{"operation":"document","citation":"CPF 32021103NOA","title":"TALLGRASS PONY EXPRESS PIPELINE, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-12-22","effective_on":null,"summary":"CLOSED notice of amendment citing 195.446(a), 195.446(b)(2), 195.446(b)(3), 195.446(b)(4), 195.446(c)(1), 195.446(c)(4), 195.446(d)(4), 195.446(e)(1), 195.446(e)(2), 195.446(e)(3), 195.446(e)(6), 195.446(f)(1), 195.446(f)(2), 195.446(h), 195.446(h)(5).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021103noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021103noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021103noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32021103NOA","body":"Notice of Amendment involving TALLGRASS PONY EXPRESS PIPELINE, LLC. PHMSA's enforcement data identifies the cited regulations as 195.446(a),  195.446(b)(2),  195.446(b)(3),  195.446(b)(4),  195.446(c)(1),  195.446(c)(4),  195.446(d)(4),  195.446(e)(1),  195.446(e)(2),  195.446(e)(3),  195.446(e)(6),  195.446(f)(1),  195.446(f)(2),  195.446(h),  195.446(h)(5). The case was opened on 2021-12-22 and is reported as closed as of 2025-05-28. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32021103NOA_Closure Letter_05282025_(21-210993).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021103NOA/32021103NOA_Closure%20Letter_05282025_(21-210993).pdf\n\n32021103NOA_Closure Letter_05282025_(21-210993)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021103NOA/32021103NOA_Closure%20Letter_05282025_(21-210993)_text.pdf\n\n32021103NOA_Notice of Amendement_12222021_(21-210993).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021103NOA/32021103NOA_Notice%20of%20Amendement_12222021_(21-210993).pdf\n\n32021103NOA_Notice of Amendement_12222021_(21-210993)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021103NOA/32021103NOA_Notice%20of%20Amendement_12222021_(21-210993)_text.pdf\n\n32021103NOA_Operator Response to Notice_01242022_(21-210993).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021103NOA/32021103NOA_Operator%20Response%20to%20Notice_01242022_(21-210993).pdf\n\n32021103NOA_Notice of Amendement_12222021_(21-210993)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: bill.moler@tallgrassenergylp.com;\njennifer.eckels@tallgrassenergylp.com; brad.armsbury@tallgrassenergylp.com;\ncrystal.heter@tallgrassenergylp.com\nDecember 22, 2021\nWilliam Moler\nChief Executive Officer\nTallgrass Energy, LP\nPony Express Pipeline, LLC\nTallgrass Midstream, LLC\n4200 W. 115th St. Suite 350\nLeawood, KS 66211\nCPF 3-2021-103-NOA\nDear Mr. Moler:\nFrom May 7 – 11, 2018 and December 4 – 6, 2018, representatives of the Pipeline and\nHazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United\nStates Code inspected Tallgrass Energy, LP (Tallgrass) procedures for the hazardous liquid\nControl Room Management procedures and records in Lakewood, Colorado. The inspection\nteam continued to work on completing the inspection by receiving requested items from\nTallgrass through 2019.\nIn addition, completion of this inspection was delayed due to an issue that was brought by a third\nparty against the operator that had a common area of focus with PHMSA’s inspection. For this\nreason, work continued on this inspection from 2019 through October 2021. While the control\nroom management procedures cover additional assets (such as gas transmission), this inspection\ncovered Pony Express Pipeline, LLC OPID 39043 and Tallgrass Midstream, LLC OPID 39216.\nAdditional assets that have become operational since the inspection may be applicable to the\namendments requested in the body of this letter.\nOn the basis of the inspection, and follow-up actions from the complaint, PHMSA has identified\nthe apparent inadequacies found within Alarm Management and Control Room Management\nplans or procedures, as described below:\n\n\n\n1. § 195.446 Control room management.\n(a) General. This section applies to each operator of a pipeline facility with a\ncontroller working in a control room who monitors and controls all or part of a\npipeline facility through a SCADA system. Each operator must have and follow\nwritten control room management procedures that implement the requirements of\nthis section. The procedures required by this section must be integrated, as\nappropriate, with the operator's written procedures required by § 195.402. 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’s O&M 1100_GL Titled: Control Room Management (CRM) Revised: April 1, 2020,\ndid not adequately develop procedures that describe or define the types of pipeline assets covered\nby the CRM plan. In the CRM AO1 form provided by Tallgrass, the control room was identified\nas having hazardous liquid transmission, and did not identify any hazardous liquid gathering\noperating from the control room. In this same form relevant to this control room, the operator\nidentified gas transmission and gas gathering to be covered by this control room. However, the\nO&M 1100_GL CRM procedure in the 1. Applicability section identified hazardous liquid\ntransmission and hazardous liquid gathering, and only natural gas transmission. Tallgrass must\namend O&M 1100_GL CRM plan to correctly identify the type of pipeline assets cover by the\nCRM plan.\n2. § 195.446 Control room management.\n(a) . . . .\n(b) Each operator must define the roles and responsibilities of a controller during\nnormal, abnormal, and emergency operating conditions. To provide for a\ncontrollers’ prompt and appropriate response to operating conditions, an operator\nmust define each of the following:\n(1) . . . .\n(2) A controller's role when an abnormal operating condition is detected, even if the\ncontroller is not the first to detect the condition, including the controller's\nresponsibility to take specific actions and to communicate with others;\nTallgrass’s O&M 1100_GL Titled: Control Room Management Revised: April 1, 2020, and the\nAO-C Loss of Communication Guidelines was inadequate because it did not provide sufficient\ndirection on how the pipeline will be confirmed by the controller to have shutdown in a safe\nmanner should three or more pipeline facilities suffer loss of communication.\n2\n\n\n\nTallgrass O&M 1100_GL in Section 7.1 references AO-C Loss of Communication (for liquid\nonly) as part of the internal communication plan requirements for manual operation. Section\n4.1.3. (b) of Tallgrass O&M 1100_GL CRM plan requires controllers during abnormal and\nemergency operating conditions to respond to abnormal operations (AO) in alignment with AO\nGuidelines. However, when reviewing the AO-C Loss of Communication, this document did not\nprovide adequate instruction for controllers when at least three or more facilities (valves or pump\nstations) have lost communication for 30-40 minutes.\nThe AO-C Loss of Communication indicates that the pipeline should either be shut down or will\nautomatically shutdown when three or more of the facilities have lost communication for a\nspecific time duration, but it does not include specifics on how the controller is to confirm that\nthis shutdown action occurred safely.\nThe AO-C Loss of Communication and the O&M 1100_GL requires amendment to address how\nthe controller will determine that the pipeline has been shut down safely in the event of a loss of\ncommunication to at least three or more facilities (valves or pump stations).\n3. § 195.446 Control room management.\n(a) . . . .\n(b) Each operator must define the roles and responsibilities of a controller during\nnormal, abnormal, and emergency operating conditions. To provide for a\ncontrollers’ prompt and appropriate response to operating conditions, an operator\nmust define each of the following:\n(1) . . . .\n(3) A controller's role during an emergency, even if the controller is not the first to\ndetect the emergency, including the controller's responsibility to take specific\nactions and to communicate with others.\nTallgrass’s O&M 1100_GL Titled: Control Room Management Revised: April 1, 2020 did not\nadequately address the roles and responsibilities of a controller during normal, abnormal, and\nemergency operating conditions regarding the Tallgrass Pony Express Pipeline ERP/Oil Spill\nResponse Plan. Specifically, the procedures do not mention the controller roles and\nresponsibilities regarding timelines and communication detailed in the Tallgrass Pony Express\nPipeline ERP/Oil Spill Response Plan.\nTallgrass’s O&M 1100_GL require an amendment to include controller roles and responsibilities\nregarding timelines and communication detailed in the Tallgrass Pony Express Pipeline ERP/Oil\nSpill Response Plan and all other relative oil spill response plans.\n4. § 195.446 Control room management.\n(a) . . . .\n(b) Each operator must define the roles and responsibilities of a controller during\nnormal, abnormal, and emergency operating conditions. To provide for a\ncontrollers’ prompt and appropriate response to operating conditions, an operator\nmust define each of the following:\n(1) . . . .\n3\n\n\n\n(3) A controller's role during an emergency, even if the controller is not the first to\ndetect the emergency, including the controller's responsibility to take specific\nactions and to communicate with others.\nTallgrass’s O&M 1100_GL Titled: Control Room Management Revised: April 1, 2020 Section\n4.3 did not adequately address the controller's responsibility to take specific actions and to\ncommunicate with others when the pipeline is transporting different commodities. O&M\n1100_GL Section 4.1.3 states, \"For calls from the public regarding potential or confirmed leaks\nor events that could potentially endanger the public, Controllers must caution callers to take\nappropriate actions to safeguard human life and safety.\" While additional guidance may be\navailable for controllers regarding appropriate actions to safeguard human life and safety, this\ninformation was not referenced in the O&M 1100_GL CRM plan. Furthermore, information\nreviewed at the time of the inspection did not address the multiple commodities (such as HVL,\ncrude oil, natural gas, and refined products) operated from this control room for which different\nappropriate actions are required (upwind of a cloud for example, versus don't hang up the phone\nfor a natural gas system). The O&M 1100_GL CRM plan requires amendment to clarify the\nappropriate actions by commodity and to reference any guidance associated with these actions.\nIn addition, the Lakewood 360 backup control room location did not have the same capabilities\nof the primary control room, such as leak detection. The OCC Evacuation and Resumption Plan,\nwhich is applicable when the controller leaves the primary control room location, did not call out\nthe differences between the primary and backup control room locations. Differences in the\ncontrol room capabilities impact the application of controller roles and responsibilities,\nespecially during an emergency and the tools provided for how controllers would detect a leak.\nThe OCC Evacuation and Resumption Plan and the O&M 1100_GL CRM plan require\namendment to address these differences in the control rooms and provide clarification to the\ncontrollers regarding roles and responsibility changes in how to detect a leak at the back up\ncontrol room location.\n5. § 195.446 Control room management.\n(a) . . . .\n(b) Each operator must define the roles and responsibilities of a controller during\nnormal, abnormal, and emergency operating conditions. To provide for a\ncontrollers’ prompt and appropriate response to operating conditions, an operator\nmust define each of the following:\n(1) . . . .\n(4) A method of recording controller shift-changes and any hand- over of\nresponsibility between controllers; and\nTallgrass’s O&M 1100_GL Titled: Control Room Management Revised: April 1, 2020, Section\n9.1 Shift Change Procedures were inadequate because the procedures incorrectly referred to\nsuppressed alarms. While Tallgrass may use other types of alarm inhibit functions, Tallgrass\nverbally stated suppressing alarms was a function that was not utilized. The O&M 1100_GL\nCRM plan requires amendment to exclude suppressed alarms (this is not applicable to other\nalarm inhibit methods) if not utilized as identified during the inspection.\n4\n\n\n\n6. § 195.446 Control room management.\n(a) . . . .\n(c) Provide adequate information. Each operator must provide its controllers with\nthe information, tools, processes, 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 API RP 1165 (incorporated by reference, see § 195.3) whenever a\nSCADA system is added, expanded, or replaced, unless the operator demonstrates\nthat certain provisions of API RP 1165 are not practical for the SCADA system\nused.\nTallgrass’s O&M 1100_GL Titled: Control Room Management Revised: April 1, 2020, and the\nHMI Philosophy for Liquids procedures were inadequate because the documents did not clearly\ndefine the types of changes to the SCADA system(s) that constituted additions, expansions, or\nreplacements to ensure API RP 1165 would be implemented. For example, a console addition\nwas not defined as an expansion of the SCADA system. This change would result in\nconfiguration and logging functions changes especially in regards to alarms that would require\nprogramming as part of this expansion or addition.\nIn addition, O&M 1100_GL CRM plan and HMI Philosophy for Liquids procedures were\ninadequate because the plans did not indicate how Section 5 of API RP 1165 would be\nimplemented, including for design and performance requirements.\nThe procedure as amended must define adequately types of additions, expansions, or\nreplacement that would lead to implementation of API RP 1165. The procedure as amended must\nalso identify the records that Tallgrass will utilize to demonstrate compliance and\nimplementation of API RPI 1165.\n7. § 195.446 Control room management.\n(a) . . . .\n(c) Provide adequate information. Each operator must provide its controllers with\nthe information, tools, processes, 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) . . . .\n(4) Test any backup SCADA systems at least once each calendar year, but at\nintervals not to exceed 15 months; and\nTallgrass’s O&M 1100_GL Titled: Control Room Management Revised: April 1, 2020 and the\nOCC Evacuation and Resumption Plan were inadequate because the procedures did not reference\nthe OCC Backup Site Test Checklist that Tallgrass utilized as one of the records to demonstrate\ncompliance for the back-up OCC/SCADA test.\nRedundant servers were part of the backup SCADA system and as such must also be tested. The\nprocedures did not include reference SCADA server tests and the records to demonstrate\n5\n\n\n\ncompliance of SCADA server tests. The record generated to demonstrate compliance needs to\nidentify which server is being used as the active server at the backup center and identify which\nserver is activated when returning to the primary control room location. The back-up test needs\nto confirm that the SCADA servers have been switched, shown to be functional, and identify\nwhich servers were involved in the switch so that the operator can test the backup servers as\nwell.\nThe OCC Evacuation and Resumption plan will be utilized when moving between the primary\nand back up control centers. This can occur when there is a loss of communication. The AO-C\nloss of communication procedure is referenced by the O&M 1100_GL CRM Plan and as such\nmay result in an OCC Evacuation. The OCC Evacuation and Resumption plan, which would be\nutilized as part of a backup system test, contains an undefined reference to “Telco”. The\nprocedure must be amended to define the reference to “Telco” and to ensure that it is consistent\nwith AO-C Loss of Communications types of communication services.\n8. § 195.446 Control room management.\n(a) . . . .\n(d) Fatigue mitigation. Each operator must implement the following methods to\nreduce the risk associated with controller fatigue that could inhibit a controller's\nability to carry out the roles and responsibilities the operator has defined:\n(1) . . . .\n(4) Establish a maximum limit on controller hours-of-service, which may provide\nfor an emergency deviation from the maximum limit if necessary for the safe\noperation of a pipeline facility.\nTallgrass’s O&M 1100_GL Titled: Control Room Management Revised: April 1, 2020, were\ninadequate because the procedure did not address how shift lead's/supervisor’s actual hours\nworked would be recorded when serving as a qualified controller. Additionally, the procedures\ndid not clarify how the 65-hour maximums in seven sliding days would be identified for\nleads/supervisors.\nFurthermore, Section 10.3 states, all deviations shall be approved by the Supervisor/Lead and\ndocumented for review. However, the procedure did not identify who was responsible for\napproving an hours of service deviation performed by a Lead/Supervisor when acting as a\nqualified controller.\nThe procedure must be amended to include a method for tracking actual hours of service for\nleads/supervisors and to include a process for approving leads/supervisors hours of service\ndeviations.\n6\n\n\n\n9. § 195.446 Control room management.\n(a) . . . .\n(e) Alarm management. Each operator using a SCADA system must have a written\nalarm management plan to provide for effective controller response to alarms. An\noperator's plan must include provisions to:\n(1) Review SCADA safety-related alarm operations using a process that ensures\nalarms are accurate and support safe pipeline operations.\nTallgrass’s Alarm Management Plan Section 3 was inadequate because the process did not\nensure all alarms that support the safe pipeline operation were accurate. Specifically, the Alarm\nManagement Plan did not address volume levels associated with tanks, valves associated with\nisolation or emergency response requirements, and other specific points that may be identified\nthrough special needs (such as special permits, Immediate Shutdown, and the applicability of\nH2S monitoring activities) or calculated (soft) point alarming. In addition, leak detection alarms\nwere also not included in the Alarm Management Plan.\nThe procedure requires amendment to include a process to ensure all alarms are accurate and\nsupport the safe operation of the pipeline. This includes volume levels associated with tanks,\nvalves associated with isolation or emergency response requirements, leak detection, and other\nspecific points that may be identified through special needs (such special permits, Immediate\nShutdown, and the applicability of H2S monitoring activities) or calculated (soft) point alarming.\n10. § 195.446 Control room management.\n(a) . . . .\n(e) Alarm management. Each operator using a SCADA system must have a written\nalarm management plan to provide for effective controller response to alarms. An\noperator's plan must include provisions to:\n(1) . . . .\n(2) Identify at least once each calendar month points affecting safety that have been\ntaken off scan in the SCADA host, have had alarms inhibited, generated false\nalarms, or that have had forced or manual values for periods of time exceeding that\nrequired for associated maintenance or operating activities;\nTallgrass’s Alarm Management plan did not adequately address false alarms or points affecting\nsafety that have been forced as part of the monthly alarm reviews. In addition, for forced or\nmanual values, the procedure did not define how the time exceeding that required for the\nassociated maintenance or operating activities would be identified.\nThe Alarm Management plan required controllers to respond to false or malfunctioning alarms\nby using the applicable Guideline: AO-F Component Failure or Malfunction Guideline.\nHowever, at the time of the inspection, AO-F was incorrectly referenced as the Component\nFailure or Malfunction Guideline, which is AO-E, not AO-F.\nIn addition, the Alarm Management Plan requires amendment to include AO-F Leak Detection\nand Response Guideline as this also addresses actions to take when a leak detection alarm is\n7\n\n\n\ndetermined to be false. The process must be amended to address how false alarms will be\nconsistently documented by the controller.\nFurthermore, the Alarm Management Plan references the AO-E Component Failure or\nMalfunction procedures, which required the controller to document false and malfunctioning\nalarms in the shift turnover. The Alarm Management Plan, and Section 11.1 of O&M 1100_GL\ndid not clarify how monthly reviews would address false alarms recorded by controllers during\nshift turnovers (shift reports or controller logs).\nTallgrass must amend its procedures to address the inadequacies identified above.\n11. § 195.446 Control room management.\n(a) . . . .\n(e) Alarm management. Each operator using a SCADA system must have a written\nalarm management plan to provide for effective controller response to alarms. An\noperator's plan must include provisions to:\n(1) . . . .\n(3) Verify the correct safety-related alarm set-point values and alarm descriptions\nwhen associated field instruments are calibrated or changed and at least once each\ncalendar year, but at intervals not to exceed 15 months;\nTallgrass’s Alarm Management Plan and O&M 1100_GL Section 11.1 were inadequate because\nthe procedures did not define what record would be used to demonstrate compliance for the\nverification of correct safety-related alarm set-point values and alarm descriptions, when\nassociated field instruments are calibrated or changed at least once each calendar year, but at\nintervals not to exceed 15 months.\nAdditionally, the O&M 1100_GL procedure indicated that the Manager or his/her designee will\nreview the alarm system to verify safety-related alarm settings and descriptions. However, the\nprocedures did not explain how the review will be performed and what documentation would be\nutilized to verify correct alarm setpoint values and alarm descriptors, such as Tallgrass PACs\n(Proposed Alarm Changes) or Enterprise Management of Change (EMOC).\nTallgrass must amend its procedures to address the inadequacies identified above.\n12. § 195.446 Control room management.\n(a) . . . .\n(e) Alarm management. Each operator using a SCADA system must have a written\nalarm management plan to provide for effective controller response to alarms. An\noperator's plan must include provisions to:\n(1) . . . .\n(6) Address deficiencies identified through the implementation of paragraphs (e)(1)\nthrough (e)(5) of this section.\n8\n\n\n\nTallgrass’s Alarm Management Plan and O&M 1100_GL Section 11.1 were inadequate because\nthe plans did not define how deficiencies identified during monthly reviews specific to points\ntaken off-scan would be addressed.\nFurthermore, the Alarm Management Plan references AO-E Component Failure or Malfunction\nprocedures which required controller to document false and malfunctioning alarms in the shift\nturnover. The Alarm Management Plan and Section 11.1 of O&M 1100_GL did not clarify how\ndeficiencies identified by controllers in Shift Reports or controller logs were addressed.\nTallgrass must amend its procedures to address the inadequacies identified above.\n13. § 195.446 Control room management.\n(a) . . . .\n(f) Change management. Each operator must assure that changes that could affect\ncontrol room operations are coordinated with the control room personnel by\nperforming each of the following:\n(1) Implement section 7 of API RP 1168 (incorporated by reference, see § 195.3) for\ncontrol room management change and require coordination between control room\nrepresentatives, operator's management, and associated field personnel when\nplanning and implementing physical changes to pipeline equipment or\nconfiguration;\nTallgrass’s O&M 1100_GL titled: Control Room Management Revised: April 1, 2020 was\ninadequate because it did not define what types of changes can be processed as an emergency\nthrough verbal communications to the controller. A clear process was not defined for how a\npressure reduction on an emergency basis is communicated to a controller, and what record\nwould be used to communicate this change to other controllers that may not be on shift at the\ntime of the emergency change. API RP 1168 Section 7 identifies 3 examples of emergency\nchanges (pressure reductions, mainline leaks, and or critical equipment failure). While a\nManagement of Change process did exist in Tallgrass’s OM155_GL Titled: Management of\nChange, it is was not clear from this procedure what types of emergency changes can be\nprocessed verbally (such as an emergency pressure reduction required by Integrity Management).\nWhile O&M 1100_GL Section 12 did address emergency management of change (EMOC) and\nreferenced OM 155 GL, EMOC in these documents refers to Enterprise Management of Change\nand not emergency changes.\nAdditionally, during the inspection, the operator indicated verbally that Maximum Operating\nPressure (MOP) would be available through the Geographic Information System (GIS) and that\nthis was utilized by the controller to determine current MOP and pressure restrictions. However,\nthis was not included as part of the process for emergency changes.\nTallgrass must amend its procedures to address the inadequacies identified above.\n9\n\n\n\n14. § 195.446 Control room management.\n(a) . . . .\n(f) Change management. Each operator must assure that changes that could affect\ncontrol room operations are coordinated with the control room personnel by\nperforming each of the following\n(1) . . . .\n(2) Require its field personnel to contact the control room when emergency\nconditions exist and when making field changes that affect control room operations.\nTallgrass’s O&M 1100_GL Titled: Control Room Management Revised: April 1, 2020 was\ninadequate because the process did not define what records would demonstrate changes in field\nequipment affecting control room operations coordinated with control room personnel. The\nprocedures did not assure that coordination with the control room occurred before the controller\nreceived the alarms and not after receiving alarms.\nThe following operation and maintenance procedures were not integrated as required by 49 CFR\n§ 195.446(a) at the time of the inspection because the procedures did not require coordination\nwith the control room when making field changes:\n O&M 301_L Inspecting and Servicing Emergency Valves must be amended to require\ncoordination with the control room prior to implementing any valve action utilizing this\nprocedure.\n O&M 703_L Pressure Limiting and Relief Devices Inspections must be amended in\nSection 3.1.2 and 3.5.3.3 to require contact with the control room when implementing\nchanges, not after, that would trip the alarm and to require the recording of the alarm\nsetpoint value that activated the alarm in the control room. This procedure required\nconfirmation of an alarm and that the alarm is set at the control system documentation,\nbut nothing required that the values that trip a setpoint level in the control room to\nconfirm analog values had been set correctly. The procedure did not require a document\nor record to demonstrate compliance and confirm the alarm descriptor.\n O&M 704_L Overpressure and Overfill Protective Devices must be amended to also\nrequire contact with the control room to coordinate implementing making changes that\nwould trip the alarm and to require the recording of the alarm setpoint value that\nactivated the alarm in the control room. This procedure requires confirmation of an\nalarm and that the alarm is set at the control system documentation, but nothing requires\nthat the values that trip a setpoint level in the control room for analog values have been\nset correctly (such as HiHi tank alarm levels). The procedure did not require a document\nor record to demonstrate compliance and confirm the alarm descriptor.\n O&M 500_L Pump Station Emergency Shutdown must be amended to require contact\nwith the control room before any action is implemented that would activate an alarm, and\nthis language should be placed Section 2.0 Scope and stated in 3.7 Alarm Testing.\n10\n\n\n\n15. § 195.446 Control room management.\n(a) . . . .\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’s O&M 1100_GL Titled: Control Room Management Revised: April 1, 2020, did not\nadequately define the roles and responsibilities to address how cross-training would be\naccomplished for controllers on the hazardous liquid pipeline systems. For gas operations, this\ndefinition was found in Section 13.4 Gas System Training and Evaluation for New Controllers.\nHowever, this information was not included in the procedure for Hazardous Liquid systems.\nIn 2019, while performing the inspection on Tallgrass’s hazardous liquid facilities for this\ncontrol room, an additional console had already been set up and was being utilized. In addition,\nSection 13.2 of the CRM procedures indicated that the controllers would be trained and qualified\nfor the PXP system only. However, the control room also operated the Red Tail assets identified\nas part of the Tallgrass Midstream (TMID) assets.\nTallgrass’s O&M 1100_GL procedures require amendment to clarify whether or not cross-\ntraining will be performed when more than one console exists in a control room, and how\ntraining and qualification requirements will cover liquid assets in addition to PXP.\n16. § 195.446 Control room management.\n(a) . . . .\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:\n(1) . . . .\n(5) For pipeline operating setups that are periodically, but infrequently used,\nproviding an opportunity for controllers to review relevant procedures in advance\nof their application; and\nTallgrass’s O&M 1100_GL Titled: Control Room Management Revised: April 1, 2020 was\ninadequate because it did not address how Tallgrass will determine operating setups that are\nperiodically, but infrequently used.\nAdditionally, the O&M 1100_GL did not identify the procedures that would be used infrequently\nsuch as those required for purging, abandonment, or pigging. The procedures require amendment\nto address how Tallgrass will determine operating setups that are periodically, but infrequently\nused and identify the required related procedures.\n11\n\n\n\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\nEnforcement Proceedings.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. 552(b), along with the complete original document you must provide a second copy of\nthe document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment\nunder 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\n90 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 Energy Partners, LP maintain documentation of the\nsafety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Gregory A Ochs, Director,\nCentral, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning\nthis matter, please refer to CPF 3-2021-103-NOA and, for each document you submit, please\nprovide a copy in electronic 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 Eckles, Director Compliance, jennifer.eckels@tallgrassenergylp.com\nCrystal Heter, Chief Operating Officer, crystal.heter@tallgrassenergylp.com\nBrad Armsbury, Compliance Engineer, brad.armsbury@tallgrassenergylp.com\n12\n\n32021103NOA_Closure Letter_05282025_(21-210993)_text.pdf\n\nVIA ELECTRONIC MAIL TO: matt@tallgrass.com;\ncrystal.heter@tallgrassenergylp.com; danielle.stephens@tallgrass.com\nMay 28, 2025\nMatt Sheehy\nPresident & Chief Executive Officer\nTallgrass Pony Express Pipeline, LLC\n370 Van Gordon Street\nLakewood, CO 80228\nRE: CPF 3-2021-103-NOA\nDear Mr. Sheehy:\nFrom May 7 – 11, 2018 and December 4 – 6, 2018, representatives of the Pipeline and\nHazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United\nStates Code conducted an inspection of Tallgrass Energy, LP’s (Tallgrass) procedures for the\nhazardous liquid Control Room Management procedures and records in Lakewood, Colorado.\nOn December 22, 2021, pursuant to 49 CFR § 190.206, PHMSA issued a Notice of Amendment\nwhich proposed amendment of Tallgrass’ procedures.\nTallgrass submitted its final amended procedures on May 28, 2025. PHMSA has reviewed the\namended procedures, and it appears that the inadequacies outlined in the Notice of Amendment\nhave been corrected.\nThis letter is to inform you that no further action is necessary, and this case is now closed.\nThank you for your cooperation.\nSincerely,\nDavid Barrett\nActing Director, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\ncc: Crystal Heter, Chief Operating Officer, Tallgrass\nDanielle Stephens, Director-PHMSA Compliance, Tallgrass","truncated":false,"body_characters":35172}