{"operation":"document","citation":"CPF 32025010NOA","title":"LAMBDA ENERGY GATHERING LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-01-14","effective_on":null,"summary":"CLOSED notice of amendment citing 195.446(a), 195.446(c)(4), 195.446(e)(1), 195.446(e)(3), 195.446(e)(4), 195.446(f)(1), 195.446(f)(2), 195.446(g)(1)(i), 195.446(h)(6).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025010noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025010noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025010noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32025010NOA","body":"Notice of Amendment involving LAMBDA ENERGY GATHERING LLC. PHMSA's enforcement data identifies the cited regulations as 195.446(a),  195.446(c)(4),  195.446(e)(1),  195.446(e)(3),  195.446(e)(4),  195.446(f)(1),  195.446(f)(2),  195.446(g)(1)(i),  195.446(h)(6). The case was opened on 2025-01-14 and is reported as closed as of 2025-11-18. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32025010NOA_Closure Letter_11182025_(24-297197).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025010NOA/32025010NOA_Closure%20Letter_11182025_(24-297197).pdf\n\n32025010NOA_Closure Letter_11182025_(24-297197)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025010NOA/32025010NOA_Closure%20Letter_11182025_(24-297197)_text.pdf\n\n32025010NOA_Notice of Amendment_01142025_(24-297197).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025010NOA/32025010NOA_Notice%20of%20Amendment_01142025_(24-297197).pdf\n\n32025010NOA_Notice of Amendment_01142025_(24-297197)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025010NOA/32025010NOA_Notice%20of%20Amendment_01142025_(24-297197)_text.pdf\n\n32025010NOA_Operator Response to Notice_01152025_(24-297197).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025010NOA/32025010NOA_Operator%20Response%20to%20Notice_01152025_(24-297197).pdf\n\n32025010NOA_Notice of Amendment_01142025_(24-297197)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: hfaulkner@lambdaoil.com;\njmcgrath@lambdaenergyllc.com; bberthelot@lambdaenergyllc.com\nJanuary 14, 2024\nMr. Harry Faulkner\nPresident and CEO\nLambda Energy Gathering, LLC\n12012 Wickchester Lane, Suite 300\nHouston, TX 77079\nCPF 3-2025-010-NOA\nDear Mr. Faulkner:\nFrom June 11 to July 25, 2024, of the on-site inspection, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code (U.S.C.), inspected Lambda Energy Gathering, LLC’s (Lambda) procedures for\nControl Room Management (CRM) in Kalkaska, Michigan.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within\nLambda’s plans or procedures. The items inspected and the inadequacies are described below:\n1. § 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(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(4) Test any backup SCADA systems at least once each calendar year, but at\nintervals not to exceed 15 months.\n\n\n\nLambda’s Control Room Management Program, (version 1.0, effective April 18, 2022) (CRM\nPlan), section C, subsection 8.4, was not adequate to describe Lambda’s process to test its\nbackup SCADA system and document the test to demonstrate compliance with § 195.446(c)(4).\nWhile Lambda did not have a designated back up control room, it did have a backup SCADA\nsystem. Lambda has only conducted a backup server test, called a “server swap,” once every six\nmonths. The test entailed cold starting1 up the backup secondary server and shutting down the\ncurrent primary server. The control center operated on the backup secondary server for 6 months.\nThis was a back-and-forth process every six months. Lambda’s documentation of the swap\nconsisted of writing on a chalk board the date of the “swap” and which server was the current\nprimary for operations. This documentation via chalk board is obviously not sufficient to meet\n[the documentation requirements of § 195.446(j)(1) because of its temporary nature.]. Lambda\nhad a very detailed procedure, outside the CRM plan, developed by its predecessor company,\nMerit Energy, entitled “Server Swap Operations Procedures Version 11.28.2018.” This process\nwas not described nor cross-referenced in its CRM plan, and it failed to include a documentation\nrequirement.\nLambda’s CRM Plan did not include a process requiring the documentation and verification of\nthe functionality of the “swapped server,” once in service. This process should include a form or\nchecklist to verify critical functions were working. CRM Plan section 8.4 contained statements\nprescribing the elements of the SCADA operation that should be tested and operations verified\nafter the server swap. The procedure designated the, “[a]larm and event logs from the backup\nSCADA system to help demonstrate adequate functioning during back up operations.” While an\nalarm-event log can be adequate to document functionality of the server, it is not adequate to\ndemonstrate compliance. This is because Lambda’s alarm-event log did not include information\nsuch as: (1) who conducted the test, (2) who verified the information, (3) which server was\nengaged during the test, and (4) whether there were any failures, if so, what were the follow up\nactions to correct. A checklist or form including this information would support constancy and\nprovide instruction to the relevant controller for test expectations. If Lambda decides to stand up\na backup control room, the required documentation would need to be expanded to include: (1)\nverification that monitors work, (2) whether IT systems are functional, (3) whether phones are\nworking and transfer, (4) whether printers are working (if applicable), etc.\nThe CRM Plan did provide guidance for manual control and monitoring of the system while the\nSCADA system is being swapped. However, the procedure did not reference Lambda’s Internal\nCommunication Plan. During the inspection, Lambda indicated that this plan was employed\nduring the swap, and therefore it should be cross-referenced in the CRM Plan.\nAdditionally, during the COVID-19 pandemic, Lambda created a second control room, in the\nplant facility, to support social distancing. While post COVID-19 the control room is no longer\nin use, it can still function, and therefore it should be clarified whether Lambda considered this\ncontrol room as its designated backup control room. If so, then this control room needs to be\nincluded in Lambda’s CRM Plan and be tested once each calendar year not to exceed 15 months,\nin addition to, or in conjunction with the “server swap.”\n1 Cold starts occur when an operator completely shuts down the server and then re-boots the system.\n\n\n\nThe CRM Plan needs to be amended to include: (1) reference to the detailed swap plan, (2) a\nformalized swap plan within the Lambda Procedure Library, (3) a checklist or form used for\ndocumenting tests and for ensuring the consistency of testing, (4) a plan to test the back up\ncontrol room, if the decision is made to stand that up as a backup control center, and (5) cross\nreference to the Internal Communication Plan for manual operation and monitoring during the\nserver swap.\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. . . .\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) Review SCADA safety-related alarm operations using a process that ensures\nalarms are accurate and support safe pipeline operations.\nLambda’s CRM Plan, section E, subsection 3.3, was not adequate to describe the current practice\nin place for identifying and correcting inaccurate or malfunctioning alarms, per the requirements\nof § 195.446(e)(1). Specifically, Lambda employed a ticket process to document, assign, and\ndispatch work orders to the field when inaccurate or malfunctioning alarms were identified.\nSubsection 3.3 required controllers to “identify, report, and correct inaccurate or malfunctioning\nalarms based on alarm priority and safety related status to maintain the safe operation of the\npipeline. The controller will make notification of any identified alarm points to the control room\nmanager for corrective action.” It also stated, “reporting and the correction of inaccurate or\nmalfunctioning alarms will be documented using Form CRM-26B, “SCADA Failure Review of\nCrude Oil Pipeline.” Form CRM-26B is different than the tickets used for documenting and\nreporting.\nLambda’s ticket process was effective for communicating issues and assigning work to field\npersonnel to correct the condition. However, Lambda’s procedures did not include the\nmanagement control aspect of the practice. The ticket process did not include a tracking system\nto ensure that the work was completed, beyond the second copy of the ticket maintained in the\ncontrol room. The ticket process did not require Lambda’s personnel to log the tickets, follow\nprogress, or match completed work tickets to the log. While Lambda was able to make\ncorrections through this process, it did not have any way of tracking what work was not\ncompleted and how long it has been dispatched. Additionally, Lambda did not have any\nestablished criteria to prioritize repair.\nLambda’s CRM Plan needs to be amended to provide a description of the process, a method of\nlogging and tracking work tickets and criteria for prioritizing work, criteria for completion, and\nfollow up for review and escalation.\n\n\n\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(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.\nLambda's CRM Plan, section E, subsection 3.3, was not adequate to provide a process to verify\nthe correct safety-related alarm set-point values and alarm descriptions when associated field\ninstruments are calibrated or changed and at least once each calendar year, but at intervals not to\nexceed 15 months, per the requirements of § 195.446(e)(3). Specifically, the CRM Plan only\nparaphrased the regulatory requirements and directed the use of Form CRM-16, “Annual Safety\nRelated Alarm Review,” to support and document the review. While Form CRM-16 was\nadequate for the annual set point and description verification, it did not require signature of who\ncompleted the review and who accepted the results of the review, which is necessary to\ndemonstrate compliance. Form CRM-16 also did not include space for comments in the event the\nreview produced findings that the set points and descriptions were not adequate and associated\nfollow up for correction and reverification.\nAdditionally, the CRM Plan did not include instructions for how the form was to be completed,\nwho was to complete the form, how to document and correct deficiencies (errors between the\nmaster database and SCADA values), and reverification. The CRM Plan also did not include a\nrequirement to verify safety related set points when field instruments are calibrated or changed.\nLambda has a form entitled “Instrument Calibration Report,” that was used to verify field set\npoints and descriptions that is well suited for this requirement.\nThe CRM Plan needs to be amended to include the following elements: (1) documentation of\ncomments when a deficiency is found; (2) documentation of the name and signature of who\ncompleted the review; (3) documentation of the date the review was finalized; and (4) instruction\non how to complete Form CRM-16, including (a) the requirement to verify the correct safety-\nrelated alarm set-point values and alarm descriptions when associated field instruments are\ncalibrated or changed, and (b) reference to the current process and forms. Form CRM-16 also\nneeds to be amended to reflect all requirements specified in the procedure. For both the CRM\nPlan and Form CRM-16, Lambda must include a process detailing required actions when\ndeficiencies are identified, such as required documentation of the identified deficiency, required\ninvestigations to determine the correct information, and required documentation of the\ncorrection.\n\n\n\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(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(4) Monitor the content and volume of general activity being directed to and\nrequired of each controller at least once each calendar year, but at intervals not\nexceeding 15 months, that will assure controllers have sufficient time to analyze\nand react to incoming alarms; and\nLambda’s CRM Plan, section E, subsection 3.3, “Safety Reviews,” was not adequate to provide a\nprocess that demonstrated compliance to monitor the content and volume of general activity\nbeing directed to and required of each controller that will assure controllers have sufficient time\nto analyze and react to incoming alarms, per the requirements of § 195.446(e)(4). Specifically,\nthe CRM Plan simply paraphrased the regulatory requirements and directed controllers to use\nForm CRM-18, “Alarm Content and Volume Review,” to support and document the review. The\nCRM Plan did not contain any instructions on how to complete the review utilizing the form.\nThe CRM Plan did not include detail on who was responsible to initiate, conduct, and analyze\nthe workload review. Additionally, the CRM Plan also did not include the criteria for\ndetermining controllers have sufficient time to analyze and react to incoming alarms. Form\nCRM-18 provided documentation spaces for a variety of time periods for activity review (day of\nthe week, time of day, season, etc.) without any direction on how these should be evaluated; for\nexample, each console, every year, a different activity each year. While Form CRM-18 did have\na table to gather data, it was a table to present summarized data, rather than raw data. Also, it\nwas unclear if the data was collected from Lambda’s data bases, such as SCADA, or from phone\nrecords, or if controllers were estimating their time spent on an activity. Form CRM-18 also did\nnot require the documentation of the identify the console related to the data.\nThe CRM Plan must be amended to specify the time frame an activity review will be conducted\nand how often for each console. This should also include conditions outside of this time\nfrequency that may be related to acquisitions or divestitures that may support adding or reducing\nconsoles. The CRM Plan must also be amended to include detail on how data will be gathered,\nsuch as from SCADA data, phone records, or controller document task frequency. The CRM\nPlan must include detail on who will initiate the review, provide the data, analyze the data, and\ndetermine if controllers have sufficient time to analyze and react to incoming alarms using the\nestablished criteria in the procedure. If the review identifies deficiencies, the CRM Plan needs to\nprovide instruction on how those deficiencies will be documented and require an action plan\ndeveloped and implemented to correct.\n\n\n\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(f) Change management. Each operator must assure that changes that could affect\ncontrol room operations are coordinated with the control room personnel by\nperforming each of the following:\n(1) Implement section 7 of API RP 1168 (incorporated by reference, see §195.3) for\ncontrol room management change and require coordination between control room\nrepresentatives, operator's management, and associated field personnel when\nplanning and implementing physical changes to pipeline equipment or\nconfiguration.\nLambda’s CRM Plan was not adequate to demonstrate compliance with § 195.446(f)(1). CRM\nPlan, section F, subsection 3.1, stated, “Lambda Energy will ensure that changes that could affect\ncontrol room operations are coordinated with control room personnel.” However, the CRM Plan\ndid not include detail on how this change and coordination would be accomplished. The CRM\nPlan lacked a mechanism to notify the control room of changes, so the control room\nrepresentative could review the changes, provide appropriate feedback, represent the control\nroom’s perspective and needs, initiate internal control room management of changes (MOC),\nupdate procedures, and training.\nLambda utilized a Process Safety Management (PSM) system that had a form—entitled\n“Management of Change Authorization” (MOCA Form)—that was used exclusively throughout\nthe plant and pipeline for documenting changes. The MOCA Form was quite thorough in its\nconsiderations. However, the CRM Plan, section F, did not cross-reference the MOCA Form nor\ndid it require its use for documenting control room management change. Instead, CRM Plan,\nsection F, subsection 3.4 identified Form CRM-11, “Management of Change Record,” to be used\nto record changes in control room management. It appeared this form should have been used for\nall changes, but during the inspection Lambda indicated that controllers, in practice used the\nPSM system’s MOCA Form to process changes, not Form CRM-11. If Form CRM-11 was\nintended to be used for smaller control room changes, it was not adequate because it did not\nidentify all the parties or systems impacted by the change and verification that stake holders were\nmade aware of the change and approved the change. The form was very generic and lacked\nsufficient detail.\nSubsection 3.4 also indicated that Form CRM-11 should be used to record temporary changes.\nSubsection 3.4 stated “[a] time restriction must be given in the ‘Summary of Change’ section.”\nHowever, Form CRM-11 did not address whether the change was temporary or permanent.\nAdditionally, Form CRM-11 only required the time restriction be recorded in the “Summary of\nChange” section and did not have a section to call out the specific date the change occurred on,\nfor tracking purposes. Subsection 4.2 stated, “control room personnel must establish a time limit\nfor temporary changes and monitor them closely.” The CRM Plan did not contain a mechanism\n\n\n\nfor tracking these time limit dates or who was responsible for that task. Form CRM-11 was also\nconfusing due to the various dates provided. It was unclear if the\n“Completed/Reviewed/Approved By” section was intended to indicate the dates the MOC was\ninitiated, when it was reviewed, or when it was completed.\nThe CRM Plan must be amended to include (1) reference to the PSM procedure and identify who\nwill be the control room representative to review the changes, (2) a requirement to provide\nappropriate feedback, (3) a requirement to document the control room’s perspective and needs,\nand (4) a requirement to initiate internal control room management of changes (MOC), update\nprocedures, and training. The CRM Plan also needs to further define whether Form CRM-11\nshould be used for smaller control room MOCs such as alarm, SCADA, or procedure changes.\nLambda must also revise Form CRM-11 to better accommodate the procedure requirement as\nwell as address tracking changes for temporary MOCs and a method to track all MOCs.\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(f) Change management. Each operator must assure that changes that could affect\ncontrol room operations are coordinated with the control room personnel by\nperforming each of the following:\n(1) . . . .\n(2) Require its field personnel to contact the control room when emergency\nconditions exist and when making field changes that affect control room operations.\nLambda’s field Standard Operating Procedures (SOP) were not adequate to demonstrate\ncompliance with § 195.446(f)(2), which requires field personnel to contact the control room\nwhen emergency conditions exist and when making field changes that affect control room\noperations, and § 195.402(c)(15) which requires the implementation of the applicable control\nroom management procedures required by § 195.446. Specifically, Lambda’s valve inspection\nSOP 1052022 and Tank Float Inspection SOP did not require field personnel to contact the\ncontrol room when making field changes that affect control room operations. Additionally, the\nTank Float Inspection SOP was maintained separately and outside of the formalized and\napproved Operations and Maintenance (O&M) Manual and SOP library.\nThe field SOPs and procedures must be amended to include a step to contact the control room\nwhen making field changes that affect control room operations which includes, but not limited to\nmaintenance, calibration, inspection and modification activities. Lambda also needs to amend its\nprocedures to require the Tank Float Inspection SOP be incorporated into its O&M Manual and\nSOP library.\n\n\n\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(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.\nLambda’s CRM Plan, section D, subsection 6.4, was not adequate to describe its practice for\nreviewing accidents that must be reported pursuant to §§ 195.50 and 195.52 to determine if\ncontrol room actions contributed to the event and, if so, correct, where necessary, deficiencies\nrelated to controller fatigue, per the requirements of § 195.446(g)(1)(i). Specifically, Lambda’s\nCRM Plan, which referenced a Lambda Form 130 “Incident Investigation,” to be utilized in\ndetermining if fatigue contributed to an accident, did not include the “[q]uantitative controller\nfatigue information to be collected,” as stated in the procedure. In practice, the control room used\nForm CRM – 20, “Event Cause Analysis,” to document controller shift and sleep hours to\nsupport determination of whether fatigue contributed to the event. However, Form CRM – 20\nwas not referenced in either CRM Plan section D, subsection 6.4, or in Form 130.\nWhile Form CRM – 20 captured information related to shift pattern, shifts worked, hours of\nsleep etc., it did not require documentation of the analysis/process used to determine, from the\ncollected quantitative controller fatigue information, whether fatigue contributed to an event.\nLambda’s CRM Plan must be amended to include a detailed process to evaluate the controller’s\nlevel of fatigue and whether it contributed to the event and requiring completion of a form to\ndocument this process. The process should include detail on the data required to perform the\nanalysis, the analysis process, and criteria for determining both controller fatigue and whether\nfatigue contributed to the event. This process should also include clarity on which form will be\nused for the analysis, either Form CRM-20, Form 130, or a combination of both and providing,\nin procedures, the appropriate form reference.\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(h) Training. Each operator must establish a controller training program and review\n\n\n\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\nmust provide for training each controller to carry out the roles and responsibilities\ndefined by the operator. In addition, the training program must include the\nfollowing elements:\n(1) . . . .\n(6) Control room team training and exercises that include both controllers and other\nindividuals, defined by the operator, who would reasonably be expected to\noperationally collaborate with controllers (control room personnel) during normal,\nabnormal or emergency situations. Operators must comply with the team training\nrequirements under this paragraph no later than January 23, 2018.\nCRM Plan, section H, subsection 5.8, “Team Training,” was not adequate to demonstrate\ncompliance with § 195.446(h)(6). Specifically, the CRM Plan did not require training to include\nthe three different operational modes of normal, abnormal and emergency conditions. The CRM\nPlan did not provide detail on the content to be considered for Team Training, nor did it include\na requirement for soft skills to be included in the training. Additionally, while the procedure\nindicated team members that “[o]perationally collaborate with the control room have been\ndefined,” there was no list of which job titles had been considered to operationally collaborate\nwith the control room, or a reference of where to find the list, nor was there a description of job\nroles that Lambda considered to be operationally collaborating with the control room.\nThe CRM Plan must be amended to include training on the three different operational modes of\nnormal, abnormal and emergency conditions, and detail content in the Team Training on soft\nskills. Also, the CRM Plan must address those, by title or job group, who can be expected\noperationally collaborate with the control room to be included in Team Training, either through a\nlist in the procedure or reference to where the information can be found.\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\n\n\n\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\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 (not mandated) that Lambda maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to Gregory A. Ochs, Director, Central Region, Pipeline and\nHazardous Materials Safety Administration. In correspondence concerning this matter, please\nrefer to CPF 3-2024-079-NOA and, for each document you submit, please provide a copy in\nelectronic format whenever possible.\nSincerely,\nGregory A. Ochs\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Ben Berthelot, Regulatory Compliance Manager, Lambda,\nbberthelot@lambdaenergyllc.com\nJames McGrath, Michigan Plant and Pipeline Manager, Lambda,\njmcgrath@lamdaenergyllc.com\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n\n32025010NOA_Closure Letter_11182025_(24-297197)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\n901 Locust Street, Suite 480\nKansas City, MO 64106\nVIA ELECTRONIC MAIL TO: hfaulkner@lambdaoil.com;\njmcgrath@lambdaenergyllc.com; bberthelot@lambdaenergyllc.com\nNovember 18, 2025\nMr. Harry Faulkner\nPresident and CEO\nLambda Energy Gathering, LLC\n12012 Wickchester Lane, Suite 300\nHouston, TX 77079\nRE: CPF 3-2025-010-NOA\nDear Mr. Faulkner:\nFrom June 11 to July 25, 2024, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), conducted\nan inspection of Lambda Energy Gathering, LLC’s (Lambda) procedures for Control Room\nManagement (CRM) in Kalkaska, Michigan. On January 14, 2025, pursuant to 49 CFR § 190.206,\nPHMSA issued a Notice of Amendment which proposed amendment of Lambda’s procedures.\nLambda submitted its amended procedures, with its final submission on July 2, 2025. PHMSA has\nreviewed the amended procedures, and it appears that the inadequacies outlined in the Notice of\nAmendment have been corrected.\nThis letter is to inform you that no further action is necessary, and this case is now closed. Thank\nyou for your cooperation.\nSincerely,\nDavid Barrett\nActing Director, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Ben Berthelot, Regulatory Compliance Manager, Lambda,\nbberthelot@lambdaenergyllc.com\nJames McGrath, Michigan Plant and Pipeline Manager, Lambda,\njmcgrath@lamdaenergyllc.com","truncated":false,"body_characters":32042}