{"operation":"document","citation":"CPF 32024039NOA","title":"NGL SUPPLY TERMINAL COMPANY LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2024-05-08","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(d)(1), 195.446(a), 195.446(c)(1), 195.446(c)(2), 195.446(c)(3), 195.446(d), 195.446(e)(3), 195.446(e)(5), 195.446(g)(1)(i), 195.446(h).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32024039noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32024039noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32024039noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32024039NOA","body":"Notice of Amendment involving NGL SUPPLY TERMINAL COMPANY LLC. PHMSA's enforcement data identifies the cited regulations as 195.402(d)(1),  195.446(a),  195.446(c)(1),  195.446(c)(2),  195.446(c)(3),  195.446(d),  195.446(e)(3),  195.446(e)(5),  195.446(g)(1)(i),  195.446(h). The case was opened on 2024-05-08 and is reported as closed as of 2025-07-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32024039NOA_Closure Letter_07022025_(23-268060).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024039NOA/32024039NOA_Closure%20Letter_07022025_(23-268060).pdf\n\n32024039NOA_Closure Letter_07022025_(23-268060)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024039NOA/32024039NOA_Closure%20Letter_07022025_(23-268060)_text.pdf\n\n32024039NOA_Notice of Amendment_05082024_(23-268060).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024039NOA/32024039NOA_Notice%20of%20Amendment_05082024_(23-268060).pdf\n\n32024039NOA_Notice of Amendment_05082024_(23-268060)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024039NOA/32024039NOA_Notice%20of%20Amendment_05082024_(23-268060)_text.pdf\n\n32024039NOA_Operator Response to Notice_06052024_(23-268060).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024039NOA/32024039NOA_Operator%20Response%20to%20Notice_06052024_(23-268060).pdf\n\n32024039NOA_Closure Letter_07022025_(23-268060)_text.pdf\n\nVIA ELECTRONIC MAIL TO: don.robinson@nglep.com; eric.coleman@nglep.com;\ntravis.cundiff@nglep.com\nJuly 2, 2025\nMr. Don Robinson, Executive V.P.\nNGL Supply Terminal Company, LLC\n6120 South Yale Avenue, Suite 1300\nTulsa, OK 74136\nRE: CPF 3-2024-039-NOA\nDear Mr. Robinson\nFrom June 5 to June 9, 2023, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49\nUnited States Code (U.S.C.), inspected the procedures for Control Room Management (CRM) of\nNGL Supply Terminal Company, LLC (NGL Supply) in Cushing, Oklahoma. On May 8, 2024,\npursuant to 49 CFR § 190.206, PHMSA issued a Notice of Amendment which proposed\namendment of NGL Supply’s procedures.\nNGL Supply submitted its amended procedures on October 31, 2024 and provided updates on\nMay 28, 29, and July 2, 2025. PHMSA has reviewed the amended procedures, and it appears\nthat the inadequacies outlined in the Notice of Amendment have been corrected.\nThis letter is to inform you that no further action is necessary, and this case is now closed.\nThank you for your cooperation.\nSincerely,\nDavid Barrett\nActing Director, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Travis Cundiff, Sr. VP, NGL, travis.cundiff@nglep.com\nEric Coleman, Director of Operation-Compliance, NGL, eric.coleman@nglep.com\n\n32024039NOA_Notice of Amendment_05082024_(23-268060)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: Jeff.pinter@nglep.com;\neric.coleman@nglep.com\nMay 8, 2024\nMr. Jeff Pinter\nPresident and CEO\nNGL Supply Terminal Company, LLC\n6120 South Yale Avenue, Suite 1300\nTulsa, OK 74136\nCPF 3-2024-039-NOA\nDear Mr. Pinter:\nFrom June 5 to June 9, 2023, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49\nUnited States Code (U.S.C.), virtually inspected NGL Supply Terminal Company, LLC’s (NGL\nSupply) procedures for Control Room Management (CRM) in Cushing, Oklahoma.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within\nNGL Supply’s plans or procedures. The items inspected and the inadequacies are described\nbelow:\n1. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . . .\n(d) Abnormal operation. The manual required by paragraph (a) of this section must\ninclude procedures for the following to provide safety when operating design limits\nhave been exceeded:\n(1) Responding to, investigating, and correcting the cause of:\n(i) Unintended closure of valves or shutdowns;\n(ii) Increase or decrease in pressure or flow rate outside normal operating limits;\n(iii) Loss of communications;\n(iv) Operation of any safety device;\n(v) Any other malfunction of a component, deviation from normal operation, or\npersonnel error which could cause a hazard to persons or property.\n\n\n\nNGL Supply’s O&M Procedure, section 13, entitled “Abnormal Operations,” dated July 1, 2022,\nwas not adequate because it did not require field personnel to call the control room when\noperating design limits were exceeded, as prescribed in § 195.402(d)(1)(i)-(v). Section 13\ndirected field personnel to call the operations supervisor, who was also not instructed to call the\ncontrol room. Information needs to flow to the controller to provide for a controller’s prompt and\nappropriate response to operating conditions, even if the controller is not the first to detect the\ncondition. Section 195.402(c)(15) requires an operator to implement the applicable control room\nmanagement procedures required by § 195.446.\nThe O&M Procedure section 13 needs to be amended to include the requirement for field\npersonnel to contact the control room upon the discovery of an abnormal operation, as defined by\n§ 195.402(d)(1)(i)-(v).\n2. § 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….\nNGL Supply’s “NGL Crude Terminals Control Centers Control Room Management Plan,”\nRevision 3, Issued May 9, 2023 (CRM Plan), was not adequate to provide a process for control\nroom determination. Section 1.7.4 of the CRM Plan only provided a statement of where the\ncontrol center is located. The procedure needs to consider all locations where there is a SCADA\nsystem that can monitor and control jurisdictional pipeline facilities.\nThe procedure needs to be amended to provide a process that evaluates each location where there\nis a SCADA system that can monitor and control jurisdictional pipeline facilities with criteria to\nsupport determination of control rooms.\n3. § 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 the\ninformation, tools, processes and procedures necessary for the controllers to carry\nout the roles and responsibilities the operator has defined by performing each of the\nfollowing:\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 used;\n\n\n\nNGL Supply’s CRM Plan was not adequate to clearly define when a SCADA system is added,\nexpanded, or replaced to appropriately ensure API RP 1165 is implemented. Section 3.1 stated,\n\"[l]atest approved version of API 1165 (latest approved version).\" The version incorporated by\nreference in the regulations is identified in § 195.3(b)(9) as the First Edition, January 2007.\nSection 6.1.4, “System/Processes Undergoing Change,” of the CRM Plan identified details on\nchanges that require implementation of the MOC process, which included (1) Control System\nChanges and (2) SCADA System Changes. While many of these types of changes may relate to\naddition, expansion, or replacement, as addressed in § 194.446(c)(1), these procedure did not\naddress when API RP 1165 must be implemented. Additionally, there was no tie between section\n3 and section 6 of the CRM Plan to make sure API RP 1165 will be implemented.\nThe procedure needs to be amended to define what a SCADA system addition, expansion, and\nreplacement means to the operator. The procedure also needs to include the requirement to\ndocument the deviation if certain provisions of API RP 1165 are not practical for the SCADA\nsystem. The procedure needs to make the tie between section 3 and section 6 of the CRM Plan,\nthrough reference between the MOC process and the intended API RP 1165 standard for\ncompliance. The correct API RP 1165 version needs to be referenced.\n4. § 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) ….\n(2) Conduct a point-to-point verification between SCADA displays and related field\nequipment when field equipment is added or moved and when other changes that\naffect pipeline safety are made to field equipment or SCADA displays.\nNGL Supply’s records failed to demonstrate it performed an adequate point-to-point (P2P)\nverification. Such records were required to be maintained by § 195.446(j)(1). A review of several\nIncoming data/Outgoing data (I/O) checkout records for various facilities (Block valve 6, Block\nvalve 12, Kalkaska, Lapeer, Wheeler) indicated P2P verification was completed and documented\nby mapping between SCADA and Programmable Logic Controller (PLC). The P2P verification\nrecord failed to include whether (1) the point was verified by live testing or simulation, (2) all\nscreens the point presented on in SCADA were verified, and (3) alarms were presented in\nSCADA with the correct priority. Additionally, the document did not include color and alarm\ndescriptions. Some points provided a verification between field and SCADA of a current value\n\n\n\nor status; for example, a comparison of pressure or valve status – but this lacked consistency\nbetween records. The document had a “Discrete I/O tab” which provided designations “As\nDesigned Setpoint” and “As Left Setpoint;” but there was no data in these cells. The “Analog IO\ntab” offered set point values from “Low Low” through “High High.” It is not clear whether these\nset point values were verified or whether these values were information to verify values.\nNGL Supply’s CRM Plan sections 3.2.2 and 3.2.3 for P2P verifications were not adequate and\ncontributed to this failure because they were written at a very high level and did not represent\nNGL Supply’s actual practice for P2P verification. The procedure “I/O Verification,” approved\nMay 8, 2023, was developed and used by SCADA for P2P/IO checkout but was not referenced in\nthe CRM Plan sections 3.2.2. and 3.2.3. The “I/O Verification” procedure provided detail of how\nto conduct a test for each device and should have been included in the CRM Plan. The “I/O\nVerification” procedure was missing the documentation process that needed to include what\nform to use and what to specifically record. As such, NGL Supply’s procedures were not in\ncompliance with § 195.446(c)(2).\nFurthermore, a review of P2P records identified the verification failed to include whether (1) the\npoint was verified by live testing or simulation, (2) all screens the point presented on in SCADA\nwere verified, and (3) alarms were presented in SCADA with the correct priority. Additionally,\nthe document did not include color and alarm descriptions. Some points provided a verification\nbetween field and SCADA of a current value or status; for example, a comparison of pressure or\nvalve status – but this lacked consistency between records. The document had a “Discrete I/O\ntab” which provided designations “As Designed Setpoint” and “As Left Setpoint;” but there was\nno data in these cells. The “Analog IO tab” offered set point values from “Low Low” through\n“High High.” It is not clear whether these set point values were verified or whether these values\nwere information to verify values. All the P2P verification elements and the process to complete\nthe form should have been defined in the procedure.\nThe procedure needs to be amended to include reference to the form to be used to document the\nP2P verification. The procedure needs to include all elements to be verified that also includes (1)\nthe point was verified by live testing or simulation, (2) all screens the point presented on in\nSCADA were verified, and (3) alarms were presented in SCADA with the correct priority.\nAnalogue values between field and SCADA as well as status points that are tested need to be\ndocumented. There also needs to be instructions on how to complete a thorough P2P to support\ncompliance.\n5. §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 the\ninformation, tools, processes and procedures necessary for the controllers to carry\n\n\n\nout the roles and responsibilities the operator has defined by performing each of the\nfollowing:\n(1) . . . .\n(3) Test and verify an internal communication plan to provide adequate means for\nmanual operation of the pipeline safely, at least once each calendar year, but at\nintervals not to exceed 15 months.\nNGL Supply’s CRM Plan did not provide an adequate internal communication plan (ICP) to\nprovide adequate means for manual operation of the pipeline safely, at least once each calendar\nyear, but at intervals not to exceed 15 months.\nThe ICP did not include consideration for manually managing leak detection whether the\ndecision is to continue to move product through the system or shut down and not move product.\nThe ICP was also missing key system points to monitor and report to the control room that\nrepresented enough information to manually operate the pipeline safely. While CRM Plan\nsection 3.3.4 identified some field points to monitor, the plan lacked specific points for the\ndesignated systems. This also included an interval requirement for reporting the information\nfrom the field. Section 3.3.1.3 incorrectly stated the interval as “annually” not to exceed 15\nmonths, rather than “once each calendar year.”\nAdditionally, sections 2.2.4 and 3.3.4 of the CRM Plan did not provide any parameters around\nhow long a controller was to wait before taking action in the event of loss of communications or\nSCADA failure. Controllers are trained to contact SCADA and wait 15 minutes before moving\nto implement the manual operations plan. This is a control room practice and not supported in\nprocedure.\nThe ICP must be amended to recognize the two different modes of operation: flowing product or\nnot flowing product. A method of leak detection needs to be provided that includes reporting and\nresponse. Specific monitoring points, adequate to support manual safe operation of the pipeline,\nas well as intervals to report to the control room for documentation, analysis and response, need\nto be provided. Additionally, procedures need to include a time parameter for how long after loss\nof communication or loss of SCADA the controller should wait before implementing the manual\noperation plan. Lastly, correction of the interval of “annual” to “calendar year” is necessary.\n6. §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(d) Fatigue mitigation. Each operator must implement the following methods to\nreduce the risk associated with controller fatigue that could inhibit a controller's\nability to carry out the roles and responsibilities the operator has defined.\n\n\n\nNGL Supply’s CRM Plan was not adequate to provide methods to reduce the risk associated\nwith controller fatigue that could inhibit a controller's ability to carry out the roles and\nresponsibilities the operator has defined in the event a controller is not able to complete a shift.\nSection 2.4.7 of the CRM Plan, entitled “Controller Unable to Complete Shift,” required the\nsupervisor to find the replacement managing the hours of service (HOS) and document any\ndeviations. The expectation of this process was that the individual must stay on the console until\nrelieved. Then, if the person cannot stay until relieved, NGL Supply control operations would\nrevert to the manual operation plan. This was not mentioned in the procedure but was described\nduring the inspection as what controllers and field do in practice. Also, the CRM Plan did not\nmention a shift change requirement as required by § 195.446(b)(4). Following this section was\nsection 2.4.8, entitled “Temporary Relief,” which considered the condition of a controller\nrequiring relief from the console. This did require a mid-day shift change. In summary, the\npractice described by the Control Room Manager was different than what was outlined in\nsections 2.4.7 and 2.4.8.\nThe procedure needs to be amended to provide greater detail on the expectation for when a\ncontroller leaves the console either for a temporary break or because they cannot continue on the\nshift due to emergency conditions. This procedure needs to include considerations for shut down\nif a suitable replacement cannot be found, shift exchange information, managing hours of\nservice, and where practices are in place, if appropriate, memorialization of them into the\nprocedure to effectively implement methods to reduce the risk associated with controller fatigue\nthat could inhibit a controller's ability to carry out their roles and responsibilities.\n7. §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(e) Alarm management. Each operator using a SCADA system must have a written\nalarm management plan to provide for effective controller response to alarms. An\noperator's plan must include provisions to:\n(1) . . . .\n(3) Verify the correct safety-related alarm set-point values and alarm descriptions\nwhen associated field instruments are calibrated or changed and at least once each\ncalendar year, but at intervals not to exceed 15 months.\nNGL Supply’s CRM Plan was not adequate to demonstrate NGL Supply had verified the correct\nsafety-related alarm set-point values and alarm descriptions when associated field instruments\nwere calibrated or changed. Specifically, CRM Plan section 5.6.2 only required the review of\nsafety-related alarms once each calendar year, not to exceed 15 months, and was silent on the\nrequirement for safety-related alarm set points and descriptions, as well as when field\ninstruments are calibrated or changed. The procedure was also missing the process that included\nthe controllers roles and responsibilities for this task, as well as documentation and verification.\n\n\n\nProcedure PTC-HL001, entitled “Pressure Transmitter Device Calibration,” dated July 10, 2019\n(PTC HL001), did not include verifying with the control room the set points when the equipment\nwas calibrated.\nThe procedure needs to be amended to include all the requirements identified in § 195.446(e)(3),\nas well as a process for the controllers to follow to complete and document the verification. Also,\nPTC HL001 must be amended to include the requirement that the correct safety related set points\nare verified and documented with the field.\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(e) Alarm management. Each operator using a SCADA system must have a written\nalarm management plan to provide for effective controller response to alarms. An\noperator's plan must include provisions to:\n(1) . . . .\n(5) Monitor the content and volume of general activity being directed to and required\nof each controller at least once each calendar year, but at intervals not exceeding 15\nmonths, that will assure controllers have sufficient time to analyze and react to\nincoming alarms.\nThe CRM Plan was not adequate to demonstrate that it considered all the content and volume of\ngeneral activity being directed to and required of each controller that will assure controllers have\nsufficient time to analyze and react to incoming alarms. Specifically, section 11.7 established the\nrequirement for the work load review. The procedure listed five items to be included in the\nreview. These review elements were: (1) volume of alarms, (2) volume of nuisance or “bad\nactor” alarms, (3) volume of states of alarm flood, (4) volume of operational events, and (5)\noperational changes increasing or decreasing the number of alarms. The procedure stated the\nreview “is not limited to” these five items. All of the five identified items pertained to the\nvolume of alarms, which required controller actions (assumed time component). One of the five\nitems provided consideration for operational events, which may be set points, but this was not\nclear. The workload review did not include other controller activities such as phone calls,\nsending commands, acknowledging alarms, report completion, monitoring, scheduling, training,\nreading, and any other activity that may be unique for the control room. The operator did not\nhave a form to guide review or detailed instructions on how to conduct the review. The operator\nhad no bench mark or relationship to time spent on activities to determine “sufficient time to\nanalyze and react to incoming alarms.”\nThe procedure needs to be amended to identify all content and volume of general activity being\ndirected to and required of each controller and establish a benchmark as to what designates\nsufficient time to analyze and react to incoming alarms. The procedure also needs to include the\n\n\n\nprocess for completing the review, as well as how the review, results, and determination will be\ndocumented and recorded.\n9. §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(g) Operating experience. Each operator must assure that lessons learned from its\noperating experience are incorporated, as appropriate, into its control room\nmanagement procedures by performing each of the following:\n(1) Review accidents that must be reported pursuant to §§ 195.50 and 195.52 to\ndetermine if control room actions contributed to the event and, if so, correct, where\nnecessary, deficiencies related to:\n(i) Controller fatigue;\nNGL Supply’s CRM Plan was not adequate to determine if control room actions contributed to\nthe event due to deficiencies related to controller fatigue. Section 4.1.10.2 provided a process to\nask probative questions that support evaluation of a controller’s potential fatigue level. This\nincluded: (1) hours of work for the preceding seven days, (2) hours of sleep in the past 24 hours,\npast 48 Hours, past 72 hours, (3) hours on duty at time of accident, (4) hours since last sleep, and\n(5) time accident occurred, with particular attention if it occurred during periods of reduced\nalertness. How this information was gathered and documented and the process to evaluate if\nfatigue was a factor were missing from the procedure. The operator indicated they used Form 4\n“AOC Report,” however there was nothing on that form related to fatigue or the questions and\ninformation gathered in section 4.1.10.2.\nThe procedure needs to be amended to include a form and method to determine a controller’s\nfatigue level and to determine if control room actions contributed to the reported accident and, if\nso, correct, where necessary, deficiencies related to controller fatigue.\n10. §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(h) Training. Each operator must establish a controller training program and review\nthe training program content to identify potential improvements at least once each\ncalendar year, but at intervals not to exceed 15 months. An operator's program must\nprovide for training each controller to carry out the roles and responsibilities defined\n\n\n\nby the operator. In addition, the training program must include the following\nelements:\nNGL Supply’s CRM Plan was not adequate because it did not provide a process to review the\ntraining program content to identify potential improvements. Section 8.1.1.3 stated the training\nprogram “[i]s to be maintained by reviewing it at least once each calendar year, but at intervals\nnot to exceed 15 months and in a manner that identifies continuous process improvement\nopportunities. The review shall ensure that documents, procedures, records and other information\nare current and accessible.” However, § 195.446(h) requires that an operator have a training\nprogram and that the content be reviewed to identify potential improvements. The review was\nrecorded through Form 9. This review included many elements that relate more to effectiveness\nof training. This type of review could identify if there were gaps in skills/knowledge/transfer of\ntraining. Those gaps could lead to evaluating training content. However, the form and process\ndid not get to the heart of training content review, which evaluates the content to verify it\naddresses all knowledge, tasks and skills required for the controller to carry out their roles and\nresponsibilities as defined by the operator.\nThe regulation also requires the training program to provide training for the controller to carry\nout their roles and responsibilities. If over the course of the year, roles and responsibilities have\nbeen added or eliminated, then the training content must be reviewed to verify there is content to\ncover that activity or the content is removed.\nThe procedure needs to be amended to include a process for reviewing the content to ensure it\nprovides training controllers in their roles and responsibilities. It must also include identification\nof the findings, and documentation of modification to findings to identify potential\nimprovements.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in\nEnforcement Proceedings.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. § 552(b), along with the complete original document you must provide a second copy of\nthe document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment\nunder 5 U.S.C. § 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under § 190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\n\n\n\nthis Notice without further notice to you and to issue an Order Directing Amendment. If your\nplans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend\nyour plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not\ncontesting this Notice, we propose that you submit your amended procedures to my office within\n30 days of receipt of this Notice. This period may be extended by written request for good cause.\nOnce the inadequacies identified herein have been addressed in your amended procedures, this\nenforcement action will be closed.\nIt is requested that NGL Supply maintain documentation of the safety improvement costs\nassociated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures)\nand submit the total to Gregory A. Ochs, Director, Central, Pipeline and Hazardous Materials\nSafety Administration. In correspondence concerning this matter, please refer to CPF 3-2024-\n039-NOA and, for each document you submit, please provide a copy in electronic format\nwhenever possible.\nSincerely,\nGregory A. Ochs\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Eric Coleman, Director Operations-Compliance, NGL Supply, eric.coleman@nglep.com\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings","truncated":false,"body_characters":30503}