# TALLGRASS INTERSTATE GAS TRANSMISSION, LLC — Notice of Amendment

- **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:** Not available
- **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).
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- **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.

Official case documents:

320201009M_Closure Letter_10012021_(18-159646S).pdf: https://primis.phmsa.dot.gov/enforcement-documents/320201009M/320201009M_Closure%20Letter_10012021_(18-159646S).pdf

320201009M_Closure Letter_10012021_(18-159646S)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320201009M/320201009M_Closure%20Letter_10012021_(18-159646S)_text.pdf

320201009M_Notice of Amendment_10262020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320201009M/320201009M_Notice%20of%20Amendment_10262020.pdf

320201009M_Notice of Amendment_10262020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320201009M/320201009M_Notice%20of%20Amendment_10262020_text.pdf

320201009M_Operator Response to Notice_11252020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320201009M/320201009M_Operator%20Response%20to%20Notice_11252020.pdf

320201009M_Closure Letter_10012021_(18-159646S)_text.pdf

VIA ELECTRONIC MAIL TO: bill.moler@tallgrassenergylp.com and
Jennifer.eckels@tallgrassenergylp.com
October 1, 2021
Mr. Williams Moler
President and Chief Executive Officer
Tallgrass Energy Partners, LP
2400 W. 115th Street, Suite 350
Leawood, KS 66221-2609
Re: CPF 3-2020-1009M
Dear Mr. Moler:
On May 7 – 11, 2018, a representative from the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an on-site
pipeline safety inspection of Tallgrass Energy Partners, LP (Tallgrass) Control Room Management
procedures in Lakewood, Colorado. As a result of the inspection, Tallgrass was issued a Notice
of Amendment on October 26, 2020, which proposed amendment of your procedures.
Tallgrass submitted its amended procedures on September 24, 2021. My staff reviewed the
amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment
have been corrected.
This letter is to inform you no further action is necessary and this case is now closed. Thank you
for your cooperation.
Sincerely,
Gregory A. Ochs
Director, Central Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration

320201009M_Notice of Amendment_10262020_text.pdf

NOTICE OF AMENDMENT
VIA ELECTRONIC MAIL TO: jennifer.eckels@tallgrassenergylp.com
bill.moler@tallgrassenergylp.com and
October 26, 2020
Mr. William Moler
President and Chief Executive Officer
Tallgrass Energy Partners, LP
2400 W. 115th Street, Suite 350
Leawood, KS 66221-2609
CPF 3-2020-1009M
Dear Mr. Moler:
On May 7 – 11, 2018 and December 4 – 6, 2018, representatives of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter
601 of 49 United States Code inspected Tallgrass Energy Partners, LP’s (Tallgrass) Control
Room Management procedures and records in Lakewood, Colorado.
On the basis of the inspection, PHMSA has identified the apparent inadequacies found within
Tallgrass’s plans or procedures, as described below:
1. §192.605 Procedural manual for operation, maintenance and emergencies.
(a) . . .
(b) Maintenance and Normal operations. The manual required by paragraph (a) to
this section must include procedures for the following, if applicable, to provide
safety during maintenance and operations.
(1) . . .



(12) Implementing the applicable control room management procedures require by
§192.631.
§192.631 Control room management.
(a) General.
(1) This section applies to each operator of a pipeline facility with a controller
working in a control room who monitors and controls all or part of a pipeline
facility through a SCADA system. Each operator must have and follow written
control room management procedures that implement the requirements of this
section, except that for each control room where an operator’s activities are limited
to either or both of:
(i) Distribution with less than 250,000 services, or
(ii) Transmission without a compressor station, the operator must have and follow
written procedures that implement only paragraphs (d) (regarding fatigue), (i)
(regarding compliance validation), and (j) regarding compliance and deviations) of
this section.
(2) The procedures required by this section must be integrated, as appropriate, with
operating and emergency procedures required by §§ 192.605 and 192.615. An
operator must develop the procedures no later than August 1, 2011, and must
implement the procedures according to the following schedule. The procedures
required by paragraphs (b), (c)(5), (d)(2) and (d)(3), (f) and (g) of this section must
be implemented no later than October 1, 2011. The procedures required by
paragraphs (c)(1) through (4), (d)(1), (d)(4), and (e) must be implemented no later
than August 1, 2012. The training procedures required by paragraph (h) must be
implemented no later than August 1, 2012, except that any training required by
another paragraph of this section must be implemented no later than the deadline
for that paragraph.
Tallgrass’ Operation and Maintenance (O&M) manual did not provide a procedure that
sets forth criteria to assess facilities that monitor and control all or part of a pipeline
facility in order to determine if said facilities are control rooms and whether personnel at
those facilities should be qualified controllers as defined in 49 CFR §192.3.
Tallgrass procedure O&M 1100_GL Section 3 states the following: “The following
pipeline systems are controlled by the OCC [Operational Control Center] located in
Lakewood, Colorado: TIGT, TCP, REX PXP. Tallgrass maintains an on-site control
room back up location in building 360 in Lakewood Colorado and an off-site control
room and/or SCADA system backup location in Fort Collins, Colorado.” While this
procedure identifies the location of the designated control rooms, it does not provide
steps or a process for why these locations are control rooms and other facilities operating
centers are not.
Tallgrass operates three natural gas pipelines (TIGT, REX, TCP) from a control room in
Lakewood, CO. Tallgrass also operates a storage field, 41 compressor stations and 2 gas
plants. The storage field and some of the compressor stations can be remotely controlled
from the Lakewood Control Room, but all can be remotely monitored. The gas plants
cannot be controlled from the Lakewood Control Room, but output flow and pressures
are monitored. Each storage field and gas plant has an operation control center or
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equipment to monitor and control the assets within the fence line through a SCADA
system. The compressor stations have programmable logic controllers (PLC) and human-
machine interfaces (HMI) to monitor and control equipment within the station. These
control centers may be staffed 24/7 with operators who have the ability to change the
flow into the pipeline.
A result of not having a procedure that sets forth criteria to assess all facilities to
determine whether they were control rooms, Tallgrass had some compressor station
operators who were switching the station to local mode during the day and operating
without control room direction, and then at night, switching back from local control to
remote control for gas control to operate. This practice effectively allowed compressor
station control centers to operate as a control room and a qualified station operator to
function as an unqualified controller. Additionally, the gas plants operate on a varying
volume of gathering gas in and treated gas out, which is another example of how lack of
procedure and criteria for control room determination relates to the gas plants connected
to the Tallgrass system. Due to the lack of criteria, the Tallgrass Lakewood Control
Room reacts to the plant flows into its pipeline rather than directing the amount of flow
they will receive from the plant, defining the gas plant control center as a control room
and the plant operators as controllers.
Tallgrass needs to develop and implement a procedure to support criteria for
determination of a control room.
2. 192.631 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 controllers’ prompt and appropriate response to
operating conditions, an operator must define each of the following:
Tallgrass’ O&M did not adequately define the roles and responsibilities of a controller to
describe the controller’s domain of responsibility as well as other field individuals
operating Tallgrass facilities.
Specifically, Procedure O&M 1100_GL, Section 4, provides the listing of roles and
responsibilities for controllers, supervisors, managers, SCADA information technology, as
well as field personnel. However, while it was identified, during the inspection
discussion, that controllers respond to 811 emergency dig calls and notifications from the
pilot performing aerial patrols, neither of these items were listed under the controller’s
roles and responsibilities.
Additionally, Section 4 of Procedure O&M 1100_GL does not indicate that only one
controller can control a console at a time. Lead Controllers are qualified controllers and
have full access and control from their HMI desktop when logged in. A definitive
statement in Tallgrass’ O&M procedure would prohibit this Lead Controller from taking
any control or alarm response action, outside of the direction of the controller who is
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controlling the console at that time. Additionally, such a statement would provide clarity
to field employees and prohibit them from taking control actions outside the direction of
the controller at the console. For example, Tallgrass compressor station employees, at
some stations, were putting the station in local control and managing set points for
compressors outside the direction of the controllers.
3. §192.631 Control room management.
(c) Provide adequate information. Each operator must provide its controllers with
the information, tools, processed and procedures necessary for the controllers to
carry out the roles and responsibilities the operator has defined by performing each
of the following:
(1) Implement sections 1, 4, 8, 9, 11.1 and 11.3 of API RP 1165 (incorporated by
reference, see § 192.7) whenever a SCADA system is added, expanded or replaces,
unless the operator demonstrates that certain provisions of sections 1, 4, 8, 9, 11.1
(and 11.3 of API RP 1165 are not practical for the SCADA system used; . . .
Tallgrass has inadequately implemented the specific sections of API RP 1165 identified
in 192.631(c)(1) by not defining what types of changes constitutes additions, expansions
or replacements to the SCADA system.
Procedure O&M 1100_GL, Section 5 states “SCADA IT will comply with the design and
display standards outlined in API RP 1165 Sections 1, 4, 8, 9, 11.1 and 11.3 when adding
expanding or replacing displays.” However, it is not a display change, but a system
change that requires implementation of API RP 1165 as required by §192.631(c)(1).
Furthermore, Section 5 of Procedure O&M 1100_GL states, “Please refer to the Gas
HMI Philosophy document for additional information on Tallgrass’ approach to HMI
development as part of the implementation and maintenance of a SCADA system for the
pipeline.” A review of the Gas HMI Philosophy provided no additional guidance on the
types of changes that constitute additions, expansions or replacements to the SCADA
system.
Tallgrass’ Gas HMI Philosophy procedure lacks direction regarding the design of
displays to provide a consistent presentation of the information to the controllers.
Specifically, Tallgrass’ procedure inadequately implemented Sections 4 and 8.3 of API
1165. Section 8.3 refers to “standard symbol libraries” that “should be used in the
development of all displays, across all systems”. This “standard symbol library” or
SCADA screen design manual would define font, line color, symbols, alarm presentation,
line thickness, hierarchy of screens, etc. While Tallgrass’ Gas HMI Philosophy provides
some guidance, it is inadequate in providing details to define such attributes as symbols,
font style and size, etc. During the inspection, PHMSA inspectors were told that SCADA
display designers copy what was done on a similar screen. An example of how this
affects the information presented to controllers relates to Trailblazer MLV1.2.4. The
functionality of this valve was changed from manual operation to remote control,
however the symbol was not changed on the display screen from a manual to remote
control valve. This single valve was displayed different for remote operation than those
on TIGT or REX. Another example is Tallgrass has no units displayed for temperature,
pressure or flow. Without a style guide or design manual someone could display this
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information in a different order causing potential confusion for the controller.
4. §192.631 Control room management.
(c)Provide adequate information. Each operator must provide its controllers with
the information, tools, processed and procedures necessary for the controllers to
carry out the roles and responsibilities the operator has defined by performing each
of the following:
(1) . . . (2) Conduct a point-to-point verification between SCADA displays
and related field equipment when field equipment is added or moved and other
changes the affect pipeline safety are made to field equipment of SCADA displays.
Tallgrass’s O&M did not include adequate written procedures for conducting point-to-
point verifications between SCADA displays and related field equipment in accordance
with §192.631(c)(2).
Procedure O&M 1100_GL, Section 6.1 directs the point-to-point test for digital and
analogue points to be conducted from the remote SCADA/PLC system to the OCC
SCADA monitoring system. This test is accomplished by applied values for analogue
points and toggling of digital points. Specifically, Tallgrass’ O&M does not have a
written procedure that describes the process used when adding a new station to SCADA.
The O&M provided detailed process related to PLC/RTU design, testing the PLC/RTU to
the SCADA screen in the back up Control Center, and at some point, installing the
PLC/RTU in the field. Additionally, testing back to the Control Center was performed
from the RTU to the Control Room. However, despite records showing that the point-to-
point tests were completed, it could not be determined that the field end device was the
actual device where field data was collected and if the data was applied or real time. It
was also difficult to identify the time frame between what seems to be various point-to-
point test stages. The intent of a point-to-point is to take the test from the field end
device (actual pressure, temperature, valve open/closed, compressor on/off) to the control
room screen. Therefore, Tallgrass’s O&M procedure does not meet the requirement
§192.631(c)(2).
5. §192.631 Control room management.
(h) Training. Each operator must establish a controller training program and
review the training program content to identify potential improvements at least
once each calendar year, but at intervals not to exceed 15 months. An operator’s
program must provide for training each controller to carry out the roles and
responsibilities defined by the operator in addition the training program must
include the following elements: . . .
Tallgrass did not establish adequate written procedures for reviewing its training program
content to identify potential improvements at least once each calendar year, but at
intervals not to exceed 15 months.
Procedure O&M 1100-GL, Section 10.6, Review of Fatigue Mitigation Training and
Mitigation Strategies, and Section 13.8, Annual Training Program Review simply
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restates the language of 49 CFR §192.631(h), without setting forth a procedure or
process. Specifically, the procedure does not detail what needs to be reviewed, how it is
to be reviewed, and how findings of the review, recommendations for improvement,
follow up actions are documented and retention.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as
part of this Notice is a document entitled Response Options for Pipeline Operators in
Compliance Proceedings. 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 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 §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 C.F.R. § 190.206). If you are not
contesting this Notice, we propose that you submit your amended procedures to my office within
120 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 Tallgrass maintain documentation of the safety improvement
costs associated with fulfilling this Notice of Amendment (preparation/revision of plans,
procedures) and submit the total to Allan Beshore, Director, Central Region, Pipeline and
Hazardous Materials Safety Administration. In correspondence concerning this matter, please
refer to CPF 3-2020-1009M and, for each document you submit, please provide a copy in
electronic format whenever possible.
Sincerely,
Gregory A. Ochs
Director, Central Region, OPS
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings
Cc: Jennifer Eckels, Manager of Compliance, Tallgrass Interstate Gas Transmission, 370 Van
Gordon, Street, Lakewood, CO 80228 jennifer.eckels@tallgrassenergylp.com
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