. The Director and Respondent will informally attempt to resolve any disputes arising under
this Consent Agreement. If Respondent and the Director are unable to informally resolve the
dispute within 15 days, Respondent may request in writing, within 10 days, a written
determination resolving the dispute from the Associate Administrator for Pipeline Safety
providing all information that Respondent believes is relevant to the dispute. If the request is
submitted as provided herein, the Associate Administrator will issue a final determination in
writing. The existence of a dispute and PHMSA's consideration of matters placed in dispute will
not excuse, toll, or suspend any term or timeframe for completion of any work to be performed
under this agreement during the pendency of the dispute resolution process except as agreed by
the Director or the Associate Administrator in writing.
V. Enforcement
23. This Consent Agreement, as adopted by the Consent Order, is subject to all enforcement
authorities available to PHMSA under 49 U.S.C. § 60101 et seq. and 49 C.F.R. Part 190,
including administrative civil penalties under § 60122 of up to $200,000 per violation for each
day the violation continues, if PHMSA determines that Respondent is not proceeding according
to the terms of the agreement, determinations made by the Director, or if appealed, decisions of
the Associate Administrator. All work plans and associated schedules set forth or referenced in
Section II will be incorporated into this Consent Agreement and are enforceable in the same
manner.
VI. Record Keeping and Information Disclosure
24. Respondent agrees to maintain records demonstrating compliance with all requirements of
this Consent Agreement for a period of at least five years following completion of all work to be
performed. For any reports, plans, or other deliverables required to be submitted to PHMSA
pursuant to this Consent Agreement, Respondent may assert a claim of business confidentiality
or other protections applicable to the release of information by PHMSA, covering part or all of



7
the information required to be submitted to PHMSA pursuant to this agreement in accordance
with 49 C.F.R. Part 7. Respondent must mark the claim of confidentiality in writing on each
page, and include a statement specifying the grounds for each claim of confidentially. PHMSA
determines release of any information submitted pursuant to this Consent Agreement in
accordance with 49 C.F.R. Part 7, the Freedom of Information Act, 5 U.S.C. § 552, DOT and/or
PHMSA policies, and other applicable regulations and Executive Orders.
VII. Modification
25. The terms of this Consent Agreement may be modified by mutual agreement of the parties.
Such modifications must be in writing and signed by both parties.
VIII. Termination
26. This Consent Agreement terminates upon completion of all terms set forth in Section II
(Corrective Measures) as determined by the Director. Respondent may request written
confirmation from PHMSA when this agreement is terminated. To the extent ongoing
monitoring is required; PHMSA may terminate this agreement with respect to all other
requirements with the exception of such monitoring. Nothing in this agreement prevents
Respondent from completing any of the obligations earlier than the deadlines provided for in this
Agreement.
IX. Ratification
27. The Parties undersigned representatives certify that they are fully authorized to enter into
the terms and conditions of this Consent Agreement and to execute and legally bind such party to
this document.
28. The Parties hereby agree to all conditions and terms of this Consent Agreement:
For PHMSA: For Respondent:
_______________________________ _________________________________
Wayne T. Lemoi Date Richard Keyser Date
Director, Office of Pipeline Safety Sr. VP, Operations
PHMSA Southern Region Gulf South Pipeline Company, LP
U.S. Department of Transportation

220151001S_Closure Letter_02092024_(15-149704S)_text.pdf

VIA ELECTRONIC MAIL TO: Tina.Baker@bwpipelines.com;
Kelly.Englehart@bwpipelines; C&SFiling@bwpipelines.com
February 9, 2024
Richard Keyser
Vice President
Gulf South Pipeline Company, LP
9 Greenway Plaza, Suite 2800
Houston, TX 77046
CPF 2-2015-1001S
Dear Mr. Keyser:
By letter dated March 27, 2015, the Pipeline and Hazardous Materials Safety Administration
(PHMSA), pursuant to chapter 601 of 49 United States Code, issued a Notice of Proposed Safety
Order to Gulf South Pipeline Company, LP. The Notice alleged that conditions exist on Gulf
South’s Index 130 and Index 129 transmission pipelines in Mississippi, Louisiana, and Texas
that pose a pipeline integrity risk to public safety, property, or the environment.
Gulf South submitted its completed remediation of all type A sleeves on April 26, 2022. My
staff reviewed the remediations that were attached to Appendix I, and it appears that the
inadequacies outlined in the Notice of Proposed Safety Order have been corrected.
This letter, in addition to the email that was sent on August 30, 2022, is to inform you no further
action is necessary and this case is now closed. Please be advised that this letter refers only to the
referenced NOPSO (CPF #2-2015-1001S) and not to any other PHMSA cases, if any. Thank you
for your cooperation.
Sincerely,
James A. Urisko
Director, Southern Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration

220151001S_Consent Agreement_06052015_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
June 5, 2015
Mr. Richard Keyser
Vice President
Gulf South Pipeline Company, LP
9 Greenway Plaza, Suite 2800
Houston, TX 77046
CPF 2-2015-1001S
Dear Mr. Keyser:
Enclosed for your signature is a Consent Agreement between the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety, Southern Region and
Gulf South Pipeline Company, LP in accordance with §190.(b)(2). Once signed by both
parties the Associate Administrator for Pipeline Safety will issue a Consent Order,
incorporating the terms of the agreement, in lieu of the Safety Order proposed by the Southern
Region via the Notice of Proposed Safety Order referenced above.
Please sign the Consent Agreement and return the signed original to me. If you have any
questions on this matter or any other pipeline safety issue please call me at (404) 832-1160.
Sincerely,
Wayne T. Lemoi
Director, Office of Pipeline Safety
PHMSA Southern Region
Enclosure: Consent Agreement



DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
Southern Region
Atlanta, GA 30303
____________________________________
In the Matter of )
)
)
Gulf South Pipeline Company, LP )
Respondent )
____________________________________)
) CPF 2-2015-1001S
CONSENT AGREEMENT
On March 27, 2015, the Pipeline and Hazardous Materials Safety Administration (PHMSA),
U.S. Department of Transportation, issued to Gulf South Pipeline Company, LP1 (Gulf South or
Respondent) a Notice of Proposed Safety Order (Notice). The Notice alleged that conditions
exist on Gulf South’s Index 130 and Index 129 transmission pipelines in Mississippi, Louisiana,
and Texas that pose a pipeline integrity risk to public safety, property, or the environment.
The Notice also proposed that Respondent take certain corrective measures if necessary to
correct the alleged conditions and ensure that the public, property, and the environment are
protected from the potential risk.
Gulf South responded to the Notice by letter dated April 13, 2015 (Response). Respondent
acknowledged receipt of the proposed safety order and requested an informal consultation,2
which was held June 4, 2015, via teleconference with the Office of Pipeline Safety, Southern
Region, Atlanta, Georgia.
During the informal consultation, PHMSA and Gulf South agreed that settlement of this
proceeding will avoid further administrative proceedings or litigation and that entry into this
Consent Agreement is the most appropriate means of resolving the Notice; therefore, pursuant to
49 C.F.R. Part 190, without adjudication of any issue of fact or law, and upon consent and
agreement of Respondent and PHMSA ("the Parties"), the Parties agree as follows:
I. General Provisions
1. Respondent acknowledges that as operator of the pipeline, Respondent and its pipeline
system are subject to the jurisdiction of the Federal pipeline safety laws, 49 U.S.C. § 60101
et seq., and the regulations and administrative orders issued thereunder. For purposes of this
1 Gulf South is a subsidiary of Boardwalk Pipeline Partners.
2 Gulf South's Response is incorporated into this Consent Agreement in whole (see attached).



2
Consent Agreement, Respondent acknowledges that it received proper notice of PHMSA's action
in this proceeding and that the Notice states claims upon which relief may be granted pursuant to
49 U.S.C. 60101 et seq. and the regulations and orders issued thereunder.
2. Respondent does not admit or deny any allegation or conclusion in the Notice but agrees,
for purposes of this Consent Agreement, that the condition identified in the Notice exists and
agrees to address it by completing the actions specified in Section II of this agreement
(“Corrective Measures”). These actions, including any work plans and schedules, shall be
incorporated into this agreement. This Consent Agreement does not constitute a finding of
violation of any Federal law or regulation and therefore may not be used in any civil proceeding
of any kind as evidence or proof of any fact, fault or liability, or as evidence of the violation of
any law, rule, regulation or requirement, except in a proceeding to enforce the provisions of this
agreement or in future PHMSA enforcement actions.
3. After Respondent returns this signed agreement, PHMSA's representative will present it to
the Associate Administrator for Pipeline Safety (“Associate Administrator”) recommending that
the Associate Administrator adopt the terms of this agreement by issuing an administrative order
(Consent Order) incorporating the terms of this Consent Agreement. The terms of this agreement
constitute an offer of settlement until accepted by the Associate Administrator.
4. Respondent consents to the issuance of the Consent Order, and hereby waives any further
procedural requirements with respect to its issuance. Respondent waives all rights to contest the
adequacy of notice, or the validity of the Consent Order or this Consent Agreement, including all
rights to administrative or judicial hearings or appeals.
5. This Consent Agreement shall apply to and be binding upon PHMSA, and upon
Respondent, its officers, directors, and employees, and its successors, assigns, or other entities or
persons otherwise bound by law. Respondent agrees to provide a copy of this agreement and any
incorporated work plans and schedules to all of Respondent's officers, employees, and agents
whose duties might reasonably include compliance with this agreement.
6. For all transfers of ownership or operating responsibility of Respondent’s pipeline,
Respondent must provide a copy of this Consent Agreement to the prospective transferee at least
30 days prior to such transfer and simultaneously provide written notice of the prospective
transfer to the PHMSA Regional Director who issued the Notice.
7. This Consent Agreement constitutes the final, complete and exclusive agreement and
understanding between the Parties with respect to the settlement embodied in this agreement, and
the Parties acknowledge that there are no representations, agreements or understandings related
to the settlement other than those expressly contained in this agreement, except that the terms of
this agreement may be construed by reference to the Notice.
8. Nothing in this Consent Agreement affects or relieves Respondent of its responsibility to
comply with all applicable requirements of the Federal pipeline safety laws, 49 U.S.C. § 60101
et seq., and the regulations and orders issued thereunder. Nothing in this agreement alters
PHMSA's right of access, entry, inspection, and information gathering or PHMSA's authority to
bring enforcement actions against Respondent pursuant to the Federal pipeline safety laws, the
regulations and orders issued thereunder, or any other provision of Federal or State law.
9. This Consent Agreement does not waive or modify any Federal, State, or local laws or
regulations that are applicable to Respondent's pipeline systems. This agreement is not a permit,



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or a modification of any permit, under any Federal, State, or local laws or regulations.
Respondent remains responsible for achieving and maintaining compliance with all applicable
Federal, State, and local laws, regulations and permits.
10. This Consent Agreement does not create rights in, or grant any cause of action to, any third
party not party to this agreement. The U.S. Department of Transportation is not liable for any
injuries or damages to persons or property arising from acts or omissions of Respondent or its
officers, employees, or agents carrying out the work required by this agreement. The U.S.
Department of Transportation, its officers, employees, agents, and representatives are not liable
for any cause of action arising from any acts or omissions of Respondent or its contractors in
carrying out any work required by this agreement.
II. Corrective Measures
11. Terms & Definitions
a. Affected Pipelines means Gulf South’s:
− Index 130 - approximately 212.9 miles from Marchand Junction (mile post 83.5) in
Ascension Parish, LA to Kosciusko (mile post 296.4) in Leake County, Mississippi;
and,
− Index 129 - approximately 385.6 miles from the Edna Compression Station (mile
post 58.8) in Jackson County, Texas to the Sterlington Compression Station (mile
post 444.4) in Ouachita Parish Louisiana.
− Affected Pipelines only include the valve sections of Index 130 and Index 129 that
contain Indicated Hard Spots (defined below).
b. Type “A” sleeves means non-pressure contacting sleeves installed on the Affected
Pipelines over Indicated Hard Spots.
Type “B” sleeves means pressure contacting sleeves installed on the Affected Pipelines
over Indicated Hard Spots.
Indicated Hard Spots means those hard spots on the Affected Pipelines with a Brinell
hardness value of 300 or greater, that are two (2) inches or greater in any direction, and
which are reinforced with Type A sleeves. Indicated Hard Spots have been identified
by Gulf South and are shown by valve section in the attached Exhibit A.
Director means Director, Office of Pipeline Safety, PHMSA Southern Region, Atlanta,
Georgia.
12. Within 30 days from the issuance of the Consent Order, Gulf South is to maintain a
pressure restriction on both Affected Pipelines of no greater than 550 psig.
f. The pressure restrictions require any relevant remote or local alarm limits, software
programming set-points or control points, and mechanical over-pressure devices to be
adjusted accordingly.
The pressure restrictions are to remain in effect in each valve section until all Type “A”
sleeves in that particular valve section have been removed or remediated in accordance
with the Remedial Work Plan described in Item 15 below, or otherwise properly
addressed using a method selected by Gulf South in consultation with PHMSA, and
c. d. e. g.



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written approval to remove and/or modify the pressure restrictions is obtained from the
Director.
h. The Director can allow the permanent removal and/or modification of the pressure
restriction on either or both Affected Pipelines or for segments of either or both Affected
Pipelines upon a written request from Gulf South demonstrating that the corrective
measures described in the Remedial Work Plan (see Item 15 below) have been
completed.
i. The Director may allow the temporary removal and/or modification of the pressure
restriction on either or both Affected Pipelines or for segments of either or both Affected
Pipelines upon a written request from Gulf South demonstrating that preventive and
mitigative measures have been implemented and will remain in place during the
temporary removal and/or modification of the pressure restriction. The Director's
determination will be based on the evidence that preventative and mitigative actions
taken by the Respondent provide for the safe operation of the pipeline(s) or pipeline
segment(s) during the temporary removal and/or modification of the pressure
restriction.
13. j. The Director may allow the temporary or permanent removal and/or modification of
the pressure restriction on either or both Affected Pipelines or for segments of either or
both Affected Pipelines upon a written request from Gulf South demonstrating that
restoring the pipeline(s) or pipeline segment(s) to normal operating pressure is justified
based on a reliable engineering analysis showing that the pressure increase is safe
considering all known defects, anomalies, and operating parameters of the pipeline.
k. Appeals to determinations of the Director in this regard will be decided by the
Associate Administrator for Pipeline Safety.
Gulf South is to complete mechanical and metallurgical testing and failure analysis to:
l. Determine the cause of the failure on the Index 130, including an analysis of the Type
“A” sleeve which also failed on the Index 130.
m. Determine a safe operating pressure using fracture mechanics modeling for all Type
“A” sleeves that will remain on the Affected Pipelines after remediation.
n. Analyze three (3) additional Type “A” sleeves on the Index 130 from the Caney Creek
block valve (mile post 255.8) to the Fannin block valve (mile post 248.9).
o. Use the data to further validate the fracture mechanics modeling, and to analyze how
the workmanship on the Type “A” sleeve may have contributed to the pipeline failure.
14. The mechanical and metallurgical testing and failure analysis must be completed and
submitted to the Director on or before September 30, 2015, or 30 days after issuance of the
Consent Order, whichever occurs last. Ensure that each testing laboratory distributes all reports
whether draft or final in their entirety to the Director at the same time they are made available to
Gulf South.
15. Within 60 days from the issuance of this Order, Gulf South must submit a Remedial Work
Plan (RWP) to the Director for review and approval. The RWP must include a proposed
schedule for completion of the RWP and must require Gulf South to accomplish the following:



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16. p. Remove or reinforce with a pressure containing Type “B” sleeve all Indicated Hard
Spots on both Affected Pipelines that are currently reinforced with Type “A” sleeves,
and which are located within High Consequence Areas (H
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