# BOARDWALK PETROCHEMICAL PIPELINE, LLC — Safety Order

- **operation:** document
- **citation:** CPF 32024081NOPSO
- **title:** BOARDWALK PETROCHEMICAL PIPELINE, LLC — Safety Order
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** current
- **official:** true
- **published on:** 2024-12-18
- **effective on:** Not available
- **summary:** OPEN safety order.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-32024081nopso.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-32024081nopso.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-32024081nopso
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/32024081NOPSO
**body:**

Safety Order involving BOARDWALK PETROCHEMICAL PIPELINE, LLC. The dataset does not identify a cited regulation for this case. The case was opened on 2024-12-18 and is reported as open. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

32024081NOPSO_Consent Agreement and Order_07072025_(24-314720).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024081NOPSO/32024081NOPSO_Consent%20Agreement%20and%20Order_07072025_(24-314720).pdf

32024081NOPSO_Consent Agreement and Order_07072025_(24-314720)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024081NOPSO/32024081NOPSO_Consent%20Agreement%20and%20Order_07072025_(24-314720)_text.pdf

32024081NOPSO_Notice of Proposed Safety Order_12182024_(24-314720).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024081NOPSO/32024081NOPSO_Notice%20of%20Proposed%20Safety%20Order_12182024_(24-314720).pdf

32024081NOPSO_Notice of Proposed Safety Order_12182024_(24-314720)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024081NOPSO/32024081NOPSO_Notice%20of%20Proposed%20Safety%20Order_12182024_(24-314720)_text.pdf

32024081NOPSO_Consent Agreement and Order_07072025_(24-314720)_text.pdf

VIA ELECTRONIC MAIL TO: scott.hallam@bwpipelines.com;
tina.baker@bwpipelines.com
Mr. Scott Hallam
President & CEO
Boardwalk Petrochemical Pipeline, LLC
9 Greenway Plaza, Suite 2800
Houston, TX 77036
CPF No. 3-2024-081-NOPSO
Dear Mr. Hallam:
Enclosed please find a Consent Order incorporating the terms of the Consent Agreement between
the Pipeline and Hazardous Materials Safety Administration (PHMSA) and Boardwalk
Petrochemical Pipeline, LLC, which was executed on June 20, 2025. Service of the Consent Order
and Consent Agreement by electronic mail is deemed effective upon the date of transmission and
acknowledgement of receipt, or as otherwise provided under 49 CFR § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Linda Daugherty
Acting Associate Administrator
for Pipeline Safety
Enclosure: Consent Order and Consent Agreement
cc: David Barrett, Acting Region Director, PHMSA Central Region, Office of Pipeline Safety
Susan Olenchuk, Counsel, Van Ness Feldman, LLP, sam@vnf.com
CONFIRMATION OF RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Boardwalk Petrochemical Pipeline, LLC, ) )
)
)
Respondent. )
____________________________________)
CPF No. 3-2024-081-NOPSO
CONSENT ORDER
By letter dated December 18, 2024, the Pipeline and Hazardous Materials Safety Administration
(PHMSA), Office of Pipeline Safety (OPS), issued a Notice of Proposed Safety Order (Notice) to
Boardwalk Petrochemical Pipeline, LLC (BPP or Respondent). In accordance with 49 CFR
§ 190.239, the Notice alleged that conditions exist on BPP’s ethylene pipeline system in
Louisiana and Texas that pose an integrity risk to public safety, property, or the environment.
The Notice also proposed that Respondent take certain corrective measures to remedy the alleged
conditions and ensure that the public, property, and the environment are protected from the
potential risk.
In response to the Notice, Respondent requested an informal consultation, whereupon the parties
engaged in discussions. As a result of those discussions, the Parties have agreed to a Consent
Agreement that settles all the allegations in the Notice.
Accordingly, the Consent Agreement is hereby approved and incorporated by reference into this
Consent Order issued pursuant to § 190.219. BPP is hereby ordered to comply with the terms of
the Consent Agreement pursuant to its terms. Pursuant to 49 U.S.C. § 60101, et seq., failure to
comply with this Consent Order may result in the assessment of civil penalties as set forth in
49 U.S.C. § 60122 and 49 CFR § 190.223, or in referral to the Attorney General for appropriate
relief in a district court of the United States.
The terms and conditions of this Consent Order are effective upon service in accordance with
49 CFR § 190.5.
______________________ ______________________
Linda Daugherty Date Issued
Acting Associate Administrator
for Pipeline Safety



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Boardwalk Petrochemical Pipeline, LLC, ) )
)
)
Respondent. )
____________________________________)
CPF No. 3-2024-081-NOPSO
CONSENT AGREEMENT
On June 10, 2024, Boardwalk Petrochemical Pipeline, LLC (“Boardwalk” or Respondent)
learned from a third party there was a leak on its pipeline system that transports liquid ethylene
from Port Neches, Texas, to Baton Rouge, Louisiana. The pipeline system is approximately
166.64 miles long and consists of 16-inch diameter, low frequency electric resistance weld (LF-
ERW) pipeline. On June 14, 2024, Boardwalk filed a report with the National Response Center
(NRC). The Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of
Pipeline Safety (OPS), pursuant to Chapter 601 of title 49, United States Code, initiated a safety
inspection on June 14, 2024.
As a result of the inspection, the Director, Central Region, OPS (Director), issued to Respondent,
by letter dated December 18, 2024, a Notice of Proposed Safety Order (Notice). In accordance
with 49 CFR § 190.239, the Notice alleged that conditions exist on Respondent’s pipeline system
that pose a pipeline integrity risk to public safety, property, or the environment. The Notice also
proposed that Boardwalk take certain corrective measures to remedy the alleged conditions and
ensure that the public, property, and the environment are protected from the alleged integrity
risk.
On January 16, 2025, Boardwalk responded to the Notice by submitting a written response and
request for an informal consultation under 49 CFR § 190.239(b)(2). An informal consultation
was held on February 25, 2025.
As a result of the informal consultations, PHMSA and Respondent (the Parties) agree that
settlement of this proceeding by entry into this Consent Agreement (Agreement) is the most
appropriate means of resolving the issues raised in the Notice, will avoid further administrative
proceedings or litigation, and is in the public interest. Therefore, pursuant to 49 CFR §
190.239(b)(2), without adjudication of any issue of law or fact, and upon consent and agreement,
the Parties agree to the following terms and conditions.



I. General Provisions
1. 2. 3. 4. 5. 6. 7. Respondent acknowledges that as the operator of the pipeline facilities subject to the
Notice, Respondent and its referenced pipeline facilities are subject to the jurisdiction of
the Federal pipeline safety laws, 49 U.S.C. § 60101, et seq., and the regulations and
administrative orders issued thereunder. For purposes of this Agreement, Respondent
acknowledges that it received proper notice of PHMSA’s action in this proceeding and
that the Notice states claims upon which relief may be granted pursuant to 49 U.S.C. §
60101, et seq., and the regulations and orders issued thereunder.
Respondent agrees, for purposes of this Agreement, to address the integrity risks identified
in the Notice by completing the actions specified in Section II of this agreement
(Corrective Measures) and to abide by the terms of this Agreement.
After Respondent returns this signed Agreement to PHMSA, the Agency’s representative
will present it to the Associate Administrator for Pipeline Safety, recommending that the
Associate Administrator adopt the terms of this Agreement by issuing an administrative
order (Consent Order) incorporating the terms of this Agreement. The terms of this
Agreement constitute an offer of settlement until accepted by the Associate Administrator.
Once accepted, the Associate Administrator will issue a Consent Order incorporating the
terms of this Agreement.
Respondent consents to the issuance of the Consent Order, and hereby waives any further
procedural requirements with respect to its issuance. Respondent waives all rights to
contest the adequacy of the Notice, or the validity of the Consent Order or this
Agreement, including all rights to administrative or judicial hearings or appeals, except
for the Dispute Resolution provisions set forth herein.
This Agreement shall apply to and be binding upon PHMSA and Respondent, its officers,
directors, and employees, and its successors, assigns, or other entities or persons
otherwise bound by law. Respondent agrees to provide a copy of this Agreement and any
incorporated work plans and schedules to all of Respondent’s officers, employees, and
agents whose duties might reasonably include compliance with this Agreement.
For all transfers of ownership or operating responsibility of Respondent’s pipeline system
referenced herein, Respondent will provide a copy of this Agreement to the prospective
transferee at least 30 days prior to such transfer. Respondent will provide written notice
of the transfer to the Director no later than 60 days after the transfer occurs.
This Agreement constitutes the final, complete and exclusive agreement and
understanding between the Parties with respect to the settlement embodied in this
Agreement. The Parties acknowledge that there are no representations, agreements or
understandings relating to settlement other than those expressly contained in this
Agreement, except that the terms of this Agreement may be construed by reference to the
Notice.



8. 9. 10. 11. Nothing in this Agreement affects or relieves Respondent of its responsibility to comply
with all applicable requirements of the Federal pipeline safety laws, 49 U.S.C. § 60101,
et seq., and the regulations and orders issued thereunder. Nothing in this Agreement
alters PHMSA's right of access, entry, inspection, and information gathering or PHMSA's
authority to bring enforcement actions against Respondent pursuant to the Federal
pipeline safety laws, the regulations and orders issued thereunder, or any other provision
of Federal or State law.
This Agreement does not waive or modify any Federal, State, or local laws or regulations
that are applicable to Respondent’s pipeline systems. This Agreement is not a permit, or
a modification of any permit, under any Federal, State, or local laws or regulations.
Respondent remains responsible for achieving and maintaining compliance with all
applicable Federal, State, and local laws, regulations and permits.
This Agreement does not create rights in, or grant any cause of action to, any third party
not party to this Agreement. The U.S. Department of Transportation is not liable for any
injuries or damages to persons or property arising from acts or omissions of Respondent
or its officers, employees, or agents carrying out the work required by this Agreement.
Respondent agrees to hold harmless the U.S. Department of Transportation, its officers,
employees, agents, and representatives from any and all causes of action arising from any
acts or omissions of Respondent or its contractors in carrying out any work required by
this Agreement.
This Agreement does not constitute a finding of violation of any Federal law or regulation
and may not be used in any civil or administrative proceeding of any kind as evidence or
proof of any fact, fault, or liability, or as evidence of the violation of any law, rule,
regulation, or requirement, except in a proceeding to enforce the provisions of this
Agreement or in future PHMSA enforcement actions.
II. Corrective Measures:
12. For the purpose of this Agreement, the following terms are defined as:
a. b. c. d. “Director” is the Director, Central Region, Office of Pipeline Safety (OPS),
Pipeline and Hazardous Materials Safety Administration (PHMSA);
“Effective Date” is the date on which the Consent Order is issued by the
Associate Administrator incorporating the terms of this Agreement;
“Affected Pipeline System” means the approximately 166.64 miles of the LF-
ERW, 16-inch diameter Boardwalk Petrochemical Pipeline transporting liquid
ethylene, originating in Port Neches, Texas, and ending in Baton Rouge,
Louisiana; and
“Leak Location” means the leak identified on June 10, 2024 at Pipeline Station
847+76 along the Sabine River in Cameron Parish, Louisiana, which was reported
to the NRC on June 14, 2024.



13. 14. 15. 16. 17. e. “Existing Bolt-On Leak Clamps” means mechanical bolt-on leak clamps existing
on the Affected Pipeline System on the Effective Date of this Agreement.
Boardwalk has completed a permanent repair of the pipe at the Leak Location at Station
847+76 by removing and replacing the section of pipe experiencing the leak, along with
the bolt-on leak clamp manufactured by PLIDCO that had been installed in 2018 to repair
a pinhole leak in the seam of the pipe. The removed section of pipe also contained a non-
leaking PLIDCO bolt-on leak clamp. Although PLIDCO’s website states that “[f]or
permanent repair, the fitting can be welded to the pipeline while it is under flow,”
welding on an ethylene pipeline presents significant safety hazards. Therefore, none of
the clamps removed from the Leak Location had been longitudinally or circumferentially
welded to the pipeline; nor had the studs been seal-welded. PLIDCO and PHMSA were
present in the field when the leaking clamp was removed and were present in the
laboratory during testing of the clamps and clamp seals.
Boardwalk sent the removed section of pipe and the PLIDCO clamps to a third party for
metallurgical and laboratory analysis. The third party submitted a preliminary copy of
the metallurgical report to the Director and to Boardwalk. The third party provided
Boardwalk and the Director a finalized copy of the metallurgical report and Root Cause
Analysis (RCA) on April 24, 2025.
The RCA described various versions of PLIDCO’s clamp installation instructions that
have existed since 2011 and found that the PLIDCO installation instructions likely used
to install the clamp at the Leak Location in 2018 did not specify the maximum size of the
gap allowed between the clamp’s two side bars. The RCA stated that an uneven gap
existed between the side bars and that PLIDCO’s installation instructions for side bar gap
tolerances were too ambiguous at the time of installation. The RCA concluded that both
of these factors contributed to the eventual leak in the PLIDCO clamp. The RCA stated
that, since 2018, PLIDCO has revised its clamp installation instructions several times and
now clearly specifies the maximum allowable size of the side bar gap. The RCA
recommends that Boardwalk consider performing instrumented leakage surveys along the
Affected Pipeline System where remaining PLIDCO clamps (installed between 2016 and
2019) are located. The RCA recommended that the surveys span 50 feet on either side of
the individual PLIDCO clamp locations and be conducted three times each calendar year
at intervals not to exceed five months.
Upon issuance of the Consent Order, Respondent agrees to perform the Corrective
Measures set forth below.
Based on the findings of the RCA, Boardwalk shall, within 90 days of the Effective Date,
revise its operating procedures to state that, when installing a bolt-on leak clamp,
Boardwalk shall use the manufacturer’s most current specifications and installation
instructions for the clamp to be installed. In addition, Boardwalk shall incorporate, if it
has not already done so, an Operator Qualification (OQ) task specific to the installation
of pressure containing bolt-on clamps that Boardwalk considers to be a repair method,



within 90 days of the Effective Date. Boardwalk shall provide a copy of the revised
procedures and OQ task to the Director for review and approval within 90 days of the
Effective Date.
18. Clamp Remedial Work Plan.
a. Boardwalk shall submit to the Director for approval, within 30 days of the Effective
Date, a Clamp Remedial Work Plan (CRWP) for monitoring of the Affected
Pipeline System and the repair of any leaking bolt-on clamp.
i. ii. iii. iv. v. The CRWP must identify and provide to the Director a list of all Existing
Bolt-On Leak Clamps and include available data on the installation date,
clamp manufacturer, and the type of flaw they were applied to (e.g. leaking
pipe, non-leaking seam feature, etc.).
Boardwalk shall increase the frequency of monitoring for leaks to monthly
at the locations of all Existing Bolt-On Leak Clamps using the instrumented
leak detection equipment that PHMSA previously approved in CPF No. 3-
2023-020-NOPV. Boardwalk shall submit the monthly monitoring results
to the Director quarterly, beginning 90 days after the Effective Date.
If a bolt-on clamp is found to be leaking on the pipeline, Boardwalk will
secure the area and schedule a repair that will be performed as soon as
Boardwalk obtains any required permits and workspaces. The repair will be
performed in a manner consistent with applicable Part 195 regulations in
effect at the time of the repair. Boardwalk will notify the Director of the
leak and provide monthly status reports until the leak is repaired.
If Boardwalk removes a block valve segment from service on the Affected
Pipeline System for maintenance, plant outage, or for any other reason,
Boardwalk will voluntarily remove all Existing Bolt-On Leak Clamps that
are located in that block valve segment and replace them in a manner
consistent with applicable Part 195 regulations in effect at the time of the
removal and replacement. Boardwalk will provide advance notification to
the Director of any plans to remove Existing Bolt-On Leak Clamps.
Boardwalk is not required to remove any non-leaking PLIDCO clamps that
may be installed on the Affected Pipeline System after the Effective Date of
this Agreement. Any such PLIDCO clamps installed after the Effective
Date must be installed in accordance with the revised procedures and OQ
task specified in paragraph 17.
Whenever an Existing Bolt-On Leak Clamp is replaced, Boardwalk shall
notify the Director of the repair method used not later than 30 days after the
replacement.



b. c. Boardwalk must revise its CRWP as necessary to incorporate new information
obtained as a result of performing leak monitoring, performing pipeline repairs, or
identifying a previously unidentified bolt-on clamp that was installed before the
Effective Date of this Agreement. Boardwalk shall submit any such plan revisions
to the Director for approval within 15 days after making the revision.
The CRWP shall remain in effect until all Existing Bolt-On Leak Clamps have been
removed.
19. Boardwalk will develop a written procedure to calculate the volume released from leaks
on the Affected Pipeline System to the Director for approval within 90 days of the
Effective Date. The computations should address all types of leaks on the pipeline, to
include minor leaks, cracks, etc.
20. Extensions of Time. The Director may grant an extension of time for compliance with
any of the terms of the Agreement upon a written request timely submitted demonstrating
good cause for the extension. The Director shall respond in writing to any such request.
III. Review and Approval Process:
21. With respect to any submission under Section II (Corrective Measures) of this Agreement
that requires the approval of the Director, the Director may: (a) approve, in whole or in
part, the submission; (b) approve the submission on specified, reasonable conditions; (c)
disapprove, in whole or in part, the submission; or (d) any combination of the foregoing.
If the Director approves, approves in part, or approves with conditions, Respondent will
take all actions as approved by the Director, subject to Respondent’s right to invoke the
dispute resolution procedures with respect to any conditions the Director identifies. If the
Director disapproves all or any portion of the submission, the Director will provide
Respondent a written notice of the deficiencies. Respondent will correct all deficiencies
within the time specified by the Director and resubmit it for approval.
IV. Dispute Resolution:
22. The Director and Respondent will informally attempt to resolve any disputes arising
under this Agreement, including any decision of the Director under the terms of Section
II (Corrective Measures). If Respondent and the Director are unable to informally
resolve the dispute within 15 calendar days after the dispute is first raised, in writing, to
the Director, Respondent may submit a written request for a determination resolving the
dispute from the Associate Administrator for Pipeline Safety. Such request must be made
in writing and provided to the Director, counsel for the Central Region, and to the
Associate Administrator, no later than 10 calendar days from the 15-day deadline for
informal resolution referenced in this paragraph. Along with its request, Respondent
must provide the Associate Administrator with all information Respondent believes is
relevant to the dispute. Decisions of the Associate Administrator under this paragraph
will constitute final agency action. The existence of a dispute and PHMSA’s
consideration of matters placed in dispute will not excuse, toll, or suspend any term or



timeframe for completion of any work to be performed under this Agreement during the
pendency of the dispute resolution process.
V. Enforcement:
23. This Agreement is subject to all enforcement authorities available to PHMSA
under 49 U.S.C. § 60101, et seq., and 49 CFR Part 190, including administrative civil
penalties under 49 U.S.C. § 60122, of up to $272,926 per violation for each day the
violation continues and referral of the case to the Attorney General for judicial
enforcement, if PHMSA determines that Respondent is not complying with the terms of
this Agreement in accordance with the determinations made by the Director, or in
accordance with decisions of the Associate Administrator if resolved pursuant to the
Dispute Resolution process herein. The maximum civil penalty amounts are adjusted
annually for inflation. See 49 CFR § 190.223. All work plans and associated schedules
set forth or referenced in Section II (Corrective Measures) are automatically incorporated
into this Agreement and are enforceable in the same manner.
VI. Recordkeeping and Information Disclosure:
24. Unless otherwise required in this Agreement, Respondent agrees to maintain records
demonstrating compliance with all requirements of this Agreement for a period of at least
five (5) years following completion of all work to be performed, unless a longer period of
time is required pursuant to 49 CFR Parts 190-199. For any reports, plans, or other
deliverables required to be submitted to PHMSA pursuant to this Agreement, Respondent
may assert a claim of business confidentiality or other protections applicable to the release
of information by PHMSA, covering part or all of the information required to be
submitted to PHMSA pursuant to this Agreement in accordance with 49 CFR Part 7.
Respondent must mark the claim of confidentiality in writing on each page, and include a
statement specifying the grounds for each claim of confidentiality. PHMSA determines
release of any information submitted pursuant to this Agreement in accordance with 49
CFR Part 7, the Freedom of Information Act, 5 U.S.C. § 552, DOT and PHMSA policies,
and other applicable regulations and Executive Orders.
VII. Modification:
25. The terms of this Agreement may be modified by mutual agreement of the Parties. Such
modifications must be in writing and signed by both parties.
VIII. Termination:
26. This Agreement will remain in effect until the Corrective Measures in Section II are
satisfied, as determined by the Director. The Agreement shall not terminate until the
Director confirms, in writing, that the Agreement is terminated in accordance with this
paragraph. Nothing in this Agreement prevents Respondent from completing any of the
obligations earlier than the deadlines provided for in this Agreement.



IX. Ratification:
27. 28. The Parties’ undersigned representatives certify that they are fully authorized to enter into
the terms and conditions of this Agreement and to execute and legally bind such party to
this document.
The Parties hereby agree to all findings, conditions, and terms of this Agreement.
[Signature Lines on Following Page]



For Boardwalk Petrochemical Pipelines, LLC:
___________________________________
________________________
Date
For PHMSA:
________________________________________
Acting Director, Central Region, Office of Pipeline Safety

32024081NOPSO_Notice of Proposed Safety Order_12182024_(24-314720)_text.pdf

VIA ELECTRONIC MAIL TO: Scott.Hallam@bwpipelines.com;
tina.baker@bwpipelines.com
December 18, 2024
Mr. Scott Hallam
President & CEO
Boardwalk Petrochemical Pipeline, LLC
9 Greenway Plaza Suite 2800
Houston, TX 77036
CPF 3-2024-081-NOPSO
Dear Mr. Hallam:
Enclosed is a Notice of Proposed Safety Order (Notice) issued in the above-referenced case. The
Notice proposes that Boardwalk Petrochemical Pipeline, LLC (BPP) take certain measures with
respect to its ethylene pipeline system in Louisiana and Texas to ensure pipeline safety. Your
options for responding are set forth in the Notice. Your receipt of the Notice constitutes service
of that document under 49 C.F.R. § 190.5.
We look forward to a successful resolution to ensure pipeline safety. Please direct any questions
on this matter to me at 816-308-2783.
Sincerely,
Gregory A. Ochs
Director, Central Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
Enclosure: Notice of Proposed Safety Order
RECEIPT CONFIRMATION REQUESTED



DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
Central Region
Kansas City, MO 64106
____________________________________
)
In the Matter of )
)
Boardwalk Petrochemical Pipeline, LLC, ) CPF No. 3-2024-081-NOPSO
)
Respondent. )
____________________________________)
NOTICE OF PROPOSED SAFETY ORDER
Background and Purpose
Pursuant to Chapter 601 of title 49, United States Code, the Pipeline and Hazardous Materials
Safety Administration (PHMSA) has initiated an investigation of the safety of Boardwalk
Petrochemical Pipeline, LLC’s (BPP or Respondent) ethylene pipeline system in Louisiana and
Texas.
As a result of the investigation, it appears that conditions exist on your pipeline facilities that pose
a pipeline integrity risk to public safety, property, or the environment. Pursuant to 49 U.S.C.
§ 60117(l), PHMSA issues this Notice of Proposed Safety Order, notifying you of the preliminary
findings of the investigation, and proposing that you take measures to ensure that the public,
property, and the environment are protected from the potential risk.
Preliminary Findings
• The affected pipeline is the approximately 166.64 miles long, 16-inch diameter, low-
frequency electric resistance weld (LF-ERW) Boardwalk Petrochemical Pipeline (the
Pipeline or BP Pipeline) transporting liquid ethylene, which is a highly volatile liquid
(HVL), originating in Port Neches, Texas, and ending in Baton Rouge, Louisiana.
• A leak was discovered on the Pipeline by Colonial Pipeline (Colonial) personnel while
performing maintenance work on its pipeline, which is adjacent to the BP Pipeline, on June
10, 2024. Colonial determined that the leak was not on its pipeline and notified BPP
personnel. On June 14, 2024, BPP determined that its pipeline was leaking and filed a
report with the NRC.1 The leak was presumed to be caused by a PLIDCO type clamp
1 See NRC Report #1402039.



failure located at Pipeline Station 847 along the Sabine River in Cameron County,
Louisiana.2
• The leak is being monitored by BPP. The leak is being aerial patrolled every two weeks
and BPP is preforming a ground non-instrumented leak survey on a bi-monthly basis.
Additionally, an instrumented leak detection is being performed quarterly.
• The leak referenced above at Pipeline Station 847 along the Sabine River in Cameron
County, Louisiana is unrepaired. The stability, type, and nature of the defect is unknown
due to the operator not removing the PLIDCO clamp and backfilling the leak. The Pipeline
is still operating, and no pressure reduction has been taken.
• The Pipeline was manufactured by Youngstown Sheet & Tube Company in 1953 and has
a LF-ERW, longitudinal pipe seam. The Pipeline is 16 inches in diameter, grade X52, with
a wall thickness of 0.312 inches. The coating is coal tar enamel. Pre-1971 LF-ERW pipe
is well known to have failures in the long seam. BPP’s 2023 Annual Report to PHMSA
indicates that 166.64 out of 177.9 miles of the pipeline is LF-ERW pipe.
• Pipelines manufactured before 1971 with LF-ERW longitudinal seams are susceptible to
failures due to multiple deficiencies created by the welding process including: cold welds,
hook cracks that are enlarged by fatigue, other manufacturing defects enlarged by fatigue,
selective seam weld corrosion, hydrogen stress cracking, sulfide stress cracking, and stress
corrosion cracking.
• The Pipeline has had 18 leaks due to use of LF-ERW pipe from 2016 to present, not
including the current leak. Previous integrity assessment and continual evaluation methods
have proven ineffective to detect these leaks. These leaks were discovered by unknown
methods that were not indicated by BPP’s inline inspection (ILI) tool. Sixteen of these
leaks were repaired with PLIDCO type clamps. The remaining two were cut out and
replaced with new pipe.
• In 2018, BPP installed a PLIDCO type clamp to repair a failure of the LF-ERW long seam.
• BPP has stated that a PLIDCO type clamp used to repair the 2018 failure did not function
as intended. This has not been confirmed as the root cause of the current failure.
• BPP did not report the 18 leaks discovered between 2016 and 2024 to the National
Response Center (NRC) as required by 49 C.F.R § 195.52, nor was an accident report filed
as required by § 195.54.
• The in-service failure of the LF-ERW longitudinal seam on the BP Pipeline is a condition
posing a pipeline integrity risk to public safety, property, and the environment. Due to its
proximity to a navigable waterway, the leak could affect a high consequence area (HCA),
as defined in § 195.450.
2 PLIDCO is a manufacturer of pipeline leak repair and maintenance fittings.



• The Pipeline transports ethylene, which is a petrochemical HVL used in the manufacture
of plastics and related products. The Pipeline has a maximum operating pressure of 1336
pounds per square inch (psi). Ethylene is a very flammable product and extreme caution
must be used while performing repairs on the pipeline.
• The Pipeline traverses an area dominated by wetlands and swamps along the Gulf Coast
coastal plains. The climate is humid subtropical. The geology is unconsolidated,
redeposited sands and clays to silty sediments of aeolian and alluvial origin.
• The Pipeline traverses the Lower Neches Water Management of Texas and the Sabine
National Wildlife Refuge in Louisiana. There are 33.89 miles of Unusually Sensitive Areas
(USA), which include drinking water and ecological resources, according to BPP’s 2023
Annual Report.
• The Pipeline traverses several highly populated areas. These include the cities of Port
Neches and Orange in Texas. These areas are industrial in character and stable in
population growth. It also traverses the cities of Lake Charles, Opelousas, and Baton Rouge
in Louisiana. The Pipeline generally traverses the southern side of these cities, and these
areas are characterized by rapid growth of commercial and residential buildings. BPP’s
2023 Annual Report states that there are 38.59 miles of High Population and Other
population areas.
• Three NTSB recommendations have been issued related to ERW pipe or manufacturing
defects:
o Williams pipeline failure Mounds View, MN July 8, 1986. NTSB report PB87-
916502.
NTSB recommended that PHMSA obtain sufficient data on LF-ERW pipe and
determine if its continued use presents an unreasonable hazard to public safety and
take appropriate regulatory action for identified deficiencies. (Class II, Priority
Action) (Safety Recommendation P-87-26).
o Dixie Pipeline failure of Propane pipeline Carmichael, MS November 1, 2007.
NTSB Report PB2009-916501.
NTSB recommended conducting a comprehensive study to identify actions that can
be implemented by pipeline operators to eliminate catastrophic longitudinal seam
failures in electric resistance welded (ERW) pipe; at a minimum, the study should
include assessments of the effectiveness and effects of in-line inspection tools,
hydrostatic pressure tests, and spike pressure tests; pipe material strength
characteristics and failure mechanisms; the effects of aging on ERW pipelines;
operational factors; and data collection and predictive analysis. (Safety
Recommendation P-09-1). Based on the results of the study requested in Safety
Recommendation P-09-1, NTSB recommended implementing the actions needed.



(Safety Recommendation P-09-2). NTSB also recommended initiating a program
to evaluate pipeline operators’ public education programs, including pipeline
operators’ self-evaluations of the effectiveness of their public education programs.
Provide the National Transportation Safety Board with a timeline for
implementation and completion of this evaluation. (Safety Recommendation P-09-
3).
o Pacific Gas and Electric Company failure San Bruno, CA September 9, 2010.
NTSB report PB2011-916501.
NTSB recommended amending Title 49 Code of Federal Regulations Part 192 of
the Federal pipeline safety regulations so that manufacturing- and construction-
related defects can only be considered stable if a gas pipeline has been subjected to
a post-construction hydrostatic pressure test of at least 1.25 times the maximum
allowable operating pressure. (Safety Recommendation P-11-15). NTSB
recommended amending Title 49 Code of Federal Regulations § 192.619 to delete
the grandfather clause and require that all gas transmission pipelines constructed
before 1970 be subjected to a hydrostatic pressure test that incorporates a spike test.
(Safety Recommendation P-11-14). NTSB also recommended assessing every
aspect of the operator’s integrity management program, paying particular attention
to the areas identified in this investigation, and implement a revised program that
includes, at a minimum, (1) a revised risk model to reflect the Pacific Gas and
Electric Company’s actual recent experience data on leaks, failures, and incidents;
(2) consideration of all defect and leak data for the life of each pipeline, including
its construction, in risk analysis for similar or related segments to ensure that all
applicable threats are adequately addressed; (3) a revised risk analysis methodology
to ensure that assessment methods are selected for each pipeline segment that
address all applicable integrity threats, with particular emphasis on design/material
and construction threats; and (4) an improved self-assessment that adequately
measures whether the program is effectively assessing and evaluating the integrity
of each covered pipeline segment. (Safety Recommendation P-11-29).
• PHMSA has issued the following advisories, reports, and regulations:
o Alert Notice advising pipeline operators who have pipe manufactured by ERW
process of the occurrence of 12 hazardous liquid pipeline failures and of actions
which operators may take to reduce the risks of similar failures. Alert Notice ALN-
89-01 (Mar. 8, 1989).
PHMSA3 advised operators who have pipe manufactured by the ERW process of
actions they may take to reduce the risk of pipeline failure. PHMSA explained that
“[t]he continuing failure of ERW seams remains a matter of concern…Since the
issuance of [the 1988] Alert Notice, [PHMSA] has data on 8 additional hazardous
3 This Alert Notice was issued by the Research and Special Programs Administration (RSPA),
PHMSA’s predecessor agency. For simplicity, this NOPSO will refer to the agency as PHMSA.



liquid pipeline failures and 1 on a gas transmission pipeline involving pipe seams
manufactured prior to 1970 by the ERW process. Of the 8 additional hazardous
liquid pipeline failures, 2 appear to be due to selective corrosion of the ERW seam.
As stated in the 1988 Alert Notice (ALN-88-01), seams with selective corrosion
occurring in an area of manufacturing defects may be particularly vulnerable to
failure. However, the other failures appear to have resulted from flat growth of
manufacturing defects in the ERW seam.”
o “TTO Number 5 Integrity Management Program Delivery Order DTRS56-02-D-
70036 Low Frequency ERW and Lap Welded Longitudinal Seam Evaluation.”
This report, commissioned by PHMSA, documents a review focused on
evaluation of longitudinal seams on LF-ERW pipe and lap-welded pipe,
particularly pipe manufactured before 1970, as well as DC-ERW pipe and EFW
pipe. The report finds that “likely causes of seam failures that could necessitate a
seam-integrity assessment are pressure cycle-induced fatigue and selective
(grooving) corrosion of the bondline region of the seam. Four factors govern the
possible growth of seam defects by pressure-cycle-induced fatigue: (1) the
pressure cycles, (2) the presence of a family of initial flaws, (3) an
environmentally affected crack-growth rate, and (4) the toughness of the pipe.”
o 49 C.F.R § 195.4 Compatibility necessary for transportation of hazardous liquids
or carbon dioxide.
“No person may transport any hazardous liquid or carbon dioxide unless the
hazardous liquid or carbon dioxide is chemically compatible with both the pipeline,
including all components, and any other commodity that it may come into contact
with while in the pipeline.”
• Current assessment and continual evaluation methods do not address the threat of leaks on
the LF-ERW long seam of the Pipeline. Current preventative and mitigative measures do
not address the ongoing threat of leaks in the long seam.
• History of Pipeline Compliance and Repair
o April 6 and November 2, 2011: Two accidents on the Pipeline occurred because of
failures of a long seam weld. Both accidents were determined to be caused by a
“cold weld” in the longitudinal LF-ERW pipe seam. In both cases, metallurgical
analysis concluded that the cold welds were original manufacturing defects in the
pipe seam.
o Summer of 2013: 10 pinhole leaks were discovered in the long seam welds.4
o September 2013: NOPV issued with a Compliance Order (CPF No. 4-2013-5019-
NOPV) to perform an integrity assessment of the pipeline by a method prescribed
4 National Response Center report numbers: 1054340, 1058513, 1058754, 1058760, 1058762,
1058766, 1058771, 1058774, 1058777, 1058779.



in Appendix G of Chevron’s Pipeline Integrity Management Program Manual.5
Hydrostatic testing of the line was performed prior to the end of 2013. A spike test
was performed to 1.39 MOP; however, the testing was limited to 80 percent SMYS.
As a result of hydrostatic test, 41 repairs were made. In addition, there were two
failures during the hydrostatic testing. One of the ruptures occurred during the spike
test.
o October 8, 2014: BPP purchases pipeline.
o October 10, 2014: A failure occurs on the long seam.
o October 20, 2014: Corrective Action Order (CAO) CPF No. 4-2014-5027H was
issued. BPP took the following the actions as a result of the CAO:
 BPP removed or replaced 27 Type A indications;
 BPP removed or replaced 53 Type B indications;
 BPP replaced 51 feet of pipeline with unknown grade; and
 BPP ran TFI tool on four segments of the pipeline from December 2014 to
May 2015.
o January 5, 2016: CAO (CPF No. 4-2014-5027H) closed.
• The table below shows the additional leak repairs since the 2014 CAO. BPP submitted no
NRC or accident reports for these leaks.
• The 15 locations with “Plidco Clamp” type of repair are sim
- **truncated:** true
- **body characters:** 52113