{"operation":"document","citation":"CPF 42021015NOPV","title":"GULF SOUTH PIPELINE COMPANY, LLC — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-11-02","effective_on":null,"summary":"CLOSED notice of probable violation citing 192.179(b)(1), 192.605(a), 192.805(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021015nopv.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021015nopv.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021015nopv","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42021015NOPV","body":"Notice of Probable Violation involving GULF SOUTH PIPELINE COMPANY, LLC. PHMSA's enforcement data identifies the cited regulations as 192.179(b)(1),  192.605(a),  192.805(b). The case was opened on 2021-11-02 and is reported as closed as of 2023-05-08. Proposed civil penalty: $38,000. Assessed civil penalty: $38,000. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42021015NOPV_Closure Letter_05082023_(20-171965).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021015NOPV/42021015NOPV_Closure%20Letter_05082023_(20-171965).pdf\n\n42021015NOPV_Closure Letter_05082023_(20-171965)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021015NOPV/42021015NOPV_Closure%20Letter_05082023_(20-171965)_text.pdf\n\n42021015NOPV_Final Order_12192022_(20-171965).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021015NOPV/42021015NOPV_Final%20Order_12192022_(20-171965).pdf\n\n42021015NOPV_Final Order_12192022_(20-171965)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021015NOPV/42021015NOPV_Final%20Order_12192022_(20-171965)_text.pdf\n\n42021015NOPV_Operator Response to Notice_12142021_(20-171965).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021015NOPV/42021015NOPV_Operator%20Response%20to%20Notice_12142021_(20-171965).pdf\n\n42021015NOPV_PCO PCP_11022021_(20-171965).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021015NOPV/42021015NOPV_PCO%20PCP_11022021_(20-171965).pdf\n\n42021015NOPV_PCO PCP_11022021_(20-171965)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021015NOPV/42021015NOPV_PCO%20PCP_11022021_(20-171965)_text.pdf\n\n42021015NOPV_Final Order_12192022_(20-171965)_text.pdf\n\nDecember 19, 2022\nVIA ELECTRONIC MAIL: stan.horton@bwpipelines.com\nMr. Stanley Horton\nPresident and Chief Executive Officer\nBoardwalk Pipeline Partners, LP\n9 Greenway Plaza, Suite 2800\nHouston, Texas 77046\nRe: CPF No. 4-2021-015-NOPV\nDear Mr. Horton:\nEnclosed please find the Final Order issued in the above-referenced case. It withdraws one Item\nand its associated compliance order, makes a finding of violation as to the remaining Item,\nwithdraws the associated compliance order item, and assesses a civil penalty of $38,000 to Gulf\nSouth Pipeline Company, LLC. The penalty payment terms are set forth in the Final Order.\nWhen the civil penalty has been paid, this enforcement action will be closed. Service of the\nFinal Order by e-mail is effective upon the date of transmission and acknowledgement of receipt\nas provided under 49 C.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Mr. Bryan Lethcoe, Director, Southwest Region, Office of Pipeline Safety, PHMSA\nMr. Tony G. Rizk, P.E., Vice President, Technical Services, Boardwalk Pipelines\nPartners, LP, tony.rizk@bwpipelines.com\nMs. Tina Baker, Manager, Compliance Services, Boardwalk Pipelines Partners, LP,\ntina.baker@bwpipelines.com\nCONFIRMATION OF RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n______________________________________________\n)\nIn the Matter of )\n)\nGulf South Pipeline Company, LLC, ) CPF No. 4-2021-015-NOPV\na subsidiary of Boardwalk Pipeline Partners, LP, )\n)\nRespondent. )\n______________________________________________)\nFINAL ORDER\nFrom November 20, 2019, through October 25, 2020, pursuant to 49 U.S.C. § 60117,\nrepresentatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office\nof Pipeline Safety (OPS), inspected the newly constructed Willis Lateral Pipeline of Gulf South\nPipeline Company, LLC (Gulf South or Respondent), a subsidiary of Boardwalk Pipeline\nPartners, LP. The Willis Lateral Pipeline traverses from San Jacinto County to Montgomery\nCounty, Texas.\nAs a result of the inspection, the Director, Southwest Region, OPS (Director), issued to\nRespondent, by letter dated November 2, 2021, a Notice of Probable Violation, Proposed Civil\nPenalty, and Proposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the\nNotice proposed finding that Gulf South committed two violations of 49 C.F.R. part 192,\nproposed assessing a civil penalty of $38,000 for the alleged violations, and proposed ordering\nRespondent to take certain measures to correct the alleged violations. The Notice also included\nan additional two warning items pursuant to 49 C.F.R. § 190.205, which warned the operator to\ncorrect the probable violations or face possible future enforcement action\nOn November 17, 2021, Gulf South requested an extension of time to respond to the Notice.\nRespondent’s request was granted. Gulf South responded to the Notice by letter dated December\n14, 2021 (Response). Respondent contested two of the allegations, offered additional\ninformation in response to the Notice, requested that the proposed civil penalty be reduced, and\nasked that the proposed compliance order (PCO) for Item 3 be withdrawn and the PCO for Item\n4 be amended if not withdrawn. Respondent did not request a hearing and therefore has waived\nits right to one.\n\n\n\nFINDINGS OF VIOLATION\nThe Notice alleged that Respondent violated 49 C.F.R. part 192, as follows:\nItem 3: The Notice alleged that Respondent violated 49 C.F.R. § 192.179(b)(1), which states:\n§ 192.179 Transmission line valves.\n(a) ….\n(b) Each sectionalizing block valve on a transmission line, other than\noffshore segments, must comply with the following:\n(1) The valve and the operating device to open or close the valve must\nbe readily accessible and protected from tampering and damage.\nThe Notice alleged that Respondent violated 49 C.F.R. § 192.179(b)(1) by failing to protect\nvalves from tampering and damage at two separate valve site locations: the Willis Lateral Line\nOrigination Station and the Willis Lateral Line Terminus Station. Specifically, the Notice\nalleged that PHMSA found the main gate to the Willis Lateral Line Origination Station did not\nhave locks. The Notice also alleged that PHMSA identified an “emergency valve” at the Willis\nLateral Line Terminus Station that was accessible by an opening in the fencing surrounding the\ninterconnect pipeline area.\nIn its Response, Respondent argued that Item 3 must be withdrawn because “OPS fail[ed] to\nestablish that the valves and the operating devices to open or close the valves are not protected\nfrom tampering and damage.\n”1 Respondent contended that the Origination Station and the\nTerminus Station are both at least partially enclosed by perimeter fencing and that the valves\nwithin those enclosures were secured with chains and locks. Respondent further contented that\n“PHMSA has previously found that locks provide protection from tampering.”2 Respondent also\nargued that “OPS also [did] not explain why the lack of a lock on the main gate or a hole in the\nfencing undermines the stated purpose of fencing to alert others to the presence of the valves at\nthe stations so as to prevent damage.”3\nAfter considering all of the evidence and the legal issues presented, I withdraw the allegation of\nviolation. PHMSA has previously found that valves secured by chains with locks provide\nsufficient protection from tampering.4 In this case, the evidence shows that the valves at both\nstations were secured by chains with locks. There is no evidence that these measures failed to\nprovide sufficient protection from tampering. The evidence also shows that there was fencing\naround the stations, but that the gates were not locked and there were gaps in the fencing. While\nthe evidence shows the fences were not fully secure, it does not show how the fencing was not\n1 Gulf South Pipeline Company, LLC, CPF No. 4-2021-015-NOPV Written Response to Notice of Probable\nViolation, Proposed Civil Penalty and Proposed Compliance Order, dated December 14, 2021 (hereinafter\n“Response”) (on file with PHMSA), at 6.\n2 Response, supra, at 6.\n3 Id.\n4 See Honeoye Storage Corp., Warning Letter, CPF No. 1-2012-0002W, dated April 2, 2011; Williams Gas Pipeline\nCo., LLC, Final Order, CPF No. 4-2010-1002, dated August 23, 2010; Alyeska Pipeline Service Co., Decision on\nPetition for Reconsideration, CPF No. 5-2000-5006, dated June 23, 2004.\n\n\n\nsufficient to protect the valves from damage. Accordingly, I withdraw this allegation of\nviolation.\nItem 4: The Notice alleged that Respondent violated 49 C.F.R. § 192.805(b), which states:\n§ 192.805(b) Qualification program.\nEach operator shall have and follow a written qualification program.\nThe program shall include provisions to:\n(a) ….\n(b) Ensure through evaluation that individuals performing covered tasks\nare qualified;\nThe Notice alleged that Respondent violated 49 C.F.R. § 192.805(b) by failing to ensure through\nevaluation that individuals performing a covered task on its pipeline are qualified. Specifically,\nthe Notice alleged that Gulf South failed to ensure that Entergy Texas, Inc. (Entergy)’s third-\nparty contractor, McDermott International, Ltd. (McDermott), was qualified, per its Operator\nQualification Program5 (OQ Plan), when performing the covered task of making an\ninterconnection between Gulf South’s Willis Lateral Pipeline and Entergy’s Montgomery County\nPower Station’s gas supply line in Montgomery County, Texas, on August 3, 2020. Gulf South\nand Entergy had an interconnection agreement for this work.\n6 Respondent, in its Response,\nconceded that the interconnect work at issue is a covered task.\nIn its Response, Respondent argued it was not required to ensure through evaluation that the\nindividuals performing the interconnection are qualified, as required by § 192.805(b), because\nthere was a qualified employee with “full stop work authority” observing Entergy’s contractor\nconnect the insulating flange to Gulf South’s pipeline. Respondent contended that this was\nconsistent with § 192.805(c).\nPer § 192.805, each operator shall have and follow a written qualification program. Section\n192.805(b) requires that the written qualification program include provisions to “ensure that\nindividuals performing covered tasks are qualified.” Section 192.805(c) “allow[s] individuals\nthat are not qualified pursuant to [subpart N] to perform a covered task if directed and observed\nby an individual that is qualified.” Respondent’s OQ Plan states that personnel are required to\nensure that contractors and entities performing covered tasks on its facilities are qualified.7 The\nOQ Plan requires Gulf South to “notify [the] contractor of the covered tasks that will be\nperformed by the contractor.”8 It also specifically requires that Gulf South “[s]ecure from the\ncontractor or VeriSource documentation (in paper form) required to ensure that the contractor’s\nemployees that will be performing the covered task(s) is qualified under this OQ Program to\n5 Boardwalk Pipelines, Operator Qualification Program, Version 5.50, Effective Date 4/1/2020. See Pipeline\nSafety Violation Report, CPF 4-2021-015-NOPV, Exhibit C-15.\n6 Pipeline Safety Violation Report, CPF 4-2021-015-NOPV, Exhibit C-13.\n7 Violation Report, Exhibit C-3, at page 5.\n8 Violation Report, Exhibit C-15, at pages 17 and 18.\n\n\n\nperform the covered task(s).”9 The OQ Plan also states that the operator must “[e]nsure\ndocumentation is maintained for all contractors performing covered tasks.”10\nThe record shows that Respondent did not comply with the regulations or its OQ Plan. Gulf\nSouth was unable to provide any OQ records for personnel who performed the covered task to\nshow it complied with § 192.805(b). The record also shows that Respondent did not maintain\ndocumentation showing McDermott personnel were qualified in accordance with its OQ Plan.\nRespondent also failed to notify the contractor of the covered tasks that would be performed in\ncompliance with its OQ Plan. Further, Respondent could not show that it reviewed the Entergy\nOQ Plan before the covered tasks were performed. Accordingly, I find Respondent failed to\nshow that it took steps to ensure the individuals performing the covered task on its pipeline were\nqualified per § 192.805(b) or that it followed its own OQ Plan, which required Respondent to\nmaintain documentation showing individuals performing covered tasks were qualified.\nI find that Respondent also did not comport with § 192.805(c) or its own OQ Plan that requires a\nqualified individual to “remain in a position where they can direct and observe the performance of\nthe covered task at all times” if non-qualified personnel are utilized to perform covered tasks.11\nThe record shows Respondent did not “direct and observe” the personnel who performed the\ncovered task at issue.\n12 During the PHMSA inspection, the Boardwalk Manager of Compliance\nprovided a written statement that detailed the following:\nBoardwalk’s (BWP) employee, Alan Pearson, was using his OQ and experience to\nensure [Entergy’s] contractor was installing to industry standards and BWP’s\nrequirements outlined in the ICA Agreement and Specifications and would have\nshut down work if a safety issue was to arise or if he felt that the work was not\nbeing done correctly. As previously stated, BWP will have an experienced\nemployee on site to oversee any work that may affect its facilities. We would not\nallow a connection to our facility without a BWP representative present. He was\nnot directing [Entergy’s] contractor nor was he providing span of control.\n13\n(Emphasis Added).\nThis written statement shows that covered Gulf South personnel were not “directing and\nobserving” the covered task which was being performed by an individual that Respondent did\nnot know was qualified or not. Respondent, therefore, does not meet the requirements of\n§ 192.805(c) or Respondent’s own OQ Plan.\nIn its Response, Respondent further argued it was in compliance with its OQ Plan because the\nOQ Plan states: “Individuals included in the program are employees, contractors and all others\n9 Id.\n10 Id.\n11 Violation Report, Exhibit C-15, at page 35.\n12 Violation Report, Exhibit C-12.\n13 Violation Report, Exhibit C-12.\n\n\n\nwho may perform covered tasks on regulated facilities (unless they are specifically exempted by\nthe applicable regulation) operated by Boardwalk.\n”14 I do not find this argument persuasive\nbecause this provision does not alter the fact that no qualified employee was directing and\nobserving the unqualified individual who performed the covered task, in accordance with\n§ 192.805(c) and Gulf South’s OQ Plan.\nAccordingly, after considering all of the evidence and the legal issues presented, I find\nthat Respondent violated 49 C.F.R. § 191.805(b) by failing to ensure through evaluation that\nindividuals performing a covered task on its pipeline were qualified per the OQ Plan.\nThis finding of violation will be considered a prior offense in any subsequent enforcement action\ntaken against Respondent.\nASSESSMENT OF PENALTY\nUnder 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed\n$200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any\nrelated series of violations.15\nIn determining the amount of a civil penalty under 49 U.S.C. § 60122 and 49 C.F.R. § 190.225, I\nmust consider the following criteria: the nature, circumstances, and gravity of the violation,\nincluding adverse impact on the environment; the degree of Respondent’s culpability; the history\nof Respondent’s prior offenses; any effect that the penalty may have on its ability to continue\ndoing business; the good faith of Respondent in attempting to comply with the pipeline safety\nregulations; and self-disclosure or actions to correct a violation prior to discovery by PHMSA.\nIn addition, I may consider the economic benefit gained from the violation without any reduction\nbecause of subsequent damages, and such other matters as justice may require. The Notice\nproposed a total civil penalty of $38,000 for the violations cited above.\nItem 4: The Notice proposed a civil penalty of $38,000 for Respondent’s violation of 49 C.F.R.\n§ 192.805(b), for failing to ensure through evaluation that individuals performing covered tasks\nare qualified. In its Response, Respondent argued that if Item 4 is not withdrawn the civil\npenalty should be reduced. Respondent asserted that the Violation Report overstates the\npotential safety risk in the Gravity section because Gulf South followed § 192.805(c), which\npermits a non-qualified individual to perform a covered task if directed and observed by a\nqualified individual. Respondent also argued that because it complied with § 192.805(c) the\nstatement under the Culpability section, that Respondent “failed to comply with an applicable\nrequirement,” is without support. Finally, Gulf South argued that the statement in the Good\nFaith section of the Violation Report that Respondent did not have a reasonable justification for\nnon-compliance fails to account for its compliance with § 192.805(c).\nRespondent’s arguments for a civil penalty reduction are, essentially, that it was in compliance\n14 Violation Report, Exhibit C-3, at page 6.\n15 These amounts are adjusted annually for inflation. See 49 C.F.R. § 190.223 for adjusted amounts.\n\n\n\nwith § 192.805(c). For the reasons described under the Findings of Violation section above, I\nfound that Respondent violated both 49 C.F.R. §§ 192.805(b) and (c). Therefore, no penalty\nreduction is warranted.\nAccordingly, having reviewed the record and considered the assessment criteria, I assess\nRespondent a civil penalty of $38,000 for violation of 49 C.F.R. § 192.805(b).\nPayment of the civil penalty must be made within 20 days after receipt of this Final Order.\nFederal regulations (49 C.F.R. § 89.21(b)(3)) require such payment to be made by wire transfer\nthrough the Federal Reserve Communications System (Fedwire), to the account of the U.S.\nTreasury. Detailed instructions are contained in the enclosure. Questions concerning wire\ntransfers should be directed to: Financial Operations Division (AMK-325), Federal Aviation\nAdministration, Mike Monroney Aeronautical Center, 6500 S MacArthur Blvd, Oklahoma City,\nOklahoma 79169. The Financial Operations Division telephone number is (405) 954-8845.\nFailure to pay the $38,000 civil penalty will result in accrual of interest at the current annual rate\nin accordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to those\nsame authorities, a late penalty charge of six percent (6%) per annum will be charged if payment\nis not made within 110 days of service. Furthermore, failure to pay the civil penalty may result in\nreferral of the matter to the Attorney General for appropriate action in a district court of the\nUnited States.\nCOMPLIANCE ORDER\nThe Notice proposed a compliance order with respect to Items 3 and 4 for violations of 49 C.F.R.\n§§ 192.179(b)(1) and 192.805(b), respectively. Under 49 U.S.C. § 60118(a), each person who\nengages in the transportation of gas or who owns or operates a pipeline facility is required to\ncomply with the applicable safety standards established under chapter 601.\nWith regard to the violation of § 192.179(b)(1) (Item 3), Respondent argued the compliance\nterms should be withdrawn. For the reasons described in the Findings of Violation section above,\nI have withdrawn the allegation of violation for Item 3. Accordingly, I hereby withdraw the\nassociated compliance order for this Item.\nWith regard to the violation of § 192.805(b) (Item 4), Respondent argued that the proposed\ncompliance terms, as written, are “overbroad and inconsistent with § 192.805(c).” Specifically,\nGulf South requested that, if the underlying violation is not withdrawn, the language be amended\nto “state that any third-party entity or its contractors are covered under the Boardwalk OQ…to\npermit Gulf South to direct and observe third-party entities and their contractors when they\nperform a covered task on Gulf South’s facilities.” I agree.\nFor the reasons stated above, Respondent failed to comply with § 192.805(b) and its OQ plan.\nHowever, the terms of the proposed compliance order for Item 4 are not necessary and are\ninconsistent with § 192.805(c). Respondent’s OQ Plan states that personnel are required to\n\n\n\nensure that contractors and entities performing covered tasks on its facilities are qualified.16 The\nOQ Plan requires Gulf South to “notify [the] contractor of the covered tasks that will be\nperformed by the contractor.”17 Gulf South’s OQ Plan requires it to “[s]ecure from the\ncontractor or VeriSource documentation (in paper form) required to ensure that the contractor’s\nemployees that will be performing the covered task(s) is qualified under this OQ Program to\nperform the covered task(s),\n”18 and such documentation must be “maintained for all contractors\nperforming covered tasks.”19 Furthermore, Respondent’s OQ Plan requires a qualified individual\nto “remain in a position where they can direct and observe the performance of the covered task at\nall times” if non-qualified personnel are utilized to perform covered tasks.\n20 While Respondent\nfailed to follow its OQ Plan, the provisions as written appear to be consistent with §§ 192.805(b)\nand (c). Further, the proposed compliance order requiring modification to Gulf South’s OQ Plan\n“to state that any third-party entity or its contractors are covered under its OQ Plan” could\nactually result in changes to the procedures that would not be consistent with the provisions in\n§192.805(c). For this reason, the Proposed Compliance Order item for the violation of Item 4 is\nwithdrawn.\nWARNING ITEMS\nWith respect to Items 1 and 2, the Notice alleged probable violations of Part 192, but identified\nthem as warning items pursuant to § 190.205. The warnings were for:\n49 C.F.R. § 192.605(a) (Item 1) ─ Respondent’s alleged failure to follow\nBoardwalk Pipelines, Operations and Maintenance Manual: Natural Gas,\nPipeline Operations, Section 2180-Prevention of Accidental Ignition (Effective\nDate 12/20/2019; Revision Date 7/20/2020) as it relates to fire extinguishers at its\nfacilities; and\n49 C.F.R. § 192.605(a) (Item 2) ─ Respondent’s alleged failure to follow\nBoardwalk Pipelines, Operations and Maintenance Manual: Natural Gas,\nPipeline Operations, Section 2180-Prevention of Accidental Ignition (Effective\nDate 12/20/2019; Revision Date 7/20/2020) as it relates to warning signage at its\nfacilities.\nIf OPS finds a violation of any of these items in a subsequent inspection, Respondent may be\nsubject to future enforcement action.\nUnder 49 C.F.R. § 190.243, Respondent may submit a Petition for Reconsideration of this Final\nOrder to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey\n16 Violation Report, Exhibit C-3, at page 5.\n17 Violation Report, Exhibit C-15, at pages 17 and 18.\n18 Id.\n19 Id.\n20 Id., at page 35.\n\n\n\nAvenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to the Office of\nChief Counsel, PHMSA, at the same address. The written petition must be received no later than\n20 days after receipt of the Final Order by Respondent. Any petition submitted must contain a\nstatement of the issue(s) and meet all other requirements of 49 C.F.R. § 190.243. The filing of a\npetition automatically stays the payment of any civil penalty assessed. The other terms of the\norder, including corrective action, remain in effect unless the Associate Administrator, upon\nrequest, grants a stay.\nThe terms and conditions of this Final Order are effective upon service in accordance with 49\nC.F.R. § 190.5.\nDecember 19, 2022\n___________________________________ __________________________\nAlan K. Mayberry Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n42021015NOPV_Closure Letter_05082023_(20-171965)_text.pdf\n\nVIA ELECTRONIC MAIL\nMay 8, 2023\nMr. Stanley Horton\nPresident and Chief Executive Officer\nBoardwalk Pipeline Partners, LP\n9 Greenway Plaza, Suite 2800\nHouston, Texas 77046\nCPF 4-2021-015-NOPV\nDear Mr. Horton:\nFrom November 20, 2019 to October 25, 2020, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter\n601 of 49 United States Code (U.S.C.), inspected Gulf South Pipeline Company, LLC’s (Gulf\nSouth) newly constructed Willis Lateral Pipeline traversing from San Jacinto County to\nMontgomery County, Texas. As a result of the inspection, Gulf South was issued a Final Order\n(Order) in the above referenced case. This Order included a Civil Penalty.\nGulf South paid the Civil Penalty on December 22, 2022.\nAccordingly, this case is now closed, and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nBryan Lethcoe\nDirector, Southwest Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Mr. Tony G. Rizk, P.E., Vice President, Technical Services, Boardwalk Pipelines\nPartners, LP, tony.rizk@bwpipelines.com\nMs. Tina Baker, Manager, Compliance Services, Boardwalk Pipelines Partners, LP,\ntina.baker@bwpipelines.com","truncated":false,"body_characters":25120}