{"operation":"document","citation":"CPF 520151003M","title":"TALLGRASS INTERSTATE GAS TRANSMISSION, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-03-27","effective_on":null,"summary":"CLOSED notice of amendment citing 192.631(b)(1), 192.631(b)(3), 192.631(b)(4), 192.631(c)(1), 192.631(d)(1), 192.631(d)(3), 192.631(d)(4), 192.631(e)(1), 192.631(e)(5), 192.631(f)(1), 192.631(h)(1), 192.631(i).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520151003m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520151003m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520151003m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520151003M","body":"Notice of Amendment involving TALLGRASS INTERSTATE GAS TRANSMISSION, LLC. PHMSA's enforcement data identifies the cited regulations as 192.631(b)(1),  192.631(b)(3),  192.631(b)(4),  192.631(c)(1),  192.631(d)(1),  192.631(d)(3),  192.631(d)(4),  192.631(e)(1),  192.631(e)(5),  192.631(f)(1),  192.631(h)(1),  192.631(i). The case was opened on 2015-03-27 and is reported as closed as of 2015-05-11. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520151003M_closure letter_05112015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520151003M/520151003M_closure%20letter_05112015.pdf\n\n520151003M_closure letter_05112015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520151003M/520151003M_closure%20letter_05112015_text.pdf\n\n520151003M_notice of amendment_03272015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520151003M/520151003M_notice%20of%20amendment_03272015.pdf\n\n520151003M_notice of amendment_03272015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520151003M/520151003M_notice%20of%20amendment_03272015_text.pdf\n\n520151003M_Operator Response to Notice_05012015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520151003M/520151003M_Operator%20Response%20to%20Notice_05012015.pdf\n\n520151003M_notice of amendment_03272015_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 27, 2015\nMr. Mick Rafter\nVice President, Operations\nTallgrass Interstate Gas Transmission, LLC\n370 Van Gordon Street\nLakewood, CO 80228\nCPF 5-2015-1003M\nDear Mr. Rafter:\nBetween November 4 and 8, 2013, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected\nTallgrass Interstate Gas Transmission, LLC’s (Tallgrass) Control Room Management\nprocedures in Lakewood, Colorado.\nOn the basis of the initial inspection, PHMSA identified apparent inadequacies within\nTallgrass’ Control Room Management (CRM) procedures, as described below:\n1. §192.631 Control Room Management\n(b) Roles and responsibilities. Each operator must define the roles and\nresponsibilities of a controller during normal, abnormal, and emergency operating\nconditions. To provide for a controller’s prompt and appropriate response to\noperating conditions, an operator must define each of the following:\n(1) A controller's authority and responsibility to make decisions and take actions\nduring normal operations.\n\n\n\nTallgrass did not establish adequate written procedures for defining the roles and\nresponsibilities of a controller as required by §192.631(b)(1). At the time of the inspection, the\nresponsibilities of all controllers were not specific and were not clearly defined. Tallgrass’\nControl Room Management procedures were inadequate because its Control Room\nManagement Plan did not clearly describe a detailed written process that defines the authority\nand responsibility of the controllers as required by §192.631(b)(1).\n2. §192.631 Control Room Management\n(b) Roles and responsibilities. Each operator must define the roles and\nresponsibilities of a controller during normal, abnormal, and emergency operating\nconditions. To provide for a controller's prompt and appropriate response to\noperating conditions, an operator must define each of the following:\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\nactions and communicate with others.\nTallgrass did not establish adequate written procedures to detail a controller’s role during an\nemergency as required by §192.631(b)(3). An operator’s procedures must specifically address\nthe controller’s responsibilities in the event the control room must be evacuated. At the time of\nthe inspection, Tallgrass’ CRM procedures were inadequate because the short term and long\nterm scenarios for Business Resumption Plan were not clearly defined, i.e., Tallgrass’ CRM\nprocedures need to be consistent for both short term and long term scenarios.\n3. §192.631 Control Room Management\n(b) Roles and responsibilities. Each operator must define the roles and\nresponsibilities of a controller during normal, abnormal, and emergency operating\nconditions. To provide for a controller's prompt and appropriate response to\noperating conditions, an operator must define each of the following:\n(4) A method of recording controller shift-changes and any hand- over of\nresponsibility between controllers.\nTallgrass did not establish adequate written procedures to address the method of recording\ncontroller shift changes as required by §192.631(b) (4). When a controller is unable to continue\nor assume responsibility for any reason, the procedure did not address what action must be\ntaken when the shift hand-over procedure includes alternative shift hand-over actions that\nspecifically address for this situation. At the time of the inspection, Tallgrass’ CRM\nprocedures were inadequate because the Shift Change Procedure did not address delayed shift\nchanges and there was no link to departmental policies.\n4. §192.631 Control Room Management\n(c) Provide adequate information. Each operator must provide its controllers\nwith the information, tools, processes and procedures necessary for the controllers\nto carry out the roles and responsibilities the operator has defined by performing\neach of the following:\n2\n\n\n\n(1) Implement sections 1, 4, 8, 9, 11.1, and 11.3 of API RP 1165\n(incorporated by reference, see § 192.7) whenever a SCADA system is added,\nexpanded or replaced, unless the operator demonstrates that certain provisions of\nsections 1, 4, 8, 9, 11.1, and 11.3 of API RP 1165 are not practical for the SCADA\nsystem used.\nTallgrass did not establish adequate written procedures for implementing the API RP 1165 as\nrequired by §192.631(c)(1). An operator must develop a written procedure to implement the\nAPI RP 1165 display standards to the SCADA systems that have been added, expanded, or\nreplaced since August 1, 2012. At the time of the inspection, Tallgrass’ CRM procedures were\ninadequate because the current displays and control system were leased from Kinder Morgan,\nand did fully meet the requirements of API 1165. The specifications for the new Tallgrass\nSCADA system addressed API 1165, but were specific to this one project and not to Tallgrass\nas a whole. A policy or procedure for API 1165 implementation needs to be created and\nimplemented that applies to Tallgrass’ company-wide CRM procedures.\n5. §192.631 Control Room Management\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.\nTallgrass did not establish adequate written procedures to address the shift lengths and schedule\nrotations for all controllers as required by §192.631(d)(1). At the time of the inspection,\nTallgrass’ CRM procedures were inadequate because there is no comprehensive plan that\naddressed identification of fatigue or addressed how fatigue risks will be reduced. With regard\nto minimizing interrupting the required 8 hours of continuous sleep, Tallgrass’ CRM\nprocedures specified that controllers would not be on-call. Leads were on-call, but would not\nbe if scheduled as a controller. This must be explicitly stated in the Fatigue Management Plan.\n6. §192.631 Control Room Management\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(3) Train controllers and supervisors to recognize the effects of fatigue.\nTallgrass did not establish adequate written procedures for recognizing the effects of fatigue as\nrequired by §192.631(d) (3). At the time of inspection, Tallgrass’ CRM procedures were\ninadequate because Tallgrass’ training records are only contracted to Tallgrass’ contractor,\nCircadian. Tallgrass managers and supervisors must also be able to recognize the effects of\nfatigue and that must be included in the Fatigue Management Plan.\n3\n\n\n\n7. §192.631 Control Room Management\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(4) Establish a maximum limit on controller hours-of-service, which may provide\nfor an emergency deviation from the maximum limit if necessary for the safe\noperation of a pipeline facility.\nTallgrass did not establish adequate written procedures to address a maximum limit on\ncontroller hours-of-service as required by §192.631(d)(4). At the time of inspection, Tallgrass’\nCRM procedures were inadequate because Tallgrass’ procedure did not contain an hours-of-\nservice (HOS) analysis. For shifts longer than 8 hours, countermeasures are made available,\nbut not mandated after the 9th hour. Specific fatigue countermeasures must be clearly described.\n8. §192.631 Control Room Management\n(e) Alarm management. Each operator using a SCADA system must have a\nwritten alarm management plan to provide for effective controller response to\nalarms. An operator'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.\nTallgrass did not establish adequate written procedures for reviewing SCADA safety-related\nalarm operations as required by §192.631(e) (1). At the time of the inspection, Tallgrass’ CRM\nprocedures were inadequate because the alarm review process was vague and response\npriorities were not clearly defined. The safety-related alarms must account for different alarm\ndesigns and all alarm types/priorities. A review of safety related alarms needs to account for\nindividual-specific controller qualification and performance. There is no requirement in the\nTallgrass CRM Plan that addresses how a controller reacts to an alarm on a specific basis as\nrequired by API 1167, paragraph 10.\n9. §192.631 Control Room Management\n(e) Alarm management. Each operator using a SCADA system must have a\nwritten alarm management plan to provide for effective controller response to\nalarms. An operator's plan must include provisions to:\n(5) 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 to\nexceed 15 months, that will assure controllers have sufficient time to analyze and\nreact to incoming alarms.\nTallgrass did not establish adequate written procedures for monitoring the content and volume\nof general activity as required by §192.631(e) (5). At the time of inspection, Tallgrass’ CRM\nprocedures were inadequate because the process of monitoring and analyzing general activity\nwas not sufficiently defined, and the criteria and metrics were not formalized in the Alarm\nManagement Plan. An operator’s procedure must have the means of determining that the\n4\n\n\n\ncontroller has sufficient time to analyze and react to incoming alarms. Tallgrass’ procedure\nhad no procedural requirement for documentation of criteria for controller performance per the\nrequirement of API RP 1167.\n10. §192.631 Control Room Management\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) Establish communications between control room representatives, operator's\nmanagement, and associated field personnel when planning and implementing\nphysical changes to pipeline equipment or configuration.\nTallgrass did not establish adequate written procedures to address the communications between\ncontrol room representatives, operator’s management, and associated field personnel as\nrequired by §192.631(f)(1). At the time of the inspection, Tallgrass’ CRM procedures were\ninadequate because they did not clearly describe the Control Room portion of Tallgrass’\nManagement of Change (MOC) procedures. Leads and supervisors viewed all MOC’s and\ndecide whether the CR is affected. This policy needs to be amended so that it is written into the\noverall MOC procedure.\n11. §192.631 Control Room Management\n(h) Training. Each operator must establish a controller training program and\nreview the training program content to identify potential improvements at least\nonce each calendar year, but at intervals not to exceed 15 months. An operator's\nprogram must provide for training each controller to carry out the roles and\nresponsibilities defined by the operator. In addition, the training program must\ninclude the following elements:\n(1) Responding to abnormal operating conditions likely to occur simultaneously or\nin sequence.\nTallgrass did not establish adequate written procedures for responding to abnormal operating\n(AO) conditions as required by §192.631(h) (1). An operator is required to establish and\nimplement a controller training program for each controller to carry out their roles and\nresponsibilities. At the time of the inspection, Tallgrass’ CRM procedures were inadequate\nbecause Tallgrass’ AO procedures did not consider simultaneous or sequential scenarios.\n12. §192.631 Control Room Management\n(i) Compliance validation. Upon request, operators must submit their procedures\nto PHMSA or, in the case of an intrastate pipeline facility regulated by a State, to\nthe appropriate State agency.\nTallgrass did not establish adequate written procedures to address the compliance validation as\nrequired by §192.631(i). An operator is required to have an individual that is responsible and\naccountable for compliance with requests from PHMSA or other applicable agencies. At the\ntime of the inspection, Tallgrass’ CRM procedures were inadequate because the CRM Plan did\n5\n\n\n\nnot list a specific individual or position responsible and accountable for compliance with\nrequests from PHMSA or other applicable agencies.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. Following\nthe initial inspection, Tallgrass demonstrated it had written CRM procedures in order to achieve\nregulatory compliance. Please submit these revised procedures for final agency review and\nacceptance.\nBe advised that all material you submit in response to this enforcement action is subject to\nbeing made publicly available. If you believe that any portion of your responsive material\nqualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete original\ndocument you must provide a second copy of the document with the portions you believe\nqualify for confidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b). If you do not respond\nwithin 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the\nallegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find\nfacts as alleged in this Notice without further notice to you and to issue a Final Order.\nIf your plans or procedures are found inadequate as alleged in this Notice, you may be ordered\nto amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.237). If you are\nnot contesting this Notice, we propose that you submit your amended procedures to my office\nwithin 30 days of receipt of this Notice. This may be extended by written request for good\ncause. Once the inadequacies identified herein have been addressed in your amended\nprocedures, this enforcement action will be closed.\nIt is requested (not mandated) that Tallgrass Intestate Gas Transmission, LLC maintain\ndocumentation of the safety improvement costs associated with fulfilling this Notice of\nAmendment (preparation/revision of plans, procedures) and submit the total to Chris Hoidal,\nDirector, Western Region, Pipeline and Hazardous Materials Safety Administration. In\ncorrespondence concerning this matter, please refer to CPF 5-2015-1003M and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\ncc: PHP-60 Compliance Registry\nPHP-500 J. Kenerson (#143316)\n6\n\n520151003M_closure letter_05112015_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMay 11, 2015\nMs. Jennifer Eckels\nCompliance Manager\nTallgrass Energy Partners\n370 Van Gordon Street\nLakewood, CO 80228\nCPF 5-2015-1003M\nDear Ms. Eckels:\nFrom November 4 through November 8, 2013, a representative from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,\nconducted an on-site pipeline safety inspection of Tallgrass procedures in Control Room\nManagement (CRM). As a result of the inspection, Tallgrass was issued a Notice of Amendment\non March 27, 2015, which proposed amendment of your CRM procedures.\nTallgrass submitted its amended procedures on May 1, 2015. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Kenerson","truncated":false,"body_characters":17921}