{"operation":"document","citation":"CPF 32023015NOA","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":"2023-07-20","effective_on":null,"summary":"CLOSED notice of amendment citing 192.631(a)(1), 192.631(b)(5), 192.631(c)(4), 192.631(f)(1), 192.631(h)(6).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32023015noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32023015noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32023015noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32023015NOA","body":"Notice of Amendment involving TALLGRASS INTERSTATE GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.631(a)(1),  192.631(b)(5),  192.631(c)(4),  192.631(f)(1),  192.631(h)(6). The case was opened on 2023-07-20 and is reported as closed as of 2024-09-12. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32023015NOA_Closure Letter_09122024_(22-238055).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023015NOA/32023015NOA_Closure%20Letter_09122024_(22-238055).pdf\n\n32023015NOA_Closure Letter_09122024_(22-238055)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023015NOA/32023015NOA_Closure%20Letter_09122024_(22-238055)_text.pdf\n\n32023015NOA_Notice of Amendment_07202023_(22-238055).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023015NOA/32023015NOA_Notice%20of%20Amendment_07202023_(22-238055).pdf\n\n32023015NOA_Notice of Amendment_07202023_(22-238055)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023015NOA/32023015NOA_Notice%20of%20Amendment_07202023_(22-238055)_text.pdf\n\n32023015NOA_Operator Response to Notice_09182023_(22-238055).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023015NOA/32023015NOA_Operator%20Response%20to%20Notice_09182023_(22-238055).pdf\n\n32023015NOA_Closure Letter_09122024_(22-238055)_text.pdf\n\nVIA ELECTRONIC MAIL TO: matt@tallgrass.com; crystal.heter@tallgrassenergylp.com;\ndanielle.stephens@tallgrass.com\nSeptember 12, 2024\nMr. Matt Sheehy\nPresident/ CEO\nTallgrass\n370 Van Gordon Street\nLakewood, CO 80228\nRE: CPF 3-2023-015-NOA\nDear Mr. Sheehy:\nFrom September 3 to November 4, 2022, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code\n(U.S.C.), inspected by video conference Tallgrass Interstate Gas Transmission, LLC’s\n(Tallgrass) procedures for Control Room Management in Lakewood, Colorado.\nTallgrass submitted its amended procedures on September 18, 2023 and supplemented its\nresponse and amended procedures on October 23, 2023 and November 15, 2023. My staff\nreviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of\nAmendment have 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,\nGregory A. Ochs\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Crystal Heter, Chief Operating Officer, crystal.heter@tallgrassenergylp.com\nDanielle Stephens, Director Compliance, danielle.stephens@tallgrass.com\n\n32023015NOA_Notice of Amendment_07202023_(22-238055)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: matt@tallgrass.com and Jennifer.eckels@tallgrass.com\nJuly 20, 2023\nMr. Matt Sheehy\nPresident/ CEO\nTallgrass\n370 Van Gordon Street\nLakewood, CO 80228\nCPF 3-2023-015-NOA\nDear Mr. Sheehy:\nFrom September 3 to November 4, 2022, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code\n(U.S.C.), inspected by video conference Tallgrass Interstate Gas Transmission, LLC’s (Tallgrass\nor TIGT) procedures for Control Room Management in Lakewood, Colorado.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within\nTallgrass’s plans or procedures. The items inspected and the inadequacies are described below:\n1. § 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 facility\nthrough a SCADA system. Each operator must have and follow written control\nroom management procedures that implement the requirements of this section,\nexcept that for each control room where an operator’s activities are limited to either\nor both of:\n(i) Distribution with less than 250,000 services, or\n(ii) Transmission without a compressor station, the operator must have an follow\nwritten procedures that implement only paragraphs (d) (regarding fatigue), and (i)\n(regarding compliance validation), and (j) (regarding compliance and deviations) of\nthis section…\n(b) Roles and Responsibilities. Each operator must define the roles and\n\n\n\nresponsibilities of a controller during normal, abnormal and emergency operating\nconditions. To provide for a controller during normal, abnormal, and emergency\noperating conditions. To provide for a controller’s prompt and appropriate response\nto operating conditions, an operator must define each of the following:\n(1)….\n(5) The roles, responsibilities and qualifications of others to direct and supersede the\nspecific technical actions of a controller.\nTallgrass’ procedure OM110_GL September 1, 2022 Section 3.6 was not adequate to define the\nqualifications of the Supervisor who was designated as having authority to direct or supersede\nthe technical actions of a Controller. The procedure states, “[O]CC leads are trained and\nauthorized through Operator Qualification to perform all duties assigned to controllers.” It also\nstates, “[T]he Leads and Supervisors have the expertise to know when conditions or situations\nwarrant the necessity to use their authority to direct or supersede the technical actions of a\nController.” The procedure was not clear if Supervisors are Operator Qualified. If the\nsupervisors were not Operator Qualified, as Controllers, then Tallgrass needs to define what\nqualifications validate someone to have the expertise to direct or supersede the technical actions\nof a Controller.\nThe procedure must be amended to include the qualifications of the Supervisor who has the\nauthority to direct or supersede the specific technical actions of a Controller.\n2. § 192.631 Control room management\n(a)….\n(c) Each operator must provide its controllers with the information, tools, processes\nand procedures necessary for the controllers to carry out the roles and\nresponsibilities tht operation has defined by performing the following:\n(1)….\n(4) Test any back up SCADA systems at least once each calendar year, but at\nintervals not to exceed 15 months;\nTallgrass procedures OM1100_GL September 1, 2022 4.8.2 and 4.8.3 were not adequate to\nprovide instructions for testing and documenting a thorough test of their SCADA backup\nsystems. Step 4.8.2 stated, “[A]t a minimum, backup SCADA system testing will include\ncommand and set point entry processes and testing for the incoming telephone numbers that\nroute to the OCC.” Step 4.8.3 stated, “[Backup site test forms encompass many critical items to\nbe tested but generally test at a minimum, the following items: Phones, Business Computers,\nSCADA equipment and server connection, Leak Detection function.” 4.8.3 also directs the\nreader to document the tests using OCC Backup Site Checklist.\nThe records, provided for review, indicated the date but did not include the personnel performing\nthe test or the start and end time of the test. It also did not include which control room (GT or\nHL) or which consoles were represented by the test. For each calendar year (2019, 2020 and\n2021) the form changed and there were inconsistencies with how the form was to be completed\nbetween years. In 2020, the form was filled with checkmarks and handwritten notes. There was\na note on the top of the form related to the local control room. It was unclear if this form was\nrelated to the offsite or local test. In 2021, there were no checkmarks, but there was a column\n\n\n\nthat indicated the test or applications were functioning. The 2019 record also had “Y” in a\ncolumn labeled \"OK?\" This column had no title in the 2020 and 2021 forms. Procedure\nOM1100_GL September 1, 2022 Section 4.8.2 and 4.8.3 stated, OCC backup tests “[w]ill be\ndone using the OCC Backup Site Checklist and will be retained on the CRM SharePoint site and\ncorrective actions will be implemented as needed.”\nIt was noted during the 2020 test that TIGT business only had 1 monitor and the “back of PC\ndoesn't have port for 2nd connection.\" In the 2021 testing record, a note stated, \"Need a DVI to\nDisplay Port for second Business Monitor on TIGT Console.\" It appears this issue was not\ncorrected, as required by the procedure, before the next test was performed .There was nothing\non the form to document the follow-up.\nCRM Plan 4.8.2 stated, \"Point-to-Point activities conducted during daily operations in the\nBackup Control Room will be noted as suitable for fulfilling the annual SCADA system\ntesting.” The procedure required the OCC Backup Site Checklist be completed for all tests. It\ndid not include documentation that indicated the event was actual, team training exercise or a\npoint to point. Also completing the task in the compliance data file is not adequate\ndocumentation for compliance. Section 4.8.3 states that at a minimum phones, business\ncomputers, SCADA equipment and server connection and leak detection function were needed\nfor a test. There is typically much more in a control room operation that must function. For\nexample, the IT system for emails, scheduling nominations, one call notifications, procedure\nreferences phone lists, etc. Also other functions such as printers, lighting, alarm event logging,\ncommunications, etc. The check list includes many more items than the minimum, they are all\nimportant to the operation.\nThe procedure needs to be amended to provide more instruction to complete the form under the\ndifferent scenarios and also to evaluate the critical functions that need to be tested. It should also\ninclude documentation related to follow-up on items identified as not functioning or in need of\ncorrection or repair.\n3. § 192.631 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) Establish communications between control room representative, operator’s\nmanagement and associated field personnel when planning and implementing\nphysical changes to pipeline equipment or configuration;\nTallgrass's procedure OM110_GL September 1, 2022 Section 7 was not adequate because it did\nnot reference and describe the Project Management In Service Process employed by Tallgrass to\ndiscuss projects. Tallgrass had a change management process for the control room and the\ncorporate enterprise. Tallgrass also had a Project Management In Service Process group that\nmeets weekly. A project management tool was developed, and the individual groups were\nidentified on the tool. Control room leadership (director, supervisor, leads) attended these\n\n\n\nmeetings to learn about new projects, update the group on progress and state their concerns.\nOM110_GL September 1, 2022 Section 7 did not describe or reference this process. Tallgrass\nindicated that when Maximo is implemented this Project Management In Service Process will\nnot be used.\nThe procedure needs to be amended to include the Project Management In Service Process in\nCRM procedures, either as a referenced procedure or included in the CRM Plan. It must also\ninclude a description of the roles and responsibilities the control room leadership has in those\nweekly meetings. As Maximo is implemented into the system, that process needs to be\ndeveloped to include how the control room will be notified of changes and how leadership\ninteracts to effectively implement the changes.\n4. § 192.631 Control room management.\n(a)….\n(h) Training. Each operator must establish a controller training program and review\nthe training program content to identify potential improvements at least once each\ncalendar year, but at intervals not to exceed 15 months. An operator’s program\nmust provide for training each controller to carry out the roles and responsibilities\ndefined by the operator. In addition, the training program must include the\nfollowing elements:\n(1)….\n(6) Control room team training and exercises that include both controllers and other\nindividuals, defined by the operator, who would reasonably be expected to\noperationally collaborate with controllers (control room personnel) during normal,\nabnormal or emergency situations. Operators must comply with the team training\nrequirements under this paragraph by no later than January 23, 2018.\nTallgrass's CRM procedure OM110_GL September 1, 2022 Section 9.15 was not adequate\nbecause it did not define the frequency of Team Training for individuals required to participate\nin the training. The procedure identified the job roles of those who collaborate with controllers\nas \"others.\" There was discrepancy in the section language about when training is required. One\nsentence stated, \"Depending on the training exercise scenario, the following non-OCC personnel\nmay also be included in the training exercise: Field Operations, SCADA, Systems Engineering,\nEngineering, Measurement, NOC, EHS, and Media Relations.” This could result in no one\nattending training, depending upon the criteria. Then, in the paragraph below, it stated,\n\"Individuals identified above will participate in at least one team training exercise once per\ncalendar year, not to exceed 15-months, thereafter.\" Since training is required annually, the\noperator would need to require all individuals identified as \"others\" participate in team\ntraining. If there is another frequency, for example every 3 years, then the procedure could\nsupport some percentage of \"others\" be trained each year, so all get trained in the course of the\nthree years.\nThe procedure must be amended to clearly state the required interval for team training and\nrequire attendance for those identified who operationally collaborate with controllers (control\nroom personnel) during normal, abnormal or emergency situations.\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\n30 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 that Tallgrass maintain documentation of the safety improvement costs associated\nwith fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit\nthe total to Gregory Ochs, Director, Central Region, Pipeline and Hazardous Materials Safety\nAdministration. In correspondence concerning this matter, please refer to CPF 3-2023-015-NOA\nand, for each document you submit, please provide a copy in electronic format whenever\npossible.\nSincerely,\nGregory A. Ochs\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\ncc: Jennifer Eckels, Manager Compliance, Jennifer.eckels@tallgrass.com","truncated":false,"body_characters":16454}