# TEXAS GAS TRANSMISSION, LLC — Notice of Amendment

- **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:** Not available
- **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.

Official case documents:

32021041NOA_Closure Letter_11222022_(20-172214).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021041NOA/32021041NOA_Closure%20Letter_11222022_(20-172214).pdf

32021041NOA_Closure Letter_11222022_(20-172214)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021041NOA/32021041NOA_Closure%20Letter_11222022_(20-172214)_text.pdf

32021041NOA_Notice of Amendment_11052021_(20-172214).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021041NOA/32021041NOA_Notice%20of%20Amendment_11052021_(20-172214).pdf

32021041NOA_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

32021041NOA_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

32021041NOA_Notice of Amendment_11052021_(20-172214)_text.pdf

NOTICE OF AMENDMENT
VIA ELECTRONIC MAIL TO: stan.horton@bwpipelines.com, and
tina.baker@bwpipelines.com
November 5, 2021
Stan Horton
CEO Boardwalk Pipelines
Texas Gas Transmission, LLC
9 Greenway Plaza, Suite 2800
Houston, TX 77066
CPF 3-2021-041-NOA
Dear Mr. Horton:
From February 5th, 2020 to February 9th, 2021, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code
inspected your subsidiary, Texas Gas Transmission, LLC’s (Texas Gas) Operation and
Maintenance Program procedures in Owensboro, KY. Texas Gas Transmission is the primary for
the Safety Program Relationship which supports the following OPID’s: 19270 Texas Gas
Transmission, LLC and 31728 Gulf South Pipeline Company, LLC
On the basis of the inspection, PHMSA has identified the apparent inadequacies found within
Texas Gas Transmission plans or procedures, as described below:
1. § 192.605 Procedural manual for operations, maintenance, and emergencies
(a) General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operations and maintenance activities and for
emergency response. For transmission lines, the manual must also include
procedures for handling abnormal operations. This manual must be reviewed and
updated by the operator at intervals not exceeding 15 months, but at least one each
calendar year. This manual must be prepared before operations of a pipeline system



2. 3. commence. Appropriate parts of the manual must be kept at locations where
operations and maintenance activities are conducted.
Boardwalk’s procedures for internal corrosion control were found to be inadequate
because they failed to define how to control internal corrosion per the requirements of
§192.475. The requirements for internal corrosion testing specified in Boardwalk’s
Corrosion Manual Section 3.3 stated that gas testing shall be performed: “if the flow
direction is changed”. Boardwalk operates a number of storage fields and bidirectional
pipelines, but does not perform testing in each instance of a flow change for these lines.
Boardwalk must amend its procedure to specify the testing frequency required to ensure
no corrosive condition is created from bidirectional flow.
§ 192.605 Procedural manual for operations, maintenance, and emergencies
(a) General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operations and maintenance activities and for
emergency response. For transmission lines, the manual must also include
procedures for handling abnormal operations. This manual must be reviewed and
updated by the operator at intervals not exceeding 15 months, but at least one each
calendar year. This manual must be prepared before operations of a pipeline system
commence. Appropriate parts of the manual must be kept at locations where
operations and maintenance activities are conducted.
Boardwalk’s Operations and Maintenance Manual (O&M) Section 3010 was found to be
inadequate because it failed to define the frequency of inspection of its emergency
equipment per the requirements of §192.615(a)(4). Boardwalk’s O&M Section 3010
states “Emergency equipment shall be periodically inspected and maintained in good
operating condition." Boardwalk must amend its procedure to provide a schedule for
conducting inspection and maintenance activities on emergency equipment.
§ 192.605 Procedural manual for operations, maintenance, and emergencies
(a) General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operations and maintenance activities and for
emergency response. For transmission lines, the manual must also include
procedures for handling abnormal operations. This manual must be reviewed and
updated by the operator at intervals not exceeding 15 months, but at least one each
calendar year. This manual must be prepared before operations of a pipeline system
commence. Appropriate parts of the manual must be kept at locations where
operations and maintenance activities are conducted.
Boardwalk’s Event Response Plan (ERP) was found to be inadequate because it failed to
identify the qualifications needed for personnel who investigate pipeline failures per the
requirements of §192.617. Boardwalk’s ERP Section 5 states “An employee at the scene
2



4. 5. of the event should be designated to coordinate the investigation and when necessary, a
qualified investigative team should be established.” Boardwalk’s procedure did not
identify what qualifications are needed for a person to lead or participate as a member of
the investigative team. The procedure must be amended to provide criteria for
establishing an investigative team.
§ 192.605 Procedural manual for operations, maintenance, and emergencies
(a) General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operations and maintenance activities and for
emergency response. For transmission lines, the manual must also include
procedures for handling abnormal operations. This manual must be reviewed and
updated by the operator at intervals not exceeding 15 months, but at least one each
calendar year. This manual must be prepared before operations of a pipeline system
commence. Appropriate parts of the manual must be kept at locations where
operations and maintenance activities are conducted.
Boardwalk’s procedures were found to be inadequate because they failed to provide
personnel with details for determining when a pipeline has been sufficiently purged with
air to ensure safety per the requirements of §192.629. Operations and Maintenance
Procedure 2140 – Purging (Rev. date 12/20/2019) relied on air movers and sampling of
atmosphere in the pipeline facility to verify a safe atmosphere. The procedures failed to
specify what final concentration of gas in air to be left in the pipeline is considered non-
hazardous. The procedures must be modified to ensure through testing that purged
pipelines contain a non-hazardous atmosphere.
§ 192.605 Procedural manual for operations, maintenance, and emergencies
(a) General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operations and maintenance activities and for
emergency response. For transmission lines, the manual must also include
procedures for handling abnormal operations. This manual must be reviewed and
updated by the operator at intervals not exceeding 15 months, but at least one each
calendar year. This manual must be prepared before operations of a pipeline system
commence. Appropriate parts of the manual must be kept at locations where
operations and maintenance activities are conducted.
Boardwalk’s procedural manual was found to be inadequate because it failed to provide
instructions for conducting maintenance and testing of gas detection and alarm systems
per the requirements of §192.736. Boardwalk failed to integrate two different procedures
into Section 9040 – Compressor Station Gas Detection (Revision effective date
02/14/2020) that are defined as “Work Instructions” (WI): Procedures WI-12502 CI
Testing And Maintaining Gas Detection Alarm/Shutdown Systems and WI-12505 CI
Testing And Maintaining Fire And Heat Detection Alarm/Shutdown Systems. These
work instructions were added to the manual after the inspection and found to be
acceptable. No further action is needed by Boardwalk.
3



6. 7. § 192.605 Procedural manual for operations, maintenance, and emergencies
(a) General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operations and maintenance activities and for
emergency response. For transmission lines, the manual must also include
procedures for handling abnormal operations. This manual must be reviewed and
updated by the operator at intervals not exceeding 15 months, but at least one each
calendar year. This manual must be prepared before operations of a pipeline system
commence. Appropriate parts of the manual must be kept at locations where
operations and maintenance activities are conducted.
Boardwalk’s procedural manual was found to be inadequate because it failed to provide
instructions for performing capacity calculations per the requirements of §192.743.
Specifically, Boardwalk failed to integrate necessary procedures into Section 2050
"Regulator and Overpressure Protection” (Revision effective date 01/01/2020) into its
manual: WI-06957 “CI Calculating Overpressure Protection Capacity (Effective date
December 2019) and an application within the Operations Management System (OMS)
Regulator and Relief Valve (RRV) which is used to perform capacity calculations, were
not incorporated. These procedures were added to the manual after the inspection and
found to be acceptable. No further action is needed by Boardwalk.
§ 192.605 Procedural manual for operations, maintenance, and emergencies
(a) General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operations and maintenance activities and for
emergency response. For transmission lines, the manual must also include
procedures for handling abnormal operations. This manual must be reviewed and
updated by the operator at intervals not exceeding 15 months, but at least once each
calendar year. This manual must be prepared before operations of a pipeline system
commence. Appropriate parts of the manual must be kept at locations where
operations and maintenance activities are conducted.
Boardwalk’s procedural manual was found to be inadequate because it failed to provide
instructions for inspection and operation of mainline valves per the requirements of
§192.745. Specifically, procedures did not specify how valves were to be inspected by
field services personnel in combination with remote control of the valve by gas control.
O&M Section 5030 “Emergency Valve Maintenance” (Revision effective date
01/01/2020) and Task 716OP “Inspect, Maintain and Operate Valves” did not specify the
responsibility for personnel to operate a remote automated block valve during an
inspection. These procedures were modified to include more detailed instructions after
the inspection and found to be acceptable. No further action is needed by Boardwalk.
4



8. 9. 10. § 192.605 Procedural manual for operations, maintenance, and emergencies
(a) General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operations and maintenance activities and for
emergency response. For transmission lines, the manual must also include
procedures for handling abnormal operations. This manual must be reviewed and
updated by the operator at intervals not exceeding 15 months, but at least one each
calendar year. This manual must be prepared before operations of a pipeline system
commence. Appropriate parts of the manual must be kept at locations where
operations and maintenance activities are conducted.
Texas Gas O&M Section 5050 “Storage of Combustible Materials” was inadequate
because it lacks sufficient guidance for the storage of combustible materials. CFR 49
§192.735 requires all combustible materials not needed for operations to be stored a safe
distance from the compressor building. From a review of Texas Gas’ O&M Section 5050,
it was found that the procedure refers to "flammable and combustible liquids" instead of
combustible material. Texas Gas must amend the procedure to state clearly that it applies
to all flammable and combustible material. The procedure was amended after the
inspection and found to be acceptable. No further action is needed by Boardwalk.
§ 192.605 Procedural manual for operations, maintenance, and emergencies
(a) General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operations and maintenance activities and for
emergency response. For transmission lines, the manual must also include
procedures for handling abnormal operations. This manual must be reviewed and
updated by the operator at intervals not exceeding 15 months, but at least one each
calendar year. This manual must be prepared before operations of a pipeline system
commence. Appropriate parts of the manual must be kept at locations where
operations and maintenance activities are conducted.
Boardwalk's O&M Section 2060 - Uprating was found to be inadequate per the
requirements of §192.553 because it does not specify the methods to be used in detecting
leaks, or prescribe criteria for determination of which leaks are allowed to be monitored
as nonhazardous. §192.553 requires an operator to check for leaks and repair hazardous
leaks when uprating a pipeline; therefore, Boardwalk must amend its procedures to
specify in detail how leaks will be detected and graded.
§ 192.605 Procedural manual for operations, maintenance, and emergencies
(a) General. Each operator shall prepare and follow for each pipeline, a manual of
written procedures for conducting operations and maintenance activities and for
emergency response. For transmission lines, the manual must also include
procedures for handling abnormal operations. This manual must be reviewed and
updated by the operator at intervals not exceeding 15 months, but at least one each
calendar year. This manual must be prepared before operations of a pipeline system
5



11. commence. Appropriate parts of the manual must be kept at locations where
operations and maintenance activities are conducted.
Boardwalk's O&M Section 2020 “Conversion to Gas Service” was found to be
inadequate because it fails to reference 49 CFR Subpart J pressure testing requirements
for conversion to gas service. The procedure must be amended to included conversion to
service requirements relevant to §192.14(a)(4) to substantiate the maximum operating
pressure. The procedure was amended after the inspection and found to be acceptable. No
further action is needed by Boardwalk.
§ 192.605 Procedural manual for operations, maintenance, and emergencies
(a) …
(b) Maintenance and normal operations. The manual required by paragraph (a) of
this section must include procedures for the following, if applicable, to provide
safety during maintenance and operations.
(1) Operating, maintaining, and repairing the pipeline in accordance with each of
the requirements of this subpart and Subpart M of this part.
Boardwalk’s O&M Appendix I Subsection 10 was found to be inadequate because it
failed to specify how plastic pipe is to be maintained and repaired. Specifically, the
procedure did not require the inspection of each joint nor describe the manner in which
the joint must be inspected as by required by §192.287. Boardwalk’s procedure must be
amended to include inspection requirements and acceptance criteria for each plastic pipe
joint made.
12. § 192.605 Procedural manual for operations, maintenance, and emergencies
(a) …
(b) Maintenance and normal operations. The manual required by paragraph (a) of
this section must include procedures for the following, if applicable, to provide
safety during maintenance and operations.
(1) Operating, maintaining, and repairing the pipeline in accordance with each of
the requirements of this subpart and Subpart M of this part.
Boardwalk’s O&M Section 2070 was found to be inadequate for failing to require
replacement pipe to be tested to pressure required for new line installed in the same
location per the requirements of §192.719(a). Specifically, Boardwalk’s procedure did
not specify the number of joints of pretested replacement pipe that are allowed to be
installed without a post-construction strength test. Therefore, Boardwalk’s procedure
must be amended to include criteria that identifies when replacement line pipe requires a
post-construction strength test. The procedure was amended after the inspection and
found to be acceptable. No further action is needed by Boardwalk.
6



13. § 192.615 Emergency plans
14. 15. (a) Each operator shall establish written procedures to minimize the hazard
resulting from a gas pipeline emergency. At a minimum, the procedures must
provide for the following:
(1) …
(7) Making safe any actual or potential hazard to life or property.
Boardwalk’s procedures were found to be inadequate because they failed to define how
to make safe any actual or potential hazard to life. Boardwalk’s Operations and
Maintenance Manual Section 2130 – General Operation (Rev. date 02/07/2020) and
Emergency Response Plan (ERP) Section 4 did not define a safe evacuation perimeter for
its personnel to ensure safety from a potential hazard or incident site. These procedures
were amended to include more detailed instructions after the inspection and found to be
acceptable. No further action is needed by Boardwalk.
§ 192.907 What must an operator do to implement this subpart?
(a) General. No later than December 17, 2004, an operator of a covered pipeline
segment must develop and follow a written integrity management program that
contains all the elements described in §192.911 and that addresses the risks on each
covered transmission pipeline segment. The initial integrity management program
must consist, at a minimum, of a framework that describes the process for
implementing each program element, how relevant decisions will be made and by
whom, a time line for completing the work to implement the program element, and
how information gained from experience will be continuously incorporated into the
program. The framework will evolve into a more detailed and comprehensive
program. An operator must make continual improvements to the program.
Boardwalk’s Integrity Management Plan (IMP) Chapter 2 Table 2-1 and Chapter 8 Table
4-1 were found to be inadequate for failing to establish by whom relevant decisions will
be made. Specifically, these tables assign two different Boardwalk Administration Titles,
“Mgr. Pipeline Safety” & “Integrity Management Specialist”, the same responsibility for
Preventive and Mitigative (P&M) Measures identification. The criteria for the
qualifications of these positions are not equivalent, the qualifications, education, training
or experience that demonstrate knowledge of P&M Measures and threats is not identified
and it is not clear who is responsible for implementation of P&M Measures.
§ 192.907 What must an operator do to implement this subpart?
(a) General. No later than December 17, 2004, an operator of a covered pipeline
segment must develop and follow a written integrity management program that
contains all the elements described in § 192.911 and that addresses the risks on each
covered transmission pipeline segment. The initial integrity management program
must consist, at a minimum, of a framework that describes the process for
implementing each program element, how relevant decisions will be made and by
7



16. 17. whom, a time line for completing the work to implement the program element, and
how information gained from experience will be continuously incorporated into the
program. The framework will evolve into a more detailed and comprehensive
program. An operator must make continual improvements to the program
Boardwalk’s IMP Chapter 6 Section 3 was found to be inadequate for failing to require a
qualified person determine reassessment intervals, per the requirements of
§192.915(b)(3). At the time of the inspection, Boardwalk’s procedure required that the
“Mgr. Pipeline Services” determine the reassessment interval. However, the Education,
Training and Experience requirements for the “Mgr. Pipeline Services” did not include
the knowledge and skills necessary for making decisions on actions to be taken based on
assessments. Boardwalk must amend its procedure to ensure that a qualified person is
determining the reassessment interval based on assessment results.
§ 192.907 What must an operator do to implement this subpart?
(a) General. No later than December 17, 2004, an operator of a covered pipeline
segment must develop and follow a written integrity management program that
contains all the elements described in §192.911 and that addresses the risks on each
covered transmission pipeline segment. The initial integrity management program
must consist, at a minimum, of a framework that describes the process for
implementing each program element, how relevant decisions will be made and by
whom, a time line for completing the work to implement the program element, and
how information gained from experience will be continuously incorporated into the
program. The framework will evolve into a more detailed and comprehensive
program. An operator must make continual improvements to the program.
Boardwalk’s IMP Appendix 4 Section 13 was found to be inadequate for failing to state
repair schedules in accordance to ASME/ANSI B31.8S, section 7 per the requirements of
§192.933(d)(1). Specifically, Boardwalk’s “Full Life” and “Half Life” corrosion growth
rate calculations inappropriately utilized the “Install Year” of the pipeline to calculate the
growth rates of corrosion defects. Boardwalk’s corrosion growth rate equations must be
amended to require the identification and utilization of appropriate information, such as
prior assessments, to ensure defects will not grow to critical dimensions prior to the next
assessment.
§ 192.907 What must an operator do to implement this subpart?
(a) General. No later than December 17, 2004, an operator of a covered pipeline
segment must develop and follow a written integrity management program that
contains all the elements described in § 192.911 and that addresses the risks on each
covered transmission pipeline segment. The initial integrity management program
must consist, at a minimum, of a framework that describes the process for
implementing each program element, how relevant decisions will be made and by
8



18. 19. whom, a time line for completing the work to implement the program element, and
how information gained from experience will be continuously incorporated into the
program. The framework will evolve into a more detailed and comprehensive
program. An operator must make continual improvements to the program
Boardwalk’s IMP Chapter 8 Section 2 was found to be inadequate per the requirements
of §192.935 because it failed to implement additional P&M measures as required by Part
192 regulations. Specifically, the procedure states “During the evaluation process, if a
selected HCA already has a P&M measure completed for this threat within the last three
year evaluation cycle, then it will be replaced with the next highest ranked HCA to ensure
that additional HCAs are being evaluated each cycle.” This is inconsistent with IMP
Chapter 4 Section 1.3 and IMP Chapter 8 Section 2.1 which required the implementation
of P&M Measures be based on the annual update and review of the risk assessment.
Therefore Boardwalk’s procedure for P&M implementation must be amended to ensure
that planned P&M measures are reviewed and implemented annually based on the actual
risk score determined by the risk analysis.
§ 192.907 What must an operator do to implement this subpart?
(a) General. No later than December 17, 2004, an operator of a covered pipeline
segment must develop and follow a written integrity management program that
contains all the elements described in § 192.911 and that addresses the risks on each
covered transmission pipeline segment. The initial integrity management program
must consist, at a minimum, of a framework that describes the process for
implementing each program element, how relevant decisions will be made and by
whom, a time line for completing the work to implement the program element, and
how information gained from experience will be continuously incorporated into the
program. The framework will evolve into a more detailed and comprehensive
program. An operator must make continual improvements to the program
Boardwalk’s IMP Chapter 8 Table 2-1 “P&M Measures by Threat” was found to be
inadequate per the requirements of §192.935(a) because it included measures that do not
go beyond the requirements of 49 CFR Part 192. Specifically, the procedure lists
measures which are already required by Part 192 such as: “O&M Procedures Training”,
“CP Maintain/Monitor”, and “Monitor Pipeline Excavation with Qualified Company
Personnel”. Boardwalk must amend its procedure to define how each P&M Measure will
exceed regulatory requirements.
§ 192.907 What must an operator do to implement this subpart?
(a) General. No later than December 17, 2004, an operator of a covered pipeline
segment must develop and follow a written integrity management program that
contains all the elements described in § 192.911 and that addresses the risks on each
covered transmission pipeline segment. The initial integrity management program
9



must consist, at a minimum, of a framework that describes the process for
implementing each program element, how relevant decisions will be made and by
whom, a time line for completing the work to implement the program element, and
how information gained from experience will be continuously incorporated into the
program. The framework will evolve into a more detailed and comprehensive
program. An operator must make continual improvements to the program.
Boardwalk’s IMP Appendix 4 Table 4.1 was found to be inadequate for failing to identify
acceptance criteria for integrity assessments performed with internal inspection tools per
the requirements of §192.937. Specifically, the procedure was inadequate for listing
unacceptable tool run performance metrics as “Open for discussion”. Boardwalk’s
procedure must be amended so that it provides clear criteria and guidance for acceptance
and rejection of an ILI tool run based on recorded tool performance metrics.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. 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).
Following the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under §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 C.F.R. § 190.206). If you are not
contesting this Notice, we propose that you submit your amended procedures to my office within
45 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 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 Gregory A. Ochs, Director, Central Region, Pipeline
and Hazardous Materials Safety Administration. In correspondence concerning this matter,
10



please refer to CPF 3-2021-041-NOA and, for each document you submit, please provide a copy
in electronic format whenever possible.
Sincerely,
Gregory A. Ochs
Director, Central Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings
11

32021041NOA_Closure Letter_11222022_(20-172214)_text.pdf

VIA ELECTRONIC MAIL TO: stan.horton@bwpipelines.com, and
tina.baker@bwpipelines.com
November 22, 2022
Stanley C. Horton
CEO Boardwalk Pipelines
Texas Gas Transmission, LLC
9 Greenway Plaza, Suite 2800
Houston, TX 77066
RE: CPF 3-2021-041-NOA
Dear Mr. Horton:
From March 2nd to March 6th
, 2020, 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 Texas Gas Transmission’s procedures at the Owensboro,
Kentucky Headquaters. As a result of the inspection, Texas Gas Transmission was issued a
Notice of Amendment on November 5, 2021, which proposed amendment of your procedures.
Texas Gas Transmission submitted its amended procedures on September 1, 2022t. My staff has
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,
Gregory A. Ochs
Director, Central Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
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