{"operation":"document","citation":"CPF 320201009M","title":"TALLGRASS INTERSTATE GAS TRANSMISSION, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-10-26","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(b)(12), 192.631(a), 192.631(b), 192.631(c)(1), 192.631(c)(2), 192.631(h).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320201009m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320201009m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320201009m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320201009M","body":"Notice of Amendment involving TALLGRASS INTERSTATE GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.605(b)(12),  192.631(a),  192.631(b),  192.631(c)(1),  192.631(c)(2),  192.631(h). The case was opened on 2020-10-26 and is reported as closed as of 2021-10-01. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320201009M_Closure Letter_10012021_(18-159646S).pdf: https://primis.phmsa.dot.gov/enforcement-documents/320201009M/320201009M_Closure%20Letter_10012021_(18-159646S).pdf\n\n320201009M_Closure Letter_10012021_(18-159646S)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320201009M/320201009M_Closure%20Letter_10012021_(18-159646S)_text.pdf\n\n320201009M_Notice of Amendment_10262020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320201009M/320201009M_Notice%20of%20Amendment_10262020.pdf\n\n320201009M_Notice of Amendment_10262020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320201009M/320201009M_Notice%20of%20Amendment_10262020_text.pdf\n\n320201009M_Operator Response to Notice_11252020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320201009M/320201009M_Operator%20Response%20to%20Notice_11252020.pdf\n\n320201009M_Closure Letter_10012021_(18-159646S)_text.pdf\n\nVIA ELECTRONIC MAIL TO: bill.moler@tallgrassenergylp.com and\nJennifer.eckels@tallgrassenergylp.com\nOctober 1, 2021\nMr. Williams Moler\nPresident and Chief Executive Officer\nTallgrass Energy Partners, LP\n2400 W. 115th Street, Suite 350\nLeawood, KS 66221-2609\nRe: CPF 3-2020-1009M\nDear Mr. Moler:\nOn May 7 – 11, 2018, a representative from the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an on-site\npipeline safety inspection of Tallgrass Energy Partners, LP (Tallgrass) Control Room Management\nprocedures in Lakewood, Colorado. As a result of the inspection, Tallgrass was issued a Notice\nof Amendment on October 26, 2020, which proposed amendment of your procedures.\nTallgrass submitted its amended procedures on September 24, 2021. My staff reviewed the\namended procedures, and it appears that the inadequacies outlined in this Notice of Amendment\nhave been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nGregory A. Ochs\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\n\n320201009M_Notice of Amendment_10262020_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: jennifer.eckels@tallgrassenergylp.com\nbill.moler@tallgrassenergylp.com and\nOctober 26, 2020\nMr. William Moler\nPresident and Chief Executive Officer\nTallgrass Energy Partners, LP\n2400 W. 115th Street, Suite 350\nLeawood, KS 66221-2609\nCPF 3-2020-1009M\nDear Mr. Moler:\nOn May 7 – 11, 2018 and December 4 – 6, 2018, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter\n601 of 49 United States Code inspected Tallgrass Energy Partners, LP’s (Tallgrass) Control\nRoom Management procedures and records in Lakewood, Colorado.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nTallgrass’s plans or procedures, as described below:\n1. §192.605 Procedural manual for operation, maintenance and emergencies.\n(a) . . .\n(b) Maintenance and Normal operations. The manual required by paragraph (a) to\nthis section must include procedures for the following, if applicable, to provide\nsafety during maintenance and operations.\n(1) . . .\n\n\n\n(12) Implementing the applicable control room management procedures require by\n§192.631.\n§192.631 Control room management.\n(a) General.\n(1) This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline\nfacility through a SCADA system. Each operator must have and follow written\ncontrol room management procedures that implement the requirements of this\nsection, except that for each control room where an operator’s activities are limited\nto either or both of:\n(i) Distribution with less than 250,000 services, or\n(ii) Transmission without a compressor station, the operator must have and follow\nwritten procedures that implement only paragraphs (d) (regarding fatigue), (i)\n(regarding compliance validation), and (j) regarding compliance and deviations) of\nthis section.\n(2) The procedures required by this section must be integrated, as appropriate, with\noperating and emergency procedures required by §§ 192.605 and 192.615. An\noperator must develop the procedures no later than August 1, 2011, and must\nimplement the procedures according to the following schedule. The procedures\nrequired by paragraphs (b), (c)(5), (d)(2) and (d)(3), (f) and (g) of this section must\nbe implemented no later than October 1, 2011. The procedures required by\nparagraphs (c)(1) through (4), (d)(1), (d)(4), and (e) must be implemented no later\nthan August 1, 2012. The training procedures required by paragraph (h) must be\nimplemented no later than August 1, 2012, except that any training required by\nanother paragraph of this section must be implemented no later than the deadline\nfor that paragraph.\nTallgrass’ Operation and Maintenance (O&M) manual did not provide a procedure that\nsets forth criteria to assess facilities that monitor and control all or part of a pipeline\nfacility in order to determine if said facilities are control rooms and whether personnel at\nthose facilities should be qualified controllers as defined in 49 CFR §192.3.\nTallgrass procedure O&M 1100_GL Section 3 states the following: “The following\npipeline systems are controlled by the OCC [Operational Control Center] located in\nLakewood, Colorado: TIGT, TCP, REX PXP. Tallgrass maintains an on-site control\nroom back up location in building 360 in Lakewood Colorado and an off-site control\nroom and/or SCADA system backup location in Fort Collins, Colorado.” While this\nprocedure identifies the location of the designated control rooms, it does not provide\nsteps or a process for why these locations are control rooms and other facilities operating\ncenters are not.\nTallgrass operates three natural gas pipelines (TIGT, REX, TCP) from a control room in\nLakewood, CO. Tallgrass also operates a storage field, 41 compressor stations and 2 gas\nplants. The storage field and some of the compressor stations can be remotely controlled\nfrom the Lakewood Control Room, but all can be remotely monitored. The gas plants\ncannot be controlled from the Lakewood Control Room, but output flow and pressures\nare monitored. Each storage field and gas plant has an operation control center or\n2\n\n\n\nequipment to monitor and control the assets within the fence line through a SCADA\nsystem. The compressor stations have programmable logic controllers (PLC) and human-\nmachine interfaces (HMI) to monitor and control equipment within the station. These\ncontrol centers may be staffed 24/7 with operators who have the ability to change the\nflow into the pipeline.\nA result of not having a procedure that sets forth criteria to assess all facilities to\ndetermine whether they were control rooms, Tallgrass had some compressor station\noperators who were switching the station to local mode during the day and operating\nwithout control room direction, and then at night, switching back from local control to\nremote control for gas control to operate. This practice effectively allowed compressor\nstation control centers to operate as a control room and a qualified station operator to\nfunction as an unqualified controller. Additionally, the gas plants operate on a varying\nvolume of gathering gas in and treated gas out, which is another example of how lack of\nprocedure and criteria for control room determination relates to the gas plants connected\nto the Tallgrass system. Due to the lack of criteria, the Tallgrass Lakewood Control\nRoom reacts to the plant flows into its pipeline rather than directing the amount of flow\nthey will receive from the plant, defining the gas plant control center as a control room\nand the plant operators as controllers.\nTallgrass needs to develop and implement a procedure to support criteria for\ndetermination of a control room.\n2. 192.631 Control room management.\n(a) . . .\n(b) Roles and responsibilities. Each operator must define the roles and\nresponsibilities of a controller during normal, abnormal, and emergency operating\nconditions. To provide for a controllers’ prompt and appropriate response to\noperating conditions, an operator must define each of the following:\nTallgrass’ O&M did not adequately define the roles and responsibilities of a controller to\ndescribe the controller’s domain of responsibility as well as other field individuals\noperating Tallgrass facilities.\nSpecifically, Procedure O&M 1100_GL, Section 4, provides the listing of roles and\nresponsibilities for controllers, supervisors, managers, SCADA information technology, as\nwell as field personnel. However, while it was identified, during the inspection\ndiscussion, that controllers respond to 811 emergency dig calls and notifications from the\npilot performing aerial patrols, neither of these items were listed under the controller’s\nroles and responsibilities.\nAdditionally, Section 4 of Procedure O&M 1100_GL does not indicate that only one\ncontroller can control a console at a time. Lead Controllers are qualified controllers and\nhave full access and control from their HMI desktop when logged in. A definitive\nstatement in Tallgrass’ O&M procedure would prohibit this Lead Controller from taking\nany control or alarm response action, outside of the direction of the controller who is\n3\n\n\n\ncontrolling the console at that time. Additionally, such a statement would provide clarity\nto field employees and prohibit them from taking control actions outside the direction of\nthe controller at the console. For example, Tallgrass compressor station employees, at\nsome stations, were putting the station in local control and managing set points for\ncompressors outside the direction of the controllers.\n3. §192.631 Control room management.\n(c) Provide adequate information. Each operator must provide its controllers with\nthe information, tools, processed and procedures necessary for the controllers to\ncarry out the roles and responsibilities the operator has defined by performing each\nof the following:\n(1) Implement sections 1, 4, 8, 9, 11.1 and 11.3 of API RP 1165 (incorporated by\nreference, see § 192.7) whenever a SCADA system is added, expanded or replaces,\nunless the operator demonstrates that certain provisions of sections 1, 4, 8, 9, 11.1\n(and 11.3 of API RP 1165 are not practical for the SCADA system used; . . .\nTallgrass has inadequately implemented the specific sections of API RP 1165 identified\nin 192.631(c)(1) by not defining what types of changes constitutes additions, expansions\nor replacements to the SCADA system.\nProcedure O&M 1100_GL, Section 5 states “SCADA IT will comply with the design and\ndisplay standards outlined in API RP 1165 Sections 1, 4, 8, 9, 11.1 and 11.3 when adding\nexpanding or replacing displays.” However, it is not a display change, but a system\nchange that requires implementation of API RP 1165 as required by §192.631(c)(1).\nFurthermore, Section 5 of Procedure O&M 1100_GL states, “Please refer to the Gas\nHMI Philosophy document for additional information on Tallgrass’ approach to HMI\ndevelopment as part of the implementation and maintenance of a SCADA system for the\npipeline.” A review of the Gas HMI Philosophy provided no additional guidance on the\ntypes of changes that constitute additions, expansions or replacements to the SCADA\nsystem.\nTallgrass’ Gas HMI Philosophy procedure lacks direction regarding the design of\ndisplays to provide a consistent presentation of the information to the controllers.\nSpecifically, Tallgrass’ procedure inadequately implemented Sections 4 and 8.3 of API\n1165. Section 8.3 refers to “standard symbol libraries” that “should be used in the\ndevelopment of all displays, across all systems”. This “standard symbol library” or\nSCADA screen design manual would define font, line color, symbols, alarm presentation,\nline thickness, hierarchy of screens, etc. While Tallgrass’ Gas HMI Philosophy provides\nsome guidance, it is inadequate in providing details to define such attributes as symbols,\nfont style and size, etc. During the inspection, PHMSA inspectors were told that SCADA\ndisplay designers copy what was done on a similar screen. An example of how this\naffects the information presented to controllers relates to Trailblazer MLV1.2.4. The\nfunctionality of this valve was changed from manual operation to remote control,\nhowever the symbol was not changed on the display screen from a manual to remote\ncontrol valve. This single valve was displayed different for remote operation than those\non TIGT or REX. Another example is Tallgrass has no units displayed for temperature,\npressure or flow. Without a style guide or design manual someone could display this\n4\n\n\n\ninformation in a different order causing potential confusion for the controller.\n4. §192.631 Control room management.\n(c)Provide adequate information. Each operator must provide its controllers with\nthe information, tools, processed and procedures necessary for the controllers to\ncarry out the roles and responsibilities the operator has defined by performing each\nof the following:\n(1) . . . (2) Conduct a point-to-point verification between SCADA displays\nand related field equipment when field equipment is added or moved and other\nchanges the affect pipeline safety are made to field equipment of SCADA displays.\nTallgrass’s O&M did not include adequate written procedures for conducting point-to-\npoint verifications between SCADA displays and related field equipment in accordance\nwith §192.631(c)(2).\nProcedure O&M 1100_GL, Section 6.1 directs the point-to-point test for digital and\nanalogue points to be conducted from the remote SCADA/PLC system to the OCC\nSCADA monitoring system. This test is accomplished by applied values for analogue\npoints and toggling of digital points. Specifically, Tallgrass’ O&M does not have a\nwritten procedure that describes the process used when adding a new station to SCADA.\nThe O&M provided detailed process related to PLC/RTU design, testing the PLC/RTU to\nthe SCADA screen in the back up Control Center, and at some point, installing the\nPLC/RTU in the field. Additionally, testing back to the Control Center was performed\nfrom the RTU to the Control Room. However, despite records showing that the point-to-\npoint tests were completed, it could not be determined that the field end device was the\nactual device where field data was collected and if the data was applied or real time. It\nwas also difficult to identify the time frame between what seems to be various point-to-\npoint test stages. The intent of a point-to-point is to take the test from the field end\ndevice (actual pressure, temperature, valve open/closed, compressor on/off) to the control\nroom screen. Therefore, Tallgrass’s O&M procedure does not meet the requirement\n§192.631(c)(2).\n5. §192.631 Control room management.\n(h) Training. Each operator must establish a controller training program and\nreview the training program content to identify potential improvements at least\nonce each calendar year, but at intervals not to exceed 15 months. An operator’s\nprogram must provide for training each controller to carry out the roles and\nresponsibilities defined by the operator in addition the training program must\ninclude the following elements: . . .\nTallgrass did not establish adequate written procedures for reviewing its training program\ncontent to identify potential improvements at least once each calendar year, but at\nintervals not to exceed 15 months.\nProcedure O&M 1100-GL, Section 10.6, Review of Fatigue Mitigation Training and\nMitigation Strategies, and Section 13.8, Annual Training Program Review simply\n5\n\n\n\nrestates the language of 49 CFR §192.631(h), without setting forth a procedure or\nprocess. Specifically, the procedure does not detail what needs to be reviewed, how it is\nto be reviewed, and how findings of the review, recommendations for improvement,\nfollow up actions are documented and retention.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis Notice without further notice to you and to issue an Order Directing Amendment. If your\nplans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend\nyour plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not\ncontesting this Notice, we propose that you submit your amended procedures to my office within\n120 days of receipt of this Notice. This period may be extended by written request for good\ncause. Once the inadequacies identified herein have been addressed in your amended\nprocedures, this enforcement action will be closed.\nIt is requested (not mandated) that Tallgrass maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to Allan Beshore, Director, Central Region, Pipeline and\nHazardous Materials Safety Administration. In correspondence concerning this matter, please\nrefer to CPF 3-2020-1009M and, for each document you submit, please provide a copy in\nelectronic format whenever possible.\nSincerely,\nGregory A. Ochs\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\nCc: Jennifer Eckels, Manager of Compliance, Tallgrass Interstate Gas Transmission, 370 Van\nGordon, Street, Lakewood, CO 80228 jennifer.eckels@tallgrassenergylp.com\n6","truncated":false,"body_characters":19086}