{"operation":"document","citation":"CPF 32022064NOA","title":"GULF SOUTH PIPELINE COMPANY, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-11-17","effective_on":null,"summary":"CLOSED notice of amendment citing 192.907(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32022064noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32022064noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32022064noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32022064NOA","body":"Notice of Amendment involving GULF SOUTH PIPELINE COMPANY, LLC. PHMSA's enforcement data identifies the cited regulation as 192.907(a). The case was opened on 2022-11-17 and is reported as closed as of 2023-09-28. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32022064NOA_Closure Letter_09282023_(21-210151).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022064NOA/32022064NOA_Closure%20Letter_09282023_(21-210151).pdf\n\n32022064NOA_Closure Letter_09282023_(21-210151)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022064NOA/32022064NOA_Closure%20Letter_09282023_(21-210151)_text.pdf\n\n32022064NOA_Notice of Amendment_11172022_(21-210151).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022064NOA/32022064NOA_Notice%20of%20Amendment_11172022_(21-210151).pdf\n\n32022064NOA_Notice of Amendment_11172022_(21-210151)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022064NOA/32022064NOA_Notice%20of%20Amendment_11172022_(21-210151)_text.pdf\n\n32022064NOA_Operator Response to Notice_01162023_(21-210151).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022064NOA/32022064NOA_Operator%20Response%20to%20Notice_01162023_(21-210151).pdf\n\n32022064NOA_Closure Letter_09282023_(21-210151)_text.pdf\n\nVIA ELECTRONIC MAIL TO: stan.horton@bwpipelines.com; tina.baker@bwpipelines.com\nSeptember 28, 2023\nStanley C. Horton, CEO\nBoardwalk Pipelines, LP\n9 Greenway Plaza, Suite 2800\nHouston, TX 77066\nRE: CPF No. 3-2022-064-NOA\nDear Mr. Horton:\nFrom April 6, 2021, through November 8, 2021, a representative from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,\nconducted an on-site pipeline safety inspection of the Gulf South Pipeline Co., LLC’s, a subsidiary of\nBoardwalk Pipelines, LP (Gulf South), procedures in Louisiana, Mississippi, Alabama, Oklahoma,\nFlorida and Texas. As a result of the inspection, Gulf South was issued a Notice of Amendment on\nNovember 17, 2022, which proposed amendment of your procedures.\nGulf South submitted its amended procedures on January 16, 2023. My staff reviewed the amended\nprocedures, and discussed the implementation of the procedures with your integrity management team\non July 20, 2023, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you for\nyour cooperation.\nSincerely,\nGregory A. Ochs\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Tina Baker, Manager, Compliance Services, Boardwalk Pipelines, tina.baker@bwpipelines.com\n\n32022064NOA_Notice of Amendment_11172022_(21-210151)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: stan.horton@bwpipelines.com; tina.baker@bwpipelines.com\nNovember 17, 2022\nStanley C. Horton\nCEO Boardwalk Pipelines\nTexas Gas Transmission, LLC\n9 Greenway Plaza, Suite 2800\nHouston, TX 77066\nCPF 3-2022-064-NOA\nDear Mr. Horton:\nFrom April 6, 2021, through November 8, 2021, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code .)\ninspected your natural gas pipeline facilities of your subsidiary, Gulf South Pipeline Company, LLC,\nin Louisiana, Mississippi, Alabama, Oklahoma, Florida and Texas.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within Texas\nGas Transmission, LLC’s (TGT) plans or procedures, as described below:\n1. § 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 segment\nmust develop and follow a written integrity management program that contains all the\nelements described in § 192.911 and that addresses the risks on each covered transmission\npipeline segment. The initial integrity management program must consist, at a minimum,\nof a framework that describes the process for implementing each program element, how\nrelevant decisions will be made and by whom, a time line for completing the work to\nimplement the program element, and how information gained from experience will be\ncontinuously incorporated into the program. The framework will evolve into a more\ndetailed and comprehensive program. An operator must make continual improvements to\nthe program.\n\n\n\nThe TGT integrity management procedure titled, “Boardwalk Pipelines Gas and Liquids Integrity\nProgram (IMP)”\nwas inadequate because it did not specify how information gained from experience\nwould be continuously incorporated into the program, or how decisions for continual improvement of\nthe program would be implemented when performing the program effectiveness review required by §\n192.945. Section 192.911(a)(i) requires an operator’s intergrity management program to include a\nperformance plan as outlined in ASME/ANSI B31.8S, section 9 that includes performance measures\nmeeting the requirements of § 192.945. Section 192.945 governs the methods that an operator must\nuse to test the effectiveness of its integrity management program. Specifically, the elements described\nunder IMP Chapter 9 Performance Plan, Section 2.3, failed to define specific benchmarks or goals that\nwould be used to verify program improvement. Additionally, IMP Chapter 12, Quality Control,\nSection 3.5, failed to define adequate documentation requirements. Chapter 12 placed the\nresponsibility for effectiveness review on the “Integrity Management Supervisor”, in addition to\nSubject Matter Experts who submit feedback to the supervisor through meetings, however, the\nprocedure did not define how proposals to change the program would be incorporated or how they\nwould be prioritized. The procedure lacked detail in defining the information, schedules, and\ndocumentation methods that would be used to verify continual improvement and program\neffectiveness.\nTGT must revise its IMP program improvement process to include detailed guidance on how decisions\nwill be made, implemented, and tracked, including detailed documentation of the decisions by key\npersonnel during each review. The procedure must include detailed guidance that defines how to\nrecord and measure the progress toward improvement for each program activity or element.\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 part\nof this Notice is a document entitled Response Options for Pipeline Operators in Compliance\nProceedings.\nPlease refer to this document and note the response options. Be advised that all material you submit in\nresponse to this enforcement action is subject to being made publicly available. If you believe that any\nportion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along\nwith the complete original document you must provide a second copy of the document with the\nportions you believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 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 receipt\nof this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and\nauthorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or procedures\nare found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures\nto correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose\nthat you submit your amended procedures to my office within 60 days of receipt of this Notice. This\nperiod may be extended by written request for good cause. Once the inadequacies identified herein\nhave been addressed in your amended procedures, this enforcement action will be closed.\n\n\n\nIt is requested that Gulf South maintain documentation of the safety improvement costs associated with\nfulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to\nGregory A. Ochs Director, Central Region, Pipeline and Hazardous Materials Safety Administration.\nIn correspondence concerning this matter, please refer to CPF 3-2022-064-NOA and, for each\ndocument you submit, please provide a copy in 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\ncc: Tina Baker, Manager, Compliance Services, Boardwalk Pipelines, tina.baker@bwpipelines.com","truncated":false,"body_characters":8962}