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Covington, Tameka (PHMSA)

From: Earley, John [John.Earley@bwpm1p.com ]

Sent: Tuesday, September 11, 2007 10:16 AM
To: Nanney, Steve <PHMSA>
Cc: McMahon, Mike; Ward, Greg; Mitchell, Dan; Garris, John; Seeley, Rodrick M. <PHMSA>; Kadnar,
Joy <PHMSA>; Mayberry, Alan <PHMSA>; Bennett, Walt
Subject: RE: Jindal Mill allegations

Steve,

We are currently in the process of consolidating and reviewing the various data records necessary to determine if
a problem exists. Many of these records are in our possession, others are in transit to our offices. Concurrent to
our data review we are developing a quality validation process which would allow us to physically locate and
validate any potential quality issues if they are discovered during our data review. Both of these activities should
be substantially complete by the end of next week at which point we would expect to be prepared to meet and
review this information and any findings with your office.

We will continue to communicate our progress to PHMSA and commit to inform you of any changes in this
schedule. As always, please do not hesitate to contact us if you have any questions or concerns.

John

PLEASE NOTE NEW EMAIL, MAILING ADDRESS, PHONE & FAX:

John Earley
Boardwalk Pipeline Partners, LP
9 Greenway Plaza, Suite 2800, Houston, TX 77046
P: 713-479-8060, F: 713-479-1760
Email: john.earley@bwpmlpsom

From: Steve.Nanney@dot.gov [mailto:Steve.Nanney@dot.gov]

Sent: Monday, September 10, 2007 10:49 PM
To: Bennett, Walt
Cc: Earley, John; McMahon, Mike; Ward, Greg; Mitchell, Dan; Garris, John; Steve.Nanney@dot.gov ;
Rodrick.M.Seeley@dot.gov ; joy.kadnar@dot.gov ; alan.mayberry@dot.gov
Subject: RE: Jindal Mill allegations

Walt, when in the future will you be in a position on this matter to review findings and your planned
implementation of additional controls as noted in your e-mail.

Thanks,

Steve

From: Bennett, Walt [mailto:Walt.Bennett@bwpmlp.com]

Sent: Monday, September 10, 2007 5:05 PM
To: Seeley, Rodrick M. <PHMSA>; Kadnar, Joy <PHMSA>; Nanney, Steve <PHMSA>; Mayberry, Alan <PHMSA>
Cc: Earley, John; McMahon, Mike; Ward, Greg; Mitchell, Dan; Garris, John
Subject: Jindal Mill allegations

On Wednesday, September 6, 2007 Gulf South received a telephone call from a former employee at the Jindal
pipe manufacturing facility. Based upon that call Gulf South requested a face-to-face meeting with this individual

11/23/2009
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which was held on September 7, 2007. At this meeting two former employees from Jindal attended. Both
individuals were employed in the coating mill at the plant. The former employees' primary concern was the
working conditions at the coating mill, and certain events surrounding their employment.

In addition, these former employees raised certain allegations concerning the pipe being manufactured for Gulf
South. The allegations with potential to impact the pipe integrity were specifically noted. Based upon these
allegations, Gulf South has commenced an investigation that will include the following activities:

• a review of current inspection procedures,

• a review of recordkeeping and data storage practices,
• cross-checks on pipe data across multiple independent sources including: Jindal, Gulf South, and third
party suppliers for Jindal (double-joint contractors, NDE contractors),
• a physical audit of selected pipe with alleged issues,
• a spot audit of inspection areas in question, and
• immediate implementation of an independent tracking and verification database for pipe procedures
beyond the pipe mill to assure an independent check of pipe specification conformance, quality, and
disposition through final shipment and receipt at Gulf South's field yards.

Any allegations that cannot be resolved through the investigation, document review and audit will be individually
addressed by an appropriate method to ensure pipe integrity. In addition, Gulf South is planning on implementing
some additional controls for future pipe production.

Please contact me with any questions or concerns.

Best regards,

Walter Bennett
Boardwalk Pipeline Partners
9 Greenway Plaza, Suite 2800
Houston, Texas 77046
713 479-8102 office
713-443-9108 mobile
713 479-1802 fax
walt.bennettbbwpmlp.com

11/23/2009