{"operation":"document","citation":"CPF 32025011WL","title":"ST LOUIS PIPELINE OPERATING LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-10-29","effective_on":null,"summary":"CLOSED warning letter citing 195.402(a), 195.444(a), 195.444(b), 195.446(a), 195.446(b), 195.446(b)(2), 195.446(b)(3), 195.446(b)(5), 195.446(c)(3), 195.446(d)(1), 195.446(e), 195.446(f)(1), 195.446(f)(2), 195.446(g)(1), 195.446(h)(1), 195.446(h)(5), 195.446(h)(6).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025011wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025011wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025011wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32025011WL","body":"Warning Letter involving ST LOUIS PIPELINE OPERATING LLC. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.444(a),  195.444(b),  195.446(a),  195.446(b),  195.446(b)(2),  195.446(b)(3),  195.446(b)(5),  195.446(c)(3),  195.446(d)(1),  195.446(e),  195.446(f)(1),  195.446(f)(2),  195.446(g)(1),  195.446(h)(1),  195.446(h)(5),  195.446(h)(6). The case was opened on 2025-10-29 and is reported as closed as of 2025-10-29. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32025011WL_Warning Letter_10292025_(24-297184).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025011WL/32025011WL_Warning%20Letter_10292025_(24-297184).pdf\n\n32025011WL_Warning Letter_10292025_(24-297184)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025011WL/32025011WL_Warning%20Letter_10292025_(24-297184)_text.pdf\n\n32025011WL_Warning Letter_10292025_(24-297184)_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: tampapc@outlook.com; stlouispipelinegm@outlook.com;\ngreg.lipscomb@panamericanpipelines.com; berry.croft@panamericanpipelines.com\nOctober 29, 2025\nMr. Robert Rose\nPresident and CEO\nSt. Louis Pipeline Operating, LLC\nP.O. Box 35236\nSarasota, FL 34242\nCPF 3-2025-011-WL\nDear Mr. Rose:\nFrom August 19 to August 28, 2024, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49\nUnited States Code (U.S.C.), conducted an inspection of the Control Room Management (CRM)\nprocedures and records of St. Louis Pipeline Operating, LLC (SLPLO) in Hartford, Illinois.\nAs a result of the inspection, it is alleged that SLPLO has committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies. This manual shall be\nreviewed at intervals not exceeding 15 months, but at least once each calendar year,\nand appropriate changes made as necessary to insure that the manual is effective.\nThis manual shall be prepared before initial operations of a pipeline system\ncommence, and appropriate parts shall be kept at locations where operations and\nmaintenance activities are conducted.\n\n\n\nSLPLO failed to provide records to demonstrate it performed an annual review of its procedures,\nas required by §§ 195.446(a) and 195.402(a).1 Page two of the SLPLO O&M Plan had a list of\nrevisions – change numbers, the associated date of the change, and an identifier used in the body\nof the O&M Plan to locate the change. If one were to use the list of changes on page two of the\nO&M Plan as a record the plan was reviewed, there were several gaps between years where no\nchanges or reviews were completed. In addition, there was no signature on the plan to verify it was\nreviewed and accepted.\n2. § 195.444 Leak Detection\n(a) Scope. Except for offshore gathering and regulated rural gathering pipelines, this\nsection applies to all hazardous liquid pipelines transporting liquid in single phase\n(without gas in the liquid).\n(b) General. A pipeline must have an effective system for detecting leaks in accordance\nwith §§ 195.134 or 195.452, as appropriate. An operator must evaluate the capability\nof its leak detection system to protect the public, property, and the environment and\nmodify it as necessary to do so. At a minimum, an operator's evaluation must consider\nthe following factors—length and size of the pipeline, type of product carried, the\nswiftness of leak detection, location of nearest response personnel, and leak history.\nSLPLO failed to evaluate the capability of its leak detection system to determine if its system was\neffective for detecting leaks in accordance with § 195.134 or § 195.452, as required by\n§ 195.444(b). The pipeline system crosses commercially navigable waterways and supplies a\nmetropolitan airport. The pipeline was in a high consequence area and necessitated an effective\nleak detection system for detecting leaks in accordance with §§ 195.452(i)(3) and 195.444(b).\nSLPLO did not provide leak detection capability evaluations for PHMSA’s review and therefore\nwas unable to demonstrate compliance with § 195.444(b).\n3. § 195.446 Control room management.\n(a) General. This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline facility\nthrough a SCADA system. Each operator must have and follow written control room\nmanagement procedures that implement the requirements of this section….\n(b) Roles and responsibilities. Each operator must define the roles and responsibilities\nof a controller during normal, abnormal, and emergency operating conditions.\nSLPLO failed to define the roles and responsibilities of a controller during normal, abnormal, and\nemergency operating conditions, as required by § 195.446(b). Specifically, SLPLO’s CRM Plan\ndid not accurately represent SLPLO’s actual operating practice, and did not provide a clear process\nto describe the conditions when the physical domain of responsibility periodically changes in the\ncontrol room.\n1 Section 195.446(a) requires integration of the control room management procedures into the written procedures\nrequired by § 195.402(a).\n\n\n\nThe CRM Plan stated the controller is normally the only personnel in the control room during\nnights, weekends, and holidays, but in practice the standard control room operations occurred\nweekdays during the daytime. At night, the controller left the control room and turned off the\nSCADA system. When the power was off, SCADA did not perform any operational monitoring\nof assets, including the monitoring of HCAs (e.g., the commercially navigable river crossings),\nand no operational information was archived. As a result, no alarms or alerts were received or\ndispatched. There was no procedure in the CRM Plan for shutting down the SCADA system at the\nend of the day or starting up the system at the beginning of the day. SLPLO used check lists for\nstandard operating procedures, but there were no checklists for shutdown and startup of the\nSCADA systems.\nIn addition, at the time of PHMSA’s inspection SLPLO had one trained and qualified controller.\nThe controller had a designated cell phone, which the controller took home in case there was need\nto respond to after-hours calls from the public. There were no procedures related to the controller’s\nroles and responsibilities for after-hour response or for the on-call practice of the controller.\nFurthermore, at the time of PHMSA’s inspection, the controller also had non-control room duties,\nincluding climbing two tanks to take product inventory, and periodic walking around the yard to\nmake observations of conditions. At any time, the controller could fall or suffer other personal\ninjury rendering them incapacitated and not be able to communicate, yet there were no procedures\nin place to cover this possibility. Detailed procedures to follow in such an event would be critical\nfor the safe operation of the pipeline.\n4. § 195.446 Control room management.\n(a) General. This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline facility\nthrough a SCADA system. Each operator must have and follow written control room\nmanagement procedures that implement the requirements of this section….\n(b) Roles and responsibilities. Each operator must define the roles and responsibilities\nof a controller during normal, abnormal, and emergency operating conditions. To\nprovide for a controller's prompt and appropriate response to operating conditions,\nan operator must define each of the following:\n(1) . . . .\n(2) A controller's role when an abnormal operating condition is detected, even if the\ncontroller is not the first to detect the condition, including the controller's\nresponsibility to take specific actions and to communicate with others.\nSLPLO’s operating procedures, including the CRM Plan, were not adequate to define the\ncontrollers' authority and responsibilities when an abnormal operating is detected, as required by\n§ 195.446(b)(2). While procedures were in place for controllers in the CRM Plan, the SLPLO\nOperations and Maintenance Procedural Manual (O&M Manual), the SLPLO Emergency\nResponse Manual, and the Operating Checklists, the procedures were not consistent in their\ndirections to controllers and references therein were not correct. Examples included notes to use\nthe Emergency Stop Switch in one procedure that was not in another, instructions to close a valve\nin one procedure that was not included in the other, one plan directing following the integrated\ncontingency plan while the other procedure did not mention this, the name of the delivery customer\n\n\n\nbeing different between procedures, and having different identification numbers for the valve on\nBanshee Road that required being closed.\nThe procedures addressing controller responsibility to take specific action and communicate with\nothers when an abnormal operating condition or emergency is identified were inconsistent. The\nO&M Manual provided specific steps for control center employees to take if abnormal operations\nare identified, followed by even more specific instructions for controller response for defined\nabnormal operation events. However, the CRM Plan addressing controller roles and\nresponsibilities for Emergency/Abnormal Operation Conditions were high level statements related\nto recognizing, reacting, and investigating. In another example, the CRM Plan stated that continued\noperations or restart of the pipeline following shutdown depended upon conditions – but these\nconditions were not articulated. The CRM procedure must address these issues to ensure the\ncontrollers’ roles and responsibilities are clearly tied to the expectations in the O&M Manual.\n5. § 195.446 Control room management.\n(a) General. This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline facility\nthrough a SCADA system. Each operator must have and follow written control room\nmanagement procedures that implement the requirements of this section….\n(b) Roles and responsibilities. Each operator must define the roles and responsibilities\nof a controller during normal, abnormal, and emergency operating conditions. To\nprovide for a controller's prompt and appropriate response to operating conditions,\nan operator must define each of the following:\n(1) . . . .\n(3) A controller's role during an emergency, even if the controller is not the first to\ndetect the emergency, including the controller's responsibility to take specific actions\nand to communicate with others.\nSLPLO’s procedures did not define a controller’s role during an emergency, as required by\n§ 195.446(b)(3). Specifically, they did not define the controller’s role in the event the control room\nneeds to be evacuated. Emergency Manual Appendix P, Tornado Emergency, provided guidance\non sheltering and, if time allows, initiating an emergency shut down of the pipeline. The procedure,\nhowever, did not address shutting down the SCADA system and SLPLO had no procedure or\nchecklist that covered the control room evacuation practice at the time of PHMSA’s inspection.\nSLPLO’s plans and procedures should have provided detailed steps for controllers to follow during\nan emergency in the event the control room needs to be evacuated, their roles and responsibilities\nin the event the control room must be evacuated, and the shutdown requirements for the pipeline\nand SCADA system for emergencies that were reasonably likely to occur.\n6. § 195.446 Control room management.\n(a) General. This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline facility\nthrough a SCADA system. Each operator must have and follow written control room\nmanagement procedures that implement the requirements of this section….\n\n\n\n(b) Roles and responsibilities. Each operator must define the roles and responsibilities\nof a controller during normal, abnormal, and emergency operating conditions. To\nprovide for a controller's prompt and appropriate response to operating conditions,\nan operator must define each of the following.\n(1) . . . .\n(3) A controller's role during an emergency, even if the controller is not the first to\ndetect the emergency, including the controller's responsibility to take specific actions\nand to communicate with others.\nSLPLO’s CRM Plan did not define the controller’s role during an emergency, as required by\n§ 195.446(b)(3). Specifically, it did not define the controller’s role in the event the SCADA system\nor data communications system fails, constituting an emergency that could impact large sections\nof the controller's domain of responsibility. SLPLO addressed loss of communications in its O&M\nManual. It considered loss of communications as an abnormal operating procedure but not one that\nwould affect the safe operation of the pipeline system. However, loss of any one communications\nsystem would impact safe operations. The pipeline is in a high consequence area and SLPLO\ndepended upon communications to report and compare meter readings between the two ends of\nthe pipeline for leak detection. If one communication system failed, the leak detection method\nSLPLO employed would not function. The O&M Manual provided directions to take in the event\ncommunication was not restored after some reasonable length of time. This included steps to\nrestore communications. It indicated that if there is a total system or data failure or if the situation is\ndeemed critical, the system will be shut down until re-establishment of communications. However,\nthere was no established time to wait before shutting down the system. The decision was left to\nthe discretion of the individual controller. The O&M Manual provided no criteria to guide the\ncontroller’s decision-making. SLPLO’s procedures should have considered the severity of the\ncommunication loss, the appropriate wait times before a controller needs to act, to include acting\nto shut down the pipeline, and points of contact depending upon the severity of the communication\nloss.\nIn addition, the CRM Plan itself did not address loss of communications, and it did not reference\nspecific O&M Manual sections. The regulation requires the control room management procedures\nto have this information.\n7. § 195.446 Control room management.\n(a) General. This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline facility\nthrough a SCADA system. Each operator must have and follow written control room\nmanagement procedures that implement the requirements of this section….\n(b) Roles and responsibilities. Each operator must define the roles and responsibilities\nof a controller during normal, abnormal, and emergency operating conditions. To\nprovide for a controller's prompt and appropriate response to operating conditions,\nan operator must define each of the following:\n(1) . . . .\n(5) The roles, responsibilities and qualifications of others who have the authority to\ndirect or supersede the specific technical actions of controllers.\n\n\n\nSLPLO failed to have a procedure that addressed the roles, responsibilities and qualifications of\nothers who have the authority to direct or supersede the specific technical actions of controllers,\nas required by § 195.446(b)(5). PHMSA requested all procedures related to implementation of\n§ 195.446 control room management. The procedures were provided and reviewed, and the\nSLPLO failed to have a procedure to demonstrate compliance.\n8. § 195.446 Control room management.\n(a) General. This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline facility\nthrough a SCADA system. Each operator must have and follow written control room\nmanagement procedures that implement the requirements of this 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) . . . .\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.\nSLPLO failed to have an internal communication plan to provide adequate means for manual\noperation of the pipeline safely, as required by § 195.446(c)(3). This was due to SLPLO’s policy\nin Appendix 12, sub-section 18, that stated it does not need to have an internal communications\nplan due to its practice to not operate its system manually. However, if the pipeline is shut down\nto a no flow condition, the pipeline is still in operating mode. Monitoring for leaks or normal,\nabnormal, or emergency conditions is still required, even if not flowing product. SLPLO did not\nhave an internal communication plan to provide adequate means for safe manual operation when\nthe pipeline is not flowing product but still in operating mode.\n9. § 195.446 Control room management.\n(a) General. This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline facility\nthrough a SCADA system. Each operator must have and follow written control room\nmanagement procedures that implement the requirements of this section….\n(b) . . . .\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(1) Establish shift lengths and schedule rotations that provide controllers off-duty\ntime sufficient to achieve eight hours of continuous sleep;\nSLPLO’s CRM Plan failed to implement the methods prescribed by § 195.446(d) to reduce the\nrisk associated with controller fatigue that could inhibit a controller’s ability to carry out the roles\nand responsibilities the operator has defined. Specifically, the CRM Plan failed to establish shift\n\n\n\nlengths and schedule rotations that address when an on-call controller must respond to after-hours\npipeline events. SLPLO’s sole controller at the time of inspection was assigned to after-hours\npipeline response. This individual took home a company cell phone and responded to after-hours\nemergency calls. Section 12.1 provided a table that illustrated shift schedule, but the table did not\naddress the single controller on duty, nor the Monday – Friday shift schedule practiced. There were\nno procedures in place to address this situation to ensure the controller’s sleep was not interrupted,\nnor did the procedures address how, when only one controller is on staff, the controller will be\nafforded appropriate rest or assigned additional fatigue mitigating techniques.\n10. § 195.446 Control room management.\n(a) This section applies to each operator of a pipeline facility with a controller working\nin a control room who monitors and controls all or part of a pipeline facility through\na SCADA system. Each operator must have and follow written control room\nmanagement procedures that implement the requirements of this 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:\nSLPLO CRM Plan section 13 failed to demonstrate compliance because it did not provide a written\nalarm management plan to provide for effective controller response to alarms, as required by\n§ 195.446(e). Specifically, the procedure laid out concepts and philosophy for alarm management,\nbut it did not provide details of how alarms were to be designed, implemented, and maintained.\nThe CRM Plan did not have a process for documenting and rationalizing alarms, to include alarm\nprioritization, establishing alarm set points and descriptions, how alarm priorities were displayed\nto the controller and describing any differences between the two SCADA systems. It did not have\na process to identify inaccurate, malfunctioning or false alarms, and document and track them to\ncorrection. While it identified safety related alarms, it did not define how they were implemented\nin the SCADA system, displayed to the controller, or the difference defined between the two\nSCADA systems. SLPLO operated two different SCADA systems, identified as HINZ and EPIC,\nwhich were designed and integrated at different times by totally different contractors. There was\nno SCADA style guide, and from PHMSA’s observations the screens were quite different, as were\nthe alarms. SLPLO had no documentation to support the SCADA alarm design or operation. In\naddition, during review of the SCADA system, PHMSA inspectors spoke with the sole controller.\nThe controller was not aware of what safety related alarms were or the priority of alarms between\nthe two systems. The CRM Plan did not provide enough detail to demonstrate SLPLO had\nadequate processes to ensure SCADA safety-related alarm operations using a process that ensures\nalarms are accurate and support safe pipeline operations, as required by § 195.446(e)(1).\nSLPLO CRM Plan section 13.3 also failed to provide a process for how the operator would identify\nat least once each calendar month points affecting safety that have been taken off scan in the\nSCADA host, have had alarms inhibited, generated false alarms, or that have had forced or manual\nvalues for periods of time exceeding that required for associated maintenance or operating\nactivities, as required by § 195.446(e)(2). CRM Plan section 13.3 paraphrased the regulation and\noffered no detail on how to conduct monthly alarm reviews. The CRM Plan offered two forms to\n\n\n\ndocument the reviews: 12e CRM - Disabled Safety Related Log and 12f CRM - Forced Point Log.\nThese forms were not referenced in the procedure, and there was no form to cover the requirements\nfor points off scan. In addition, the two forms appeared to be redundant except the CRM - Disabled\nSafety-Related Alarm Log included a category for false alarms. There was no definition or\ninstruction on how to identify and document false alarms in either the procedure or the form. There\nwas no process addressing how to evaluate corresponding equipment, maintenance, or repair\nactivities to related points affecting safety taken off-scan, inhibited, and or that have had forced or\nmanual valves to determine whether those periods of time exceeded that required for maintenance\nor operating activities.\nSLPLO CRM Plan sections 13.4(h) and 13.4(i) did not provide a process to verify the correct\nsafety-related alarm set-point values and alarm descriptions when associated field instruments are\ncalibrated or changed and at least once each calendar year, but at intervals not to exceed 15 months,\nas required by § 195.446(e)(3). Both sections 13.4(h) and 13.4(i) only provided a statement of the\nactivity without any details on the process, to include who is responsible, how the verification will\nbe completed, and how the activity will be documented. CRM Plan section 18.3 simply restated\nthe language of 49 CFR § 195.446(e)(3) with no additional details or process. SLPLO checklists M-\n5, M-6 and M-7, related to equipment calibrations, did not require field personnel to verify alarm\nsetpoints or alarm descriptions with the control room. The controller did verify the alarms\npresented by lowering the alarm set point until an alarm sounded. Checklist M-5 did not verify an\nalarm set point, but rather verified that an alarm will present itself. In addition, the M-5 checklist\nstep conflicted with CRM Plan section 13.5, which stated that controllers are not authorized to\ndisable, override, or change safety-related alarm settings.\nSLPLO CRM Plan section 18.4 did not support a thorough monitoring and analyzing of the content\nand volume of general activity being directed to and required of each controller at least once each\ncalendar year, but at intervals not exceeding 15 months, which will assure controllers have\nsufficient time to analyze and react to incoming alarms general activity directed to the controller,\nas required by § 195.446(e)(5). The procedure indicated a job task analysis form would be used to\nanalyze the controllers task load. Form 12h was developed in an Excel spread sheet and used for\nthe evaluation. The form provided adequate details to consider all the tasks of the controller;\nhowever, SLPLO’s procedure did not reference the form. The procedure provided considerations\nand a philosophy on what should be included in the review, but provided no task specifics nor did\nit detail how to conduct the assessment. In addition, the procedure provided metrics related to\nalarms per hour, per day as “the maximum manageable number of alarms.” Form 12h documented\ntime the controller spent on activities. But the form did not incorporate the stated metrics from the\nprocedure, and it did not provide metrics related to the data collected to determine if the controller\nhad sufficient time to respond to alarms.\nFurthermore, SLPLO CRM Plan section 13.5 did not provide details on how to address\ndeficiencies identified through implementation of § 195.4465(e)(1)-(e)(5), as required by\n§ 195.446(e)(6). In addition, other inadequacies were present in CRM Plan section 13.3. Section\n13.3stated, “[a]ppropriate corrective action is required to return alarm points to service in an\nexpedited manner,” but offered no further details. Section 13.5, stated, “[p]romptly address all\ndeficiencies identified in the SCADA reviews,” but did not define a process to address the\ndeficiencies.\n\n\n\n11. § 195.446 Control room management.\n(a) General. This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline facility\nthrough a SCADA system. Each operator must have and follow written control room\nmanagement procedures that implement the requirements of this section….\n(b) ….\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 configuration.\nSLPLO failed to assure that changes that could affect control room operations are coordinated with\nthe control room personnel, as required by § 195.446(f). Specifically, SLPLO did not follow its\nprocedure, O&M Plan Appendix 12, sub-section 14.7, to document and maintain records for the\nchanges related to the SLPLO pipeline relocation as well as for the SCADA and station\nmodifications for the Lambert Field project. Per its procedure, and as required by section 7 of API\nRP 1168, this change required SLPLO to conduct a point-to-point verification following the\nrelocation of the tank, pipeline, and SCADA points at Lambert Field in July 2021, as required by\nO&M Plan Appendix 12, sub-section 14.6.The procedure also required records be retained to\ndemonstrate training and communication of the physical control room changes and SCADA\nchanges to the control room personnel. PHMSA requested records of the point-to-point verification\nand records of the training and communication related to the physical control room changes and\nSCADA changes on August 30, 2024.2 SLPLO did not provide the records for review.\n3 A request\nfor the Management of Change (MOC) as well as any controller communication and training\nrecords related to the pipeline, facility and SCADA changes were made on August 30 and October\n16, 2024.\n4 SLPLO did not provide records for review. Therefore, SLPLO did not demonstrate\ncompliance.\n12. § 195.446 Control room management.\n(a) General. This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline facility\nthrough a SCADA system. Each operator must have and follow written control room\nmanagement procedures that implement the requirements of this section….\n(b) . . . .\n2 PHMSA requested these records on August 30, 2024, Requested Item #5.\n3 Records were required to be maintained pursuant to 49 CFR § 195.446(j)(1).\n4 Requested items submitted to the operator on August 30, 2024, Requested Item #9 and Request for Specific\nInformation #5 on October 16, 2024.\n\n\n\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 conditions\nexist and when making field changes that affect control room operations.\nThe checklists that SLPLO used to effectuate section 14 of its CRM Plan failed to require its field\npersonnel to contact the control room when emergency conditions exist and when making field\nchanges that affect control room operations, as required by § 195.446(f)(2). Section 14 of the CRM\nPlan required field personnel to notify the control room when emergency conditions exist and\nwhen making field changes that affect control room operations. However, Checklist M and O\nseries, which provide detailed steps used for testing, calibration, operations, and maintenance\nactivities of field equipment, did not require field personnel to notify the control room before\nbeginning work or in the event of an emergency. In addition, O&M Manual section 6.2, entitled\nReceiving, Identifying, Classifying and Notifying of Emergencies, did not require field personnel\nto notify the control room or reference CRM Plan section 14.\n13. § 195.446 Control room management.\n(a) General. This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline facility\nthrough a SCADA system. Each operator must have and follow written control room\nmanagement procedures that implement the requirements of this 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;\n(ii) Field equipment;\n(iii) The operation of any relief device;\n(iv) Procedures;\n(v) SCADA system configuration; and\n(vi) SCADA system performance.\nSLPLO’s O&M Manual section 6.7 and its CRM Plan sections 15.1 and 15.2 failed to provide\ndetails on how accidents reported pursuant to §§ 195.50 and 195.52 should be reviewed to\ndetermine if control room actions contributed to the event and, if so, how to correct them, as\nrequired by § 195.446(g)(1). Specifically, the procedures paraphrased the regulation and did not\nprovide details for how an assessment would be made to determine if control room actions\ncontributed to the event.\n\n\n\n14. § 195.446 Control room management.\n(a) General. This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline facility\nthrough a SCADA system. Each operator must have and follow written control room\nmanagement procedures that implement the requirements of this 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\nby the operator. In addition, the training program must include the following\nelements:\n(1) Responding to abnormal operating conditions likely to occur simultaneously or in\nsequence;\n(2) . . . .\n(5) For pipeline operating setups that are periodically, but infrequently used,\nproviding an opportunity for controllers to review relevant procedures in advance of\ntheir application; and\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.\nSLPLO failed to establish a controller training program to provide for training each controller to\ncarry out the roles and responsibilities defined by the operator, as required by § 195.446(h).\nSpecifically, SLPLO did not have a controller training program to provide for: (1) responding to\nabnormal operating conditions likely to occur simultaneously or in sequence, required by\n§ 195.446(h)(1); (2) pipeline operating setups that are periodically, but infrequently used,\nproviding an opportunity for controllers to review relevant procedures in advance of their\napplication, required by § 195.446(h)(5); and (3) control room team training and exercises that\nincluded both controllers and other individuals who would be reasonably expected to operationally\ncollaborate with controllers during normal, abnormal, or emergency situations, required by §\n195.446(h)(6). PHMSA reviewed SLPLO’s training checklist and found them to lack content for\nthe aforementioned elements. In addition, the procedure did not include the requirement for control\nroom team training and exercises that included both controllers and other individuals, and no\ncontent was developed. O&M Plan Appendix 12, sections 16.0 through 16.8 provided a narrative\non what would be included in SLPLO’s training program, but there was no content attached other\nthan the three identified Energy World Net (EWN) Computer Based Training (CBT). There was\nno training program with established content, training time frames, or assessments or evaluations.\nPHMSA requested SLPLO’s training records. The documents provided in response included\ntabletop drills, EWN records, and Part 195 procedure and checklist reviews. Much of the training\ncontent related to the field or terminal activities. This does not constitute a controller training\nprogram. Therefore, SLPLO failed to comply with § 195.446(h).\n\n\n\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$272,926 per violation per day the violation persists, up to a maximum of $2,729,245 for a related\nseries of violations. For violation occurring on or after December 28, 2023 and before December\n30, 2024 the maximum penalty may not exceed $266,015 per violation per day the violation\npersists, up to a maximum of $2,660,135 for a related series of violations. For violation occurring\non or after January 6, 2023 and before December 28, 2023 the maximum penalty may not exceed\n$257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a related\nseries of violations. For violation occurring on or after March 21, 2022 and before January 6, 2023\nthe maximum penalty may not exceed $239,142 per violation per day the violation persists, up to\na maximum of $2,391,142 for a related series of violations. For violation occurring on or after\nMay 3, 2021 and before March 21, 2022 the maximum penalty may not exceed $225,134 per\nviolation per day the violation persists, up to a maximum of $2,251,334 for a related series of\nviolations. For violation occurring on or after January 11, 2021 and before May 3, 2021 the\nmaximum penalty may not exceed $222,504 per violation per day the violation persists, up to a\nmaximum of $2,225,034 for a related series of violations. For violation occurring on or after July\n31, 2019 and before January 11, 2021 the maximum penalty may not exceed $218,647 per violation\nper day the violation persists, up to a maximum of $2,186,465 for a related series of violations.\nWe have reviewed the circumstances and supporting documents involved in this case and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the items identified in this letter. Failure to do so will result in St.\nLouis Pipeline Operating, LLC being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 3-2025-011-WL. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. § 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe the\nredacted information qualifies for confidential treatment under 5 U.S.C. § 552(b).\nSincerely,\nDavid Barrett\nActing Director, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Greg Lipscomb, General Manager, Tampa Bay Pipeline Corp.,\ngreg.lipscomb@panamericanpipelines.com\nBerry Croft, Facility Supervisor, St Louis Pipeline Operating LLC,\nstlouispipelinegm@outlook.com; berry.croft@panamericanpipelines.com\nRECEIPT CONFIRMATION REQUESTED","truncated":false,"body_characters":38518}