# NGL CRUDE TERMINALS — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 32024022NOPV
- **title:** NGL CRUDE TERMINALS — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2024-05-08
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 195.446(a), 195.446(c)(1), 195.446(c)(4), 195.446(e)(1), 195.446(e)(2).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-32024022nopv.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-32024022nopv.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-32024022nopv
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/32024022NOPV
**body:**

Notice of Probable Violation involving NGL CRUDE TERMINALS. PHMSA's enforcement data identifies the cited regulations as 195.446(a),  195.446(c)(1),  195.446(c)(4),  195.446(e)(1),  195.446(e)(2). The case was opened on 2024-05-08 and is reported as closed as of 2025-09-03. Proposed civil penalty: $21,200. Assessed civil penalty: $21,200. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

32024022NOPV_Closure Letter_09032025_(23-268060).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024022NOPV/32024022NOPV_Closure%20Letter_09032025_(23-268060).pdf

32024022NOPV_Closure Letter_09032025_(23-268060)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024022NOPV/32024022NOPV_Closure%20Letter_09032025_(23-268060)_text.pdf

32024022NOPV_Final Order_08132025_(23-268060).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024022NOPV/32024022NOPV_Final%20Order_08132025_(23-268060).pdf

32024022NOPV_Final Order_08132025_(23-268060)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024022NOPV/32024022NOPV_Final%20Order_08132025_(23-268060)_text.pdf

32024022NOPV_Operator Response to Notice and Request for Time Extension_06042024_(23-268060).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024022NOPV/32024022NOPV_Operator%20Response%20to%20Notice%20and%20Request%20for%20Time%20Extension_06042024_(23-268060).pdf

32024022NOPV_PCP PCO_05082024_(23-268060).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024022NOPV/32024022NOPV_PCP%20PCO_05082024_(23-268060).pdf

32024022NOPV_PCP PCO_05082024_(23-268060)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024022NOPV/32024022NOPV_PCP%20PCO_05082024_(23-268060)_text.pdf

32024022NOPV_Final Order_08132025_(23-268060)_text.pdf

August 13, 2025
VIA ELECTRONIC MAIL TO: jeff.pinter@nglep.com
Jeff Pinter
President and CEO
NGL Supply Terminal Company, LLC
6120 South Yale Avenue, Suite 1300
Tulsa, OK 74136
Re: CPF No. 3-2024-022-NOPV
Dear Mr. Pinter:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation, assesses a civil penalty of $21,200, and specifies actions that need to be taken by NGL
Supply Terminal Company, LLC to comply with the pipeline safety regulations. The penalty
payment terms are set forth in the Final Order. When the civil penalty has been paid and the
terms of the compliance order completed, as determined by the Director, Central Region, this
enforcement action will be closed. Service of the Final Order by e-mail is effective upon the
date of transmission and acknowledgement of receipt as provided under 49 CFR § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Linda Daugherty
Acting Associate Administrator
for Pipeline Safety
Enclosures (Final Order and NOPV)
cc: Mr. David Barrett, Acting Director, Central Region, Office of Pipeline Safety, PHMSA,
Office of Pipeline Safety



CPF No. 3-2024-022-NOPV
Page 2
Mr. Eric S. Coleman, Director of Operations, Compliance, NGL Energy Partners, LP,
eric.coleman@nglep.com
CONFIRMATION OF RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
In the Matter of )
NGL Supply Terminal Company, LLC, )
a subsidiary of NGL Energy Partners, LP,) Respondent. )
)
)
)
)
CPF No. 3-2024-022-NOPV
FINAL ORDER
From June 5 to June 9, 2023, pursuant to 49 U.S.C. § 60117, a representative of the Pipeline and
Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), virtually
inspected NGL Supply Terminal Company, LLC’s (NGL) control room management procedures
in Cushing, Oklahoma. NGL Supply Terminal Company, LLC is a subsidiary of NGL Energy
Partners, LP, a publicly traded midstream organization that provides multiple services to
producers and end-users, including transportation, storage, blending and marketing of crude oil,
natural gas liquids, refined products/renewables, and water solutions.
1 NGL Supply Terminal
Company, LLC operates the Ambassador Pipeline, an eight-inch 225-mile anhydrous ammonia
pipeline that spans from Kalkaska, Michigan to Marysville, Michigan.
As a result of the inspection, the Director, Central Region, OPS (Director), issued to Respondent,
by letter dated May 8, 2024, a Notice of Probable Violation, Proposed Civil Penalty, and
Proposed Compliance Order (Notice). In accordance with 49 CFR § 190.207, the Notice
proposed finding that NGL had committed three violations of 49 CFR Part 195, proposed
assessing a civil penalty of $21,200 for the alleged violations, and proposed ordering Respondent
to take certain measures to correct the alleged violations. The Notice also included an additional
warning item pursuant to 49 CFR § 190.205, which warned Respondent to correct the probable
violation or face possible future enforcement action.
NGL responded to the Notice by letter dated June 4, 2024 (Response). Respondent did not
contest the allegations of violation but provided an explanation of its actions and requested that
the proposed civil penalty be reduced or eliminated. Respondent also requested additional time
to complete the proposed corrective actions. Respondent did not request a hearing and therefore
has waived its right to one.
1 NGL Energy Partners LP, “Who We Are,” https://www.nglenergypartners.com/about-ngl/ (last visited March 19,
2025).



FINDINGS OF VIOLATION
In its Response, NGL did not contest the allegations in the Notice that it violated 49 CFR Part
195, as follows:
Item 1: The Notice alleged that Respondent violated 49 CFR § 195.446(c)(1), which states:
§ 195.446 Control room management.
(a) . . . .
(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;
The Notice alleged that Respondent violated 49 CFR § 195.446(c)(1) by failing to implement
API RP 1165 whenever a SCADA system is added, expanded or replaced. Specifically, the
Notice alleged that NGL failed to implement API RP 1165 when it added the 225-mile Michigan
Ambassador Pipeline to its SCADA system in September 2022.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
the evidence, I find that Respondent violated 49 CFR § 195.446(c)(1) by failing to implement
API RP 1165 whenever a SCADA system is added, expanded or replaced.
Item 3: The Notice alleged that Respondent violated 49 CFR § 195.446(e)(1), which states:
§ 195.446 Control room management.
(a) . . . .
(e) Alarm management. Each operator using a SCADA system must
have a written alarm management plan to provide for effective controller
response to alarms. An operator’s plan must include provisions to:
(1) Review SCADA safety-related alarm operations using a process that
ensures alarms are accurate and support safe pipeline operations;
The Notice alleged that Respondent violated 49 CFR § 195.446(e)(1) by failing to review
SCADA safety-related alarm operations using a process that ensures alarms are accurate and
support safe pipeline operations. Specifically, the Notice alleged that NGL failed to consider
three types of alarms as safety-related and critical (rate of change, mass balance, and
communication alarms) and failed to identify alarms according to its alarm priorities table in its
control room management plan.



Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
the evidence, I find that Respondent violated 49 CFR § 195.446(e)(1) by failing to review
SCADA safety-related alarm operations using a process that ensures alarms are accurate and
support safe pipeline operations.
Item 4: The Notice alleged that Respondent violated 49 CFR § 195.446(e)(2), which states:
§ 195.446 Control room management.
(a) . . . .
(e) Alarm management. Each operator using a SCADA system must
have a written alarm management plan to provide for effective controller
response to alarms. An operator’s plan must include provisions to:
(1) . . . .
(2) Identify at least once each calendar month points affecting safety
that have been taken off scan in the SCADA host, have had alarms inhibited,
generated false alarms, or that have had forced or manual values for periods
of time exceeding that required for associated maintenance or operating
activities;
The Notice alleged that Respondent violated 49 CFR § 195.446(e)(2) by failing to identify at
least once each calendar month points affecting safety that have been taken off scan in the
SCADA host, have had alarms inhibited, generated false alarms, or that have had forced or
manual values for periods of time exceeding that required for associated maintenance or
operating activities. Specifically, the Notice alleged that NGL failed to have sufficient
procedures implementing section 195.446(e)(2) and failed to provide records that indicated it
conducted the required monthly review.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 CFR § 195.446(e)(2) by failing to identify at
least once each calendar month points affecting safety that have been taken off scan in the
SCADA host, have had alarms inhibited, generated false alarms, or that have had forced or
manual values for periods of time exceeding that required for associated maintenance or
operating activities.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
ASSESSMENT OF PENALTY
Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed
$200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any



related series of violations.
2
In determining the amount of a civil penalty under 49 U.S.C. § 60122 and 49 CFR § 190.225, I
must consider the following criteria: the nature, circumstances, and gravity of the violation,
including adverse impact on the environment; the degree of Respondent’s culpability; the history
of Respondent’s prior offenses; any effect that the penalty may have on its ability to continue
doing business; the good faith of Respondent in attempting to comply with the pipeline safety
regulations; and self-disclosure or actions to correct a violation prior to discovery by PHMSA.
In addition, I may consider the economic benefit gained from the violation without any reduction
because of subsequent damages, and such other matters as justice may require. The Notice
proposed a total civil penalty of $21,200 for the violation cited above. Effective May 20, 2025,
PHMSA revised its proposed civil penalty calculation policy to use the version of the Civil
Penalty Worksheet in effect when the alleged violation occurred. The new policy did not change
the proposed civil penalty in this case.
Item 4: The Notice proposed a civil penalty of $21,200 for Respondent’s violation of 49 CFR
§ 195.446(e)(2), for failing to identify at least once each calendar month points affecting safety
that have been taken off scan in the SCADA host, have had alarms inhibited, generated false
alarms, or that have had forced or manual values for periods of time exceeding that required for
associated maintenance or operating activities. The new policy for calculating a proposed civil
penalty did not change the proposed civil penalty for this item. NGL contended that the
proposed penalty should be reduced or withdrawn for three reasons. First, NGL stated it had no
reason to believe its monthly reviews were not sufficient because this issue was not identified by
three recent state inspections (in 2018, 2020, and 2023). Second, NGL contended it was
following its existing procedure for monthly reviews but was unaware its procedure was not
sufficient, and had NGL been aware, the duration of the violation would have different. Third,
NGL stated that it began to implement corrective action before receiving the Notice.
Turning to the assessment factors, I note that with respect to the nature of the violation, OPS
selected that this was an “activities” violation as reflected in the Violation Report. An
“activities” violation may be a failure to perform or conduct activities. I find that the record
supports this selection because NGL failed to conduct all required activities (the monthly alarm
review).
With respect to the circumstances of the violation, I note that NGL did not self-report the non-
compliance. Therefore, OPS appropriately selected that “PHMSA or a State Partner discovered
the violation” in the Violation Report. With respect to the duration of the violation, OPS alleged
that the violation occurred for “10 days or more.” While NGL claimed that the duration could
have been different if the non-compliance was identified during one of the recent state
inspections, it did not otherwise dispute that this violation occurred for 10 days or more.
With respect to the gravity of the violation, OPS selected the lowest possible criteria for gravity
(“Pipeline safety was minimally affected, notwithstanding the conditions above.”). The evidence
supports this selection. Therefore, there is no basis to reduce the penalty. The Violation Report
noted three instances of the violation and the evidence supports this selection. NGL did not
contest the number of instances of violation.
2 These amounts are adjusted annually for inflation. See 49 CFR § 190.223 for adjusted amounts.



With respect to Respondent’s culpability, OPS alleged that NGL “failed to comply with an
applicable requirement.” OPS did not allege that NGL intentionally violated the pipeline safety
regulations. Therefore, NGL’s belief or intent (resulting from recent state inspections or
otherwise) did not impact this civil penalty calculation. Moreover, NGL is not entitled to a
penalty reduction for its corrective actions because they were not performed prior to PHMSA’s
discovery of the violations. Corrective action taken after PHMSA learns of the violation is not a
basis to reduce a civil penalty.
3 I find that the record supports the culpability selection because
NGL failed to conduct the requisite monthly alarm reviews.
As to good faith, NGL presented no circumstances beyond its control that would have prevented
it from complying. As to history of prior offenses, the Violation Report noted that Respondent
did not have any prior offenses; therefore, this was already factored into the proposed penalty
amount. Lastly, Respondent did not claim the penalty would affect its ability to continue in
business.
For the above reasons, after considering the arguments provided to reduce the proposed penalty,
I find NGL’s arguments unpersuasive. Accordingly, having reviewed the record and considered
the assessment criteria, I assess Respondent a civil penalty of $21,200 for violation of 49 CFR
§ 195.446(e)(2).
Payment of the civil penalty must be made within 20 days after receipt of this Final Order.
Federal regulations (49 CFR § 89.21(b)(3)) require such payment to be made by wire transfer
through the Federal Reserve Communications System (Fedwire), to the account of the U.S.
Treasury. Detailed instructions are contained in the enclosure. Questions concerning wire
transfers should be directed to: Financial Operations Division (AMK-325), Federal Aviation
Administration, Mike Monroney Aeronautical Center, 6500 S MacArthur Blvd, Oklahoma City,
Oklahoma 79169. The Financial Operations Division telephone number is (405) 954-8845.
Failure to pay the civil penalty will result in accrual of interest at the current annual rate in
accordance with 31 U.S.C. § 3717, 31 CFR § 901.9 and 49 CFR § 89.23. Pursuant to those
same authorities, a late penalty charge of six percent (6%) per annum will be charged if payment
is not made within 110 days of service. Furthermore, failure to pay the civil penalty may result
in referral of the matter to the Attorney General for appropriate action in a district court of the
United States.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Items 1, 3, and 4 in the Notice for
violations of 49 CFR §§ 195.446(c)(1), 195.446(e)(1), and 195.446(e)(2), respectively. Under 49
U.S.C. § 60118(a), each person who engages in the transportation of hazardous liquids or who
owns or operates a pipeline facility is required to comply with the applicable safety standards
established under chapter 601.
3 Toledo Refining Company LLC, Final Order, CPF No. 1-2022-028-NOPV, 2023 WL 2611154, at *4 (Mar. 22,
2023); NuStar Pipeline Operating Partnership, L.P., Final Order, CPF No. 3-2021-005-NOPV, 2021 WL 5907916,
at *5 (Dec. 1, 2021).



With regard to the violation of section 195.446(e)(1) (Item 3), Respondent requested an
additional 90 days to complete the corrective actions. In a recommendation for final action
submitted pursuant to section 190.209(b)(7), the Director recommended extending the
compliance deadline as requested, but only if an update is provided after 90 days. I find it
reasonable to extend the compliance deadline and require a status update by the original deadline
proposed.
With regard to the violation of section 195.446(e)(2) (Item 4), Respondent requested an
additional 90 days to complete the corrective actions. In a recommendation for final action
submitted pursuant to section 190.209(b)(7), the Director recommended extending the
compliance deadline as requested, but only if an update is provided after 90 days. I find it
reasonable to extend the compliance deadline and require a status update by the original deadline
proposed.
For the above reasons, the Compliance Order is modified as set forth below.
Pursuant to the authority of 49 U.S.C. § 60118(b) and 49 CFR § 190.217, Respondent is ordered
to take the following actions to ensure compliance with the pipeline safety regulations applicable
to its operations:
1. With respect to the violation of section 195.446(c)(1) (Item 1), Respondent must
conduct an audit of SCADA screens and system as well as the Style Guide/SCADA
Design Manual against API RP 1165 and provide records of the audit to the Director,
Central Region within 90 days of receipt of the Final Order.
2. With respect to the violation of section 195.446(e)(1) (Item 3), Respondent must
amend its procedure to include all categories identified in the SCADA master data
base as safety related and correctly implement in the SCADA data base all categories
identified in the data base. This also includes the considerations of alarms related to
Leak Detection and training controllers on the procedure and safety related points.
Respondent must provide an update on the status of this corrective action to the
Director, Central Region within 90 days of receipt of the Final Order. Respondent
must provide the amended procedures and any associated records of the completed
corrective actions to the Director, Central Region within 180 days of receipt of the
Final Order.
3. With respect to the violation of section 195.446(e)(2) (Item 4), Respondent must
amend its procedure to identify and review all points affecting safety that have been
taken off scan in the SCADA host, have had alarms inhibited, generated false alarms,
or that have had forced or manual values for periods of time exceeding that required
for associated maintenance or operating activities and conduct two consecutive month
reviews using the new process. Respondent must provide an update on the status of
this corrective action to the Director, Central Region within 90 days of receipt of the
Final Order. Respondent must provide the amended procedures, records of the
monthly reviews using the new process, and any other associated records of the
completed corrective actions to the Director, Central Region within 180 days of
receipt of the Final Order.



The Director may grant an extension of time to comply with any of the required items upon a
written request timely submitted by the Respondent and demonstrating good cause for an
extension.
PHMSA requests that Respondent maintain documentation of the safety improvement costs
associated with fulfilling this Compliance Order and submit the total to the Director. It is
requested that these costs be reported in two categories: (1) total cost associated with
preparation/revision of plans, procedures, studies and analyses; and (2) total cost associated with
replacements, additions and other changes to pipeline infrastructure.
Failure to comply with this Order may result in the administrative assessment of civil penalties
not to exceed $200,000, as adjusted for inflation (see 49 CFR § 190.223 for adjusted amounts),
for each violation for each day the violation continues or in referral to the Attorney General for
appropriate relief in a district court of the United States.
WARNING ITEM
With respect to Item 2, the Notice alleged a probable violation of Part 195, but identified it as a
warning item pursuant to section 190.205. The warning was for:
49 CFR § 195.446(c)(4) (Item 2) ─ Respondent’s alleged failure to test any backup
SCADA systems at least once each calendar year, but at intervals not to exceed 15
months in accordance with its control room management plan.
If OPS finds a violation of this provision in a subsequent inspection, Respondent may be subject
to future enforcement action.
Under 49 CFR § 190.243, Respondent may submit a Petition for Reconsideration of this Final
Order to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey
Avenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to the Office of
Chief Counsel, PHMSA, at the same address. The written petition must be received no later than
20 days after receipt of the Final Order by Respondent. Any petition submitted must contain a
statement of the issue(s) and meet all other requirements of 49 CFR § 190.243. The filing of a
petition automatically stays the payment of any civil penalty assessed. The other terms of the
order, including corrective action, remain in effect unless the Associate Administrator, upon
request, grants a stay. The terms and conditions of this Final Order are effective upon service in
accordance with 49 CFR § 190.5.
Linda Daugherty Date Issued
Acting Associate Administrator
for Pipeline Safety



NOTICE OF PROBABLE VIOLATION
PROPOSED CIVIL PENALTY
and
PROPOSED COMPLIANCE ORDER
VIA ELECTRONIC MAIL TO: Jeff.pinter@nglep.com, eric.colman@nglep.com
May 8, 2024
Mr. Jeff Pinter
President and CEO
NGL Supply Terminal Company, LLC
6120 South Yale Avenue, Suite 1300
Tulsa, OK 74136
CPF 3-2024-022-NOPV
Dear Mr. Pinter:
From June 5 to June 9, 2023, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United States
Code (U.S.C.), virtually inspected NGL Supply Terminal Company, LLC’s (NGL Supply) Control Room
Management (CRM) procedures in Cushing, Oklahoma.
As a result of the inspection, it is alleged that you have committed probable violations of the Pipeline
Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected and the probable
violations are:
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) ….
(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.
NGL Supply failed to verify that API RP 1165 had been implemented in the SCADA system and its Style



Guide/SCADA Design Manual when it added the 225-mile Michigan Ambassador Pipeline to their
SCADA system in September 2022, per the requirement of § 195.446(c)(1).
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) ….
(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) ….
(4) Test any backup SCADA systems at least once each calendar year, but at intervals not to
exceed 15 months; and
NGL Supply failed to follow its procedure, CRM Plan section 3.5.4.2, when it tested its backup SCADA
systems at least once each calendar year, but at intervals not to exceed 15 months, per the requirements of
§ 195.446(c)(4). Specifically, CRM Plan section 3.5.4.2 required a test period of 30 minutes. While NGL
Supply’s controllers conducted a test monthly (more frequent than the procedure required), 7 out of 15
tests reviewed did not last the full 30 minutes.
This failure to follow procedures was identified before the inspection and corrected by NGL Supply. No
further action required.
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) ….
(e) Alarm management. Each operator using a SCADA system must have a written alarm
management plan to provide for effective controller response to alarms. An operator’s plan
must include provisions to:
(1) Review SCADA safety-related alarm operations using a process that ensures alarms are
accurate and support safe pipeline operations.



NGL Supply’s SCADA Safety-Related Alarm List failed to ensure alarms were accurate and supported
safe pipeline operations by failing to define and implement safety related points and alarms, per the
requirements of § 195.446(e)(1). Specifically, three alarms were not considered safety related
points/alarms: rate of change, mass balance, and communication alarms. CRM Plan section 5.2.8
provided a table with a listing of safety related alarms and noted that, “these alarms will have the highest
alarm priority and will generate the most critical alarm level.” Section 5.4.4 defined the Alarm Priorities
as Critical (C), High (H), Medium (M), Low (L), and section 5.4.4.1.4 stated, “Critical Priority alarms are
considered Safety Related Alarms for NGL Control Centers.” Rate of change (ROC) and mass balance
alarms were used in SCADA for Leak Detection but were not defined in the Table of section 5.2.8 as
safety related alarms. NGL Supply’s ROC pressure and flow alarms for its Ambassador Pipeline were
classified low priority in the data base. This was done to reduce the number of false alarms to the
controller. NGL Supply was in the process of refining these alarm set points to improve alarming for Leak
Detection. The mass balance, which can be an indication of leaks, was set to high priority and not critical,
so it was not included in the safety related category when it should have been. These actions resulted in
under reporting of safety related alarms related to leak detection. Also, communication failures were not
considered safety related. By not including these alarms in section 5.2.8 and implementing them as lower
priorities in the data base than defined through procedure, NGL Supply did not support safe pipeline
operations.
A review of the SCADA master database identified that some points were indicated with a
critical priority but not included in Table 5.2.8. These alarms were (1) “Gas Detect High High,”
(2) “Temp Transmitter High High,” (3) “Density High High,” and (4) “Meter Temp High High.”
NGL Supply also incorrectly identified multiple pressure information transmitters (PIT) as High
rather than critical. These included PID-120, PIT 1201, PIT 1202, PID 2701, and PIT 2702.
Additionally, there were rapid rate of change alarms listed as low priority and most
communication outages were labeled as low priority. PHMSA determined during the inspection
that there were gaps between the CRM Plan that defined safety related alarms and NGL Supply’s
implementation of safety related alarms and points. Thus, NGL Supply’s CRM Plan failed to
have an alarm management plan with sufficient review of SCADA safety-related alarm
operations, in violation of § 195.446(e)(1).
4. § 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) ….
(e) Alarm management. Each operator using a SCADA system must have a written alarm
management plan to provide for effective controller response to alarms. An operator's plan
must include provisions to:
(1) ….
(2) Identify at least once each calendar month points affecting safety that have been taken
off scan in the SCADA host, have had alarms inhibited, generated false alarms, or that have
had forced or manual values for periods of time exceeding that required for associated
maintenance or operating activities.



NGL Supply failed to complete the monthly review of points affecting safety that have been taken off
scan in the SCADA host, have had alarms inhibited, generated false alarms, or that have had forced or
manual values for periods of time exceeding that required for associated maintenance or operating
activities, per the requirements of § 195.446(e)(2). PHMSA reviewed records for the months of December
2020, April 2021, March 2022, and March 2023. These records identified that while NGL Supply
reviewed several important factors related to operating alarms, it failed to review and document those
points affecting safety that have been taken off scan in the SCADA host, have had alarms inhibited,
generated false alarms, or that have had forced or manual values for periods of time exceeding that
required for associated maintenance or operating activities. Thus, NGL Supply was not in compliance
with § 195. 446(e)(2).
Furthermore, the CRM Plan section 5.1.2.16 detailed the requirement for the monthly review by
only restating the regulation. The CRM Plan referenced a review of nuisance alarms under
procedure “Nuisance Alarm Resolution Procedure.” False alarms are gathered under nuisance
alarms. CRM Plan section 11.8 also restated the regulation and offered guidance on review of
nuisance alarms. A review of the records identified four areas of review: (1) Key Performance
Indicators (KPIs), (2) “Top 10 All Alarm Review,” (3) “Critical Alarm Review,” and (4) “Stale
Alarm Review.” These reviews were not defined in a procedure in the CRM Plan. Therefore,
NGL Supply failed to have, in practice, procedures to identify points affecting safety that have
been taken off scan in the SCADA host, have had alarms inhibited, generated false alarms, or
that have had forced or manual values for periods of time exceeding that required for associated
maintenance or operating activities, in violation of § 195.446(e)(2).
Proposed Civil Penalty
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$266,015 per violation per day the violation persists, up to a maximum of $2,660,135 for a related series
of violations. For violation occurring on or after January 6, 2023, and before December 28, 2023, the
maximum penalty may not exceed $257,664 per violation per day the violation persists, up to a maximum
of $2,576,627 for a related series of violations. For violation occurring on or after March 21, 2022, and
before January 6, 2023, the maximum penalty may not exceed $239,142 per violation per day the
violation persists, up to a maximum of $2,391,412 for a related series of violations. For violation
occurring on or after May 3, 2021, and before March 21, 2022, the maximum penalty may not exceed
$225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a related series
of violations. For violation occurring on or after January 11, 2021, and before May 3, 2021, the maximum
penalty may not exceed $222,504 per violation per day the violation persists, up to a maximum of
$2,225,034 for a related series of violations. For violation occurring on or after July 31, 2019, and before
January 11, 2021, the maximum penalty may not exceed $218,647 per violation per day the violation
persists, up to a maximum of $2,186,465 for a related series of violations. For violation occurring on or
after November 27, 2018, and before July 31, 2019, the maximum penalty may not exceed $213,268 per
violation per day, with a maximum penalty not to exceed $2,132,679.
For each violation involving LNG facilities, an additional penalty of not more than $79,875 occurring on
or after July 31, 2019, and before January 11, 2021, may be imposed. For each violation involving LNG
facilities, an additional penalty of not more than $77,910 occurring on or after November 27, 2018, and
before July 31, 2019, may be imposed.
We have reviewed the circumstances and supporting documentation involved for the above probable



violations and recommend that you be preliminarily assessed a civil penalty of $ 21,200 as follows:
Item number PENALTY
4 $ 21,200
Proposed Compliance Order
With respect to Items 1, 3, and 4, pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous Materials
Safety Administration proposes to issue a Compliance Order to NGL Supply. Please refer to the
Proposed Compliance Order, which is enclosed and made a part of this Notice.
Warning Item
With respect to Item 2, we have reviewed the circumstances and supporting documents involved in this
case and have decided not to conduct additional enforcement action or penalty assessment proceedings at
this time. We advise you to promptly correct this item. Failure to do so may result in additional
enforcement action.
Response to this Notice
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. All material you
submit in response to this enforcement action may be 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 your receipt of this Notice, you have 30 days to respond as described in the enclosed Response
Options. 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 a Final Order. If
you are responding to this Notice, we propose that you submit your correspondence to my office within
30 days from receipt of this Notice. The Region Director may extend the period for responding upon a
written request timely submitted demonstrating good cause for an extension.
In your correspondence on this matter, please refer to CPF 3-2024-022-NOPV 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
cc: Eric Coleman, Director Operations-Compliance eric.colman@nglep.com



Enclosures: Proposed Compliance Order
Response Options for Pipeline Operators in Enforcement Proceedings



PROPOSED COMPLIANCE ORDER
Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration
(PHMSA) proposes to issue to NGL Supply a Compliance Order incorporating the following remedial
requirements to ensure the compliance of NGL Supply with the pipeline safety regulations:
A. B. C. D. In regard to Item 1 of the Notice, pertaining to NGL Supply’s failure to verify that API
RP 1165 had been implemented in the SCADA system or the Style Guide/SCADA
Design Manual, NGL Supply must conduct an audit of SCADA screens and system as
well as the Style Guide/SCADA Design Manual against API 1165 (incorporated by
reference) within 90 days of receipt of the Final Order.
In regard to Item 3 of the Notice, pertaining to NGL Supply’s failure to define safety
related points and alarms, NGL Supply must amend its procedure to include all categories
identified in the SCADA master data base as safety related and correctly implement in
the SCADA data base all categories identified in the data base. This also includes the
considerations of alarms related to Leak Detection and training controllers on the
procedure and safety related points within 90 days of receipt of the Final Order.
In regard to Item 4 of the Notice, pertaining to NGL Supply’s failure to complete the
monthly review of points affecting safety that have been taken off scan in the SCADA
host, have had alarms inhibited, generated false alarms, or that have had forced or manual
values for periods of time exceeding that required for associated maintenance or
operating activities, NGL Supply must amend its procedure to identify and review all
points affecting safety that have been taken off scan in the SCADA host, have had alarms
inhibited, generated false alarms, or that have had forced or manual values for periods of
time exceeding that required for associated maintenance or operating activities within 90
days of receipt of the Final Order. NGL Supply must also conduct two consecutive
month reviews using the new process within 90 days of receipt of the Final Order
It is requested that NGL Supply maintain documentation of the safety improvement costs
associated with fulfilling this Compliance Order and submit the total to Gregory Ochs,
Director, Central Region, Pipeline and Hazardous Materials Safety Administration. It is
requested that these costs be reported in two categories: (1) total cost associated with
preparation/revision of plans, procedures, studies and analyses, and (2) total cost
associated with replacements, additions and other changes to pipeline infrastructure.

32024022NOPV_Closure Letter_09032025_(23-268060)_text.pdf

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
901 Locust Street, Suite 480
Kansas City, MO 64106
VIA ELECTRONIC MAIL TO: travis.cundiff@nglep.com; eric.coleman@nglep.com;
September 3, 2025
Mr. Travis Cundiff, VP Asset Operations
NGL Supply Terminal Company, LLC
612
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