# COLLINS PIPELINE CO — Notice of Amendment

- **operation:** document
- **citation:** CPF 12026007NOA
- **title:** COLLINS PIPELINE CO — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2026-03-16
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 195.446(b)(4), 195.446(e)(4), 195.446(e)(5), 195.446(e)(6), 195.446(g)(1), 195.446(g)(2).
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/12026007NOA
**body:**

Notice of Amendment involving COLLINS PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 195.446(b)(4),  195.446(e)(4),  195.446(e)(5),  195.446(e)(6),  195.446(g)(1),  195.446(g)(2). The case was opened on 2026-03-16 and is reported as closed as of 2026-07-24. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

12026007NOA_Closure Letter_07242026_(23-263951).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026007NOA/12026007NOA_Closure%20Letter_07242026_(23-263951).pdf

12026007NOA_Closure Letter_07242026_(23-263951)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026007NOA/12026007NOA_Closure%20Letter_07242026_(23-263951)_text.pdf

12026007NOA_Notice of Amendment_03162026_(23-263951).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026007NOA/12026007NOA_Notice%20of%20Amendment_03162026_(23-263951).pdf

12026007NOA_Notice of Amendment_03162026_(23-263951)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026007NOA/12026007NOA_Notice%20of%20Amendment_03162026_(23-263951)_text.pdf

12026007NOA_Operator Response to Notice_05152026_(23-263951).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026007NOA/12026007NOA_Operator%20Response%20to%20Notice_05152026_(23-263951).pdf

12026007NOA_Notice of Amendment_03162026_(23-263951)_text.pdf

U.S. Department
of Transportation
Pipeline and
Hazardous Materials
Safety Administration
840 Bear Tavern Road, Suite 300
West Trenton, NJ 08628
609.771.7800
NOTICE OF AMENDMENT
VIA ELECTRONIC MAIL TO: matthew.lucey@pbfenergy.com
March 16, 2026
Mr. Matthew Lucey
Chief Executive Officer and President
PBF Energy Inc.
1 Sylvan Way, 2nd Floor
Parsippany, New Jersey 07054
CPF 1-2026-007-NOA
Dear Mr. Lucey:
From December 4, 2023 to March 15, 2024 of the on-site inspection, a representative of the
Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49
United States Code (U.S.C.) inspected Collins Pipeline Company’s (Collins Pipeline)1 control
room procedures in Woodlands, Texas.
As a result of the inspection, PHMSA has identified the apparent inadequacies found within
Collins Pipeline’s plans or procedures. The items inspected and the alleged inadequacies and
proposed revisions are described below:
1. § 195.446 Control room management
(a) …
(b) Roles and responsibilities. Each operator must define the roles
and responsibilities of a controller during normal, abnormal, and
emergency operating conditions. To provide for a controller’s prompt
and appropriate response to operating conditions, an operator must
define each of the following:
(1) …
(4) A method of recording controller shift-changes and any
hand-over of responsibility between controllers;
1 Collins Pipeline Company is a subsidiary of PBF Energy, Inc.



CPF 1-2026-007-NOA
Collins Pipeline’s written control room management procedures were inadequate to assure safe
operation of a pipeline facility. Specifically, Collins Pipeline’s CRM Plan2 failed to include an
adequate shift handover process when the outgoing controller is unable to complete their scheduled
shift in accordance with section 195.446(b)(4).
The CRM Plan, section F8, stated that “[i]n the event a Controller is unable to complete their
scheduled shift; it is the responsibility of the Controller to notify the Control Room Supervisor or
designee.” In addition, the CRM Plan stated that “[t]he outgoing controller will record ‘Mid’ in
the ‘Shift’ field on the Controller Shift Change Checklist on the green sheet.” However, the CRM
Plan failed to identify how the console is managed (shutdown or monitored) while a replacement
is found, and how to proceed if the outgoing controller is unable to fulfill the outgoing
responsibilities in section F3.
Therefore, Collins Pipeline’s written control room management procedures were inadequate to
ensure safe operation of a pipeline facility in accordance with section 195.446(b)(4). PHMSA
proposes that Collins Pipeline revise its written control room management procedures to include a
shift handover process that addresses how the console is managed (shutdown or monitored) while
a replacement is found, and how to proceed if the outgoing controller is unable to fulfill the
outgoing responsibilities in section F3.
2. § 195.446 Control room management.
(a) …
(e) Alarm management. Each operator using a SCADA system must
have a written alarm management plan to provide for effective
controller response to alarms. An operator’s plan must include
provisions to:
(1) …
(4) Review the alarm management plan required by this
paragraph at least once each calendar year, but at intervals not
exceeding 15 months, to determine the effectiveness of the plan;
Collins Pipeline’s written control room management procedures were inadequate to assure safe
operation of a pipeline facility. Specifically, Collins Pipeline’s CRM Plan failed to include an
adequate process to review the alarm management plan to determine the effectiveness of the plan
at least once a calendar year but at intervals not exceeding 15 months in accordance with section
195.446(e)(4).
Collins Pipeline’s CRM Plan, sections A7 and M2.15 required an annual review of the alarm
management plan. However, the CRM Plan failed to include adequate details regarding the annual
review process. The CRM Plan failed to detail data sources, key performance indicators,
effectiveness evaluation methods, decision criteria, documentation requirements, and corrective
action procedures.
Therefore, Collins Pipeline’s written control room management procedures were inadequate to
assure safe operation of a pipeline facility in accordance with section 195.446(e)(4). PHMSA
2 PBF Logistics Pipeline Control Center: Control Room Management Plan, Rev-8 (08/25/23) (CRM Plan).
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CPF 1-2026-007-NOA
proposes that Collins Pipeline revise its written control room management procedures to establish
a detailed process for reviewing the effectiveness of the alarm management plan. This includes
defining data sources, key performance indicators, evaluation methods, decision criteria,
documentation standards, and corrective action procedures.
3. § 195.446 Control room management.
(a) …
(e) Alarm management. Each operator using a SCADA system must
have a written alarm management plan to provide for effective
controller response to alarms. An operator’s plan must include
provisions to:
(1) …
(5) Monitor the content and volume of general activity being
directed to and required of each controller at least once each
calendar year, but at intervals not exceeding 15 months, that will
assure controllers have sufficient time to analyze and react to
incoming alarms; and
Collins Pipeline’s written control room management procedures were inadequate to assure safe
operation of a pipeline facility. Specifically, Collins Pipeline’s CRM Plan failed to provide a
process for effective monitoring of the content and volume of general activity being directed to
and required of each controller at least once a calendar year but at intervals not exceeding 15
months in accordance with section 195.446(e)(5).
Collins Pipeline’s CRM Plan, sections A6.8 and M2.15 required an annual review of the content
and volume of general activity being directed to and required of each controller. However, the
CRM Plan failed to include adequate details regarding this annual review process. The CRM Plan
stated that the review will be monitored with a special application without describing it or how it
functioned in the workload study analysis. Section A6.8 stated that Collins Pipeline “will strive
for Controller availability percentage greater than 60%,” but failed to specify what this percentage
measured, how it was calculated, what activities were included in the measurement, or how the
results will be evaluated or acted upon if thresholds are not met. The CRM Plan also failed to
include documentation requirements for this annual review or specify how the results would be
used to reduce controller workload.
Therefore, Collins Pipeline’s written control room management procedures were inadequate to
ensure safe operation of a pipeline facility in accordance with section 195.446(e)(5). PHMSA
proposes that Collins Pipeline revise its written control room procedures to establish a data-driven
process for analyzing controller workload and its impact on alarm response times. This includes
defining metrics, specifying how data is collected and analyzed, outlining corrective actions when
deficiencies are found, and documenting findings.
4. § 195.446 Control room management.
(a) …
(e) Alarm management. Each operator using a SCADA system must
have a written alarm management plan to provide for effective
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CPF 1-2026-007-NOA
controller response to alarms. An operator’s plan must include
provisions to:
(1) …
(6) Address deficiencies identified through the implementation
of paragraphs (e)(1) through (e)(5) of this section.
Collins Pipeline’s written control room management procedures were inadequate to ensure safe
operation of a pipeline facility. Specifically, Collins Pipeline’s CRM Plan failed to include
adequate procedures to address deficiencies identified through the implementation of subsections
195.446(e)(1) through (e)(5) in accordance with section 195.446(e)(6).
Collins Pipeline’s CRM Plan, section A6.9 stated that any deficiencies discovered through
implementation of the CRM Plan procedures will be addressed and documented by the Control
Room Supervisor or Designee. However, the CRM Plan failed to specify how deficiencies are to
be evaluated, what constitutes an actionable deficiency, how corrective measures will be
determined or prioritized, or how follow-up and verification of effectiveness will occur.
Furthermore, the CRM Plan also failed to require that this process be documented or incorporated
into future reviews and plan updates.
Therefore, Collins Pipeline’s written control room management procedures were inadequate to
ensure safe operation of a pipeline facility in accordance with section 195.446(e)(6). PHMSA
proposes that Collins Pipeline revise its written control room management procedures to include
define a process for identifying, analyzing, documenting, correcting, and verifying the resolution
of deficiencies for each of the elements found under subsections 195.446(e)(1) through (e)(5).
These procedures must include documentation requirements, timelines for action, criteria for
evaluation, and a feedback loop to ensure continuous improvement.
5. § 195.446 Control room management.
(a) …
(g) Operating experience. Each operator must assure that lessons
learned from its operating experience are incorporated, as appropriate,
into its control room management procedures by performing each of
the following:
(1) Review accidents that must be reported pursuant to § 195.50
and 195.52 to determine if control room actions contributed to the
event and, if so, correct, where necessary, deficiencies related to:
(i) Controller fatigue;
(ii) Field equipment;
(iii) The operation of any relief device;
(iv) Procedures;
(v) SCADA system configuration; and
(vi) SCADA system performance.
Collins Pipeline’s written control room management procedures were inadequate to ensure safe
operation of a pipeline facility. Specifically, Collins Pipeline’s CRM Plan failed to provide a
process for reportable accident reviews to determine if control room actions contributed to the
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CPF 1-2026-007-NOA
event and, if so, correct, where necessary, deficiencies related controller fatigue, field equipment,
the operation of any relief device, procedures, and SCADA system configuration and performance
in accordance with section 195.446(g)(1)(i)-(vi).
Collins Pipeline’s CRM Plan included multiple sections related to learning from experience but
failed to include a process for reviewing reportable accidents and correcting related control room
deficiencies:
• Section H2.2 mentioned continuous improvement and lessons learned but did not correlate
those efforts to the systematic review of reportable accidents or required corrective actions
based on such reviews.
• Section H4 included review metrics such as the number of lessons learned and drills but
did not require evaluation of control room actions after reportable incidents to determine if
they contributed to the event.
• Section S1 outlined general goals for collecting lessons learned from abnormal operating
conditions, near misses, and DOT reports but did not include an adequate process for
reviewing reportable accidents under sections 195.50 and 195.52.
• Section D7 included some investigation requirements following leaks or test failures, but
it did not require an investigation of control room actions after reportable accidents. While
it acknowledged the need to review procedures and consider controller fatigue, it did not
establish a requirement to evaluate whether control room actions contributed to reportable
accidents. Furthermore, it lacked a defined process to analyze and correct system-level
deficiencies such as SCADA system configuration, procedural inadequacies, or controller
response.
Collins Pipeline’s written control room management procedures were inadequate to assure safe
operation of a pipeline facility in accordance with section 195.446(g)(1). PHMSA proposes that
Collins Pipeline revise its written control room management procedures to define a process for
reviewing reportable accidents to determine if control room actions contributed to the accident
considering the criteria in section 195.446(g)(1)(i)-(vi).
6. § 195.446 Control room management.
(a) …
(g) Operating experience. Each operator must assure that lessons
learned from its operating experience are incorporated, as appropriate,
into its control room management procedures by performing each of
the following:
(1) …
(2) Include lessons learned from the operator’s experience in the
training program required by this section.
Collins Pipeline’s written control room management procedures were inadequate to assure safe
operation of a pipeline facility. Specifically, Collins Pipeline’s CRM Plan failed to include a
process that ensures lessons learned from the operator’s experience are incorporated in the training
program as required by section 195.446(g)(2).
Page 5 of 7



CPF 1-2026-007-NOA
Collins Pipeline’s CRM Plan contained several sections that mention lessons learned and operating
experience. These sections, however, did not establish a consistent, documented process for
integrating lessons learned into controller training. For instance, Collins Pipeline failed to
incorporate lessons learned from a 2021 reportable accident into its training program. Under the
terms of the Corrective Action Order (CAO), Collins Pipeline was required to evaluate controller
responses to all alarms occurring both immediately before and after the confirmation of that
accident.3
Section E5 Continuous Improvement notes that opportunities for improvement will be integrated
into procedures and training, but the process for how lessons are selected, reviewed, and
incorporated into training is not defined. Section H2.2 assigns responsibility to the Control Room
Supervisor or Designee for communicating lessons learned and improving processes. However,
this section did not describe how those lessons are translated into training materials or instructional
formats. Section H4 outlined performance metrics such as the number or lessons learned but did
not describe how those lessons informed training design or execution.
Sections S1 and S2 referred to an Operating Experience Program and indicated sources of lessons
learned, including AOCs, near misses and DOT reports. These sections identified that lessons were
to be reviewed and disseminated. However, the process for incorporating those lessons into
training were not detailed. For example:
• Section S2.1.4 stated that the Control Room Supervisor shall review reports and include
lessons in training but did not specify how the training is updated, delivered, or
documented.
• Section S2.1.5 stated that lessons learned “should be used” in various forums, but use of
discretionary language and lack of documentation requirements did not provide assurance
of consistent implementation.
• Section S1.3 assigned responsibilities for reporting lessons learned but did not define
how or when this information is delivered to training personnel or integrated into course
content.
• Section S3 addressed retention of lessons learned but did not ensure traceability between
those lessons and updates made to the training program.
While the CRM Plan referenced multiple responsibilities and general expectations it did not
include an actionable process for evaluating, selecting, integrating, and documenting lessons
learned within the controller training program.
Therefore, Collins Pipeline’s written control room management procedures were inadequate
pursuant to section 195.446(g)(2). PHMSA proposes that Collins Pipeline revise its written control
room management procedures to establish a defined and documented process for incorporating
lessons learned into controller training, as required by section 195.446(g)(2).
Response to this Notice
Please refer to this document and note the response options. Be advised that all material you submit
in response to this enforcement action is subject to being made publicly available. If you believe
3 See Corrective Action Order, CPF No. 1-2021-077-CAO, Required Corrective Action 7 (Dec. 30, 2021).
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CPF 1-2026-007-NOA
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 the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under 49 CFR § 190.211. 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 an Order Directing Amendment. If your
plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend
your plans or procedures to correct the inadequacies (49 CFR § 190.206). If you are not contesting
this Notice, we propose that you submit your amended procedures to my office within 30 days of
receipt of this Notice. This period may be extended by written request for good cause. Once the
inadequacies identified herein have been addressed in your amended procedures, this enforcement
action will be closed.
It is requested (not mandated) that Collins Pipeline Company maintain documentation of the safety
improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of
plans, procedures) and submit the total to Robert Burrough, Director, Eastern Region, Pipeline and
Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer
to CPF 1-2026-007-NOA and, for each document you submit, please provide a copy in electronic
format whenever possible.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
cc: Thomas McLane, Director Logistics Regulatory Compliance,
thomas.mclane@pbfenergy.com
Jeff Hersperger, Sr. Operations Director, jeffrey.hersperger@pbfenergy.com
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings
Page 7 of 7

12026007NOA_Closure Letter_07242026_(23-263951)_text.pdf

U.S. Department
of Transportation
Pipeline and
Hazardous Materials
Safety Administration
840 Bear Tavern Road, Suite 300
West Trenton, NJ 08628
609.771.7800
VIA ELECTRONIC MAIL TO: matthew.lucey@pbfenergy.com
July 24, 2026
Mr. Matthew Lucey
Chief Executive Officer and President
PBF Energy Inc.
1 Sylvan Way, 2nd Floor
Parsippany, New Jersey 07054
RE: CPF 1-2026-007-NOA
Dear Mr. Lucey:
From December 4, 2023 to March 15, 2024, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code
(U.S.C.) conducted an inspection of Collins Pipeline Company’s (Collins Pipeline) control room
procedures in Woodlands, Texas. On March 16, 2026, pursuant to 49 CFR § 190.206, PHMSA
issued a Notice of Amendment which proposed amendment of Collins Pipeline’s procedures.
Collins Pipeline submitted its amended procedures on May 15, 2026. PHMSA has reviewed the
amended procedures, and it appears that the inadequacies outlined in the Notice of Amendment
have been corrected.
This letter is to inform you that no further action is necessary, and this case is now closed. Thank
you for your cooperation.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
cc: Thomas McLane, Director Logistics Regulatory Compliance, thomas.mclane@pbfenergy.com
Jeff Hersperger, Sr., Operations Director, jeffrey.hersperger@pbfenergy.com
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