# TALLGRASS INTERSTATE GAS TRANSMISSION, LLC — Notice of Amendment

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

Official case documents:

32023015NOA_Closure Letter_09122024_(22-238055).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023015NOA/32023015NOA_Closure%20Letter_09122024_(22-238055).pdf

32023015NOA_Closure Letter_09122024_(22-238055)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023015NOA/32023015NOA_Closure%20Letter_09122024_(22-238055)_text.pdf

32023015NOA_Notice of Amendment_07202023_(22-238055).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023015NOA/32023015NOA_Notice%20of%20Amendment_07202023_(22-238055).pdf

32023015NOA_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

32023015NOA_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

32023015NOA_Closure Letter_09122024_(22-238055)_text.pdf

VIA ELECTRONIC MAIL TO: matt@tallgrass.com; crystal.heter@tallgrassenergylp.com;
danielle.stephens@tallgrass.com
September 12, 2024
Mr. Matt Sheehy
President/ CEO
Tallgrass
370 Van Gordon Street
Lakewood, CO 80228
RE: CPF 3-2023-015-NOA
Dear Mr. Sheehy:
From September 3 to November 4, 2022, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code
(U.S.C.), inspected by video conference Tallgrass Interstate Gas Transmission, LLC’s
(Tallgrass) procedures for Control Room Management in Lakewood, Colorado.
Tallgrass submitted its amended procedures on September 18, 2023 and supplemented its
response and amended procedures on October 23, 2023 and November 15, 2023. 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 that 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
cc: Crystal Heter, Chief Operating Officer, crystal.heter@tallgrassenergylp.com
Danielle Stephens, Director Compliance, danielle.stephens@tallgrass.com

32023015NOA_Notice of Amendment_07202023_(22-238055)_text.pdf

NOTICE OF AMENDMENT
VIA ELECTRONIC MAIL TO: matt@tallgrass.com and Jennifer.eckels@tallgrass.com
July 20, 2023
Mr. Matt Sheehy
President/ CEO
Tallgrass
370 Van Gordon Street
Lakewood, CO 80228
CPF 3-2023-015-NOA
Dear Mr. Sheehy:
From September 3 to November 4, 2022, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code
(U.S.C.), inspected by video conference Tallgrass Interstate Gas Transmission, LLC’s (Tallgrass
or TIGT) procedures for Control Room Management in Lakewood, Colorado.
As a result of the inspection, PHMSA has identified the apparent inadequacies found within
Tallgrass’s plans or procedures. The items inspected and the inadequacies are described below:
1. § 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 an follow
written procedures that implement only paragraphs (d) (regarding fatigue), and (i)
(regarding compliance validation), and (j) (regarding compliance and deviations) of
this section…
(b) Roles and Responsibilities. Each operator must define the roles and



responsibilities of a controller during normal, abnormal and emergency operating
conditions. To provide for a controller during normal, abnormal, and emergency
operating conditions. To provide for a controller’s prompt and appropriate response
to operating conditions, an operator must define each of the following:
(1)….
(5) The roles, responsibilities and qualifications of others to direct and supersede the
specific technical actions of a controller.
Tallgrass’ procedure OM110_GL September 1, 2022 Section 3.6 was not adequate to define the
qualifications of the Supervisor who was designated as having authority to direct or supersede
the technical actions of a Controller. The procedure states, “[O]CC leads are trained and
authorized through Operator Qualification to perform all duties assigned to controllers.” It also
states, “[T]he Leads and Supervisors have the expertise to know when conditions or situations
warrant the necessity to use their authority to direct or supersede the technical actions of a
Controller.” The procedure was not clear if Supervisors are Operator Qualified. If the
supervisors were not Operator Qualified, as Controllers, then Tallgrass needs to define what
qualifications validate someone to have the expertise to direct or supersede the technical actions
of a Controller.
The procedure must be amended to include the qualifications of the Supervisor who has the
authority to direct or supersede the specific technical actions of a Controller.
2. § 192.631 Control room management
(a)….
(c) Each operator must provide its controllers with the information, tools, processes
and procedures necessary for the controllers to carry out the roles and
responsibilities tht operation has defined by performing the following:
(1)….
(4) Test any back up SCADA systems at least once each calendar year, but at
intervals not to exceed 15 months;
Tallgrass procedures OM1100_GL September 1, 2022 4.8.2 and 4.8.3 were not adequate to
provide instructions for testing and documenting a thorough test of their SCADA backup
systems. Step 4.8.2 stated, “[A]t a minimum, backup SCADA system testing will include
command and set point entry processes and testing for the incoming telephone numbers that
route to the OCC.” Step 4.8.3 stated, “[Backup site test forms encompass many critical items to
be tested but generally test at a minimum, the following items: Phones, Business Computers,
SCADA equipment and server connection, Leak Detection function.” 4.8.3 also directs the
reader to document the tests using OCC Backup Site Checklist.
The records, provided for review, indicated the date but did not include the personnel performing
the test or the start and end time of the test. It also did not include which control room (GT or
HL) or which consoles were represented by the test. For each calendar year (2019, 2020 and
2021) the form changed and there were inconsistencies with how the form was to be completed
between years. In 2020, the form was filled with checkmarks and handwritten notes. There was
a note on the top of the form related to the local control room. It was unclear if this form was
related to the offsite or local test. In 2021, there were no checkmarks, but there was a column



that indicated the test or applications were functioning. The 2019 record also had “Y” in a
column labeled "OK?" This column had no title in the 2020 and 2021 forms. Procedure
OM1100_GL September 1, 2022 Section 4.8.2 and 4.8.3 stated, OCC backup tests “[w]ill be
done using the OCC Backup Site Checklist and will be retained on the CRM SharePoint site and
corrective actions will be implemented as needed.”
It was noted during the 2020 test that TIGT business only had 1 monitor and the “back of PC
doesn't have port for 2nd connection." In the 2021 testing record, a note stated, "Need a DVI to
Display Port for second Business Monitor on TIGT Console." It appears this issue was not
corrected, as required by the procedure, before the next test was performed .There was nothing
on the form to document the follow-up.
CRM Plan 4.8.2 stated, "Point-to-Point activities conducted during daily operations in the
Backup Control Room will be noted as suitable for fulfilling the annual SCADA system
testing.” The procedure required the OCC Backup Site Checklist be completed for all tests. It
did not include documentation that indicated the event was actual, team training exercise or a
point to point. Also completing the task in the compliance data file is not adequate
documentation for compliance. Section 4.8.3 states that at a minimum phones, business
computers, SCADA equipment and server connection and leak detection function were needed
for a test. There is typically much more in a control room operation that must function. For
example, the IT system for emails, scheduling nominations, one call notifications, procedure
references phone lists, etc. Also other functions such as printers, lighting, alarm event logging,
communications, etc. The check list includes many more items than the minimum, they are all
important to the operation.
The procedure needs to be amended to provide more instruction to complete the form under the
different scenarios and also to evaluate the critical functions that need to be tested. It should also
include documentation related to follow-up on items identified as not functioning or in need of
correction or repair.
3. § 192.631 Control room management.
(a) ….
(f) Change management. Each operator must assure that changes that could affect
control room operations are coordinated with the control room personnel by
performing each of the following:
(1) Establish communications between control room representative, operator’s
management and associated field personnel when planning and implementing
physical changes to pipeline equipment or configuration;
Tallgrass's procedure OM110_GL September 1, 2022 Section 7 was not adequate because it did
not reference and describe the Project Management In Service Process employed by Tallgrass to
discuss projects. Tallgrass had a change management process for the control room and the
corporate enterprise. Tallgrass also had a Project Management In Service Process group that
meets weekly. A project management tool was developed, and the individual groups were
identified on the tool. Control room leadership (director, supervisor, leads) attended these



meetings to learn about new projects, update the group on progress and state their concerns.
OM110_GL September 1, 2022 Section 7 did not describe or reference this process. Tallgrass
indicated that when Maximo is implemented this Project Management In Service Process will
not be used.
The procedure needs to be amended to include the Project Management In Service Process in
CRM procedures, either as a referenced procedure or included in the CRM Plan. It must also
include a description of the roles and responsibilities the control room leadership has in those
weekly meetings. As Maximo is implemented into the system, that process needs to be
developed to include how the control room will be notified of changes and how leadership
interacts to effectively implement the changes.
4. § 192.631 Control room management.
(a)….
(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:
(1)….
(6) Control room team training and exercises that include both controllers and other
individuals, defined by the operator, who would reasonably be expected to
operationally collaborate with controllers (control room personnel) during normal,
abnormal or emergency situations. Operators must comply with the team training
requirements under this paragraph by no later than January 23, 2018.
Tallgrass's CRM procedure OM110_GL September 1, 2022 Section 9.15 was not adequate
because it did not define the frequency of Team Training for individuals required to participate
in the training. The procedure identified the job roles of those who collaborate with controllers
as "others." There was discrepancy in the section language about when training is required. One
sentence stated, "Depending on the training exercise scenario, the following non-OCC personnel
may also be included in the training exercise: Field Operations, SCADA, Systems Engineering,
Engineering, Measurement, NOC, EHS, and Media Relations.” This could result in no one
attending training, depending upon the criteria. Then, in the paragraph below, it stated,
"Individuals identified above will participate in at least one team training exercise once per
calendar year, not to exceed 15-months, thereafter." Since training is required annually, the
operator would need to require all individuals identified as "others" participate in team
training. If there is another frequency, for example every 3 years, then the procedure could
support some percentage of "others" be trained each year, so all get trained in the course of the
three years.
The procedure must be amended to clearly state the required interval for team training and
require attendance for those identified who operationally collaborate with controllers (control
room personnel) during normal, abnormal or emergency situations.



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
Enforcement 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
30 days of receipt of this Notice. This period may be extended by written request for good
cause. Once the inadequacies identified herein have been addressed in your amended
procedures, this enforcement action will be closed.
It is requested 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 Gregory Ochs, Director, Central Region, Pipeline and Hazardous Materials Safety
Administration. In correspondence concerning this matter, please refer to CPF 3-2023-015-NOA
and, for each document you submit, please provide a copy in electronic format whenever
possible.
Sincerely,
Gregory A. Ochs
Director, Central Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings
cc: Jennifer Eckels, Manager Compliance, Jennifer.eckels@tallgrass.com
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