GULF SOUTH PIPELINE COMPANY, LLC — Notice of Probable Violation

party submissionOfficial PDF420181001_Operator Response to Notice_02262018.pdf#

420181001_Closure Letter_12132019_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED December 13, 2019 Richard Keyser Sr. Vice President of Operations Gulf South Pipeline, LP 9 Greenway Plaza, Suite 2800 Houston, Texas 77046 CPF 4-2018-1001 Dear Mr. Keyser: On August 8, 2019, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to Gulf South Pipeline a Final Order in the above-referenced case. This Order included a Compliance Order and Civil Penalty assessment. Based on our review of the documentation you provided and confirmation of payment of the civil penalty, it has been determined that you have complied with the terms of this 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, Mary L. McDaniel, P.E. Director, Southwest Region Pipeline and Hazardous Materials Safety Administration#

420181001_Final Order_08082019_text.pdf, page 1Official PDFAugust 8, 2019 Mr. Stanley Horton Chief Executive Officer and President Boardwalk Pipeline Partners, LP 9 Greenway Plaza, Suite 2800 Houston, Texas 77046 Re: CPF No. 4-2018-1001 Dear Mr. Horton: Enclosed please find the Final Order issued in the above-referenced case to your subsidiary, Gulf South Pipeline, LP. It makes findings of violation and assesses a civil penalty of $62,000. This is to acknowledge receipt of payment of the full penalty amount, by wire transfer, dated February 26, 2018. When the terms of the compliance order are completed, as determined by the Director, Southwest Region, this enforcement action will be closed. Service of the Final Order by certified mail is effective upon the date of mailing, as provided under 49 C.F.R. § 190.5. Thank you for your cooperation in this matter. Sincerely, Alan K. Mayberry Associate Administrator for Pipeline Safety Enclosure cc: Ms. Mary McDaniel, Director, Southwest Region, Office of Pipeline Safety, PHMSA Mr. Richard Keyser, Sr. Vice President of Operations, Gulf South Pipeline, LP Ms. Tina H. Baker, Manager, Compliance Services, Gulf South Pipeline, LP CERTIFIED MAIL - RETURN RECEIPT REQUESTED#

420181001_Final Order_08082019_text.pdf, page 2U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D.C. 20590 ________________________________________ ____ In the Matter of ) Gulf South Pipeline, LP, ) CPF No. 4-2018-1001 a subsidiary of Boardwalk Pipeline Partners, LP, ) ) ) ) Respondent. ) __________________________________________ ) FINAL ORDER From May 8, 2015, through September 15, 2016, pursuant to 49 U.S.C. § 60117, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), conducted an on-site pipeline safety inspection of the facilities and records of Gulf South Pipeline, LP (Gulf South or Respondent), a wholly-owned, operating subsidiary of Boardwalk Pipeline Partners, LP,1 in Texas and Louisiana. Gulf South is an interstate natural gas system that gathers gas from basins between Texas and Alabama and delivers to on-system markets in the Northeast, Midwest, and Southeast through interconnections with third-party pipelines. The Gulf South system is composed of approximately 7,275 miles of pipeline having an average daily throughput of approximately 2.8 billion cubic feet (of natural gas) per day in 2017. Gulf South is headquartered in Houston, Texas, with a major operations office in Owensboro, Kentucky.2 As a result of the inspection, the Director, Southwest Region, OPS (Director), issued to Respondent, by letter dated January 31, 2018, a Notice of Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order (Notice), which also included a warning pursuant to 49 C.F.R. § 190.205. In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that Gulf South had committed four violations of 49 C.F.R. Part 192 and proposed assessing a civil penalty of $62,000 for the alleged violations. The Notice also proposed ordering Respondent to take certain measures to correct the alleged violations. The warning item required no further action, but warned the operator to correct the probable violation or face possible future enforcement action. Gulf South responded to the Notice by letter dated February 26, 2018 (Response). The company did not contest the allegations of violation and paid the proposed civil penalty of $62,000. In 1 http://www.gulfsouthpl.com/ (last accessed June 24, 2019). 2 Pipeline Safety Violation Report (on file with PHMSA).#

420181001_Final Order_08082019_text.pdf, page 3CPF No. 4-2018-1001 Page 2 accordance with 49 C.F.R. § 190.208(a)(1), such payment authorizes the Associate Administrator to make findings of violation and to issue this final order without further proceedings. The company also provided information concerning the corrective actions it had agreed to complete under the proposed compliance order. Respondent did not request a hearing and therefore has waived its right to one. FINDINGS OF VIOLATION In its Response, Gulf South did not contest the allegations in the Notice that it violated 49 C.F.R. Part 192, as follows: Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 192.615(b)(2), which states: § 192.615 Emergency plans. (a) …. (b) Each operator shall: …. (2) Train the appropriate operating personnel to assure that they are knowledgeable of the emergency procedures and verify that the training is effective. The Notice alleged that Respondent violated 49 C.F.R. § 192.615(b)(2) by failing to perform training of personnel through mock drills to assure knowledge of the emergency procedures and to verify effectiveness of the training as required by Gulf South Procedure 3010 – Event Response Plan, dated June 1, 2016. Specifically, the Notice alleged that Gulf South failed to conduct exercises and mock drills in its Hall Summit-Sarepta, Westlake, and Goodrich Units in 2014, and its Hall Summit-Sarepta, and Goodrich Units in 2015, despite its procedure and the regulation requiring such action. Respondent did not contest this allegation of violation. Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 192.615(b)(2) by failing to perform training of personnel through mock drills to assure knowledge of the emergency procedures and to verify effectiveness of the training as required. Item 3: The Notice alleged that Respondent violated 49 C.F.R. § 192.743(a)-(b), which states: § 192.743 Pressure limiting and regulating stations: Capacity of relief devices. (a) Pressure relief devices at pressure limiting stations and pressure regulating stations must have sufficient capacity to protect the facilities to which they are connected. Except as provided in § 192.739(b), the capacity must be consistent with the pressure limits of § 192.201(a). This capacity must be determined at intervals not exceeding 15 months, but at least once each calendar year, by testing the devices in place or by review and calculations. (b) If review and calculations are used to determine if a device has#

420181001_Final Order_08082019_text.pdf, page 4CPF No. 4-2018-1001 Page 3 sufficient capacity, the calculated capacity must be compared with the rated or experimentally determined relieving capacity of the device for the conditions under which it operates. After the initial calculations, subsequent calculations need not be made if the annual review documents that parameters have not changed to cause the rated or experimentally determined relieving capacity to be insufficient. The Notice alleged that Respondent violated 49 C.F.R. § 192.743(a)-(b) by failing to properly determine the capacity of pressure-relief devices to protect the facilities to which they are connected. Specifically, the Notice alleged that Gulf South’s control room equipment inspection reports, which were presented as records of annual inspection of overpressure protection, failed to reflect actual or up-to-date information related to regulator and relief-valve capacities at several locations. The Notice stated that the required annual testing or reviews of capacities of regulators and overpressure protection relief devices should have revealed to the reviewers that, in some cases, capacities of regulators appeared to exceed the capacities of overpressure protective-relief devices. Respondent did not contest this allegation of violation. Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 192.743(a)-(b) by failing to properly determine the capacity of pressure-relief devices to protect the facilities to which they are connected. Item 4: The Notice alleged that Respondent violated 49 C.F.R. § 192.465(d), which states: § 192.465 External corrosion control: Monitoring. (a) …. (d) Each operator shall take prompt remedial action to correct any deficiencies indicated by the monitoring. The Notice alleged that Respondent violated 49 C.F.R. § 192.465(d) by failing to take prompt remedial action to remediate cathodic-protection deficiencies discovered during annual monitoring of cathodically protected facilities. Specifically, the Notice alleged that Gulf South failed to meet the established criteria for adequate cathodic protection for 2014 and 2015 on its Line 64, Magasco C.S. to Call Junction, as evidenced by pipe-to-soil measurements taken at mile pole 62.9600, and pipe-to-soil measurements taken at mile pole 63.9010, which failed to meet adequate cathodic-protection levels for 2014, 2015, and 2016. Respondent did not contest this allegation of violation. Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 192.465(d) by failing to take prompt remedial action to remediate cathodic-protection deficiencies discovered during annual monitoring of cathodically protected facilities. These findings of violation will be considered prior offenses in any subsequent enforcement action taken against Respondent.#

420181001_Final Order_08082019_text.pdf, page 5CPF No. 4-2018-1001 Page 4 ASSESSMENT OF PENALTY Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed $200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any related series of violations.3 In determining the amount of a civil penalty under 49 U.S.C. § 60122 and 49 C.F.R. § 190.225, I must consider the following criteria: the nature, circumstances, and gravity of the violation, including adverse impact on the environment; the degree of Respondent’s culpability; the history of Respondent’s prior offenses; any effect that the penalty may have on its ability to continue doing business; and the good faith of Respondent in attempting to comply with the pipeline safety regulations. In addition, I may consider the economic benefit gained from the violation without any reduction because of subsequent damages, and such other matters as justice may require. The Notice proposed a total civil penalty of $62,000 for the violations cited above. Item 1: The Notice proposed a civil penalty of $29,600 for Respondent’s violation of 49 C.F.R. § 192.615(b)(2), for failing to perform training of personnel through mock drills to assure knowledge of the emergency procedures and to verify effectiveness of the training as required by Gulf South Procedure 3010 – Event Response Plan. Gulf South neither contested the allegation nor presented any evidence or argument justifying a reduction or elimination of the proposed penalty. Accordingly, having reviewed the record and considered the assessment criteria, I assess Respondent a civil penalty of $29,600 for violation of 49 C.F.R. § 192.615(b)(2). Item 4: The Notice proposed a civil penalty of $32,400 for Respondent’s violation of 49 C.F.R. § 192.465(d), for failing to take prompt action to remediate cathodic-protection deficiencies discovered during annual monitoring of cathodically protected facilities. Gulf South neither contested the allegation nor presented any evidence or argument justifying a reduction or elimination of the proposed penalty. Accordingly, having reviewed the record and considered the assessment criteria, I assess Respondent a civil penalty of $32,400 for violation of 49 C.F.R. § 192.465(d). In summary, having reviewed the record and considered the assessment criteria for each of the Items cited above, I assess Respondent a total civil penalty of $62,000, which amount was paid in full by wire transfer on February 26, 2018. COMPLIANCE ORDER The Notice proposed a compliance order with respect to Item 3 in the Notice for a violation of 49 C.F.R. § 192.743(a)-(b). Under 49 U.S.C. § 60118(a), each person who engages in the transportation of hazardous liquids or who owns or operates a pipeline facility is required to comply with the applicable safety standards established under chapter 601. Pursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the following actions to ensure compliance with the pipeline safety regulations applicable to its 3 These amounts are adjusted annually for inflation. See 49 C.F.R. § 190.223; Revisions to Civil Penalty Amounts, 83 Fed. Reg. 60732, 60744 (Nov. 27, 2018).#

420181001_Final Order_08082019_text.pdf, page 6CPF No. 4-2018-1001 Page 5 operations: 1. With respect to the violation of § 192.743(a)-(b) (Item 3), Respondent must: a. Conduct a review of pressure-reduction and relief-device capacities to ensure adequate overpressure protection capacities are in place to maintain downstream operating pressures within the maximum allowable operating pressure limits and provide training to individuals responsible for the annual reviews required by § 192.743. b. Provide documentation of the reviews of pressure reduction and overpressure protection capacities performed. Also provide the names and dates of when the training was completed for individuals who would be performing the annual reviews required by § 192.743. 2. Gulf South shall complete the items required by this Compliance Order within 120 days after receipt of the Final Order. 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. It is requested (not mandated) that Respondent maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to the Director. 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. Failure to comply with this Order may result in the administrative assessment of civil penalties not to exceed $200,000, as adjusted for inflation (49 C.F.R. § 190.223), for each violation for each day the violation continues or in referral to the Attorney General for appropriate relief in a district court of the United States. WARNING ITEM With respect to Item 2, the Notice alleged probable violations of Part 192 but did not propose a civil penalty or compliance order for this item. Therefore, this is considered to be a warning item. The warning was for: 49 C.F.R. §§ 192.605(a) and 192.615(b)(3) (Item 2) ─ Respondent’s alleged failure to perform a review of employee activities following an emergency situation to determine whether emergency procedures were effectively followed as required by Gulf South Procedure 3010 – Event Response Plan.#

420181001_Final Order_08082019_text.pdf, page 7CPF No. 4-2018-1001 Page 6 If OPS finds a violation of these provisions in a subsequent inspection, Respondent may be subject to future enforcement action. Under 49 C.F.R. § 190.243, Respondent may submit a Petition for Reconsideration of this Final Order to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey Avenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to the Office of Chief Counsel, PHMSA, at the same address, no later than 20 days after receipt of service of this Final Order by Respondent. Any petition submitted must contain a statement of the issue(s) and meet all other requirements of 49 C.F.R. § 190.243. The terms of the order, including corrective action, remain in effect unless the Associate Administrator, upon request, grants a stay. The terms and conditions of this Final Order are effective upon service in accordance with 49 C.F.R. § 190.5. August 8, 2019 ___________________________________ __________________________ Alan K. Mayberry Date Issued Associate Administrator for Pipeline Safety#

420181001_NOPV PCP PCO_01312018_text.pdf, page 1Official PDFNOTICE OF PROBABLE VIOLATION PROPOSED CIVIL PENALTY and PROPOSED COMPLIANCE ORDER CERTIFIED MAIL - RETURN RECEIPT REQUESTED January 31, 2018 Mr. Richard Keyser Sr. Vice President of Operations Gulf South Pipeline, LP 9 Greenway Plaza, Suite 2800 Houston, Texas 77046 CPF 4-2018-1001 Dear Mr. Keyser: On multiple occasions between May 8, 2015 and September 15, 2016, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United States Code were onsite and inspected Gulf South Pipeline’s assets in Texas and Louisiana. As a result of the investigation, it appears that you have committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. 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 operating and maintenance activities and for emergency response. For transmission lines, the manual must also include procedures for handling abnormal operations. This manual must be reviewed and updated by the operator at intervals not exceeding 15 months, but at least#

420181001_NOPV PCP PCO_01312018_text.pdf, page 2once each calendar year. This manual must be prepared before operations of a pipeline system commence. Appropriate parts of the manual must be kept at locations where operations and maintenance activities are conducted. § 192.615 Emergency plans. (b) Each operator shall: (2) Train the appropriate operating personnel to assure that they are knowledgeable of the emergency procedures and verify that the training is effective. Gulf South failed to perform training of personnel through mock drills to assure knowledge of the emergency procedures and to verify effectiveness of the training as required by Gulf South Procedure 3010. During the inspection, records of annual training of personnel in emergency procedures and mock drills were reviewed for the operating areas visited. In 2014, exercises and mock drills were not conducted in Hall Summit Sarepta, Westlake, and Goodrich Units and in 2015, exercises and mock drills were not conducted in Hall Summit Sarepta and Goodrich Units. Gulf South Procedure 3010 – Event Response Plan states: “Supervisors who may be expected to implement a portion of this plan shall:  Verify that training is effective through performance of exercises and mock drills (document on Form 3000-40: Emergency Response Scenario and Training Record); and  Review employee activities after responses to events and emergency situations to determine whether procedures were adequate and were effectively followed. Documentation of training meetings, people attending, and the material covered shall be put in writing and maintained in field office records (document on Form 0000-10: Meeting/Training Roster). Exercises and mock drills shall be conducted periodically, typically once a year, as operations permit. Exercise documentation shall be maintained at each facility (document on Form 3000-40: Emergency Response Scenario and Training Record).” 2. §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 operating and maintenance activities and for emergency response. For transmission lines, the manual must also include procedures for handling abnormal operations. This manual must be reviewed 2#

420181001_NOPV PCP PCO_01312018_text.pdf, page 3and updated by the operator at intervals not exceeding 15 months, but at least once each calendar year. This manual must be prepared before operations of a pipeline system commence. Appropriate parts of the manual must be kept at locations where operations and maintenance activities are conducted. § 192.615 Emergency plans. (b) Each operator shall: (3) Review employee activities to determine whether the procedures were effectively followed in each emergency. Gulf South failed to perform a review of employee activities following an emergency situation to determine whether emergency procedures were effectively followed as required by Gulf South Procedure 3010. Event Notification Reports 1062 and 1063 involved pipeline leaks that occurred within 220 yards of a building intended for human occupancy. The events did not result in reportable Safety Related Condition Reports since they were promptly corrected. They were, however, considered to be emergency situations due to their proximity to a building intended for human occupancy. Gulf South’s documentation of these emergency event situations on Form 3000-10 did not include a review of employee activities to determine whether procedures were effectively followed in response to the emergency. Gulf South Procedure 3010 – Event Response Plan states: “Supervisors who may be expected to implement a portion of this plan shall:  Review employee activities after responses to events and emergency situations to determine whether procedures were adequate and were effectively followed.” Gulf South Procedure 2130 – General Operation of the Pipeline states: Safety-Related Condition “Potential safety-related conditions include, but are not limited to the following:  A leak in a pipeline or LNG facility that contains or processes gas or LNG that constitutes and emergency. A leak discovered, especially one that exists within 220 yards (220 m) from any building intended for human occupancy or outside place of assembly by default is an emergency.” 3. §192.743 Pressure limiting and regulating stations: Capacity of relief devices. (a) Pressure relief devices at pressure limiting stations and pressure regulating stations must have sufficient capacity to protect the facilities to which they are connected. Except as provided in §192.739(b), the capacity must be consistent with the pressure limits of §192.201(a). This capacity must be determined at intervals not exceeding 15 months, but 3#

420181001_NOPV PCP PCO_01312018_text.pdf, page 4at least once each calendar year, by testing the devices in place or by review and calculations. (b) If review and calculations are used to determine if a device has sufficient capacity, the calculated capacity must be compared with the rated or experimentally determined relieving capacity of the device for the conditions under which it operates. After the initial calculations, subsequent calculations need not be made if the annual review documents that parameters have not changed to cause the rated or experimentally determined relieving capacity to be insufficient. Gulf South failed to properly determine the capacity of pressure relief devices to protect the facilities to which they are connected as required by §192.743. The Control Equipment Inspection Reports presented as a record of annual inspection of overpressure protection did not represent actual or up to date information related to regulator and relief valve capacities. Outlined below are locations where overpressure protection device capacities were presented incorrectly on the Control Equipment Inspection Report form. The required annual testing or reviews of capacities of regulators and overpressure protection relief devices should have revealed to the reviewers that, in some cases, capacities of regulators appeared to exceed the capacities of overpressure protective relief devices. Control Equipment Inspection Reports for Relief Valve SLN 571, Alto City Gate Equipment No. 255600 and Regulator SLN 571, Alto City Gate Reg-Primary Equipment No. 255501 indicate improper capacities of 71.5 MSCF/HR and 85 MSCF/HR respectively for 2013 and 2015. Control Equipment Inspection Report for Relief Valve SLN 508 Entex-Carthage TB Equipment No. 255695 indicated an inadequate capacity of 266 MSCF/HR with the Regulator Capacity @ set point of MAOP to the relief valve in MSCF/HR of 500 in the 2013 inspection cycle. Control Equipment Inspection Reports reviewed from 2011 – 2015 indicated the capacity of Relief Valve 727470-1 SLN 4695 Equipment No. 257753 to be 2835 MSCF/HR and Regulator Capacity (Equipment No. 259011) @ set point of MAOP to the relief valve in MSCF/HR to also be 2835. Further investigation revealed the correct capacities of the Relief Valve and Regulator to be 2218.4 and 1926.3 MSCF/HR respectively. Gulf South Procedure 2050 – Regulator and Overpressure Protection states: “Requirements and Frequencies for Testing and Inspection Operations Personnel shall inspect and test all DOT regulated pressure regulating and overpressure protection equipment at facilities to determine that it meets the following:  In good mechanical condition;  Adequate from the standpoint of capacity and reliability of operation for the service in which it is employed; 4#

420181001_NOPV PCP PCO_01312018_text.pdf, page 5 Properly installed and protected from dirt, liquids, or other conditions that might prevent proper operation; and  It is set to function at the correct pressure. Annually the Regional Measurement Leader (RML) shall perform capacity verification on all regulator, relief valve and/or overpressure protection equipment.” 4. §192.465 External corrosion control: Monitoring. (d) Each operator shall take prompt remedial action to correct any deficiencies indicated by the monitoring. Gulf South failed to take prompt remedial action to remediate cathodic protection deficiencies discovered during annual monitoring of cathodically protected facilities. On Line 64, Magasco C.S. to Call Junction, pipe-to-soil measurements taken at mile pole 62.9600 failed to meet the established criteria for adequate cathodic protection for 2014 and 2015 and pipe- to-soil measurements taken at mile pole 63.9010 failed to meet adequate cathodic protection levels for 2014, 2015, and 2016. Proposed Civil Penalty Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $209,002 per violation per day the violation persists up to a maximum of $2,090,022 for a related series of violations. For violations occurring prior to November 2, 2015, the maximum penalty may not exceed $200,000 per violation per day, with a maximum penalty not to exceed $2,000,000 for a related series of violations. The Compliance Officer has reviewed the circumstances and supporting documentation involved in the above probable violation(s) and has recommended that you be preliminarily assessed a civil penalty of $62,000as follows: Item number PENALTY 1 $ 29,600 4 $ 32,400 Warning Items With respect to Item 2, 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 these items. Failure to do so may result in additional enforcement action. 5#

420181001_NOPV PCP PCO_01312018_text.pdf, page 6Proposed Compliance Order With respect to Item 3 pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration proposes to issue a Compliance Order to Gulf South Pipeline, LP. Please refer to the Proposed Compliance Order, which is enclosed and made a part of this Notice. Response to this Notice Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance Proceedings. Please refer to this document and note the response options. All material 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). 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. In your correspondence on this matter, please refer to CPF 4-2018-1001 and for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Terri J. Binns Acting Director, Southwest Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings 6#

420181001_NOPV PCP PCO_01312018_text.pdf, page 7PROPOSED COMPLIANCE ORDER Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration (PHMSA) proposes to issue to Gulf South Pipeline, LP a Compliance Order incorporating the following remedial requirements to ensure the compliance of Gulf South Pipeline, LP with the pipeline safety regulations: 1. 2. 3. In regard to Item Number 3 of the Notice pertaining to the failure to properly determine the capacity of pressure reduction and relief devices to protect facilities to which they are connected as required by §192.743: a. Gulf South must conduct a review of pressure reduction and relief device capacities to ensure adequate overpressure protection capacities are in place to maintain downstream operating pressures within the MAOP limits and provide training to individuals responsible for the annual reviews required by §192.743. b. Provide documentation of the reviews of pressure reduction and overpressure protection capacities performed. Also provide the names and dates of when the training was completed for individuals who would be performing the annual reviews required by §192.743. Gulf South shall complete Item 1 within 60 days after receipt of the Final Order. It is requested (not mandated) that Gulf South Pipeline, LP maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to Terri J. Binns, Acting Director, Southwest Region, Pipeline and Hazardous Materials Safety Administration. 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. 7#