# BOARDWALK PETROCHEMICAL PIPELINE, LLC — Notice of Amendment

- **operation:** document
- **citation:** CPF 32023013NOA
- **title:** BOARDWALK PETROCHEMICAL PIPELINE, LLC — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2023-07-20
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 195.446(a), 195.446(b)(3), 195.446(c)(1), 195.446(c)(2), 195.446(c)(3), 195.446(d), 195.446(e)(1), 195.446(e)(5), 195.446(e)(6), 195.446(f)(1).
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-32023013noa.md
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/32023013NOA
**body:**

Notice of Amendment involving BOARDWALK PETROCHEMICAL PIPELINE, LLC. PHMSA's enforcement data identifies the cited regulations as 195.446(a),  195.446(b)(3),  195.446(c)(1),  195.446(c)(2),  195.446(c)(3),  195.446(d),  195.446(e)(1),  195.446(e)(5),  195.446(e)(6),  195.446(f)(1). The case was opened on 2023-07-20 and is reported as closed as of 2023-12-07. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

32023013NOA_Closure Letter_12072023_(22-250434).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023013NOA/32023013NOA_Closure%20Letter_12072023_(22-250434).pdf

32023013NOA_Closure Letter_12072023_(22-250434)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023013NOA/32023013NOA_Closure%20Letter_12072023_(22-250434)_text.pdf

32023013NOA_Notice of Amendment_07202023_(22-250434).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023013NOA/32023013NOA_Notice%20of%20Amendment_07202023_(22-250434).pdf

32023013NOA_Notice of Amendment_07202023_(22-250434)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023013NOA/32023013NOA_Notice%20of%20Amendment_07202023_(22-250434)_text.pdf

32023013NOA_Operator Response to Notice_08172023_(22-250434).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023013NOA/32023013NOA_Operator%20Response%20to%20Notice_08172023_(22-250434).pdf

32023013NOA_Closure Letter_12072023_(22-250434)_text.pdf

VIA ELECTRONIC MAIL TO: stan.horton@bwpipelines.com; tina.baker@bwpipelines.com
December 7, 2023
Mr. Stanley Horton
President/CEO
Boardwalk Petrochemical Pipeline, LLC
9 Greenway Plaza, Suite 2800
Houston, TX 77036
RE: CPF 3-2022-013-NOA
Dear Mr. Horton:
From September 19 through September 23, 2022, 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 Boaredwalk Petrochemical
Pipeline, LLC (Boardwalk) procedures in Sulphur, Louisiana. As a result of the inspection,
Boardwalk was issued a Notice of Amendment on July 2023, which proposed amendment of
your procedures.
Boardwalk submitted its amended procedures on August 17, 2023. My staff 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
cc: Tina Baker, Manager Compliance Service, tina.baker@bwpipelines.com

32023013NOA_Notice of Amendment_07202023_(22-250434)_text.pdf

NOTICE OF AMENDMENT
VIA ELECTRONIC MAIL TO: stan.horton@bwpipelines.com; tina.baker@bwpipelines.com
July 20, 2023
Mr. Stanley Horton
President/CEO
Boardwalk Petrochemical Pipeline, LLC
9 Greenway Plaza, Suite 2800
Houston, TX 77036
CPF 3-2023-013-NOA
Dear Mr. Horton:
From September 19 to September 23, 2022, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code
(U.S.C.), inspected, by means of video conference, Boardwalk Petrochemical Pipeline, LLC’s
(Boardwalk) procedures for Control Room Management (CRM) in Sulphur Springs, Louisiana.
As a result of the inspection, PHMSA has identified the apparent inadequacies found within
Boardwalk’s plans or procedures. The items inspected and the inadequacies are described
below:
1. § 195.446 Control room management.
(a) General. This section applies to each operator of a pipeline facility with a
controller working in a control room who monitors and controls all or part of a
pipeline facility through a SCADA system. Each operator must have and follow
written control room management procedures that implement the requirements
of this section. The procedures required by this section must be integrated as
appropriate, with the operator’s written procedures required by § 195.402. An
operator must develop the procedures no later than August 1, 2011, and must
implement the procedures according to the following schedule. The procedures
required by paragraphs (b), (c)(5), (d)(2) and (d)(3), (f) and (g) of this section
must be implemented no later than October 1, 2011. The procedures required
by paragraphs (c)(1) through (4), (d)(1), (d)(4), and (e) must be implemented no
later than August 1, 2012. The training procedures required by paragraph (h)



must be implemented no later than August 1, 2012, except that any training
required by another paragraph of this section must be implemented no later
than the deadline for that paragraph.
(b) Roles and Responsibilities. Each operator must define the roles and
responsibilities of a controller during normal, abnormal and emergency
operation conditions. To provide for a controller’s prompt and appropriate
response to operating conditions, and operator must define each of the following:
(1) ….
(3) A controllers role during an emergency, even if the controller is not the first to
detect the emergency, including the controllers responsibility to take specific
actions and to communicate with others;
Boardwalk's procedures CRM Plan 7/27/2022 Rev 5.30 and BWP 6618-HL were not adequate to
support control room evacuation. Missing from the procedure were steps relating to muster point
locations, and who decides to return to the primary control room or go to the backup control
room. Also, the plan included utilizing the qualified manager of the control room to monitor the
system remotely on a laptop computer. This required quick notification of the manager to allow
for monitoring during the controller absence. Missing from the procedure was a step related to
calling the manager to remotely monitor the system.
The procedure needs to be amended to include additional information related to muster points,
who makes the decision to return to the primary control room or go to back up control room, and
a step to call the manager to remotely monitor the system.
Following the inspection, Boardwalk followed up with amended procedures. Upon review, the
amended procedures were determined adequate. No further action is required.
2. § 195.446 Control room management.
(a) General. This section applies to each operator of a pipeline facility with a
controller working in a control room who monitors and controls all or part of a
pipeline facility through a SCADA system. Each operator must have and follow
written control room management procedures that implement the requirements
of this section. The procedures required by this section must be integrated as
appropriate, with the operator’s written procedures required by §195.402. An
operator must develop the procedures no later than August 1, 2011, and must
implement the procedures according to the following schedule. The procedures
required by paragraphs (b), (c)(5), (d)(2) and (d)(3), (f) and (g) of this section
must be implemented no later than October 1, 2011. The procedures required
by paragraphs (c)(1) through (4), (d)(1), (d)(4), and (e) must be implemented no
later than August 1, 2012. The training procedures required by paragraph (h)
must be implemented no later than August 1, 2012, except that any training
required by another paragraph of this section must be implemented no later
than the deadline for that paragraph.
(b) ….



(c) Provide adequate information. Each operator must provide its controllers with
the information tools, processes and procedures necessary for the controllers to
carry out the roles and responsibilities the operator has defined by performing
each of the following:
(1) Implement API RP 1165 (incorporated by reference, see §195.3) whenever a
SCADA system is added, expanded or replaced, unless the operator
demonstrates that certain provisions of API RP 1165 are not practical for the
SCADA system used;
Boardwalk’s CRM Plan Rev 5.30 7/27/2022 was not adequate to define addition, expansion or
replacement to demonstrate compliance when implementing API 1165. In addition to
definitions, there were no examples to provide support of the definitions and future control room
/ SCADA activities.
The procedure needs to be amended to provide definitions and examples of addition, expansion,
and replacement of a SCADA system to implement API 1165.
Following inspection, Boardwalk followed up with amended procedures. Upon review, the
amended procedures were determined adequate. No further action is required.
3. § 195.446 Control room management.
(a) General. This section applies to each operator of a pipeline facility with a
controller working in a control room who monitors and controls all or part of a
pipeline facility through a SCADA system. Each operator must have and follow
written control room management procedures that implement the requirements
of this section. The procedures required by this section must be integrated as
appropriate, with the operator’s written procedures required by §195.402. An
operator must develop the procedures no later than August 1, 2011, and must
implement the procedures according to the following schedule. The procedures
required by paragraphs (b), (c)(5), (d)(2) and (d)(3), (f) and (g) of this section
must be implemented no later than October 1, 2011. The procedures required
by paragraphs (c)(1) through (4), (d)(1), (d)(4), and (e) must be implemented no
later than August 1, 2012. The training procedures required by paragraph (h)
must be implemented no later than August 1, 2012, except that any training
required by another paragraph of this section must be implemented no later
than the deadline for that paragraph.
(b) ….
(c) Provide adequate information. Each operator must provide its controllers with
the information tools, processes and procedures necessary for the controllers to
carry out the roles and responsibilities the operator has defined by performing
each of the following:
(1) ….
(2) Conduct point-to-point verification between SCADA displays and related field
equipment when field equipment is added or removed and when other changes
that affect pipeline safety are made to field equipment or SCADA displays;



Boardwalk’s CRM Plan Rev 5.30 7/27/2022 was not adequate to define and prioritize leak
alarms as safety-related. A review of the SCADA alarm database for both analogue and status
points revealed there were a few additional alarms identified as safety-related that were not
included in the procedure. Boardwalk also provided Rate of Change (ROC) alarms for pressures
and flows. The benchmark value was not designed with any priority or set point parameters for
alarming. Because Appendix 8, of the CRM Plan, identified that pressure and flow ROC can be
an indication for a leak, some alarming level should be considered as safety-related; none was
provided.
The procedure needs to be amended to provide some consideration for leak detection
points/alarms and ROC as safety-related, as well as include the additional tags identified in the
SCADA database noted as safety-related (if the operator determines them to be safety-related).
4. § 195.446 Control room management.
(a) General. This section applies to each operator of a pipeline facility with a
controller working in a control room who monitors and controls all or part of a
pipeline facility through a SCADA system. Each operator must have and follow
written control room management procedures that implement the requirements
of this section. The procedures required by this section must be integrated as
appropriate, with the operator’s written procedures required by §195.402. An
operator must develop the procedures no later than August 1, 2011, and must
implement the procedures according to the following schedule. The procedures
required by paragraphs (b), (c)(5), (d)(2) and (d)(3), (f) and (g) of this section
must be implemented no later than October 1, 2011. The procedures required
by paragraphs (c)(1) through (4), (d)(1), (d)(4), and (e) must be implemented no
later than August 1, 2012. The training procedures required by paragraph (h)
must be implemented no later than August 1, 2012, except that any training
required by another paragraph of this section must be implemented no later
than the deadline for that paragraph.
(b) ….
(c) Provide adequate information. Each operator must provide its controllers with
the information, tools, processes and procedures necessary for the controllers to
carry out the roles and responsibilities the operator has defined by performing
each of the following:
(1) ….
(3) Test and verify an internal communication plan to provide adequate means for
manual operation of the pipeline safely, at least once each calendar year, but at
intervals not to exceed 15 months;
Boardwalk’s CRM Plan Rev 5.30 7/27/2022 Section 4.9 and Task 6650 was not adequate to test
and verify their internal communication plan for the manual operation of the pipeline. While the
procedure was well thought out, the procedure was missing: a consistent method to record the
information related to shut down to ensure everything was in the desired appropriate state for
shutdown, a process to document information over a long outage timeframe over multiple



controllers shifts, and a process for monitoring and reporting leaks, abnormal operations and
emergencies.
The procedure needs to be amended to provide a consistent method to record the information
related to shut down to ensure everything was in the desired appropriate state for shutdown. The
procedure must include steps to document information over a long outage timeframe over
multiple controllers shifts and a process for monitoring and reporting leaks, abnormal operations
and emergencies.
5. § 195.446 Control room management.
(a) General. This section applies to each operator of a pipeline facility with a
controller working in a control room who monitors and controls all or part of a
pipeline facility through a SCADA system. Each operator must have and follow
written control room management procedures that implement the requirements
of this section. The procedures required by this section must be integrated as
appropriate, with the operator’s written procedures required by §195.402. An
operator must develop the procedures no later than August 1, 2011, and must
implement the procedures according to the following schedule. The procedures
required by paragraphs (b), (c)(5), (d)(2) and (d)(3), (f) and (g) of this section
must be implemented no later than October 1, 2011. The procedures required
by paragraphs (c)(1) through (4), (d)(1), (d)(4), and (e) must be implemented no
later than August 1, 2012. The training procedures required by paragraph (h)
must be implemented no later than August 1, 2012, except that any training
required by another paragraph of this section must be implemented no later
than the deadline for that paragraph.
(b) ….
(d) Fatigue mitigation. Each operator must implement the following methods to
reduce the risk associated with controller fatigue that could inhibit a controllers’
ability to carry out the roles and responsibilities the operator has defined:
Boardwalk’s CRM Plan Rev 5.30 7/27/2022 was not adequate to identify the risks associated
with controller fatigue to reduce the risk through mitigation strategies. Boardwalk did not
specifically state and define fatigue risks in Section 5 of the CRM Plan, other than noting
commute time as a possible risk. Section 9.5 of the CRM Plan identified fatigue risks but
addresses them as Fatigue Mitigation Training. Boardwalk also had Task List 6605 Fatigue
Mitigation Guidelines. This task list covered fatigue mitigation countermeasures.
The procedure needs to be amended to identify fatigue risks for the controllers that can then
support fatigue mitigation and training.
Following inspection, Boardwalk followed up with amended procedures. Upon review, the
amended procedures were determined adequate. No further action is required.



6. § 195.446 Control room management.
(a) General. This section applies to each operator of a pipeline facility with a
controller working in a control room who monitors and controls all or part of a
pipeline facility through a SCADA system. Each operator must have and follow
written control room management procedures that implement the requirements
of this section. The procedures required by this section must be integrated as
appropriate, with the operator’s written procedures required by §195.402. An
operator must develop the procedures no later than August 1, 2011, and must
implement the procedures according to the following schedule. The procedures
required by paragraphs (b), (c)(5), (d)(2) and (d)(3), (f) and (g) of this section
must be implemented no later than October 1, 2011. The procedures required
by paragraphs (c)(1) through (4), (d)(1), (d)(4), and (e) must be implemented no
later than August 1, 2012. The training procedures required by paragraph (h)
must be implemented no later than August 1, 2012, except that any training
required by another paragraph of this section must be implemented no later
than the deadline for that paragraph.
(b) ….
(d) Fatigue mitigation. Each operator must implement the following methods to
reduce the risk associated with controller fatigue that could inhibit a controllers’
ability to carry out the roles and responsibilities the operator has defined:
Boardwalk’s CRM Plan Section 5 was inadequate because it did not require the manager of the
control room, who is OQ qualified and can be called into service to monitor the pipeline, to track
his hours of work in SchedulePro, a time tracking application. Even though the manager does
not work a shift, he is someone identified in procedure who can be called upon to monitor the
system in the event the control room must be evacuated and or controllers need to relocate to the
backup control center. Tracking hours worked for all qualified controllers who can be pulled
into service is important. The manager is bound by the hours-of-service standards that apply to
all controllers. If the manager is required to monitor and control the system, for any reason, his
hours of service must be considered for fatigue and or deviation from the hours of service.
The procedure must be amended to include tracking time and hours of service for all personnel
who are qualified and could be pulled into service to monitor and control the pipeline system.
7. § 195.446 Control room management.
(a) General. This section applies to each operator of a pipeline facility with a
controller working in a control room who monitors and controls all or part of a
pipeline facility through a SCADA system. Each operator must have and follow
written control room management procedures that implement the requirements
of this section. The procedures required by this section must be integrated as
appropriate, with the operator’s written procedures required by §195.402. An
operator must develop the procedures no later than August 1, 2011, and must
implement the procedures according to the following schedule. The procedures
required by paragraphs (b), (c)(5), (d)(2) and (d)(3), (f) and (g) of this section



must be implemented no later than October 1, 2011. The procedures required
by paragraphs (c)(1) through (4), (d)(1), (d)(4), and (e) must be implemented no
later than August 1, 2012. The training procedures required by paragraph (h)
must be implemented no later than August 1, 2012, except that any training
required by another paragraph of this section must be implemented no later
than the deadline for that paragraph.
(b) ….
(e) Alarm Management. Each operator using a SCADA system must have a written
alarm management plan to provide for effective controller response to alarms.
An operator’s plan must include provisions to:
(1) Review SCADA safety-related alarm operations using a process that ensures
alarms are accurate and support safe pipeline operations;
Boardwalk’s CRM Plan was not adequate because it did not provide a specific process for
managing stale or unreliable data to ensure alarms are accurate and support safe pipeline
operations. Boardwalk's Display Standards and Style Guide: Liquids Control 7/27/2022
provided a definition of stale data icons. This offered a very good definition of stale data and
how the indicator was generated and presented to the controller. Task List 6619 mentioned
malfunctioning or loss of communication, but it did not include stale data, which may be a subset
of both or something totally different. Therefore, it warranted independent
consideration. Section 2.0 of the CRM Plan did not offer definitions for malfunctioning,
inaccurate, stale or unreliable alarms. The procedure offered no guidance to the controller on
how to recognize stale or unreliable data or what to do if identified through alarms or other
means.
The procedure must be amended to include guideance for the controller on alarm response and
handling of stale and unreliable data. Additionally, it should provide more definition around
malfunctioning, loss of communication, stale and unreliable alarms as they are different in nature
and require different responses.
Following inspection, Boardwalk followed up with amended procedures. Upon review, these
procedures were determined adequate. No further action is required.
8. § 195.446 Control room management.
(a) General. This section applies to each operator of a pipeline facility with a
controller working in a control room who monitors and controls all or part of a
pipeline facility through a SCADA system. Each operator must have and follow
written control room management procedures that implement the requirements
of this section. The procedures required by this section must be integrated as
appropriate, with the operator’s written procedures required by §195.402. An
operator must develop the procedures no later than August 1, 2011, and must
implement the procedures according to the following schedule. The procedures
required by paragraphs (b), (c)(5), (d)(2) and (d)(3), (f) and (g) of this section
must be implemented no later than October 1, 2011. The procedures required



by paragraphs (c)(1) through (4), (d)(1), (d)(4), and (e) must be implemented no
later than August 1, 2012. The training procedures required by paragraph (h)
must be implemented no later than August 1, 2012, except that any training
required by another paragraph of this section must be implemented no later
than the deadline for that paragraph.
(b) ….
(e) Alarm Management. Each operator using a SCADA system must have a written
alarm management plan to provide for effective controller response to alarms.
An operator’s plan must include provisions to:
(1) ….
(5) Monitor content and volume of general activity being directed to and required of
each controller at least once each calendar year, but at intervals not exceeding 15
months, that will assure controllers have sufficient time to analyze and react to
incoming alarms;
Boardwalk's CRM Plan was not adequate because it did not define the criteria to determine if the
controller has sufficient time to analyze and react to incoming alarms. Boardwalk’s plan states
in Task List 6611 that if the controller activity review concludes that any aspect of the controller
workload is "excessive," adjustments will be made. However, the procedure did not define
criteria for determining “excessive” Controller workload. From all the information gathered and
analyzed, there should be some criteria that is the driver for determining "excessive" or
"sufficient."
The procedure needs to be amended to define the criteria that will be used to identify the
controller has sufficient time to analyze and react to incoming alarms.
9. § 195.446 Control room management.
(a) General. This section applies to each operator of a pipeline facility with a
controller working in a control room who monitors and controls all or part of a
pipeline facility through a SCADA system. Each operator must have and follow
written control room management procedures that implement the requirements
of this section. The procedures required by this section must be integrated as
appropriate, with the operator’s written procedures required by §195.402. An
operator must develop the procedures no later than August 1, 2011 and must
implement the procedures according to the following schedule. The procedures
required by paragraphs (b), (c)(5), (d)(2) and (d)(3), (f) and (g) of this section
must be implemented no later than October 1, 2011. The procedures required
by paragraphs (c)(1) through (4), (d)(1), (d)(4), and (e) must be implemented no
later than August 1, 2012. The training procedures required by paragraph (h)
must be implemented no later than August 1, 2012, except that any training
required by another paragraph of this section must be implemented no later
than the deadline for that paragraph.
(b) ….
(e) Alarm Management. Each operator using a SCADA system must have a written
alarm management plan to provide for effective controller response to alarms.



An operator’s plan must include provisions to:
(1) ….
(6) Address deficiencies identified through the implementation of paragraphs (e)(1)
through (e)(5) of this section.
Boardwalk’s CRM procedures for addressing deficiencies identified through the implementation
of paragraphs (e)(1) - (5) was not adequate. Section 6.9 of the CRM Plan addressed deficiencies
found implementing §§ 195.446(e)(1) through 195.446(e)(5) and identified Form BWP-HL 6640
Alarm Management Deficiency Review. The procedure stated that Boardwalk “[w]ill promptly
correct specific issues commensurate with their importance to safety.” It also stated that
documentation should also record the basis for the selection and scheduling of corrective
action. During the inspection, a review of the form was completed. The review demonstrated
that documenting a deficiency was very similar to documenting a deviation. These are not the
same.
The operator used GMS tickets, a subset of MAXIMO, to assign alarm or equipment repairs to
the field, such as malfunctioning or inaccurate alarms. This practice was not defined in the CRM
procedure or their Task 6619 for handling malfunctioning and inaccurate alarms. MOC's were
also used for alarm changes, which could be required due to identified deficiencies. The
procedure did not include who is responsible for reviewing these work orders to resolution.
The CRM procedure and Task needs to be amended to identify types of deficiencies that could
arise while implementing §§ 195.446(e)(1) through (5), and how the deficiencies, when
identified, will be recorded and tracked to resolution. The procedure must include a periodic
review process to support tracking to resolution.
10. § 195.446 Control room management.
(a) General. This section applies to each operator of a pipeline facility with a
controller working in a control room who monitors and controls all or part of a
pipeline facility through a SCADA system. Each operator must have and follow
written control room management procedures that implement the requirements
of this section. The procedures required by this section must be integrated as
appropriate, with the operator’s written procedures required by §195.402. An
operator must develop the procedures no later than August 1, 2011, and must
implement the procedures according to the following schedule. The procedures
required by paragraphs (b), (c)(5), (d)(2) and (d)(3), (f) and (g) of this section
must be implemented no later than October 1, 2011. The procedures required
by paragraphs (c)(1) through (4), (d)(1), (d)(4), and (e) must be implemented no
later than August 1, 2012. The training procedures required by paragraph (h)
must be implemented no later than August 1, 2012, except that any training
required by another paragraph of this section must be implemented no later
than the deadline for that paragraph.
(b) ….
(f) Change Management. Each operator must assure that changes that could affect
control room operations are coordinated with the control room personnel by



performing each of the following:
(1) Implement section 7 of API RP 1168 (incorporated by reference, see §195.3) for
control room management change and require coordination between control
room representatives, operator’s management, and associated field personnel
when planning and implementing physical changes to pipeline equipment or
configuration;
Boardwalk's CRM procedure was not adequate to substantiate that the OMS MAXIMO system is
the overarching management of change used by the company. While it appears in many Task
Lists as a way to initiate and track different types of changes or work requests, it appeared to be
more of a practice used by the company rather than a policy or procedure. It was clear from
Task List 6602 that information for changes that involved SCADA came through the OMS
system. But changes that were not SCADA related, yet could still affect control room
operations, were initiated through OMS – they were not defined in procedure. Section 7 of the
CRM Plan required pipeline operations, engineering, and construction to contact the control
center when making field changes that affect the operations of the control center. It provided
options of communications as telephone, text, email, memorandum, mail, or another method
found acceptable. It did not include the OMS MAXIMO system. Yet, it was referenced as the
communication change method in Task List 6602 as well as in other procedures that required
controllers to review the OMS system, as in BWP 6638-HL and BWP-6649-HL.
Boardwalk's procedure needs to be amended to include how it is getting information from the
OMS system related to changes initiated outside the control room and internal changes initiated
within the control room for both SCADA and non-SCADA changes.
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
Enforcement 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



thirty 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 that Boardwalk 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 Ochs, Director, Central Region, Pipeline and Hazardous
Materials Safety Administration. In correspondence concerning this matter, please refer to CPF
3-2023-013-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
cc: Tina Baker, Manager Compliance Service, tina.baker@bwpipelines.com
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