BOARDWALK

000
PIPELINE PAR NERS

July 22, 2009

Mr. Alan Mayberry

Director, Engineering and Emergency Support
Pipeline and Hazardous Materials Safety Administration
East Building, 3rd Floor
Mail Stop: E32-303
1200 New Jersey Ave SE
Room E22-207
Washington DC, 20590

Re: Request for Variance from. the Special Permit Modification Agreement,
("Modification Agreement"), by and between the Pipeline and Hazardous
Materials Safety Administration ("PHMSA") and Boardwalk Pipeline
Partners, LP, and its Subsidiaries (collectively, "Boardwalk") Dated April
30, 2009 for 42" Welspun Manufactured Pipe with a POSCO Coil Source

Dear Mr. Mayberry:

Under the Modification Agreement, Boardwalk is required to complete testing of

pipe removed from the line to establish the serviceability up to 80% SMYS operating
parameters for each 42-inch and 36-inch pipe steel supplier, rolling campaign, and slab
source with identified pipe expansion for 5 specific categories.

Since entering into the Modification Agreement, Boardwalk has completed the
following work for the 42-inch VVelspun manufactured pipe with a POSCO coil source.
The removal of the only expanded joint for this manufacturer/coil source has been
completed. Two pipe joints showing no expansion after the hydrostatic test for this
manufacturer/coil source and four pipe joints from stock that have not undergone a
construction hydrostatic test have been secured.

Section II Condition #7a of the Modification Agreement requires "A minimum of

four pipe joints must be tested showing no expansion after hydrotest." After reviewing
the location of remaining 42-inch pipe replacements, it has been determined that there are
no remaining joints for this manufacturer and slab source combination without
expansions after the hydrotest within the line segments scheduled to be removed from
service or in the vicinity of any of the remaining work locations. As such, removal of the
two other joints required to fulfill Section II Condition #7a of the Modification

reycias OAS
CROSSING GU.LF SOL".:!:H"

9 Greenway Plaza, Suite 2800 Houston, Texas 77046 713.479.8000

BOARDWALK

000
PIPELINE PARTNERS

Agreement will require additional sections of pipe to be removed from service for the
sole reason of securing these test pipe joints.

Boardwalk requests PHMSA to grant a variance allowing the substitution of two

pipes that have not undergone a field hydrostatic test for the completion of Section II
Condition #7a of the Modification Agreement. Boardwalk proposes to hydrostatically
test these two pipe joints to a minimum of 100% of the specified minimum yield strength
and then perform mechanical and chemical testing on these pipe joints, before and after
hydrostatic testing, to fulfill the requirements of Section II Condition #7a of the
Modification Agreement.

Approval of this variance will: 1) avoid additional disruption to supply and

delivery customers, 2) lessen the impact to the environment by eliminating ground
disturbance activities resulting from accessing/excavating location and by eliminating the
release of gas to the atmosphere, 3) lessen the impact to landowners and the public due to
ground disturbance activities required by this activity and 4) will lessen impacts to the
gas market. The approval of this variance will not negatively impact the end results of
the testing requirements of the Modification Agreement.

Boardwalk appreciates PHMSA's ongoing cooperation and assistance with these

important issues. Please respond with your approval or comments at your earliest
convenience. Should you have any questions or comments, please feel free to contact
myself or Frank Maraia at (985) 898-1004, Frank.Maraia@bwpm1p.corn.

Sincerely,

David Goodwin
Vice President

cc: Steve Nanney (via e-mail only)