{"operation":"document","citation":"CPF 32021041NOA","title":"TEXAS GAS TRANSMISSION, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-11-05","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(a), 192.605(b)(1), 192.615(a)(7), 192.907(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021041noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021041noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021041noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32021041NOA","body":"Notice of Amendment involving TEXAS GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.605(a),  192.605(b)(1),  192.615(a)(7),  192.907(a). The case was opened on 2021-11-05 and is reported as closed as of 2022-11-22. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32021041NOA_Closure Letter_11222022_(20-172214).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021041NOA/32021041NOA_Closure%20Letter_11222022_(20-172214).pdf\n\n32021041NOA_Closure Letter_11222022_(20-172214)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021041NOA/32021041NOA_Closure%20Letter_11222022_(20-172214)_text.pdf\n\n32021041NOA_Notice of Amendment_11052021_(20-172214).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021041NOA/32021041NOA_Notice%20of%20Amendment_11052021_(20-172214).pdf\n\n32021041NOA_Notice of Amendment_11052021_(20-172214)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021041NOA/32021041NOA_Notice%20of%20Amendment_11052021_(20-172214)_text.pdf\n\n32021041NOA_Operator Response to Notice_12152021_(20-172214).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021041NOA/32021041NOA_Operator%20Response%20to%20Notice_12152021_(20-172214).pdf\n\n32021041NOA_Notice of Amendment_11052021_(20-172214)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: stan.horton@bwpipelines.com, and\ntina.baker@bwpipelines.com\nNovember 5, 2021\nStan Horton\nCEO Boardwalk Pipelines\nTexas Gas Transmission, LLC\n9 Greenway Plaza, Suite 2800\nHouston, TX 77066\nCPF 3-2021-041-NOA\nDear Mr. Horton:\nFrom February 5th, 2020 to February 9th, 2021, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected your subsidiary, Texas Gas Transmission, LLC’s (Texas Gas) Operation and\nMaintenance Program procedures in Owensboro, KY. Texas Gas Transmission is the primary for\nthe Safety Program Relationship which supports the following OPID’s: 19270 Texas Gas\nTransmission, LLC and 31728 Gulf South Pipeline Company, LLC\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nTexas Gas Transmission plans or procedures, as described below:\n1. § 192.605 Procedural manual for operations, maintenance, and emergencies\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least one each\ncalendar year. This manual must be prepared before operations of a pipeline system\n\n\n\n2. 3. commence. Appropriate parts of the manual must be kept at locations where\noperations and maintenance activities are conducted.\nBoardwalk’s procedures for internal corrosion control were found to be inadequate\nbecause they failed to define how to control internal corrosion per the requirements of\n§192.475. The requirements for internal corrosion testing specified in Boardwalk’s\nCorrosion Manual Section 3.3 stated that gas testing shall be performed: “if the flow\ndirection is changed”. Boardwalk operates a number of storage fields and bidirectional\npipelines, but does not perform testing in each instance of a flow change for these lines.\nBoardwalk must amend its procedure to specify the testing frequency required to ensure\nno corrosive condition is created from bidirectional flow.\n§ 192.605 Procedural manual for operations, maintenance, and emergencies\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least one each\ncalendar year. This manual must be prepared before operations of a pipeline system\ncommence. Appropriate parts of the manual must be kept at locations where\noperations and maintenance activities are conducted.\nBoardwalk’s Operations and Maintenance Manual (O&M) Section 3010 was found to be\ninadequate because it failed to define the frequency of inspection of its emergency\nequipment per the requirements of §192.615(a)(4). Boardwalk’s O&M Section 3010\nstates “Emergency equipment shall be periodically inspected and maintained in good\noperating condition.\" Boardwalk must amend its procedure to provide a schedule for\nconducting inspection and maintenance activities on emergency equipment.\n§ 192.605 Procedural manual for operations, maintenance, and emergencies\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least one each\ncalendar year. This manual must be prepared before operations of a pipeline system\ncommence. Appropriate parts of the manual must be kept at locations where\noperations and maintenance activities are conducted.\nBoardwalk’s Event Response Plan (ERP) was found to be inadequate because it failed to\nidentify the qualifications needed for personnel who investigate pipeline failures per the\nrequirements of §192.617. Boardwalk’s ERP Section 5 states “An employee at the scene\n2\n\n\n\n4. 5. of the event should be designated to coordinate the investigation and when necessary, a\nqualified investigative team should be established.” Boardwalk’s procedure did not\nidentify what qualifications are needed for a person to lead or participate as a member of\nthe investigative team. The procedure must be amended to provide criteria for\nestablishing an investigative team.\n§ 192.605 Procedural manual for operations, maintenance, and emergencies\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least one each\ncalendar year. This manual must be prepared before operations of a pipeline system\ncommence. Appropriate parts of the manual must be kept at locations where\noperations and maintenance activities are conducted.\nBoardwalk’s procedures were found to be inadequate because they failed to provide\npersonnel with details for determining when a pipeline has been sufficiently purged with\nair to ensure safety per the requirements of §192.629. Operations and Maintenance\nProcedure 2140 – Purging (Rev. date 12/20/2019) relied on air movers and sampling of\natmosphere in the pipeline facility to verify a safe atmosphere. The procedures failed to\nspecify what final concentration of gas in air to be left in the pipeline is considered non-\nhazardous. The procedures must be modified to ensure through testing that purged\npipelines contain a non-hazardous atmosphere.\n§ 192.605 Procedural manual for operations, maintenance, and emergencies\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least one each\ncalendar year. This manual must be prepared before operations of a pipeline system\ncommence. Appropriate parts of the manual must be kept at locations where\noperations and maintenance activities are conducted.\nBoardwalk’s procedural manual was found to be inadequate because it failed to provide\ninstructions for conducting maintenance and testing of gas detection and alarm systems\nper the requirements of §192.736. Boardwalk failed to integrate two different procedures\ninto Section 9040 – Compressor Station Gas Detection (Revision effective date\n02/14/2020) that are defined as “Work Instructions” (WI): Procedures WI-12502 CI\nTesting And Maintaining Gas Detection Alarm/Shutdown Systems and WI-12505 CI\nTesting And Maintaining Fire And Heat Detection Alarm/Shutdown Systems. These\nwork instructions were added to the manual after the inspection and found to be\nacceptable. No further action is needed by Boardwalk.\n3\n\n\n\n6. 7. § 192.605 Procedural manual for operations, maintenance, and emergencies\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least one each\ncalendar year. This manual must be prepared before operations of a pipeline system\ncommence. Appropriate parts of the manual must be kept at locations where\noperations and maintenance activities are conducted.\nBoardwalk’s procedural manual was found to be inadequate because it failed to provide\ninstructions for performing capacity calculations per the requirements of §192.743.\nSpecifically, Boardwalk failed to integrate necessary procedures into Section 2050\n\"Regulator and Overpressure Protection” (Revision effective date 01/01/2020) into its\nmanual: WI-06957 “CI Calculating Overpressure Protection Capacity (Effective date\nDecember 2019) and an application within the Operations Management System (OMS)\nRegulator and Relief Valve (RRV) which is used to perform capacity calculations, were\nnot incorporated. These procedures were added to the manual after the inspection and\nfound to be acceptable. No further action is needed by Boardwalk.\n§ 192.605 Procedural manual for operations, maintenance, and emergencies\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least once each\ncalendar year. This manual must be prepared before operations of a pipeline system\ncommence. Appropriate parts of the manual must be kept at locations where\noperations and maintenance activities are conducted.\nBoardwalk’s procedural manual was found to be inadequate because it failed to provide\ninstructions for inspection and operation of mainline valves per the requirements of\n§192.745. Specifically, procedures did not specify how valves were to be inspected by\nfield services personnel in combination with remote control of the valve by gas control.\nO&M Section 5030 “Emergency Valve Maintenance” (Revision effective date\n01/01/2020) and Task 716OP “Inspect, Maintain and Operate Valves” did not specify the\nresponsibility for personnel to operate a remote automated block valve during an\ninspection. These procedures were modified to include more detailed instructions after\nthe inspection and found to be acceptable. No further action is needed by Boardwalk.\n4\n\n\n\n8. 9. 10. § 192.605 Procedural manual for operations, maintenance, and emergencies\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least one each\ncalendar year. This manual must be prepared before operations of a pipeline system\ncommence. Appropriate parts of the manual must be kept at locations where\noperations and maintenance activities are conducted.\nTexas Gas O&M Section 5050 “Storage of Combustible Materials” was inadequate\nbecause it lacks sufficient guidance for the storage of combustible materials. CFR 49\n§192.735 requires all combustible materials not needed for operations to be stored a safe\ndistance from the compressor building. From a review of Texas Gas’ O&M Section 5050,\nit was found that the procedure refers to \"flammable and combustible liquids\" instead of\ncombustible material. Texas Gas must amend the procedure to state clearly that it applies\nto all flammable and combustible material. The procedure was amended after the\ninspection and found to be acceptable. No further action is needed by Boardwalk.\n§ 192.605 Procedural manual for operations, maintenance, and emergencies\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least one each\ncalendar year. This manual must be prepared before operations of a pipeline system\ncommence. Appropriate parts of the manual must be kept at locations where\noperations and maintenance activities are conducted.\nBoardwalk's O&M Section 2060 - Uprating was found to be inadequate per the\nrequirements of §192.553 because it does not specify the methods to be used in detecting\nleaks, or prescribe criteria for determination of which leaks are allowed to be monitored\nas nonhazardous. §192.553 requires an operator to check for leaks and repair hazardous\nleaks when uprating a pipeline; therefore, Boardwalk must amend its procedures to\nspecify in detail how leaks will be detected and graded.\n§ 192.605 Procedural manual for operations, maintenance, and emergencies\n(a) General. Each operator shall prepare and follow for each pipeline, a manual of\nwritten procedures for conducting operations and maintenance activities and for\nemergency response. For transmission lines, the manual must also include\nprocedures for handling abnormal operations. This manual must be reviewed and\nupdated by the operator at intervals not exceeding 15 months, but at least one each\ncalendar year. This manual must be prepared before operations of a pipeline system\n5\n\n\n\n11. commence. Appropriate parts of the manual must be kept at locations where\noperations and maintenance activities are conducted.\nBoardwalk's O&M Section 2020 “Conversion to Gas Service” was found to be\ninadequate because it fails to reference 49 CFR Subpart J pressure testing requirements\nfor conversion to gas service. The procedure must be amended to included conversion to\nservice requirements relevant to §192.14(a)(4) to substantiate the maximum operating\npressure. The procedure was amended after the inspection and found to be acceptable. No\nfurther action is needed by Boardwalk.\n§ 192.605 Procedural manual for operations, maintenance, and emergencies\n(a) …\n(b) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following, if applicable, to provide\nsafety during maintenance and operations.\n(1) Operating, maintaining, and repairing the pipeline in accordance with each of\nthe requirements of this subpart and Subpart M of this part.\nBoardwalk’s O&M Appendix I Subsection 10 was found to be inadequate because it\nfailed to specify how plastic pipe is to be maintained and repaired. Specifically, the\nprocedure did not require the inspection of each joint nor describe the manner in which\nthe joint must be inspected as by required by §192.287. Boardwalk’s procedure must be\namended to include inspection requirements and acceptance criteria for each plastic pipe\njoint made.\n12. § 192.605 Procedural manual for operations, maintenance, and emergencies\n(a) …\n(b) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following, if applicable, to provide\nsafety during maintenance and operations.\n(1) Operating, maintaining, and repairing the pipeline in accordance with each of\nthe requirements of this subpart and Subpart M of this part.\nBoardwalk’s O&M Section 2070 was found to be inadequate for failing to require\nreplacement pipe to be tested to pressure required for new line installed in the same\nlocation per the requirements of §192.719(a). Specifically, Boardwalk’s procedure did\nnot specify the number of joints of pretested replacement pipe that are allowed to be\ninstalled without a post-construction strength test. Therefore, Boardwalk’s procedure\nmust be amended to include criteria that identifies when replacement line pipe requires a\npost-construction strength test. The procedure was amended after the inspection and\nfound to be acceptable. No further action is needed by Boardwalk.\n6\n\n\n\n13. § 192.615 Emergency plans\n14. 15. (a) Each operator shall establish written procedures to minimize the hazard\nresulting from a gas pipeline emergency. At a minimum, the procedures must\nprovide for the following:\n(1) …\n(7) Making safe any actual or potential hazard to life or property.\nBoardwalk’s procedures were found to be inadequate because they failed to define how\nto make safe any actual or potential hazard to life. Boardwalk’s Operations and\nMaintenance Manual Section 2130 – General Operation (Rev. date 02/07/2020) and\nEmergency Response Plan (ERP) Section 4 did not define a safe evacuation perimeter for\nits personnel to ensure safety from a potential hazard or incident site. These procedures\nwere amended to include more detailed instructions after the inspection and found to be\nacceptable. No further action is needed by Boardwalk.\n§ 192.907 What must an operator do to implement this subpart?\n(a) General. No later than December 17, 2004, an operator of a covered pipeline\nsegment must develop and follow a written integrity management program that\ncontains all the elements described in §192.911 and that addresses the risks on each\ncovered transmission pipeline segment. The initial integrity management program\nmust consist, at a minimum, of a framework that describes the process for\nimplementing each program element, how relevant decisions will be made and by\nwhom, a time line for completing the work to implement the program element, and\nhow information gained from experience will be continuously incorporated into the\nprogram. The framework will evolve into a more detailed and comprehensive\nprogram. An operator must make continual improvements to the program.\nBoardwalk’s Integrity Management Plan (IMP) Chapter 2 Table 2-1 and Chapter 8 Table\n4-1 were found to be inadequate for failing to establish by whom relevant decisions will\nbe made. Specifically, these tables assign two different Boardwalk Administration Titles,\n“Mgr. Pipeline Safety” & “Integrity Management Specialist”, the same responsibility for\nPreventive and Mitigative (P&M) Measures identification. The criteria for the\nqualifications of these positions are not equivalent, the qualifications, education, training\nor experience that demonstrate knowledge of P&M Measures and threats is not identified\nand it is not clear who is responsible for implementation of P&M Measures.\n§ 192.907 What must an operator do to implement this subpart?\n(a) General. No later than December 17, 2004, an operator of a covered pipeline\nsegment must develop and follow a written integrity management program that\ncontains all the elements described in § 192.911 and that addresses the risks on each\ncovered transmission pipeline segment. The initial integrity management program\nmust consist, at a minimum, of a framework that describes the process for\nimplementing each program element, how relevant decisions will be made and by\n7\n\n\n\n16. 17. whom, a time line for completing the work to implement the program element, and\nhow information gained from experience will be continuously incorporated into the\nprogram. The framework will evolve into a more detailed and comprehensive\nprogram. An operator must make continual improvements to the program\nBoardwalk’s IMP Chapter 6 Section 3 was found to be inadequate for failing to require a\nqualified person determine reassessment intervals, per the requirements of\n§192.915(b)(3). At the time of the inspection, Boardwalk’s procedure required that the\n“Mgr. Pipeline Services” determine the reassessment interval. However, the Education,\nTraining and Experience requirements for the “Mgr. Pipeline Services” did not include\nthe knowledge and skills necessary for making decisions on actions to be taken based on\nassessments. Boardwalk must amend its procedure to ensure that a qualified person is\ndetermining the reassessment interval based on assessment results.\n§ 192.907 What must an operator do to implement this subpart?\n(a) General. No later than December 17, 2004, an operator of a covered pipeline\nsegment must develop and follow a written integrity management program that\ncontains all the elements described in §192.911 and that addresses the risks on each\ncovered transmission pipeline segment. The initial integrity management program\nmust consist, at a minimum, of a framework that describes the process for\nimplementing each program element, how relevant decisions will be made and by\nwhom, a time line for completing the work to implement the program element, and\nhow information gained from experience will be continuously incorporated into the\nprogram. The framework will evolve into a more detailed and comprehensive\nprogram. An operator must make continual improvements to the program.\nBoardwalk’s IMP Appendix 4 Section 13 was found to be inadequate for failing to state\nrepair schedules in accordance to ASME/ANSI B31.8S, section 7 per the requirements of\n§192.933(d)(1). Specifically, Boardwalk’s “Full Life” and “Half Life” corrosion growth\nrate calculations inappropriately utilized the “Install Year” of the pipeline to calculate the\ngrowth rates of corrosion defects. Boardwalk’s corrosion growth rate equations must be\namended to require the identification and utilization of appropriate information, such as\nprior assessments, to ensure defects will not grow to critical dimensions prior to the next\nassessment.\n§ 192.907 What must an operator do to implement this subpart?\n(a) General. No later than December 17, 2004, an operator of a covered pipeline\nsegment must develop and follow a written integrity management program that\ncontains all the elements described in § 192.911 and that addresses the risks on each\ncovered transmission pipeline segment. The initial integrity management program\nmust consist, at a minimum, of a framework that describes the process for\nimplementing each program element, how relevant decisions will be made and by\n8\n\n\n\n18. 19. whom, a time line for completing the work to implement the program element, and\nhow information gained from experience will be continuously incorporated into the\nprogram. The framework will evolve into a more detailed and comprehensive\nprogram. An operator must make continual improvements to the program\nBoardwalk’s IMP Chapter 8 Section 2 was found to be inadequate per the requirements\nof §192.935 because it failed to implement additional P&M measures as required by Part\n192 regulations. Specifically, the procedure states “During the evaluation process, if a\nselected HCA already has a P&M measure completed for this threat within the last three\nyear evaluation cycle, then it will be replaced with the next highest ranked HCA to ensure\nthat additional HCAs are being evaluated each cycle.” This is inconsistent with IMP\nChapter 4 Section 1.3 and IMP Chapter 8 Section 2.1 which required the implementation\nof P&M Measures be based on the annual update and review of the risk assessment.\nTherefore Boardwalk’s procedure for P&M implementation must be amended to ensure\nthat planned P&M measures are reviewed and implemented annually based on the actual\nrisk score determined by the risk analysis.\n§ 192.907 What must an operator do to implement this subpart?\n(a) General. No later than December 17, 2004, an operator of a covered pipeline\nsegment must develop and follow a written integrity management program that\ncontains all the elements described in § 192.911 and that addresses the risks on each\ncovered transmission pipeline segment. The initial integrity management program\nmust consist, at a minimum, of a framework that describes the process for\nimplementing each program element, how relevant decisions will be made and by\nwhom, a time line for completing the work to implement the program element, and\nhow information gained from experience will be continuously incorporated into the\nprogram. The framework will evolve into a more detailed and comprehensive\nprogram. An operator must make continual improvements to the program\nBoardwalk’s IMP Chapter 8 Table 2-1 “P&M Measures by Threat” was found to be\ninadequate per the requirements of §192.935(a) because it included measures that do not\ngo beyond the requirements of 49 CFR Part 192. Specifically, the procedure lists\nmeasures which are already required by Part 192 such as: “O&M Procedures Training”,\n“CP Maintain/Monitor”, and “Monitor Pipeline Excavation with Qualified Company\nPersonnel”. Boardwalk must amend its procedure to define how each P&M Measure will\nexceed regulatory requirements.\n§ 192.907 What must an operator do to implement this subpart?\n(a) General. No later than December 17, 2004, an operator of a covered pipeline\nsegment must develop and follow a written integrity management program that\ncontains all the elements described in § 192.911 and that addresses the risks on each\ncovered transmission pipeline segment. The initial integrity management program\n9\n\n\n\nmust consist, at a minimum, of a framework that describes the process for\nimplementing each program element, how relevant decisions will be made and by\nwhom, a time line for completing the work to implement the program element, and\nhow information gained from experience will be continuously incorporated into the\nprogram. The framework will evolve into a more detailed and comprehensive\nprogram. An operator must make continual improvements to the program.\nBoardwalk’s IMP Appendix 4 Table 4.1 was found to be inadequate for failing to identify\nacceptance criteria for integrity assessments performed with internal inspection tools per\nthe requirements of §192.937. Specifically, the procedure was inadequate for listing\nunacceptable tool run performance metrics as “Open for discussion”. Boardwalk’s\nprocedure must be amended so that it provides clear criteria and guidance for acceptance\nand rejection of an ILI tool run based on recorded tool performance metrics.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings.\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\nunder 5 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 §190.211. If you do not respond within 30 days of\nreceipt 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 C.F.R. § 190.206). If you are not\ncontesting this Notice, we propose that you submit your amended procedures to my office within\n45 days of receipt of this Notice. This period may be extended by written request for good\ncause. Once the inadequacies identified herein have been addressed in your amended\nprocedures, this enforcement action will be closed.\nIt is requested (not mandated) that Texas Gas Transmission maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Gregory A. Ochs, Director, Central Region, Pipeline\nand Hazardous Materials Safety Administration. In correspondence concerning this matter,\n10\n\n\n\nplease refer to CPF 3-2021-041-NOA and, for each document you submit, please provide a copy\nin electronic format whenever possible.\nSincerely,\nGregory A. Ochs\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n11\n\n32021041NOA_Closure Letter_11222022_(20-172214)_text.pdf\n\nVIA ELECTRONIC MAIL TO: stan.horton@bwpipelines.com, and\ntina.baker@bwpipelines.com\nNovember 22, 2022\nStanley C. Horton\nCEO Boardwalk Pipelines\nTexas Gas Transmission, LLC\n9 Greenway Plaza, Suite 2800\nHouston, TX 77066\nRE: CPF 3-2021-041-NOA\nDear Mr. Horton:\nFrom March 2nd to March 6th\n, 2020, a representative from the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted\nan on-site pipeline safety inspection of Texas Gas Transmission’s procedures at the Owensboro,\nKentucky Headquaters. As a result of the inspection, Texas Gas Transmission was issued a\nNotice of Amendment on November 5, 2021, which proposed amendment of your procedures.\nTexas Gas Transmission submitted its amended procedures on September 1, 2022t. My staff has\nreviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of\nAmendment have 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,\nGregory A. Ochs\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":30996}