TEXAS GAS TRANSMISSION, LLC — Notice of Amendment

party submissionOfficial PDF220151006M_Operator Response to Notice and Request For Hearing and Request for Case Documents_11112015.pdf#

220151006M_Closure Letter_11142017.pdf, page 1Official PDFU.S. Department 233 Peachtree Street Ste. 600 of Transportation Atlanta, GA 30303 Pipeline and Administration Hazardous Materials Safety CERTIFIED MAIL - RETURN RECEIPT REQUESTED November 14, 2017 Mr. Richard Keyser Sr. Vice President Operations Texas Gas Transmission, LLC Boardwalk Pipeline Partners, LP 9 Greenway Plaza, Suite 2800 Houston, TX 77046 CPF 2-2015-1006M Dear Mr. Keyser: On July 28-29, 2015, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), Southern Region inspected the Texas Gas Transmission, LLC (TGT) Operator Qualification program at your office in Owensboro, Kentucky, pursuant to Chapter 601 of 49 United States Code. TGT is a subsidiary of Boardwalk Pipeline Partners, LP (BWP). As a result of the inspection, PHMSA issued a Notice of Amendment (NOA) on October 13, 2015. The OPS Southern Region has received and reviewed several written responses to the NOA from TGT, including TT's final response dated July 21, 2016. Based on our review of these responses we have determined that TT has complied with the terms of the NOA. This case is now closed and no further action is necessary with respect to the matters involved in this case. Please be advised that this letter refers only to the referenced NOA (CPF 2-2015-1006M) and not to any other PHMSA cases, if any. Sincerely, CeL James A. Urisko Director, Office of Pipeline Safety PHMSA Southern Region#

220151006M_Notice Of Amendment_10132015_text.pdf, page 1Official PDFNOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT REQUESTED October 13, 2015 Mr. Richard Keyser Sr. Vice President Operations Texas Gas Transmission, LLC Boardwalk Pipeline Partners, LP 9 Greenway Plaza, Suite 2800 Houston, TX 77046 CPF 2-2015-1006M Dear Mr. Keyser: On July 28-29, 2015, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), Southern Region inspected the Texas Gas Transmission, LLC (TGT) Operator Qualification program at your office in Owensboro, Kentucky, pursuant to Chapter 601 of 49 United States Code. TGT is a subsidiary of Boardwalk Pipeline Partners, LP (BWP). On the basis of the inspection, PHMSA has identified apparent inadequacies within the TGT written Operator Qualification Plan as described below: 1. §192.805 Qualification program. Each operator shall have and follow a written qualification program. The program shall include provisions to: … (c) Allow individuals that are not qualified pursuant to this subpart to perform a covered task if directed and observed by an individual that is qualified; TGT’s written qualification program was inadequate because it contained span of control limits of 1:3 for some covered tasks that only 1 non-qualified individual could perform while under the direction and observation of a qualified individual. As an example, the written program lists the following tasks with a span of control limit of 1:3. • Task 408OP Inspect Cathodic Protection Rectifier • Task 409OP Inspect Interference Bonds • Task 419OP Cathodic Protection Potential Measurement#

220151006M_Notice Of Amendment_10132015_text.pdf, page 2Tasks 408OP, 409OP and 419OP all require an individual to measure voltage and/or current using an electrical meter. It is not reasonable that three individuals could be doing any of these tasks at the same time while one qualified individual is directing and observing them in a manner that would allow the qualified individual to intervene if necessary. Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. 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). 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 a Final Order. If, after opportunity for a hearing, 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. § 190.237). 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 inadequacy identified herein has been addressed in your amended procedures, this enforcement action will be closed. It is requested (not mandated) that Texas Gas Transmission maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/ revision of plans, procedures) and submit the total to the Director, Southern Region – Office of Pipeline Safety, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 2-2015-1006M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Lori Hutwagner Acting Director, Office of Pipeline Safety PHMSA Southern Region Enclosure: Response Options for Pipeline Operators in Compliance Proceedings 2#