# LAMBDA ENERGY GATHERING LLC — Notice of Amendment

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

Official case documents:

32025010NOA_Closure Letter_11182025_(24-297197).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025010NOA/32025010NOA_Closure%20Letter_11182025_(24-297197).pdf

32025010NOA_Closure Letter_11182025_(24-297197)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025010NOA/32025010NOA_Closure%20Letter_11182025_(24-297197)_text.pdf

32025010NOA_Notice of Amendment_01142025_(24-297197).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025010NOA/32025010NOA_Notice%20of%20Amendment_01142025_(24-297197).pdf

32025010NOA_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

32025010NOA_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

32025010NOA_Notice of Amendment_01142025_(24-297197)_text.pdf

NOTICE OF AMENDMENT
VIA ELECTRONIC MAIL TO: hfaulkner@lambdaoil.com;
jmcgrath@lambdaenergyllc.com; bberthelot@lambdaenergyllc.com
January 14, 2024
Mr. Harry Faulkner
President and CEO
Lambda Energy Gathering, LLC
12012 Wickchester Lane, Suite 300
Houston, TX 77079
CPF 3-2025-010-NOA
Dear Mr. Faulkner:
From June 11 to July 25, 2024, of the on-site inspection, a representative of the Pipeline and
Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United
States Code (U.S.C.), inspected Lambda Energy Gathering, LLC’s (Lambda) procedures for
Control Room Management (CRM) in Kalkaska, Michigan.
As a result of the inspection, PHMSA has identified the apparent inadequacies found within
Lambda’s plans or procedures. The items inspected and the inadequacies are described below:
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. . . .
(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.



Lambda’s Control Room Management Program, (version 1.0, effective April 18, 2022) (CRM
Plan), section C, subsection 8.4, was not adequate to describe Lambda’s process to test its
backup SCADA system and document the test to demonstrate compliance with § 195.446(c)(4).
While Lambda did not have a designated back up control room, it did have a backup SCADA
system. Lambda has only conducted a backup server test, called a “server swap,” once every six
months. The test entailed cold starting1 up the backup secondary server and shutting down the
current primary server. The control center operated on the backup secondary server for 6 months.
This was a back-and-forth process every six months. Lambda’s documentation of the swap
consisted of writing on a chalk board the date of the “swap” and which server was the current
primary for operations. This documentation via chalk board is obviously not sufficient to meet
[the documentation requirements of § 195.446(j)(1) because of its temporary nature.]. Lambda
had a very detailed procedure, outside the CRM plan, developed by its predecessor company,
Merit Energy, entitled “Server Swap Operations Procedures Version 11.28.2018.” This process
was not described nor cross-referenced in its CRM plan, and it failed to include a documentation
requirement.
Lambda’s CRM Plan did not include a process requiring the documentation and verification of
the functionality of the “swapped server,” once in service. This process should include a form or
checklist to verify critical functions were working. CRM Plan section 8.4 contained statements
prescribing the elements of the SCADA operation that should be tested and operations verified
after the server swap. The procedure designated the, “[a]larm and event logs from the backup
SCADA system to help demonstrate adequate functioning during back up operations.” While an
alarm-event log can be adequate to document functionality of the server, it is not adequate to
demonstrate compliance. This is because Lambda’s alarm-event log did not include information
such as: (1) who conducted the test, (2) who verified the information, (3) which server was
engaged during the test, and (4) whether there were any failures, if so, what were the follow up
actions to correct. A checklist or form including this information would support constancy and
provide instruction to the relevant controller for test expectations. If Lambda decides to stand up
a backup control room, the required documentation would need to be expanded to include: (1)
verification that monitors work, (2) whether IT systems are functional, (3) whether phones are
working and transfer, (4) whether printers are working (if applicable), etc.
The CRM Plan did provide guidance for manual control and monitoring of the system while the
SCADA system is being swapped. However, the procedure did not reference Lambda’s Internal
Communication Plan. During the inspection, Lambda indicated that this plan was employed
during the swap, and therefore it should be cross-referenced in the CRM Plan.
Additionally, during the COVID-19 pandemic, Lambda created a second control room, in the
plant facility, to support social distancing. While post COVID-19 the control room is no longer
in use, it can still function, and therefore it should be clarified whether Lambda considered this
control room as its designated backup control room. If so, then this control room needs to be
included in Lambda’s CRM Plan and be tested once each calendar year not to exceed 15 months,
in addition to, or in conjunction with the “server swap.”
1 Cold starts occur when an operator completely shuts down the server and then re-boots the system.



The CRM Plan needs to be amended to include: (1) reference to the detailed swap plan, (2) a
formalized swap plan within the Lambda Procedure Library, (3) a checklist or form used for
documenting tests and for ensuring the consistency of testing, (4) a plan to test the back up
control room, if the decision is made to stand that up as a backup control center, and (5) cross
reference to the Internal Communication Plan for manual operation and monitoring during the
server swap.
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. . . .
(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.
Lambda’s CRM Plan, section E, subsection 3.3, was not adequate to describe the current practice
in place for identifying and correcting inaccurate or malfunctioning alarms, per the requirements
of § 195.446(e)(1). Specifically, Lambda employed a ticket process to document, assign, and
dispatch work orders to the field when inaccurate or malfunctioning alarms were identified.
Subsection 3.3 required controllers to “identify, report, and correct inaccurate or malfunctioning
alarms based on alarm priority and safety related status to maintain the safe operation of the
pipeline. The controller will make notification of any identified alarm points to the control room
manager for corrective action.” It also stated, “reporting and the correction of inaccurate or
malfunctioning alarms will be documented using Form CRM-26B, “SCADA Failure Review of
Crude Oil Pipeline.” Form CRM-26B is different than the tickets used for documenting and
reporting.
Lambda’s ticket process was effective for communicating issues and assigning work to field
personnel to correct the condition. However, Lambda’s procedures did not include the
management control aspect of the practice. The ticket process did not include a tracking system
to ensure that the work was completed, beyond the second copy of the ticket maintained in the
control room. The ticket process did not require Lambda’s personnel to log the tickets, follow
progress, or match completed work tickets to the log. While Lambda was able to make
corrections through this process, it did not have any way of tracking what work was not
completed and how long it has been dispatched. Additionally, Lambda did not have any
established criteria to prioritize repair.
Lambda’s CRM Plan needs to be amended to provide a description of the process, a method of
logging and tracking work tickets and criteria for prioritizing work, criteria for completion, and
follow up for review and escalation.



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. . . .
(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) . . . .
(3) Verify the correct safety-related alarm set-point values and alarm descriptions
when associated field instruments are calibrated or changed and at least once each
calendar year, but at intervals not to exceed 15 months.
Lambda's CRM Plan, section E, subsection 3.3, was not adequate to provide a process to verify
the correct safety-related alarm set-point values and alarm descriptions when associated field
instruments are calibrated or changed and at least once each calendar year, but at intervals not to
exceed 15 months, per the requirements of § 195.446(e)(3). Specifically, the CRM Plan only
paraphrased the regulatory requirements and directed the use of Form CRM-16, “Annual Safety
Related Alarm Review,” to support and document the review. While Form CRM-16 was
adequate for the annual set point and description verification, it did not require signature of who
completed the review and who accepted the results of the review, which is necessary to
demonstrate compliance. Form CRM-16 also did not include space for comments in the event the
review produced findings that the set points and descriptions were not adequate and associated
follow up for correction and reverification.
Additionally, the CRM Plan did not include instructions for how the form was to be completed,
who was to complete the form, how to document and correct deficiencies (errors between the
master database and SCADA values), and reverification. The CRM Plan also did not include a
requirement to verify safety related set points when field instruments are calibrated or changed.
Lambda has a form entitled “Instrument Calibration Report,” that was used to verify field set
points and descriptions that is well suited for this requirement.
The CRM Plan needs to be amended to include the following elements: (1) documentation of
comments when a deficiency is found; (2) documentation of the name and signature of who
completed the review; (3) documentation of the date the review was finalized; and (4) instruction
on how to complete Form CRM-16, including (a) the requirement to verify the correct safety-
related alarm set-point values and alarm descriptions when associated field instruments are
calibrated or changed, and (b) reference to the current process and forms. Form CRM-16 also
needs to be amended to reflect all requirements specified in the procedure. For both the CRM
Plan and Form CRM-16, Lambda must include a process detailing required actions when
deficiencies are identified, such as required documentation of the identified deficiency, required
investigations to determine the correct information, and required documentation of the
correction.



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…
(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) . . . .
(4) Monitor the content and volume of general activity being directed to and
required of each controller at least once each calendar year, but at intervals not
exceeding 15 months, that will assure controllers have sufficient time to analyze
and react to incoming alarms; and
Lambda’s CRM Plan, section E, subsection 3.3, “Safety Reviews,” was not adequate to provide a
process that demonstrated compliance to monitor the content and volume of general activity
being directed to and required of each controller that will assure controllers have sufficient time
to analyze and react to incoming alarms, per the requirements of § 195.446(e)(4). Specifically,
the CRM Plan simply paraphrased the regulatory requirements and directed controllers to use
Form CRM-18, “Alarm Content and Volume Review,” to support and document the review. The
CRM Plan did not contain any instructions on how to complete the review utilizing the form.
The CRM Plan did not include detail on who was responsible to initiate, conduct, and analyze
the workload review. Additionally, the CRM Plan also did not include the criteria for
determining controllers have sufficient time to analyze and react to incoming alarms. Form
CRM-18 provided documentation spaces for a variety of time periods for activity review (day of
the week, time of day, season, etc.) without any direction on how these should be evaluated; for
example, each console, every year, a different activity each year. While Form CRM-18 did have
a table to gather data, it was a table to present summarized data, rather than raw data. Also, it
was unclear if the data was collected from Lambda’s data bases, such as SCADA, or from phone
records, or if controllers were estimating their time spent on an activity. Form CRM-18 also did
not require the documentation of the identify the console related to the data.
The CRM Plan must be amended to specify the time frame an activity review will be conducted
and how often for each console. This should also include conditions outside of this time
frequency that may be related to acquisitions or divestitures that may support adding or reducing
consoles. The CRM Plan must also be amended to include detail on how data will be gathered,
such as from SCADA data, phone records, or controller document task frequency. The CRM
Plan must include detail on who will initiate the review, provide the data, analyze the data, and
determine if controllers have sufficient time to analyze and react to incoming alarms using the
established criteria in the procedure. If the review identifies deficiencies, the CRM Plan needs to
provide instruction on how those deficiencies will be documented and require an action plan
developed and implemented to correct.



5. § 195.446 Control room management.
(a) General. This section applies to each operator of a pipeline facility with a
controller working in a control room who monitors and controls all or part of a
pipeline facility through a SCADA system. Each operator must have and follow
written control room management procedures that implement the requirements of
this section. . . .
(f) Change management. Each operator must assure that changes that could affect
control room operations are coordinated with the control room personnel by
performing each of the following:
(1) Implement section 7 of API RP 1168 (incorporated by reference, see §195.3) for
control room management change and require coordination between control room
representatives, operator's management, and associated field personnel when
planning and implementing physical changes to pipeline equipment or
configuration.
Lambda’s CRM Plan was not adequate to demonstrate compliance with § 195.446(f)(1). CRM
Plan, section F, subsection 3.1, stated, “Lambda Energy will ensure that changes that could affect
control room operations are coordinated with control room personnel.” However, the CRM Plan
did not include detail on how this change and coordination would be accomplished. The CRM
Plan lacked a mechanism to notify the control room of changes, so the control room
representative could review the changes, provide appropriate feedback, represent the control
room’s perspective and needs, initiate internal control room management of changes (MOC),
update procedures, and training.
Lambda utilized a Process Safety Management (PSM) system that had a form—entitled
“Management of Change Authorization” (MOCA Form)—that was used exclusively throughout
the plant and pipeline for documenting changes. The MOCA Form was quite thorough in its
considerations. However, the CRM Plan, section F, did not cross-reference the MOCA Form nor
did it require its use for documenting control room management change. Instead, CRM Plan,
section F, subsection 3.4 identified Form CRM-11, “Management of Change Record,” to be used
to record changes in control room management. It appeared this form should have been used for
all changes, but during the inspection Lambda indicated that controllers, in practice used the
PSM system’s MOCA Form to process changes, not Form CRM-11. If Form CRM-11 was
intended to be used for smaller control room changes, it was not adequate because it did not
identify all the parties or systems impacted by the change and verification that stake holders were
made aware of the change and approved the change. The form was very generic and lacked
sufficient detail.
Subsection 3.4 also indicated that Form CRM-11 should be used to record temporary changes.
Subsection 3.4 stated “[a] time restriction must be given in the ‘Summary of Change’ section.”
However, Form CRM-11 did not address whether the change was temporary or permanent.
Additionally, Form CRM-11 only required the time restriction be recorded in the “Summary of
Change” section and did not have a section to call out the specific date the change occurred on,
for tracking purposes. Subsection 4.2 stated, “control room personnel must establish a time limit
for temporary changes and monitor them closely.” The CRM Plan did not contain a mechanism



for tracking these time limit dates or who was responsible for that task. Form CRM-11 was also
confusing due to the various dates provided. It was unclear if the
“Completed/Reviewed/Approved By” section was intended to indicate the dates the MOC was
initiated, when it was reviewed, or when it was completed.
The CRM Plan must be amended to include (1) reference to the PSM procedure and identify who
will be the control room representative to review the changes, (2) a requirement to provide
appropriate feedback, (3) a requirement to document the control room’s perspective and needs,
and (4) a requirement to initiate internal control room management of changes (MOC), update
procedures, and training. The CRM Plan also needs to further define whether Form CRM-11
should be used for smaller control room MOCs such as alarm, SCADA, or procedure changes.
Lambda must also revise Form CRM-11 to better accommodate the procedure requirement as
well as address tracking changes for temporary MOCs and a method to track all MOCs.
6. § 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. . . .
(f) Change management. Each operator must assure that changes that could affect
control room operations are coordinated with the control room personnel by
performing each of the following:
(1) . . . .
(2) Require its field personnel to contact the control room when emergency
conditions exist and when making field changes that affect control room operations.
Lambda’s field Standard Operating Procedures (SOP) were not adequate to demonstrate
compliance with § 195.446(f)(2), which requires field personnel to contact the control room
when emergency conditions exist and when making field changes that affect control room
operations, and § 195.402(c)(15) which requires the implementation of the applicable control
room management procedures required by § 195.446. Specifically, Lambda’s valve inspection
SOP 1052022 and Tank Float Inspection SOP did not require field personnel to contact the
control room when making field changes that affect control room operations. Additionally, the
Tank Float Inspection SOP was maintained separately and outside of the formalized and
approved Operations and Maintenance (O&M) Manual and SOP library.
The field SOPs and procedures must be amended to include a step to contact the control room
when making field changes that affect control room operations which includes, but not limited to
maintenance, calibration, inspection and modification activities. Lambda also needs to amend its
procedures to require the Tank Float Inspection SOP be incorporated into its O&M Manual and
SOP library.



7. § 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. . . .
(g) Operating experience. Each operator must assure that lessons learned from its
operating experience are incorporated, as appropriate, into its control room
management procedures by performing each of the following:
(1) Review accidents that must be reported pursuant to §§ 195.50 and 195.52 to
determine if control room actions contributed to the event and, if so, correct, where
necessary, deficiencies related to:
(i) Controller fatigue.
Lambda’s CRM Plan, section D, subsection 6.4, was not adequate to describe its practice for
reviewing accidents that must be reported pursuant to §§ 195.50 and 195.52 to determine if
control room actions contributed to the event and, if so, correct, where necessary, deficiencies
related to controller fatigue, per the requirements of § 195.446(g)(1)(i). Specifically, Lambda’s
CRM Plan, which referenced a Lambda Form 130 “Incident Investigation,” to be utilized in
determining if fatigue contributed to an accident, did not include the “[q]uantitative controller
fatigue information to be collected,” as stated in the procedure. In practice, the control room used
Form CRM – 20, “Event Cause Analysis,” to document controller shift and sleep hours to
support determination of whether fatigue contributed to the event. However, Form CRM – 20
was not referenced in either CRM Plan section D, subsection 6.4, or in Form 130.
While Form CRM – 20 captured information related to shift pattern, shifts worked, hours of
sleep etc., it did not require documentation of the analysis/process used to determine, from the
collected quantitative controller fatigue information, whether fatigue contributed to an event.
Lambda’s CRM Plan must be amended to include a detailed process to evaluate the controller’s
level of fatigue and whether it contributed to the event and requiring completion of a form to
document this process. The process should include detail on the data required to perform the
analysis, the analysis process, and criteria for determining both controller fatigue and whether
fatigue contributed to the event. This process should also include clarity on which form will be
used for the analysis, either Form CRM-20, Form 130, or a combination of both and providing,
in procedures, the appropriate form reference.
8. § 195.446 Control room management.
(a) General. This section applies to each operator of a pipeline facility with a
controller working in a control room who monitors and controls all or part of a
pipeline facility through a SCADA system. Each operator must have and follow
written control room management procedures that implement the requirements of
this section. . . .
(h) Training. Each operator must establish a controller training program and review



the training program content to identify potential improvements at least once each
calendar year, but at intervals not to exceed 15 months. An operator's program
must provide for training each controller to carry out the roles and responsibilities
defined by the operator. In addition, the training program must include the
following elements:
(1) . . . .
(6) Control room team training and exercises that include both controllers and other
individuals, defined by the operator, who would reasonably be expected to
operationally collaborate with controllers (control room personnel) during normal,
abnormal or emergency situations. Operators must comply with the team training
requirements under this paragraph no later than January 23, 2018.
CRM Plan, section H, subsection 5.8, “Team Training,” was not adequate to demonstrate
compliance with § 195.446(h)(6). Specifically, the CRM Plan did not require training to include
the three different operational modes of normal, abnormal and emergency conditions. The CRM
Plan did not provide detail on the content to be considered for Team Training, nor did it include
a requirement for soft skills to be included in the training. Additionally, while the procedure
indicated team members that “[o]perationally collaborate with the control room have been
defined,” there was no list of which job titles had been considered to operationally collaborate
with the control room, or a reference of where to find the list, nor was there a description of job
roles that Lambda considered to be operationally collaborating with the control room.
The CRM Plan must be amended to include training on the three different operational modes of
normal, abnormal and emergency conditions, and detail content in the Team Training on soft
skills. Also, the CRM Plan must address those, by title or job group, who can be expected
operationally collaborate with the control room to be included in Team Training, either through a
list in the procedure or reference to where the information can be found.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. 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. Be advised that all material you
submit in response to this enforcement action is subject to being 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 the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under § 190.211. 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 an Order Directing Amendment. If your
plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend
your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not
contesting this Notice, we propose that you submit your amended procedures to my office within
30 days of receipt of this Notice. This period may be extended by written request for good cause.
Once the inadequacies identified herein have been addressed in your amended procedures, this
enforcement action will be closed.
It is requested (not mandated) that Lambda maintain documentation of the safety improvement
costs associated with fulfilling this Notice of Amendment (preparation/revision of plans,
procedures) and submit the total to Gregory A. Ochs, Director, Central Region, Pipeline and
Hazardous Materials Safety Administration. In correspondence concerning this matter, please
refer to CPF 3-2024-079-NOA 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: Ben Berthelot, Regulatory Compliance Manager, Lambda,
bberthelot@lambdaenergyllc.com
James McGrath, Michigan Plant and Pipeline Manager, Lambda,
jmcgrath@lamdaenergyllc.com
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings

32025010NOA_Closure Letter_11182025_(24-297197)_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: hfaulkner@lambdaoil.com;
jmcgrath@lambdaenergyllc.com; bberthelot@lambdaenergyllc.com
November 18, 2025
Mr. Harry Faulkner
President and CEO
Lambda Energy Gathering, LLC
12012 Wickchester Lane, Suite 300
Houston, TX 77079
RE: CPF 3-2025-010-NOA
Dear Mr. Faulkner:
From June 11 to July 25, 2024, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), conducted
an inspection of Lambda Energy Gathering, LLC’s (Lambda) procedures for Control Room
Management (CRM) in Kalkaska, Michigan. On January 14, 2025, pursuant to 49 CFR § 190.206,
PHMSA issued a Notice of Amendment which proposed amendment of Lambda’s procedures.
Lambda submitted its amended procedures, with its final submission on July 2, 2025. PHMSA has
reviewed the amended procedures, and it appears that the inadequacies outlined in the Notice of
Amendment have been corrected.
This letter is to inform you that no further action is necessary, and this case is now closed. Thank
you for your cooperation.
Sincerely,
David Barrett
Acting Director, Central Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Ben Berthelot, Regulatory Compliance Manager, Lambda,
bberthelot@lambdaenergyllc.com
James McGrath, Michigan Plant and Pipeline Manager, Lambda,
jmcgrath@lamdaenergyllc.com
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