# CALIBER SPRING CREEK LLC — Notice of Amendment

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

Official case documents:

32024017NOA_Closure Letter_05212026_(22-236545).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024017NOA/32024017NOA_Closure%20Letter_05212026_(22-236545).pdf

32024017NOA_Closure Letter_05212026_(22-236545)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024017NOA/32024017NOA_Closure%20Letter_05212026_(22-236545)_text.pdf

32024017NOA_Notice of Amendment_07032024_(22-236545).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024017NOA/32024017NOA_Notice%20of%20Amendment_07032024_(22-236545).pdf

32024017NOA_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

32024017NOA_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

32024017NOA_Closure Letter_05212026_(22-236545)_text.pdf

U.S. Department of Transportation
Pipeline and Hazardous
Materials Safety Administration
1100 Main Street, Suite 800
Kansas City, MO 64105
(816) 329-3800
VIA ELECTRONIC MAIL TO: bkent@calibermidstream.com;
dwerth@calibermidstream.com; cmaybee@calibermidstream.com
May 21, 2026
Mr. Tad True, COO
Caliber Spring Creek, LLC
455 North Poplar Street
Casper, Wyoming 82602
RE: CPF 3-2024-017-NOA
Dear Mr. True:
On April 25 through April 29, May 2 through May 4, and May 9 through May 11, 2022, a
representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant
to Chapter 601 of 49 United States Code (U.S.C.), conducted an inspection of Caliber Spring
Creek, LLC’s (“Caliber”) procedures for Control Room Management (CRM), SCADA, Leak
Detection, and Operations and Maintenance (O&M) relevant to the control room located in
Houston, Texas. On July 3, 2024, pursuant to 49 CFR § 190.206, PHMSA issued a Notice of
Amendment which proposed amendment of Caliber’s procedures.
Caliber submitted its amended procedures on October 18 and November 18, 2024 and provided
supplements on November 21 and December 2, 2025. PHMSA has reviewed the amended
procedures, and it appears that the inadequacies outlined in the 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,
Amy McKean
Director, Central Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Ken Dockweiler, Director Land and Government (ken.dockweiler@truecos.com)
Kevin Pena, Pipeline Compliance Coordinator (kevin.pena@truecos.com)

32024017NOA_Notice of Amendment_07032024_(22-236545)_text.pdf

NOTICE OF AMENDMENT
VIA ELECTRONIC MAIL TO: bkent@calibermidstream.com;
dwerth@calibermidstream.com; cmaybee@calibermidstream.com
July 3, 2024
Bill Kent
Chief Executive Officer
Caliber Midstream Partners, LP
Caliber Spring Creek, LLC
1805 Shea Center Drive, Suite 120
Highlands Ranch, CO 80129
CPF 3-2024-017-NOA
Dear Mr. Kent:
From April 25 through April 29, May 2 through May 4, and May 9 through May 11, 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
Caliber Spring Creek, LLC’s procedures for Control Room Management (CRM), SCADA, Leak
Detection, and Operations and Maintenance (O&M) relevant to the control room located in
Houston, Texas.
Caliber Midstream Partners, LP (Caliber) operates multiple systems: Caliber North Dakota,
Caliber Bear Den Interconnect, and Caliber Spring Creek Pipeline System (CSC). On October
29, 2019, CSC assets were monitored and controlled by a third party control room, NuGen
Automation. On October 1, 2021, NuGen Automation became part of Everline Automation
(Everline). At the time of the inspection, CSC assets were operated by a third-party control room,
Everline. Everline was still using some of the NuGen Automation procedures. Everline’s CRM
procedures apply to CSC.
As a result of the inspection, PHMSA has identified the apparent inadequacies found within
Caliber and CSC’s plans or procedures. The items inspected and the inadequacies are described
below:



1. § 195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a
manual of written procedures for conducting normal operations and maintenance
activities and handling abnormal operations and emergencies. This manual shall be
reviewed at intervals not exceeding 15 months, but at least once each calendar year,
and appropriate changes made as necessary to insure that the manual is effective.
This manual shall be prepared before initial operations of a pipeline system
commence, and appropriate parts shall be kept at locations where operations and
maintenance activities are conducted.
“Caliber Midstream Operations and Maintenance Manual Hazardous Liquids Pipelines” (revised
September 23, 2020) procedure (O&M), section 2A, entitled “Normal Operations and
Maintenance, Caliber Spring Creek Pipeline System,” dated February 20, 2020, was inadequate
as it referenced incorrect control room management procedures and did not adequately describe
the process used by Caliber and CSC to determine which facilities are control rooms, as required
by 49 CFR §§ 195.402 and 195.446(a). Specifically, O&M section 2A.15, entitled
“Communications and Control System,” stated, “The Caliber Spring Creek System’s Control
Room Management program is operated by NuGen Automation. A full copy of NuGen CRM
program has been made readily available. Please see Control Center-SOP-CRM. (NGA-CNTL-
SOP-0001).” However, at the time of the inspection, the CRM procedures presented by Caliber
as the relevant operating procedures for the third-party control room was “Everline CRM
Pipeline Control Room Management” (CSC CRM), version 15, dated May 20, 2016. Caliber’s
O&M procedure section 2A.15 specific to CSC requires amendment to address the correct CRM
procedure currently used for operations and it must be properly integrated as required.
Additionally, during the inspection, when Caliber was asked how a control room was
determined, Caliber referenced section 1.3 of CSC’s CRM procedures. However, this section of
the procedure was inadequate as it did not describe the process used by Caliber and CSC to
identify control rooms; rather it described the process used by Everline to define a control room.
Further, this section only applied to the CSC assets authorized for Everline to operate. Caliber’s
procedures require amendment to clarify the process used by Caliber on any assets to identify a
control room (including those used by CSC).
During the inspection, PHMSA reviewed Caliber’s O&M procedure section 4.5.4, entitled
“Suspected Leaks,” and this section referenced SOP 1001-2002 entitled “Crude Oil System
Operating Procedures.” PHMSA requested this procedure (RI #11) and Caliber responded, “This
SOP does not exist in the Caliber system.” Caliber’s O&M procedures require amendment to
clarify what will be done for suspected leaks and reference the correct shutdown procedures. The
incorrect procedure referenced requires removal.
For these reasons, Caliber and CSC's O&M procedures were not adequate and require
amendment, per § 195.402 and § 195.446(a).



2. § 195.408 Communications.
(a) . . . .
(b) The communication system required by paragraph (a) of this section must, as a
minimum, include means for:
(1) . . . .
(3) Conducting two-way vocal communication between a control center and the
scene of abnormal operations and emergencies; and
Caliber’s O&M procedure section 4, entitled “Emergency Procedures,” did not adequately
address communications between a control center and the scene of abnormal operations and
emergencies as required by § 195.408(b)(3).
Throughout sections 4.4 through 4.9 (entitled “Receiving, Identifying, Classifying Notices,”
“Vapor Detected Inside or Near a Building,” “Natural Disasters,” “Extreme Weather and Natural
Disasters,” “Fire and Explosion,” and “Extortion Threats”), the communication with the control
room is only referenced once, in section 4.6.2, entitled “Wildfires.” Section 4.6.2 stated, “If a
wildfire is observed by Caliber personnel in an open field, forest, or other area it should
be immediately reported to the control room….” This is the only section that required
communication with the control room; however, the control room would need to be made aware
of any of the conditions described in sections 4.4 through 4.9.
Even within section 4.6.2, the control room communication was not properly addressed. Section
4.6.2 included two conditions that do not require contacting the control room yet clearly could
impact the control room. Thus communication should be required. First, the procedure did not
require contacting the control room in a situation where a wildfire is near or approaching an
above ground valve station, despite the fact that the above ground valve station can impact valve
position or valve controls on the pipeline. Second, the procedure did not require contacting the
control room in a situation when a fire is reported by a third party. This would also be significant
to communicate to the control room.
The procedure did not adequately address communication with the control room in multiple
other sections. Sections 4.15, entitled “Alerting and Notification Procedure,” 4.2.1, entitled
“Readiness,” 4.2.2, entitled “Availability of Resources,” 4.3.3, entitled “Containment,” 4.3.4,
entitled “Protection of Public,” 4.10.2, entitled “Operations Manager or Designee,” and 4.14.1,
entitled “Media Relations,” all referenced completing notification as described in Section 4A.14.
However, nothing in section 4A.14 required communication with the control room.
The Emergency Procedures referenced oil response or oil spill response procedures in sections
4.2.3, entitled “Organization Basics,” 5.4.5, entitled “Spill Control Training,” and 5.4.6, entitled
“Emergency Prevention Training;” however none of these sections referenced communication
with the control room.
The Emergency Procedures also addressed oil spill response and Federal Response Plan (FRP)
relevant to Part 194 (located in sections 4.2.1 “Readiness,” 4.5.3, “Duties & Requirements,”
4.3.5, “Reviews,” and 5.4.1 “Emergency Response Drill /Tabletop”) but again, nothing



3. referenced communication with the control room. Additionally, nothing in the CSC’s CRM
procedures addressed aspects of FRP plans and Part 194 for CSC.
For these reasons, the Emergency Procedures relevant to all Caliber pipeline systems (applicable
also to CSC) require amendment to identify a process for communication with any control room,
including a third-party control room, to comply with § 195.408(b)(3).
§ 195.446 Control room management.
(a) General. 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. . . .
(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's prompt and appropriate response to
operating conditions, an operator must define each of the following:
(1) A controller's authority and responsibility to make decisions and take actions
during normal operations;
CSC’s CRM procedures did not adequately define a controller’s authority and responsibilities to
make decisions and take actions during normal operations, as required by § 195.446(b)(1). This
control room monitors and controls multiple operators’ assets in addition to CSC. At the time of
the inspection, the control room had 10 consoles that were manned by individual controllers, and
2 supervisors located in the control room. Console 8 has CSC assets but this control room cross-
trained controllers for console 7 and console 8. During the inspection, Caliber and the control
room personnel communicated to PHMSA inspectors that all controllers can access any console
if they have log-in privileges to the SCADA system, including those assets on consoles for which
the controllers are not qualified. Any person with SCADA log-in access could execute
commands on other assets. Further, more than one controller could access a given pipeline
system at the same time (such as CSC). Nothing prevented command actions for the same asset
from being executed by multiple controllers on different consoles. The procedures did not clarify
which controller is to make decisions and take actions on the CSC system at any given time.
CSC’s CRM procedure Exhibit B, entitled “Domain of Responsibility Table,” indicated that
Watford PMP101 and PMP102 pumps are commanded by a controller; however, the indications
on the display did not allow for commanding these pumps. PHMSA was verbally told during the
inspection that these pumps were not commanded as indicated in Exhibit B.
Additionally, CSC’s CRM procedures included inaccurate titles of control room personnel. For
example, at the time of inspection, “Lead Controllers” were referred to as “Control Room
Supervisors.” Amendment is required so that each employee knows their roles and
responsibilities as stated in the procedures without confusion.
Further, during the inspection it was confirmed with Caliber personnel that the control room did



4. 5. not receive 811 calls during or after normal work hours. CSC CRM procedures in section 3.4,
entitled “Controller Responsibility,” Item 14 in the “Controller-Normal Operations” table
indicated the control room does address 811 calls. CSC CRM procedure requires amendment
specific to 811 calls for CSC assets.
For these reasons, Caliber and CSC’s procedures were inadequate to define a controller’s
authority and responsibilities during normal operations as required by § 195.446(b)(1).
§ 195.446 Control room management.
(a) General. 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. . . .
(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's prompt and appropriate response to
operating conditions, an operator must define each of the following:
(1) . . . .
(2) A controller's role when an abnormal operating condition is detected, even if the
controller is not the first to detect the condition, including the controller's
responsibility to take specific actions and to communicate with others;
CSC’s CRM procedures were inadequate to define a controller’s roles and responsibilities during
abnormal operations per § 195.445(b)(2). The control room does not receive 811 calls. The CRM
procedure section 3.4, entitled “Controller Responsibility,” Item 9 in the “Controller - Abnormal
Operations/Abnormal Operating Conditions” table requires amendment to clarify that 811 calls
are not addressed for CSC assets by the control room during abnormal operations/abnormal
operating conditions.
CSC’s CRM procedures were inadequate to define a controller’s authority and responsibilities
during abnormal operations as required by § 195.446(b)(2).
§ 195.446 Control room management.
(a) General. 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. . . .
(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's prompt and appropriate response to
operating conditions, an operator must define each of the following:
(1) . . . .



6. (3) A controller's role during an emergency, even if the controller is not the first to
detect the emergency, including the controller's responsibility to take specific
actions and to communicate with others;
Caliber’s O&M and CSC’s CRM procedures were inadequate to define a controller’s role during
an emergency, even if the controller is not the first to detect the emergency, including the
controller's responsibility to take specific actions and to communicate with others, per
§ 195.446(b)(3). Specifically, the CSC’s CRM procedures had multiple inconsistencies when
defining a controller’s role and responsibility during an emergency. CRM procedure section 1.8
referenced a document entitled “Everline’s Emergency Evacuation Procedure,” but that
document did not exist. Also, CRM procedure section 4.9.3, entitled “Unplanned Evacuations
(e.g. bomb threat, fire threat),” in Item C referenced “mobile go kits” that are no longer used
during emergencies, as confirmed by control room personnel during the PHMSA inspection.
Additionally, CRM procedure, section 3.4, entitled “Controller Responsibility,” Item 6
“Controller – Emergency Operations” table did not incorporate or provide reference to the
appropriate Internal Communication Plan. If an evacuation occurs of the control room, the
Internal Communication Plan may be implemented until the back-up center is up and running
with controllers present or until the specific situation that caused the evacuation is resolved.
Thus, reference to the Internal Communication Plan is necessary.
Further, CRM procedure section 4.9.1 did not identify whether 800 calls would be received for
CSC. During the inspection, PHMSA asked how 800 calls were handled for Caliber, and CSC,
and conflicting answers were provided by Caliber, CSC, and the control room. As a result, this
needs to be clarified in procedures. This was not presented in the O&M procedures as to how this
was integrated with the control room.
Caliber’s O&M and CSC’s CRM procedures require amendment to adequately define a
controller’s role during an emergency, even if the controller is not the first to detect the
emergency, including the controller's responsibility to take specific actions and to communicate
with others, per § 195.446(b)(3).
§ 195.446 Control room management.
(a) General. 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. . . .
(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's prompt and appropriate response to
operating conditions, an operator must define each of the following:
(1) . . . .
(4) A method of recording controller shift-changes and any hand-over of
responsibility between controllers; and. . . .



CSC’s CRM procedures were inadequate to define a method of recording shift-changes and any
hand-over of responsibility between controllers, per § 195.446(b)(4) and § 195.446(c)(5), which
requires the operator to implement section 5 of API RP 1168 (First Edition, September of 2008)
to establish procedures for when a different controller assumes responsibility, including the
content of information to be exchanged. During the inspection, CSC and control room personnel
explained that the Shift Turnover process had moved from the “Shift Turnover Checklist,” Form
11-1 (this was referenced in CSC’s CRM procedures, sections 3, entitled “Responsibility,” and 5,
entitled “Shift Turnover”) to an electronic form known as Elogger. However, the Elogger and the
Shift Turnover Checklist were not the same, so the CRM procedures require revision in order to
confirm what information is to be exchanged between controllers. Additionally, when changing
the shift turnover form to the Elogger, the CSC CRM procedure section 5, entitled “Shift
Turnover,” did not include step-by-step instructions for populating the form nor did it clarify that
the “Yes/NA” data field will be blank at the start of each shift change, and comments must be
added for each element when completing the shift change as explained by the operator during the
inspection.
CSC’s CRM procedures did not require controllers to log off the SCADA system when leaving
the console. However, this was clearly communicated during the inspection as an expectation by
control room representatives, and older shift turnover documentation from 2021 had this step
identified as an instruction rather than a requirement. CSC’s CRM procedures in sections 3 and 5
did not describe this required action. Shift Turnover documentation from 2022 also did not
include this instruction.
During the inspection, PHMSA determined that manual tracking sheets were populated for
operational changes made during the shift. CSC’s CRM procedures did not address this
documentation. CSC’s CRM procedures require amendment to include any manual sheets that
are populated as part of the shift turnover process and associated records.
Caliber’s O&M and CSC’s CRM procedures did not include how volume movements and any
imbalances will be monitored and communicated to controllers as part of the shift change
process. PHMSA determined during the inspection that Caliber provided a summary of all
meters in and out of the system to the control room daily to assist with imbalance tracking on the
CSC system. Caliber’s O&M procedures and CSC’s CRM procedures did not define how a
controller received the operations schedule (shipping or movement requirements) or imbalance
information on a daily basis, however all of this information would need to be included as part of
the Shift change documentation. This information is required for a controller to perform normal
pipeline operations and to assist with abnormal operations detection. It was not clear if Caliber or
CSC provides the information by email to a control room manager or supervisor for distribution
to controllers, if controllers receive this information directly, or if the SCADA system
automatically receives this information. CSC’s CRM procedures did not define whether any of
the operations scheduling values require manual entry by a controller.
CSC’s CRM procedure section 3 did not address an emergency where the controller is
incapacitated and does not plan to leave the console. Similarly, CSC’s CRM procedure did not
address if anyone can log off of the console for someone else (such as would be required should
a controller not be able to log off the system). As such, the procedures need to be amended to
include what actions will be required of the operator.



7. CSC’s CRM procedure section 3.3, “Impromptu Change in Responsibility,” did not clearly
define the role and responsibilities of a controller when planning to leave the console for less
than 30 minutes. The procedure should clarify that the controller must confirm before leaving the
control room that the individual answering the phones has the controller’s correct contact
information as part of the process for handover. Section 3.3 did not clarify if the individual
assigned to answer the phone must have qualification to the console being vacated for 30
minutes. Moreover, section 3.3 did not address how the individual answering the phones will
also be responsible for confirming that no other controller or person in the control room activates
commands or makes keyboard actions while the qualified and scheduled controller has stepped
away. Section 3.3 did not adequately define what would be required for a shift turnover if a
controller has left the console for more than 30 minutes. An adequate procedure would include
how the incoming controller would handle logging off for the previously scheduled controller.
For these reasons, Caliber’s O&M and CSC’s CRM procedures were inadequate for shift
turnover when a different controller assumes responsibility, for implementing section 5 of API
RP 1168, in identifying the content of information to be exchanged, for clarifying actions to be
taken by the operator or controller, and in defining a method of recording shift-changes and any
hand-over of responsibility between controllers as required by § 195.446(b)(4) and §
195.446(c)(5).
§ 195.446 Control room management.
(a) General. 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. . . .
(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'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 who have the authority to
direct or supersede the specific technical actions of controllers.
Caliber’s O&M and CSC’s CRM procedures were not adequate to define the roles,
responsibilities, and qualifications of others who have the authority to direct or supersede the
specific technical actions of controllers as required by § 195.446(b)(5). The CRM procedures
require amendment to adequately address direct and supersede in section 3 and to adequately
cover how restarts are achieved after a potential release. CRM procedure section 3 indicated that
only the lead controller can direct or supersede a controller action if they are qualified as a
controller to the specific console. Section 3 also noted that a record of Lead Controllers with this
ability will be listed in the “Domain of Responsibility Table” (located in CSC’s CRM procedure
Exhibit B). However, Exhibit B’s “Domain of Responsibility Table” did not address directing
the controller’s actions. Also Exhibit B included names of individuals that were no longer
qualified controllers on Console 8. Exhibit B requires amendment to correctly identify who can
direct and supersede, not just supersede, controllers’ actions.



Additionally, CSC’s CRM procedure in section 3.1, “Authority and Responsibility,” stated
“Authority to restart a pipeline that has been shut down due to a potential release should follow
the Asset Specific O&M Manuals or Emergency Response Procedures (ERP) Manuals.”
However, Caliber’s O&M and ERP Manuals did not indicate who would approve a restart
beyond O&M sections 3.4, “Maintaining Design Limits,” and 4.6.2, “Wildfires.” This did not
adequately address who from Caliber or the control room would approve a restart and if
communication with the Lead Controller would be required so that a controller could be directed
to restart the pipeline. At the time of the inspection, when discussing this with Caliber and
control room personnel, it was not clear if any employee from Caliber (including any specific
field personnel) would provide approval for a restart or how the Lead Controller would be made
aware of this information.
Caliber’s O&M and CSC’s CRM procedures require amendment to adequately define the roles,
responsibilities, and qualifications of others who have the authority to direct or supersede the
specific technical actions of controllers per § 195.446(b)(5).
8. § 195.446 Control room management.
(a) General. 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. . . .
(b) . . . .
(c) Provide adequate information. Each operator must provide its controllers with
the information, tools, processes and procedures necessary for the controllers to
carry out the roles and responsibilities the operator has defined by performing each
of the following:
(1) Implement API RP 1165 (incorporated by reference, see § 195.3) whenever a
SCADA system is added, expanded or replaced, unless the operator demonstrates
that certain provisions of API RP 1165 are not practical for the SCADA system
used;
CSC’s CRM procedures were not adequate to determine when implementing API RP 1165
would be required, as per § 195.446(c)(1). Specifically, CSC’s CRM procedures and referenced
procedures (such as the Everline SCADA Functional Technical Specification) did not define a
SCADA system addition, expansion, or replacement. The CRM procedures were not clear on
whether API RP 1165 would be implemented when hardware or software (such as server
architecture changes, console additions, software and hardware revisions including upgrades,
assets being added or moved, a separate SCADA system being added to this control room or a
SCADA system change) changes were made to the SCADA system.
CSC’s CRM procedures referenced API RP 1165 in various ways (for example the procedures
did state “1165,” “recommended practice RP 1165,” etc. in sections 1.8, “Reference
Documents,” 1.10, “Definitions,” 2.4, “Record Keeping,” 3.8, “SCADA/IT/Network



Operations,” 4.5, “Pipeline SCADA Displays and API RP-1165,” and in Form 11-17, “Pipeline
SCADA Displays 1165 Checklist.”). CSC’s CRM section 4.5, “Pipeline SCADA Displays and
API RP-1165,” stated “[t]he requirements shall be waived if it is demonstrated that the API RP-
1165 requirements are not practical to implement. This may be demonstrated by a description, in
memorandum or other form, of why API RP-1165 is not appropriate for a given system change.”
However, “Not appropriate” is not equivalent to “not being practical” for implementation and the
language requires revision.
CSC’s CRM procedure referenced the SCADA Functional Technical Specification; the CRM
procedure did not reference the NuGen Display Guide. At the time of the inspection, PHMSA
requested a copy of the SCADA Functional Technical Specification, but the document provided
to PHMSA as a result of this request was titled “NuGen OCC Display Standard” (referred to
below as NuGen Display Guide). CSC’s CRM procedure and SCADA Functional Technical
Specification (called the “NuGen Display Guide” during the inspection) were inadequate and
require the following amendments:
1) The NuGen Display Guide, section 4.0, “Display Hardware,” needs to be updated to
include the primary and backup center locations (as different configurations were
identified for these locations: 12 monitors per console in the primary control room, 9
monitors per console in the back up location, 8 monitors were listed in the NuGen
Display Guide, CRM 4.5.2 referenced 10-14 monitors depending on workload).
2) The NuGen Display Guide, section 5.0, “Display Layout and Organization (PHMSA
c1-5),” requires multiple amendments. Subsection 5.1, “General Design
Considerations,” was not clear that section 2, “General Considerations (PHMSA C1-
3),” of the Nugen Display Guide was relevant, not section 2 of API RP1165, entitled
“References.” Section 5.1 should also reference section 3 in this same document,
entitled “Human Factors Engineering (PHMSA C1-4),” and it did not. Subsection 5.2,
“Display Hierarchy,” was not clear regarding API RP1165 applicability and needs to be
changed to start with Level 1 and work through Level 4. Section 5.3, “Window
Management,” referenced screen savers however at the time of the inspection screen
savers were disabled for CSC. Additionally, this same section did not address the
number of windows being open at one time as limited to 100 (the control room
personnel indicated this verbally during the inspection, but this was not clarified in
specifications or procedures). During the inspection, PHMSA observed that Object
Menus and other display features had various permission levels for access (such as
SCADA versus that for the controller), but this was not described at any location in the
procedures or specifications and would impact various sections such as section 5.3.2,
“Toolbars.” It was not clear for each of the menu drop down options what controllers
would be allowed to access.
3) The NuGen Display Guide, section 7.0, “Object Characteristics (PHMSA C1-7),” was
not clear on how it is employed. Procedures should be clarified on how flow setpoints
(or pressure setpoints) would be linked in the display to the corresponding control
valve. API RP 1165 states in section 9, entitled “Object Dynamics,” that “Object
dynamics refers to changes in an object’s characteristics associated with changes in the



4) 5) 6) 7) database point(s) tied to that object.” However, PHMSA could not determine how a
setpoint in the display would be linked to the control valve the setpoint impacted. An
example was the flow setpoint associated with Tesoro 12177 34th Street NW would
affect the control valve V335 on this display. However, the valve (object) was not
linked to the flow setpoint on the display.
The NuGen Display Guide section 7.1.1, “Color,” utilized incorrect colors for what was
used in the system, as observed by PHMSA during the inspection, and referenced in
other sections of the same document and found in the CSC CRM procedures. The
colors defined in section 7.1.10, “Alarm Colors,” differed from the colors described
within the same document in section 7.1.1. Further, the colors referenced in the CRM
procedures sections 8.4, “Alarm Design,” and 8.5, “Alarm Priority,” conflicted with the
colors referenced the NuGen Display Guide section 7.1.1. Clarification is required to
describe whether a loss of communication and a loss of the equipment is displayed
differently than a pink color as referenced in section 7.1.1 versus that of section 7.1.11,
“Reserved Colors.”
The NuGen Display Guide in section 7.1.3, “Dynamic Lines and Symbols,” referenced
Appendix A, “Symbols.” However, Appendix A did not reference symbols or objects
that are being used in displays. Manual valve symbols were not defined, valves in travel
status were not described as to how this would be displayed, tanks needed to be
included, and 2- and 3-way valves should be added. The check valve symbol requires
updating as the symbol in the procedures was not the symbol that was being used in the
displays observed during the inspection. Lease Automatic Custody Transfer (LACT)
units need to be added. Information provided should reflect what would occur or
change on the symbol or object should the element go into alarm or change status (such
as a pump changing from local to remote, manual to automatic, or Hand to Auto).
The NuGen Display Guide, section 8.3.1, “Data States,” needs to be updated to match
the data states identified in CSC’s CRM procedure section 8.10.6.3, “Data Quality &
Configuration Issues,” and to clarify what color will be used. The information in the
procedure did not address how calculated points will be displayed if one of the required
inputs to the calculation is out of communication or in alarm status. Error coding and
associated color also needs to be clarified.
The NuGen Display Guide section 9, “Control and Selection Techniques (PHMSA C1-
9),” did not clearly define what happens when a valve is commanded to a state (such as
open or closed) and the state was not achieved in a certain amount of time. The
procedure did not clarify what happens and how this would be displayed. Similarly, it
was not clear what would be displayed if a valve shows open and closed at the same
time. Section 9 also needs further amendment to define each step required to execute a
command (for example, click on the symbol/object, view pop-up menu, identify what is
selected, and then include what is done to execute the command). Section 9’s error
management was inadequate as described and should be amended to address other
elements such as maximum keystrokes, clamped values on setpoint maximums or
minimums. It was also not clear how valve status and pumps would be shown, such as



8) 9) 10) 11) open color green with an O, on for pumps with green, or R, along with green, for
running. Additionally, section 9.3, “Error Management,” stated “Errors are logged in
the log files stored in predefined locations. If errors are found, they are addressed.”
However, the procedures did not define what is done with the log files nor did it
identify where the logs reside (on the share drive, in SCADA, reviewed Monthly, etc.).
During the inspection, PHMSA determined that flatlining is an option within the
SCADA system. Thus, flatlining should be referenced and identified when it will be
used and how it will be represented to the controller in procedures.
The NuGen Display Guide, section 10.2, “Consistency between control centers and
remote locations” stated “[t]he redundant systems are monitored monthly to be ready
for operation if needed.” During the inspection PHMSA determined that monthly
monitoring is no longer practiced. The procedures should be amended to reflect the
updated process.
CSC’s CRM procedures, section 4.5.3, “Consistency,” and the NuGen Display Guide
section 3.5, “Consistency Across the Company,” both addressed consistency in a way
that was inconsistent. The CRM procedures stated, “Display designs are documented in
Everline SCADA Functional Technical Specification or the Client’s SCADA standard.
For consoles where a Client’s SCADA system is displayed, the control room provides a
copy of the SCADA standard at the console for reference, conducts additional training
on the Client’s SCADA standard and provides a summary template identifying key
differences between Everline SCADA Functional Technical Specification and Client’s
SCADA standard. CSC’s CRM procedures indicated that all SCADA standards
referenced in this manual are listed in Exhibit Z. However, Exhibit Z is the “Alarm
System Specifics” and did not contain anything relevant to displays and consistency in
standard or practice. Thus, CSC’s CRM procedures require amendment to address this
issue. Additionally, NuGen Display Guide stated, “Consistency is important from not
only a specific coding aspect but also when looking at the system. Ensuring consistency
across the entire company and system ensures that personnel can deal with each other
efficiently and effectively when working on the system whether it is in the same
location or in-between the control center and remote locations. Every attempt has been
made to ensure that NuGen’ s SCADA system is as consistent as possible and that all
displays f
- **truncated:** true
- **body characters:** 112597