{"operation":"document","citation":"CPF 32024017NOA","title":"CALIBER SPRING CREEK LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-07-03","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(a), 195.408(b)(3), 195.446(a), 195.446(b)(1), 195.446(b)(2), 195.446(b)(3), 195.446(b)(4), 195.446(b)(5), 195.446(c)(1), 195.446(c)(2), 195.446(c)(3), 195.446(c)(4), 195.446(d), 195.446(d)(1), 195.446(d)(4), 195.446(e)(1), 195.446(e)(2), 195.446(e)(4), 195.446(e)(5), 195.446(e)(6), 195.446(f)(1), 195.446(f)(2), 195.446(g)(1), 195.446(g)(2), 195.446(h), 195.446(h)(1), 195.446(h)(3), 195.446(h)(4), 195.446(h)(5), 195.446(h)(6), 195.446(i), 195.446(j)(1), 195.452(a), 195.452(i)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32024017noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32024017noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32024017noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32024017NOA","body":"Notice of Amendment involving CALIBER SPRING CREEK LLC. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.408(b)(3),  195.446(a),  195.446(b)(1),  195.446(b)(2),  195.446(b)(3),  195.446(b)(4),  195.446(b)(5),  195.446(c)(1),  195.446(c)(2),  195.446(c)(3),  195.446(c)(4),  195.446(d),  195.446(d)(1),  195.446(d)(4),  195.446(e)(1),  195.446(e)(2),  195.446(e)(4),  195.446(e)(5),  195.446(e)(6),  195.446(f)(1),  195.446(f)(2),  195.446(g)(1),  195.446(g)(2),  195.446(h),  195.446(h)(1),  195.446(h)(3),  195.446(h)(4),  195.446(h)(5),  195.446(h)(6),  195.446(i),  195.446(j)(1),  195.452(a),  195.452(i)(3). The case was opened on 2024-07-03 and is reported as closed as of 2026-05-21. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32024017NOA_Closure Letter_05212026_(22-236545).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024017NOA/32024017NOA_Closure%20Letter_05212026_(22-236545).pdf\n\n32024017NOA_Closure Letter_05212026_(22-236545)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024017NOA/32024017NOA_Closure%20Letter_05212026_(22-236545)_text.pdf\n\n32024017NOA_Notice of Amendment_07032024_(22-236545).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024017NOA/32024017NOA_Notice%20of%20Amendment_07032024_(22-236545).pdf\n\n32024017NOA_Notice of Amendment_07032024_(22-236545)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024017NOA/32024017NOA_Notice%20of%20Amendment_07032024_(22-236545)_text.pdf\n\n32024017NOA_Operator Response to Notice and Request Time Extension_07152024_(22-236545).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024017NOA/32024017NOA_Operator%20Response%20to%20Notice%20and%20Request%20Time%20Extension_07152024_(22-236545).pdf\n\n32024017NOA_Closure Letter_05212026_(22-236545)_text.pdf\n\nU.S. Department of Transportation\nPipeline and Hazardous\nMaterials Safety Administration\n1100 Main Street, Suite 800\nKansas City, MO 64105\n(816) 329-3800\nVIA ELECTRONIC MAIL TO: bkent@calibermidstream.com;\ndwerth@calibermidstream.com; cmaybee@calibermidstream.com\nMay 21, 2026\nMr. Tad True, COO\nCaliber Spring Creek, LLC\n455 North Poplar Street\nCasper, Wyoming 82602\nRE: CPF 3-2024-017-NOA\nDear Mr. True:\nOn April 25 through April 29, May 2 through May 4, and May 9 through May 11, 2022, a\nrepresentative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant\nto Chapter 601 of 49 United States Code (U.S.C.), conducted an inspection of Caliber Spring\nCreek, LLC’s (“Caliber”) procedures for Control Room Management (CRM), SCADA, Leak\nDetection, and Operations and Maintenance (O&M) relevant to the control room located in\nHouston, Texas. On July 3, 2024, pursuant to 49 CFR § 190.206, PHMSA issued a Notice of\nAmendment which proposed amendment of Caliber’s procedures.\nCaliber submitted its amended procedures on October 18 and November 18, 2024 and provided\nsupplements on November 21 and December 2, 2025. PHMSA has reviewed the amended\nprocedures, and it appears that the inadequacies outlined in the Notice of Amendment have been\ncorrected.\nThis letter is to inform you that no further action is necessary, and this case is now closed. Thank\nyou for your cooperation.\nSincerely,\nAmy McKean\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Ken Dockweiler, Director Land and Government (ken.dockweiler@truecos.com)\nKevin Pena, Pipeline Compliance Coordinator (kevin.pena@truecos.com)\n\n32024017NOA_Notice of Amendment_07032024_(22-236545)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: bkent@calibermidstream.com;\ndwerth@calibermidstream.com; cmaybee@calibermidstream.com\nJuly 3, 2024\nBill Kent\nChief Executive Officer\nCaliber Midstream Partners, LP\nCaliber Spring Creek, LLC\n1805 Shea Center Drive, Suite 120\nHighlands Ranch, CO 80129\nCPF 3-2024-017-NOA\nDear Mr. Kent:\nFrom April 25 through April 29, May 2 through May 4, and May 9 through May 11, 2022, a\nrepresentative of the Pipeline and Hazardous Materials Safety Administration (PHMSA),\npursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected by video conference\nCaliber Spring Creek, LLC’s procedures for Control Room Management (CRM), SCADA, Leak\nDetection, and Operations and Maintenance (O&M) relevant to the control room located in\nHouston, Texas.\nCaliber Midstream Partners, LP (Caliber) operates multiple systems: Caliber North Dakota,\nCaliber Bear Den Interconnect, and Caliber Spring Creek Pipeline System (CSC). On October\n29, 2019, CSC assets were monitored and controlled by a third party control room, NuGen\nAutomation. On October 1, 2021, NuGen Automation became part of Everline Automation\n(Everline). At the time of the inspection, CSC assets were operated by a third-party control room,\nEverline. Everline was still using some of the NuGen Automation procedures. Everline’s CRM\nprocedures apply to CSC.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within\nCaliber and CSC’s plans or procedures. The items inspected and the inadequacies are described\nbelow:\n\n\n\n1. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies. This manual shall be\nreviewed at intervals not exceeding 15 months, but at least once each calendar year,\nand appropriate changes made as necessary to insure that the manual is effective.\nThis manual shall be prepared before initial operations of a pipeline system\ncommence, and appropriate parts shall be kept at locations where operations and\nmaintenance activities are conducted.\n“Caliber Midstream Operations and Maintenance Manual Hazardous Liquids Pipelines” (revised\nSeptember 23, 2020) procedure (O&M), section 2A, entitled “Normal Operations and\nMaintenance, Caliber Spring Creek Pipeline System,” dated February 20, 2020, was inadequate\nas it referenced incorrect control room management procedures and did not adequately describe\nthe process used by Caliber and CSC to determine which facilities are control rooms, as required\nby 49 CFR §§ 195.402 and 195.446(a). Specifically, O&M section 2A.15, entitled\n“Communications and Control System,” stated, “The Caliber Spring Creek System’s Control\nRoom Management program is operated by NuGen Automation. A full copy of NuGen CRM\nprogram has been made readily available. Please see Control Center-SOP-CRM. (NGA-CNTL-\nSOP-0001).” However, at the time of the inspection, the CRM procedures presented by Caliber\nas the relevant operating procedures for the third-party control room was “Everline CRM\nPipeline Control Room Management” (CSC CRM), version 15, dated May 20, 2016. Caliber’s\nO&M procedure section 2A.15 specific to CSC requires amendment to address the correct CRM\nprocedure currently used for operations and it must be properly integrated as required.\nAdditionally, during the inspection, when Caliber was asked how a control room was\ndetermined, Caliber referenced section 1.3 of CSC’s CRM procedures. However, this section of\nthe procedure was inadequate as it did not describe the process used by Caliber and CSC to\nidentify control rooms; rather it described the process used by Everline to define a control room.\nFurther, this section only applied to the CSC assets authorized for Everline to operate. Caliber’s\nprocedures require amendment to clarify the process used by Caliber on any assets to identify a\ncontrol room (including those used by CSC).\nDuring the inspection, PHMSA reviewed Caliber’s O&M procedure section 4.5.4, entitled\n“Suspected Leaks,” and this section referenced SOP 1001-2002 entitled “Crude Oil System\nOperating Procedures.” PHMSA requested this procedure (RI #11) and Caliber responded, “This\nSOP does not exist in the Caliber system.” Caliber’s O&M procedures require amendment to\nclarify what will be done for suspected leaks and reference the correct shutdown procedures. The\nincorrect procedure referenced requires removal.\nFor these reasons, Caliber and CSC's O&M procedures were not adequate and require\namendment, per § 195.402 and § 195.446(a).\n\n\n\n2. § 195.408 Communications.\n(a) . . . .\n(b) The communication system required by paragraph (a) of this section must, as a\nminimum, include means for:\n(1) . . . .\n(3) Conducting two-way vocal communication between a control center and the\nscene of abnormal operations and emergencies; and\nCaliber’s O&M procedure section 4, entitled “Emergency Procedures,” did not adequately\naddress communications between a control center and the scene of abnormal operations and\nemergencies as required by § 195.408(b)(3).\nThroughout sections 4.4 through 4.9 (entitled “Receiving, Identifying, Classifying Notices,”\n“Vapor Detected Inside or Near a Building,” “Natural Disasters,” “Extreme Weather and Natural\nDisasters,” “Fire and Explosion,” and “Extortion Threats”), the communication with the control\nroom is only referenced once, in section 4.6.2, entitled “Wildfires.” Section 4.6.2 stated, “If a\nwildfire is observed by Caliber personnel in an open field, forest, or other area it should\nbe immediately reported to the control room….” This is the only section that required\ncommunication with the control room; however, the control room would need to be made aware\nof any of the conditions described in sections 4.4 through 4.9.\nEven within section 4.6.2, the control room communication was not properly addressed. Section\n4.6.2 included two conditions that do not require contacting the control room yet clearly could\nimpact the control room. Thus communication should be required. First, the procedure did not\nrequire contacting the control room in a situation where a wildfire is near or approaching an\nabove ground valve station, despite the fact that the above ground valve station can impact valve\nposition or valve controls on the pipeline. Second, the procedure did not require contacting the\ncontrol room in a situation when a fire is reported by a third party. This would also be significant\nto communicate to the control room.\nThe procedure did not adequately address communication with the control room in multiple\nother sections. Sections 4.15, entitled “Alerting and Notification Procedure,” 4.2.1, entitled\n“Readiness,” 4.2.2, entitled “Availability of Resources,” 4.3.3, entitled “Containment,” 4.3.4,\nentitled “Protection of Public,” 4.10.2, entitled “Operations Manager or Designee,” and 4.14.1,\nentitled “Media Relations,” all referenced completing notification as described in Section 4A.14.\nHowever, nothing in section 4A.14 required communication with the control room.\nThe Emergency Procedures referenced oil response or oil spill response procedures in sections\n4.2.3, entitled “Organization Basics,” 5.4.5, entitled “Spill Control Training,” and 5.4.6, entitled\n“Emergency Prevention Training;” however none of these sections referenced communication\nwith the control room.\nThe Emergency Procedures also addressed oil spill response and Federal Response Plan (FRP)\nrelevant to Part 194 (located in sections 4.2.1 “Readiness,” 4.5.3, “Duties & Requirements,”\n4.3.5, “Reviews,” and 5.4.1 “Emergency Response Drill /Tabletop”) but again, nothing\n\n\n\n3. referenced communication with the control room. Additionally, nothing in the CSC’s CRM\nprocedures addressed aspects of FRP plans and Part 194 for CSC.\nFor these reasons, the Emergency Procedures relevant to all Caliber pipeline systems (applicable\nalso to CSC) require amendment to identify a process for communication with any control room,\nincluding a third-party control room, to comply with § 195.408(b)(3).\n§ 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. . . .\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 controller's prompt and appropriate response to\noperating conditions, an operator must define each of the following:\n(1) A controller's authority and responsibility to make decisions and take actions\nduring normal operations;\nCSC’s CRM procedures did not adequately define a controller’s authority and responsibilities to\nmake decisions and take actions during normal operations, as required by § 195.446(b)(1). This\ncontrol room monitors and controls multiple operators’ assets in addition to CSC. At the time of\nthe inspection, the control room had 10 consoles that were manned by individual controllers, and\n2 supervisors located in the control room. Console 8 has CSC assets but this control room cross-\ntrained controllers for console 7 and console 8. During the inspection, Caliber and the control\nroom personnel communicated to PHMSA inspectors that all controllers can access any console\nif they have log-in privileges to the SCADA system, including those assets on consoles for which\nthe controllers are not qualified. Any person with SCADA log-in access could execute\ncommands on other assets. Further, more than one controller could access a given pipeline\nsystem at the same time (such as CSC). Nothing prevented command actions for the same asset\nfrom being executed by multiple controllers on different consoles. The procedures did not clarify\nwhich controller is to make decisions and take actions on the CSC system at any given time.\nCSC’s CRM procedure Exhibit B, entitled “Domain of Responsibility Table,” indicated that\nWatford PMP101 and PMP102 pumps are commanded by a controller; however, the indications\non the display did not allow for commanding these pumps. PHMSA was verbally told during the\ninspection that these pumps were not commanded as indicated in Exhibit B.\nAdditionally, CSC’s CRM procedures included inaccurate titles of control room personnel. For\nexample, at the time of inspection, “Lead Controllers” were referred to as “Control Room\nSupervisors.” Amendment is required so that each employee knows their roles and\nresponsibilities as stated in the procedures without confusion.\nFurther, during the inspection it was confirmed with Caliber personnel that the control room did\n\n\n\n4. 5. not receive 811 calls during or after normal work hours. CSC CRM procedures in section 3.4,\nentitled “Controller Responsibility,” Item 14 in the “Controller-Normal Operations” table\nindicated the control room does address 811 calls. CSC CRM procedure requires amendment\nspecific to 811 calls for CSC assets.\nFor these reasons, Caliber and CSC’s procedures were inadequate to define a controller’s\nauthority and responsibilities during normal operations as required by § 195.446(b)(1).\n§ 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. . . .\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 controller's prompt and appropriate response to\noperating conditions, an operator must 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;\nCSC’s CRM procedures were inadequate to define a controller’s roles and responsibilities during\nabnormal operations per § 195.445(b)(2). The control room does not receive 811 calls. The CRM\nprocedure section 3.4, entitled “Controller Responsibility,” Item 9 in the “Controller - Abnormal\nOperations/Abnormal Operating Conditions” table requires amendment to clarify that 811 calls\nare not addressed for CSC assets by the control room during abnormal operations/abnormal\noperating conditions.\nCSC’s CRM procedures were inadequate to define a controller’s authority and responsibilities\nduring abnormal operations as required by § 195.446(b)(2).\n§ 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. . . .\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 controller's prompt and appropriate response to\noperating conditions, an operator must define each of the following:\n(1) . . . .\n\n\n\n6. (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;\nCaliber’s O&M and CSC’s CRM procedures were inadequate to define a controller’s role during\nan emergency, even if the controller is not the first to detect the emergency, including the\ncontroller's responsibility to take specific actions and to communicate with others, per\n§ 195.446(b)(3). Specifically, the CSC’s CRM procedures had multiple inconsistencies when\ndefining a controller’s role and responsibility during an emergency. CRM procedure section 1.8\nreferenced a document entitled “Everline’s Emergency Evacuation Procedure,” but that\ndocument did not exist. Also, CRM procedure section 4.9.3, entitled “Unplanned Evacuations\n(e.g. bomb threat, fire threat),” in Item C referenced “mobile go kits” that are no longer used\nduring emergencies, as confirmed by control room personnel during the PHMSA inspection.\nAdditionally, CRM procedure, section 3.4, entitled “Controller Responsibility,” Item 6\n“Controller – Emergency Operations” table did not incorporate or provide reference to the\nappropriate Internal Communication Plan. If an evacuation occurs of the control room, the\nInternal Communication Plan may be implemented until the back-up center is up and running\nwith controllers present or until the specific situation that caused the evacuation is resolved.\nThus, reference to the Internal Communication Plan is necessary.\nFurther, CRM procedure section 4.9.1 did not identify whether 800 calls would be received for\nCSC. During the inspection, PHMSA asked how 800 calls were handled for Caliber, and CSC,\nand conflicting answers were provided by Caliber, CSC, and the control room. As a result, this\nneeds to be clarified in procedures. This was not presented in the O&M procedures as to how this\nwas integrated with the control room.\nCaliber’s O&M and CSC’s CRM procedures require amendment to adequately define a\ncontroller’s role during an emergency, even if the controller is not the first to detect the\nemergency, including the controller's responsibility to take specific actions and to communicate\nwith others, per § 195.446(b)(3).\n§ 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. . . .\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 controller's prompt and appropriate response to\noperating conditions, an operator must 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. . . .\n\n\n\nCSC’s CRM procedures were inadequate to define a method of recording shift-changes and any\nhand-over of responsibility between controllers, per § 195.446(b)(4) and § 195.446(c)(5), which\nrequires the operator to implement section 5 of API RP 1168 (First Edition, September of 2008)\nto establish procedures for when a different controller assumes responsibility, including the\ncontent of information to be exchanged. During the inspection, CSC and control room personnel\nexplained that the Shift Turnover process had moved from the “Shift Turnover Checklist,” Form\n11-1 (this was referenced in CSC’s CRM procedures, sections 3, entitled “Responsibility,” and 5,\nentitled “Shift Turnover”) to an electronic form known as Elogger. However, the Elogger and the\nShift Turnover Checklist were not the same, so the CRM procedures require revision in order to\nconfirm what information is to be exchanged between controllers. Additionally, when changing\nthe shift turnover form to the Elogger, the CSC CRM procedure section 5, entitled “Shift\nTurnover,” did not include step-by-step instructions for populating the form nor did it clarify that\nthe “Yes/NA” data field will be blank at the start of each shift change, and comments must be\nadded for each element when completing the shift change as explained by the operator during the\ninspection.\nCSC’s CRM procedures did not require controllers to log off the SCADA system when leaving\nthe console. However, this was clearly communicated during the inspection as an expectation by\ncontrol room representatives, and older shift turnover documentation from 2021 had this step\nidentified as an instruction rather than a requirement. CSC’s CRM procedures in sections 3 and 5\ndid not describe this required action. Shift Turnover documentation from 2022 also did not\ninclude this instruction.\nDuring the inspection, PHMSA determined that manual tracking sheets were populated for\noperational changes made during the shift. CSC’s CRM procedures did not address this\ndocumentation. CSC’s CRM procedures require amendment to include any manual sheets that\nare populated as part of the shift turnover process and associated records.\nCaliber’s O&M and CSC’s CRM procedures did not include how volume movements and any\nimbalances will be monitored and communicated to controllers as part of the shift change\nprocess. PHMSA determined during the inspection that Caliber provided a summary of all\nmeters in and out of the system to the control room daily to assist with imbalance tracking on the\nCSC system. Caliber’s O&M procedures and CSC’s CRM procedures did not define how a\ncontroller received the operations schedule (shipping or movement requirements) or imbalance\ninformation on a daily basis, however all of this information would need to be included as part of\nthe Shift change documentation. This information is required for a controller to perform normal\npipeline operations and to assist with abnormal operations detection. It was not clear if Caliber or\nCSC provides the information by email to a control room manager or supervisor for distribution\nto controllers, if controllers receive this information directly, or if the SCADA system\nautomatically receives this information. CSC’s CRM procedures did not define whether any of\nthe operations scheduling values require manual entry by a controller.\nCSC’s CRM procedure section 3 did not address an emergency where the controller is\nincapacitated and does not plan to leave the console. Similarly, CSC’s CRM procedure did not\naddress if anyone can log off of the console for someone else (such as would be required should\na controller not be able to log off the system). As such, the procedures need to be amended to\ninclude what actions will be required of the operator.\n\n\n\n7. CSC’s CRM procedure section 3.3, “Impromptu Change in Responsibility,” did not clearly\ndefine the role and responsibilities of a controller when planning to leave the console for less\nthan 30 minutes. The procedure should clarify that the controller must confirm before leaving the\ncontrol room that the individual answering the phones has the controller’s correct contact\ninformation as part of the process for handover. Section 3.3 did not clarify if the individual\nassigned to answer the phone must have qualification to the console being vacated for 30\nminutes. Moreover, section 3.3 did not address how the individual answering the phones will\nalso be responsible for confirming that no other controller or person in the control room activates\ncommands or makes keyboard actions while the qualified and scheduled controller has stepped\naway. Section 3.3 did not adequately define what would be required for a shift turnover if a\ncontroller has left the console for more than 30 minutes. An adequate procedure would include\nhow the incoming controller would handle logging off for the previously scheduled controller.\nFor these reasons, Caliber’s O&M and CSC’s CRM procedures were inadequate for shift\nturnover when a different controller assumes responsibility, for implementing section 5 of API\nRP 1168, in identifying the content of information to be exchanged, for clarifying actions to be\ntaken by the operator or controller, and in defining a method of recording shift-changes and any\nhand-over of responsibility between controllers as required by § 195.446(b)(4) and §\n195.446(c)(5).\n§ 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. . . .\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 controller's prompt and appropriate response to\noperating conditions, an operator must define each of the following:\n(1) . . . .\n(5) The roles, responsibilities and qualifications of others who have the authority to\ndirect or supersede the specific technical actions of controllers.\nCaliber’s O&M and CSC’s CRM procedures were not adequate to define the roles,\nresponsibilities, and qualifications of others who have the authority to direct or supersede the\nspecific technical actions of controllers as required by § 195.446(b)(5). The CRM procedures\nrequire amendment to adequately address direct and supersede in section 3 and to adequately\ncover how restarts are achieved after a potential release. CRM procedure section 3 indicated that\nonly the lead controller can direct or supersede a controller action if they are qualified as a\ncontroller to the specific console. Section 3 also noted that a record of Lead Controllers with this\nability will be listed in the “Domain of Responsibility Table” (located in CSC’s CRM procedure\nExhibit B). However, Exhibit B’s “Domain of Responsibility Table” did not address directing\nthe controller’s actions. Also Exhibit B included names of individuals that were no longer\nqualified controllers on Console 8. Exhibit B requires amendment to correctly identify who can\ndirect and supersede, not just supersede, controllers’ actions.\n\n\n\nAdditionally, CSC’s CRM procedure in section 3.1, “Authority and Responsibility,” stated\n“Authority to restart a pipeline that has been shut down due to a potential release should follow\nthe Asset Specific O&M Manuals or Emergency Response Procedures (ERP) Manuals.”\nHowever, Caliber’s O&M and ERP Manuals did not indicate who would approve a restart\nbeyond O&M sections 3.4, “Maintaining Design Limits,” and 4.6.2, “Wildfires.” This did not\nadequately address who from Caliber or the control room would approve a restart and if\ncommunication with the Lead Controller would be required so that a controller could be directed\nto restart the pipeline. At the time of the inspection, when discussing this with Caliber and\ncontrol room personnel, it was not clear if any employee from Caliber (including any specific\nfield personnel) would provide approval for a restart or how the Lead Controller would be made\naware of this information.\nCaliber’s O&M and CSC’s CRM procedures require amendment to adequately define the roles,\nresponsibilities, and qualifications of others who have the authority to direct or supersede the\nspecific technical actions of controllers per § 195.446(b)(5).\n8. § 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. . . .\n(b) . . . .\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;\nCSC’s CRM procedures were not adequate to determine when implementing API RP 1165\nwould be required, as per § 195.446(c)(1). Specifically, CSC’s CRM procedures and referenced\nprocedures (such as the Everline SCADA Functional Technical Specification) did not define a\nSCADA system addition, expansion, or replacement. The CRM procedures were not clear on\nwhether API RP 1165 would be implemented when hardware or software (such as server\narchitecture changes, console additions, software and hardware revisions including upgrades,\nassets being added or moved, a separate SCADA system being added to this control room or a\nSCADA system change) changes were made to the SCADA system.\nCSC’s CRM procedures referenced API RP 1165 in various ways (for example the procedures\ndid state “1165,” “recommended practice RP 1165,” etc. in sections 1.8, “Reference\nDocuments,” 1.10, “Definitions,” 2.4, “Record Keeping,” 3.8, “SCADA/IT/Network\n\n\n\nOperations,” 4.5, “Pipeline SCADA Displays and API RP-1165,” and in Form 11-17, “Pipeline\nSCADA Displays 1165 Checklist.”). CSC’s CRM section 4.5, “Pipeline SCADA Displays and\nAPI RP-1165,” stated “[t]he requirements shall be waived if it is demonstrated that the API RP-\n1165 requirements are not practical to implement. This may be demonstrated by a description, in\nmemorandum or other form, of why API RP-1165 is not appropriate for a given system change.”\nHowever, “Not appropriate” is not equivalent to “not being practical” for implementation and the\nlanguage requires revision.\nCSC’s CRM procedure referenced the SCADA Functional Technical Specification; the CRM\nprocedure did not reference the NuGen Display Guide. At the time of the inspection, PHMSA\nrequested a copy of the SCADA Functional Technical Specification, but the document provided\nto PHMSA as a result of this request was titled “NuGen OCC Display Standard” (referred to\nbelow as NuGen Display Guide). CSC’s CRM procedure and SCADA Functional Technical\nSpecification (called the “NuGen Display Guide” during the inspection) were inadequate and\nrequire the following amendments:\n1) The NuGen Display Guide, section 4.0, “Display Hardware,” needs to be updated to\ninclude the primary and backup center locations (as different configurations were\nidentified for these locations: 12 monitors per console in the primary control room, 9\nmonitors per console in the back up location, 8 monitors were listed in the NuGen\nDisplay Guide, CRM 4.5.2 referenced 10-14 monitors depending on workload).\n2) The NuGen Display Guide, section 5.0, “Display Layout and Organization (PHMSA\nc1-5),” requires multiple amendments. Subsection 5.1, “General Design\nConsiderations,” was not clear that section 2, “General Considerations (PHMSA C1-\n3),” of the Nugen Display Guide was relevant, not section 2 of API RP1165, entitled\n“References.” Section 5.1 should also reference section 3 in this same document,\nentitled “Human Factors Engineering (PHMSA C1-4),” and it did not. Subsection 5.2,\n“Display Hierarchy,” was not clear regarding API RP1165 applicability and needs to be\nchanged to start with Level 1 and work through Level 4. Section 5.3, “Window\nManagement,” referenced screen savers however at the time of the inspection screen\nsavers were disabled for CSC. Additionally, this same section did not address the\nnumber of windows being open at one time as limited to 100 (the control room\npersonnel indicated this verbally during the inspection, but this was not clarified in\nspecifications or procedures). During the inspection, PHMSA observed that Object\nMenus and other display features had various permission levels for access (such as\nSCADA versus that for the controller), but this was not described at any location in the\nprocedures or specifications and would impact various sections such as section 5.3.2,\n“Toolbars.” It was not clear for each of the menu drop down options what controllers\nwould be allowed to access.\n3) The NuGen Display Guide, section 7.0, “Object Characteristics (PHMSA C1-7),” was\nnot clear on how it is employed. Procedures should be clarified on how flow setpoints\n(or pressure setpoints) would be linked in the display to the corresponding control\nvalve. API RP 1165 states in section 9, entitled “Object Dynamics,” that “Object\ndynamics refers to changes in an object’s characteristics associated with changes in the\n\n\n\n4) 5) 6) 7) database point(s) tied to that object.” However, PHMSA could not determine how a\nsetpoint in the display would be linked to the control valve the setpoint impacted. An\nexample was the flow setpoint associated with Tesoro 12177 34th Street NW would\naffect the control valve V335 on this display. However, the valve (object) was not\nlinked to the flow setpoint on the display.\nThe NuGen Display Guide section 7.1.1, “Color,” utilized incorrect colors for what was\nused in the system, as observed by PHMSA during the inspection, and referenced in\nother sections of the same document and found in the CSC CRM procedures. The\ncolors defined in section 7.1.10, “Alarm Colors,” differed from the colors described\nwithin the same document in section 7.1.1. Further, the colors referenced in the CRM\nprocedures sections 8.4, “Alarm Design,” and 8.5, “Alarm Priority,” conflicted with the\ncolors referenced the NuGen Display Guide section 7.1.1. Clarification is required to\ndescribe whether a loss of communication and a loss of the equipment is displayed\ndifferently than a pink color as referenced in section 7.1.1 versus that of section 7.1.11,\n“Reserved Colors.”\nThe NuGen Display Guide in section 7.1.3, “Dynamic Lines and Symbols,” referenced\nAppendix A, “Symbols.” However, Appendix A did not reference symbols or objects\nthat are being used in displays. Manual valve symbols were not defined, valves in travel\nstatus were not described as to how this would be displayed, tanks needed to be\nincluded, and 2- and 3-way valves should be added. The check valve symbol requires\nupdating as the symbol in the procedures was not the symbol that was being used in the\ndisplays observed during the inspection. Lease Automatic Custody Transfer (LACT)\nunits need to be added. Information provided should reflect what would occur or\nchange on the symbol or object should the element go into alarm or change status (such\nas a pump changing from local to remote, manual to automatic, or Hand to Auto).\nThe NuGen Display Guide, section 8.3.1, “Data States,” needs to be updated to match\nthe data states identified in CSC’s CRM procedure section 8.10.6.3, “Data Quality &\nConfiguration Issues,” and to clarify what color will be used. The information in the\nprocedure did not address how calculated points will be displayed if one of the required\ninputs to the calculation is out of communication or in alarm status. Error coding and\nassociated color also needs to be clarified.\nThe NuGen Display Guide section 9, “Control and Selection Techniques (PHMSA C1-\n9),” did not clearly define what happens when a valve is commanded to a state (such as\nopen or closed) and the state was not achieved in a certain amount of time. The\nprocedure did not clarify what happens and how this would be displayed. Similarly, it\nwas not clear what would be displayed if a valve shows open and closed at the same\ntime. Section 9 also needs further amendment to define each step required to execute a\ncommand (for example, click on the symbol/object, view pop-up menu, identify what is\nselected, and then include what is done to execute the command). Section 9’s error\nmanagement was inadequate as described and should be amended to address other\nelements such as maximum keystrokes, clamped values on setpoint maximums or\nminimums. It was also not clear how valve status and pumps would be shown, such as\n\n\n\n8) 9) 10) 11) open color green with an O, on for pumps with green, or R, along with green, for\nrunning. Additionally, section 9.3, “Error Management,” stated “Errors are logged in\nthe log files stored in predefined locations. If errors are found, they are addressed.”\nHowever, the procedures did not define what is done with the log files nor did it\nidentify where the logs reside (on the share drive, in SCADA, reviewed Monthly, etc.).\nDuring the inspection, PHMSA determined that flatlining is an option within the\nSCADA system. Thus, flatlining should be referenced and identified when it will be\nused and how it will be represented to the controller in procedures.\nThe NuGen Display Guide, section 10.2, “Consistency between control centers and\nremote locations” stated “[t]he redundant systems are monitored monthly to be ready\nfor operation if needed.” During the inspection PHMSA determined that monthly\nmonitoring is no longer practiced. The procedures should be amended to reflect the\nupdated process.\nCSC’s CRM procedures, section 4.5.3, “Consistency,” and the NuGen Display Guide\nsection 3.5, “Consistency Across the Company,” both addressed consistency in a way\nthat was inconsistent. The CRM procedures stated, “Display designs are documented in\nEverline SCADA Functional Technical Specification or the Client’s SCADA standard.\nFor consoles where a Client’s SCADA system is displayed, the control room provides a\ncopy of the SCADA standard at the console for reference, conducts additional training\non the Client’s SCADA standard and provides a summary template identifying key\ndifferences between Everline SCADA Functional Technical Specification and Client’s\nSCADA standard. CSC’s CRM procedures indicated that all SCADA standards\nreferenced in this manual are listed in Exhibit Z. However, Exhibit Z is the “Alarm\nSystem Specifics” and did not contain anything relevant to displays and consistency in\nstandard or practice. Thus, CSC’s CRM procedures require amendment to address this\nissue. Additionally, NuGen Display Guide stated, “Consistency is important from not\nonly a specific coding aspect but also when looking at the system. Ensuring consistency\nacross the entire company and system ensures that personnel can deal with each other\nefficiently and effectively when working on the system whether it is in the same\nlocation or in-between the control center and remote locations. Every attempt has been\nmade to ensure that NuGen’ s SCADA system is as consistent as possible and that all\ndisplays f","truncated":true,"body_characters":112597}