# TEXAS GAS TRANSMISSION, LLC — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 32025006NOPV
- **title:** TEXAS GAS TRANSMISSION, LLC — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2025-08-18
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 192.605(a), 192.739(a).
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-32025006nopv
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/32025006NOPV
**body:**

Notice of Probable Violation involving TEXAS GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.605(a),  192.739(a). The case was opened on 2025-08-18 and is reported as closed as of 2026-01-13. Proposed civil penalty: $115,400. Assessed civil penalty: $115,400. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

32025006NOPV_Closure Letter_01132026_(23-264820).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025006NOPV/32025006NOPV_Closure%20Letter_01132026_(23-264820).pdf

32025006NOPV_Closure Letter_01132026_(23-264820)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025006NOPV/32025006NOPV_Closure%20Letter_01132026_(23-264820)_text.pdf

32025006NOPV_Final Order_10152025_(23-264820).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025006NOPV/32025006NOPV_Final%20Order_10152025_(23-264820).pdf

32025006NOPV_Final Order_10152025_(23-264820)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025006NOPV/32025006NOPV_Final%20Order_10152025_(23-264820)_text.pdf

32025006NOPV_Operator Response to Notice_09102025_(23-264820).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025006NOPV/32025006NOPV_Operator%20Response%20to%20Notice_09102025_(23-264820).pdf

32025006NOPV_PCP PCO_08182025_(23-264820).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025006NOPV/32025006NOPV_PCP%20PCO_08182025_(23-264820).pdf

32025006NOPV_PCP PCO_08182025_(23-264820)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025006NOPV/32025006NOPV_PCP%20PCO_08182025_(23-264820)_text.pdf

32025006NOPV_Closure Letter_01132026_(23-264820)_text.pdf

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
901 Locust Street, Suite 480
Kansas City, MO 64106
VIA ELECTRONIC MAIL TO: scott.hallam@bwpipelines.com;
tina.baker@bwpipelines.com
January 13, 2026
Mr. Scott Hallam, President & CEO
Boardwalk Pipelines, LP
9 Greenway Plaza, Suite 2800
Houston, TX 77066
RE: CPF 3-2025-006-NOPV
Dear Mr. Hallam:
On October 15, 2025, the Pipeline and Hazardous Materials Safety Administration (PHMSA)
issued to Texas Gas Transmission, LLC (Texas Gas), a subsidiary of Boardwalk Pipelines, LP, a
Final Order, pursuant to 49 CFR § 190.213, in the above-referenced case. This Order included a
Compliance Order. Based on our review of the documentation provided, it has been determined
that Texas Gas has complied with the terms of the Order.
Accordingly, this case is now closed, and no further action is contemplated with respect to the
matters involved in this case. Thank you for your cooperation in this matter.
Sincerely,
David Barrett
Acting Director, Central Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Tina Baker, Manager, Compliance Services, BP, Tina.Baker@bwpipelines.com

32025006NOPV_Final Order_10152025_(23-264820)_text.pdf

October 15, 2025
VIA ELECTRONIC MAIL TO: scott.hallam@bwpipelines.com
Scott Hallam
President & Chief Executive Officer
Boardwalk Pipelines, LP
9 Greenway Plaza, Suite 2800
Houston, Texas 77066
Re: CPF No. 3-2025-006-NOPV
Dear Mr. Hallam:
Enclosed please find the Final Order issued in the above-referenced case. It makes a finding of
violation, finds that the civil penalty amount of $115,400 has been paid in full, and specifies
actions that need to be taken to comply with the pipeline safety regulations. When the terms of
the compliance order are completed, as determined by the Acting Director, Central Region, this
enforcement action will be closed. Service of the Final Order by e-mail is effective upon the date
of transmission and acknowledgement of receipt as provided under 49 CFR § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Linda Daugherty
Acting Associate Administrator
for Pipeline Safety
Enclosures (Final Order and NOPV)
cc: David Barrett, Acting Director, Central Region, Office of Pipeline Safety, PHMSA
Tina Baker, Manager, Compliance Services, Boardwalk Pipelines, LP.,
tina.baker@bwpipelines.com
Jeff Sanderson, VP Field Operations Safety & Security, Boardwalk Pipelines, LP.,
jeff.sanderson@bwpipelines.com
Tesha Doerner, MBA, Supervisor, Compliance Services, Boardwalk Pipelines, LP.,
tesha.doerner@bwpipelines.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 )
Texas Gas Transmission, LLC, )
a subsidiary of Boardwalk Pipelines, LP, ) )
)
)
Respondent. )
____________________________________)
CPF No. 3-2025-006-NOPV
FINAL ORDER
On August 18, 2025, pursuant to 49 CFR § 190.207, the Acting Director, Central Region, Office
of Pipeline Safety (OPS), issued a Notice of Probable Violation (Notice) to Texas Gas
Transmission, LLC, a subsidiary of Boardwalk Pipelines, LP (Respondent). The Notice proposed
finding that Respondent had violated the pipeline safety regulations in 49 CFR Part 192 and
proposed a civil penalty of $115,400. The Notice also proposed certain measures to correct the
violations. Respondent did not contest the allegations of violation or corrective measures and
paid the proposed civil penalty on September 10, 2025.
Pursuant to 49 CFR § 190.213, I find Respondent violated the pipeline safety regulation listed
below, as more fully described in the enclosed Notice, which is incorporated by reference:
49 CFR § 192.739(a) (Item 2) ─ Respondent failed to inspect and test at intervals
not to exceed 15 months, but at least once each calendar year, the devices to
regulate and limit pressure at pressure limiting stations in its Leesville and
Wilfred stations in Indiana and its Dixie and West Greenville stations in
Kentucky.
This finding of violation will be considered a prior offense in any subsequent enforcement action
taken against Respondent. In accordance with 49 CFR § 190.223, Respondent is assessed the
proposed civil penalty amount of $115,400, which Respondent has already paid in full.
Compliance Actions
Pursuant to 49 U.S.C. § 60118(b) and 49 CFR § 190.217, Respondent is ordered to take the
actions proposed in the enclosed Notice to correct the violation. The Director may grant an
extension of time to comply with any of the required items upon a written request timely
submitted by the Respondent and demonstrating good cause for an extension. Upon completion
of the ordered actions, Respondent may request that the Director close the case. Failure to



comply with this Order may result in the assessment of civil penalties under 49 CFR § 190.223
or in referral to the Attorney General for appropriate relief in a district court of the United States.
Warning Item
With respect to Item 1, the Notice alleged a probable violation of 49 CFR § 192.605(a) but did
not propose a civil penalty or compliance order for this item. Therefore, this is considered to be a
warning item. If OPS finds a violation of this provision in a subsequent inspection, Respondent
may be subject to future enforcement action.
The terms and conditions of this order are effective upon service in accordance with 49 CFR
§ 190.5.
___________________________________ _________________________
Linda Daugherty Date Issued
Acting Associate Administrator
for Pipeline Safety



NOTICE OF PROBABLE VIOLATION
PROPOSED CIVIL PENALTY
and
PROPOSED COMPLIANCE ORDER
VIA ELECTRONIC MAIL TO: scott.hallam@bwpipelines.com;
jeff.sanderson@bwpipelines.com; tina.baker@bwpipelines.com
August 18, 2025
Mr. Scott Hallam, President & CEO
Boardwalk Pipelines, LP
9 Greenway Plaza, Suite 2800
Houston, TX 77066
CPF 3-2025-006-NOPV
Dear Mr. Hallam:
From June 6, 2023 to August 2, 2023, a representative of the Pipeline and Hazardous Materials
Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49
United States Code (U.S.C.), conducted an onsite inspection of the natural gas pipelines of Texas
Gas Transmission, LLC, a subsidiary of Boardwalk Pipelines, LP (TGT) in Kentucky and Indiana.
As a result of the inspection, it is alleged that TGT has committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected
and the probable violations are:
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. . .
TGT failed to follow its written procedures, as required by § 192.605(a), by not documenting
periodic odorant intensity testing in the Wilfred, Indiana, operating area.
Section 192.625(f) requires that “each operator must conduct periodic sampling of combustible
gases using an instrument capable of determining the percentage of gas in air at which the odor



becomes readily detectable.” In response to PHMSA’s November 2, 2023 information request,
TGT acknowledged in its response dated December 13, 2023 (Response), that the odorization
requirements of § 192.625 are applicable in the Wilfred, Indiana “free gas” area (i.e., a portion of
the system where TGT provides gas service to certain landowners at no cost, in exchange for leased
access to its underground gas storage fields).
1
Section 7010 of TGT’s “Operations and Maintenance Manual: Natural Gas” (O&M Manual)
stated, “[the] Area Manager (or designee) shall ensure that Assigned Operations Personnel (or
designee) shall test odorization levels with a sniff test quarterly and an odorant intensity tester at
least annually” and “[the] Assigned Operations Personnel shall conduct periodic sampling of
combustible gases using an instrument capable of determining the percentage of gas in air at which
the odor becomes readily detectable.” It further addressed the required documentation of this test,
stating, “Use Form 7000-10: Odorizer Inspection & Sniff Test Report for inspection of Odorizer
and proper levels of odorant or equivalent form provided by third-party contractor.” The evaluation
criteria for TGT’s operator qualification task, “610OP - Monitor Odorant Concentration,” also
listed “Record results” as a required element of using an odorometer.
In calendar years 2020 and 2021, odorant monitoring for the Wilfred operating area was not
documented on form 7000-10, as required by the O&M Manual. Rather, it was documented on a
form designated as “TXG-0032.” Form TXG-0032 had no field for recording odorant
concentration data (i.e., quantitative testing). Only qualitative testing (often referred to as “sniff
testing”) was recorded on form TXG-0032. TGT indicated in its Response that the quantitative
testing had been performed in 2020 and 2021 but not documented, and provided records on Form
7000-10 for calendar years 2022 and 2023.
Therefore, TGT lacked records of its required annual odorant intensity testing for calendar years
2020 and 2021, and failed to follow its procedures for odorant testing and associated recordkeeping
in 2020 and 2021, contrary to the requirements of § 192.605(a).
2. § 192.739 Pressure limiting and regulating stations: Inspection and testing.
(a) Each pressure limiting station, relief device (except rupture discs), and pressure
regulating station and its equipment must be subjected at intervals not exceeding 15
months, but at least once each calendar year, to inspections and tests to determine
that it is. . . .
TGT failed to inspect and test each pressure regulating station at intervals not exceeding 15
months, but at least once each calendar year, as required by § 192.739(a). Specifically, devices to
regulate and limit pressure at pressure limiting stations in its Leesville and Wilfred “free gas” areas
in Indiana and its Dixie and West Greenville “free gas” areas in Kentucky were being inspected
every three years, rather than annually.2 Pressure limiting and regulating stations automatically
control the supply of gas to prevent downstream piping and equipment from being subjected to
pressures that exceed what they can safely contain. It is important that such stations be inspected
1 The Wilfred operating area spans over 90 miles of transmission pipeline. The “free gas” area is a subset
of this area, limited to the boundaries of its underground natural gas storage field.
2 The “free gas” areas are subsets of the larger operating areas.



and maintained at the required frequency to ensure that excess pressure does not lead to pipeline
failure, endangering persons and property.
Section 2050 of TGT’s O&M Manual included procedures related to inspection and maintenance
of pressure limiting devices. In Table 2050-1 of section 2050, TGT specified the frequency of
testing for pressure regulators and relief devices at a three-year, not to exceed 39-months, interval
for inspection, testing, and capacity review of all regulators and reliefs designated as “free gas.”
Devices outside of “free gas” areas were assigned a one-year, not to exceed 15-months, interval.
The only portion of Part 192 that allows for testing overpressure equipment at three-year intervals
is § 192.740, which is titled “Pressure regulating, limiting, and overpressure protection—
Individual service lines directly connected to regulated gathering or transmission pipelines.”
Section 2050’s three-year testing interval appears to be derived from TGT’s blanket application of
the requirements of § 192.740 to all equipment in “free gas” areas.
Section 192.740 is not applicable to those taps3 in TGT’s system which are not directly connected
to service lines. Section § 192.740(a) states: “This section applies, except as provided in paragraph
(c) of this section, to any service line directly connected to a transmission pipeline or regulated
gathering pipeline as determined in § 192.8 that is not operated as part of a distribution system.”
Section § 192.3 defines the term service line as follows: “Service line means a distribution line
that transports gas from a common source of supply to an individual customer, to two adjacent or
adjoining residential or small commercial customers, or to multiple residential or small
commercial customers served through a meter header or manifold. A service line ends at the outlet
of the customer meter or at the connection to a customer's piping, whichever is further downstream,
or at the connection to customer piping if there is no meter.”
According to records provided by TGT on March 27, 2024, in response to PHMSA’s January 30,
2024 information request, TGT’s system has multiple taps feeding “community lines”4 that supply
multiple recipients. In some cases, the records indicate that dozens of residences or businesses are
fed from a single tap.5 Most recipients are freestanding single-family residential structures and
are not fed through a common meter header or manifold. Such “community lines” therefore do
not transport gas either to an individual customer, to two adjacent or adjoining residential or small
commercial customers, or to multiple residential or small commercial customers served through a
meter header or manifold. Consequently, the “community lines” do not meet the definition of
service lines and § 192.740 does not apply.
Because TGT's free gas taps are designed to automatically reduce and regulate gas pressure in
downstream pipelines, including customer-owned "community" pipelines, they constitute pressure
regulating stations, and must be inspected and tested at the intervals established by § 192.739. The
taps in question are required to be tested at least once each year, not to exceed 15 months, per
§ 192.739(a).
3 “Tap” is TGT’s term for a pressure regulating station serving the “free gas” areas.
4 This is TGT’s term for a line which services multiple recipients.
5 Examples include TGT’s taps L-13, L-18, and WG-10, which supply 40, 24, and 57 recipients, respectively.



In correspondence dated March 3, 2022, PHMSA requested TGT’s most recent testing records for
its overpressure protection devices in the “free gas” areas. In its April 1, 2022 response, TGT
provided records from calendar year 2020 for the Dixie and West Greenville areas, and records
from 2019 for the Leesville and Wilfred areas. In a subsequent request dated January 30, 2024,
PHMSA requested records of all such testing performed since the 2022 response. On March 27,
2024, TGT provided records from 2022 and 2023 for all four “free gas” areas. TGT also provided
data identifying which tap locations serve three or more discrete recipients, as opposed to
individual “farm tap” service lines which fall under § 192.740.
From this data, in multiple instances, TGT failed to meet the interval required by § 192.739(a).
1. In the Leesville operating area, TGT tested six devices (TGT asset numbers 349460,
349461, 350169, 349459, 350170, and 350171) in calendar years 2019 and 2022, at a
testing interval of every three years;
2. In the Dixie operating area, TGT tested three devices (TGT assets 348890, 348904, and
349868) in calendar years 2020 and 2023, at a testing interval of every three years;
3. In the Wilfred operating area, TGT tested five devices (TGT assets 349015, 349016,
349017, 349018, and 349950) in calendar years 2019 and 2022, at a testing interval of
every three years;
4. In the West Greenville operating area, TGT tested eleven devices (TGT assets 349796,
349798, 348811, 348812, 349850, 348876, 349851, 348894, 349971, 350198, and
349042) in calendar years 2020 and 2023 at a testing interval of every three years;
5. In the West Greenville operating area, TGT tested one device (TGT asset 349829) on
June 27, 2022 and October 21, 2023 in consecutive calendar years, but exceeding the
15-month interval by 24 days; and
6. In the West Greenville operating area, TGT tested five devices (TGT assets 348903,
349970, 349041, 349972, and 348832) only in calendar year 2023, with no record
provided of any other testing in calendar years 2020 through 2022.
By not performing annual testing of its pressure-limiting devices, TGT failed to follow the
inspection and testing requirements of § 192.739.
Proposed Civil Penalty
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$272,926 per violation per day the violation persists, up to a maximum of $2,729,245 for a related
series of violations. For violation occurring on or after December 28, 2023 and before December
30, 2024 the maximum penalty may not exceed $266,015 per violation per day the violation
persists, up to a maximum of $2,660,135 for a related series of violations. For violation occurring
on or after January 6, 2023 and before December 28, 2023 the maximum penalty may not exceed
$257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a related



series of violations. For violation occurring on or after March 21, 2022 and before January 6, 2023
the maximum penalty may not exceed $239,142 per violation per day the violation persists, up to
a maximum of $2,391,412 for a related series of violations. For violation occurring on or after
May 3, 2021 and before March 21, 2022 the maximum penalty may not exceed $225,134 per
violation per day the violation persists, up to a maximum of $2,251,334 for a related series of
violations. For violation occurring on or after January 11, 2021 and before May 3, 2021 the
maximum penalty may not exceed $222,504 per violation per day the violation persists, up to a
maximum of $2,225,034 for a related series of violations. For violation occurring on or after July
31, 2019, and before January 11, 2021 the maximum penalty may not exceed $218,647 per
violation per day the violation persists, up to a maximum of $2,186,465 for a related series of
violations.
We have reviewed the circumstances and supporting documentation involved for the above
probable violations and recommend that you be preliminarily assessed a civil penalty of $115,400
as follows:
Item number PENALTY
2 $115,400
Proposed Compliance Order
With respect to Item 2 pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous Materials Safety
Administration proposes to issue a Compliance Order to Texas Gas Transmission, LLC. Please
refer to the Proposed Compliance Order, which is enclosed and made a part of this Notice.
Warning Item
With respect to Item 1, we have reviewed the circumstances and supporting documents involved
in this case and have decided not to conduct additional enforcement action or penalty assessment
proceedings at this time. We advise you to promptly correct this item. Failure to do so may result
in additional enforcement action.
Response to this Notice
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. All
material you submit in response to this enforcement action may be 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 your receipt of this Notice, you have 30 days to respond as described in the enclosed
Response Options. 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 a Final Order. If you are responding to this Notice, we propose that you submit
your correspondence to my office within 30 days from receipt of this Notice. The Region Director
may extend the period for responding upon a written request timely submitted demonstrating good
cause for an extension.
In your correspondence on this matter, please refer to CPF 3-2025-006-NOPV and, for each
document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
David Barrett
Acting Director, Central Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Jeff Sanderson, VP Field Operations Safety & Security, BP,
Jeff.Sanderson@bwpipelines.com
Tina Baker, Manager, Compliance Services, BP, Tina.Baker@bwpipelines.com
Enclosures: Proposed Compliance Order
Response Options for Pipeline Operators in Enforcement Proceedings



PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety
Administration (PHMSA) proposes to issue to Texas Gas Transmission, LLC, a Compliance
Order incorporating the following remedial requirements to ensure the compliance of TGT with
the pipeline safety regulations:
A. B. In regard to Item 2 of the Notice, pertaining to inspection and testing of pressure-
limiting devices, TGT must revise its applicable procedures to accurately
differentiate pressure limiting devices which meet the criteria of § 192.740 from
those falling under § 192.739 to ensure that the frequency of inspection,
maintenance, and capacity calculation is compliant with the regulations. TGT must
submit its revised procedures for review and approval within 60 days of receipt of
the Final Order.
It is requested (not mandated) that TGT maintain documentation of the safety
improvement costs associated with fulfilling this Compliance Order and submit the
total to the, Director, Central Region, Pipeline and Hazardous Materials Safety
Administration, Office of Pipeline Safety. It is requested that these costs be
reported in two categories: (1) total cost associated with preparation/revision of
plans, procedures, studies and analyses, and (2) total cost associated with
replacements, additions and other changes to pipeline infrastructure.
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