{"operation":"document","citation":"PHMSA GD.2023.01","title":"2023 Gas Distribution IA Question Set","source_type":"inspection","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2022-12-28","effective_on":"2022-12-28","summary":"PHMSA - Gas Distribution - GD.2023.01 IA Question Set - January 2023 Assessment and Repair - Integrity Assessment Via Pressure Test 1. Test Acceptance Criteria and Procedures Were test acceptance criteria and procedures/processes sufficient to","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-2023-gas-distribution-ia-question-set.json","markdown":"https://regulus.evalyn.ai/document/phmsa-2023-gas-distribution-ia-question-set.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-2023-gas-distribution-ia-question-set","source_url":"https://primis.phmsa.dot.gov/IA-Releases/ia-release-notes/notes/iac-fed.2023.01","body":"<<<PAGE 1>>>\n\nPHMSA - Gas Distribution - GD.2023.01 IA Question Set - January 2023\nAssessment and Repair - Integrity Assessment Via Pressure Test\n1. Test Acceptance Criteria and Procedures Were test acceptance criteria and procedures/processes sufficient to\nassure the basis for an acceptable pressure test? (AR.PTI.PRESSTESTACCEP.P) 192.503(a)\n(192.503(b);192.503(c);192.503(d);192.503(e);192.505(a);192.505(b);192.505(c);192.505(d);192.507(a);192.507(b);192.507(\nc);192.513(a);192.513(b);192.513(c);192.513(d))\nAssessment and Repair - Repair Criteria (O and M)\n1. Repair of Corroded Pipe Does the process give sufficient guidance for personnel to repair or replace pipe that has\ncorroded to an extent that there is no longer sufficient remaining strength in the pipe wall? (AR.RCOM.REPAIR.P) 192.605(b)(2)\n(192.487(a);192.487(b);192.489(a);192.489(b);192.491(c))\n2. Repair of Corroded Pipe Do records document the repair or replacement of pipe that has been internally corroded to\nan extent that there is not sufficient remaining strength in the pipe wall? (AR.RCOM.REPAIR.R) 192.491(c) (192.487;192.489)\n3. Field Inspection - Remedial Actions (OM) Is anomaly remediation and documentation of remediation adequate\nfor all segments? (AR.RCOM.REMEDIATIONOM.O) 192.487(a) (192.487(b);192.489)\nAssessment and Repair - Repair Methods and Practices\n1. Safety While Making Repairs Does the process ensure that repairs are made in a safe manner and are made so as\nto prevent damage to persons and property? (AR.RMP.SAFETY.P) 192.605(b)(9) (192.713(b))\n2. Prevention of Accidental Ignition Perform observations of selected locations to verify that adequate steps have\nbeen taken by the operator to minimize the potential for accidental ignition. (AR.RMP.IGNITION.O) 192.751(a)\n(192.751(b);192.751(c))\n3. Tapping Pipelines Under Pressure Is the process adequate for tapping pipelines under pressure?\n(AR.RMP.HOTTAP.P) 192.605(b)(1) (192.627)\nGD.2023.01 Page 1 of 79\n\n<<<PAGE 2>>>\n\nPHMSA - Gas Distribution - GD.2023.01 IA Question Set - January 2023\n4. Test Reinstated Service Lines Is the process adequate for the testing of disconnected service lines?\n(AR.RMP.TESTREINSTATE.P) 192.605(b) (192.725(a);192.725(b))\n5. Test Reinstated Service Lines From the review of records, did the operator properly test disconnected service lines?\n(AR.RMP.TESTREINSTATE.R) 192.603(b) (192.725(a);192.725(b))\nCRM, SCADA, and Leak Detection - General\n1. Control Room Management Criteria Do procedures adequately address the process and criteria to determine\nwhich facilities are control rooms? (CR.CRMGEN.CRMCRITERIA.P) 192.631(a)(2)\n2. Control Room Management Are CRM procedures formalized and controlled? (CR.CRMGEN.CRMMGMT.P)\n192.631(a)(2)\n3. Control Room Management Were procedures approved, in place, and implemented on or before the regulatory\ndeadline? (CR.CRMGEN.CRMIMPLEMENT.R) 192.631(a)(2)\n4. Control Room Management Are procedures readily available to controllers in the control room?\n(CR.CRMGEN.CRMPROCLOCATION.O) 192.631(a)(2)\nCRM, SCADA, and Leak Detection - Roles and Responsibilities\n1. Roles and Responsibilities Are there clear processes to describe each controller's physical domain of responsibility\nfor pipelines and other facility assets? (CR.CRMRR.RESPONSIBLE.P) 192.631(b)\n2. Roles and Responsibilities Are there provisions in place to assure that only qualified individuals may assume control\nat any console/desk? (CR.CRMRR.QUALCONTROL.P) 192.631(b)\nGD.2023.01 Page 2 of 79\n\n<<<PAGE 3>>>\n\nPHMSA - Gas Distribution - GD.2023.01 IA Question Set - January 2023\n3. Roles and Responsibilities If the physical domain of responsibility periodically changes, has a clear process been\nestablished to describe the conditions for when such a change occurs? (CR.CRMRR.DOMAINCHANGE.P) 192.631(b)\n4. Controller Authority (Abnormal Operations) Have processes been established to define the controllers'\nauthority and responsibilities when an abnormal operating condition is detected? (CR.CRMRR.AUTHORITYABNORMAL.P)\n192.631(b)(2)\n5. Roles and Responsibilities Do processes address a controller's role during temporary impromptu (unplanned)\nchanges in controller responsibilities? (CR.CRMRR.RESPCHANGE.P) 192.631(b)\n6. Roles and Responsibilities Do the defined roles and responsibilities require controllers to stay at the console to verify\nall SCADA commands that have been initiated are fulfilled, and that commands given via verbal communications are acknowledged\nbefore leaving the console for any reason? (CR.CRMRR.COMMANDVERIFY.P) 192.631(b)\n7. Overpressure Limits Are controllers aware of the current MAOPs of all pipeline segments for which they are\nresponsible, and have they been assigned the responsibility to maintain those pipelines at or below the MAOP?\n(CR.CRMRR.PRESSLIMITS.O) 192.631(b)(2) (192.619(a);192.631(e)(1))\n8. Controller Authority (Emergency Operations) Do processes define the controllers' authority and responsibility\nto make decisions, take actions, and communicate with others upon being notified of, or upon detection of, and during, an\nemergency or if a leak or rupture is suspected? (CR.CRMRR.AUTHORITYEMERGENCY.P) 192.631(b)(3) (192.615(a)(8);NTSB P-11-\n9)\n9. Control Center Evacuation Do processes specifically address the controller's responsibilities in the event the control\nroom must be evacuated? (CR.CRMRR.EVACUATION.P) 192.631(b)(3)\n10. Communication Failure Do processes specifically address the controller's responsibilities in the event of a SCADA\nsystem or data communications system failure impacting large sections of the controller's domain of responsibility?\n(CR.CRMRR.COMMSYSFAIL.P) 192.631(b)(3)\n11. Shift Change Process Have processes been established for the hand-over of responsibility that specify the type of\ninformation to be communicated to the oncoming shift? (CR.CRMRR.HANDOVER.P) 192.631(b)(4) (192.631(c)(5))\nGD.2023.01 Page 3 of 79\n\n<<<PAGE 4>>>\n\nPHMSA - Gas Distribution - GD.2023.01 IA Question Set - January 2023\n12. Shift Change Process Do observations indicate adequate hand-over of responsibility to the oncoming shift?\n(CR.CRMRR.HANDOVER.O) 192.631(b)(4) (192.631(c)(5))\n13. Shift Change Process - Documentation Do processes require that records document the hand-over of\nresponsibility, document the time the actual hand-over of responsibility occurs, and the key information and topics that were\ncommunicated during the hand-over? (CR.CRMRR.HANDOVERDOC.P) 192.631(b)(4) (192.631(c)(5))\n14. Shift Change Process - Documentation Are there records that document the hand-over of responsibility,\ndocument the time the actual hand-over of responsibility occurs, and the key information and topics that were communicated\nduring the hand-over? (CR.CRMRR.HANDOVERDOC.R) 192.631(b)(4) (192.631(c)(5))\n15. Shift Change Process - Overlap Do processes require the controllers to discuss recent and impending important\nactivities ensuring adequate overlap? (CR.CRMRR.HANDOVEROVERLAP.P) 192.631(b)(4)\n16. Shift Change Process - Handover Alternative When a controller is unable to continue or assume\nresponsibility for any reason, do the shift hand-over processes include alternative shift hand-over actions that specifically address\nthis situation? (CR.CRMRR.HANDOVERALTERNATIVE.P) 192.631(b)(4)\n17. Shift Change Process - Unattended Consoles Has the operator established an adequate process for\noccasions when the console is left temporarily unattended for any reason? (CR.CRMRR.UNATTENDCONSOLE.P) 192.631(b)(4)\n18. Shift Change Process - Console Coverage Do processes maintain adequate console coverage during shift\nhand-over? (CR.CRMRR.CONSOLECOVERAGE.P) 192.631(b)(4)\n19. Authority to Supersede Controller Action Disallowed - Controllers Do processes disallow others to\nhave authority to direct or supersede the specific technical actions of a controller? (CR.CRMRR.OTHERAUTHORITYDISALLOW.P)\n192.631(b)(5)\n20. Authority to Supersede Controller Action Disallowed - Controllers Do records indicate that the\npolicy disallowing others to have authority to direct or supersede the specific technical actions of a controller has been\ncommunicated to controllers and others? (CR.CRMRR.OTHERAUTHORITYDISALLOW.R) 192.631(b)(5)\nGD.2023.01 Page 4 of 79\n\n<<<PAGE 5>>>\n\nPHMSA - Gas Distribution - GD.2023.01 IA Question Set - January 2023\n21. Authority to Supersede Controller Action Disallowed - Controllers Are controllers aware of, and can\nreference, processes that disallow others to have authority to direct or supersede the specific technical actions of a controller?\n(CR.CRMRR.OTHERAUTHORITYDISALLOW.O) 192.631(b)(5)\n22. Others with Authority Qualification - Controllers Does the process result in identification of required\nqualification elements for those authorized to direct or supersede the technical actions of a controller that are sufficient for those\nindividuals to understand the implications of the scope of potential actions? (CR.CRMRR.OTHERAUTHORITYQUAL.P) 192.631(b)(5)\n23. Others with Authority Qualification - Controllers Do records indicate that others given authority to direct\nor supersede the specific technical actions of a controller were qualified? (CR.CRMRR.OTHERAUTHORITYQUAL.R) 192.631(b)(5)\n24. Others with Authority Implementation - Controllers Is the process defined with respect to the details of\nhow those authorized to direct or supersede the technical actions of a controller are to implement their authority?\n(CR.CRMRR.OTHERAUTHORITYIMPLEMENT.P) 192.631(b)(5)\n25. Others with Authority List - Controllers Is a list of individuals with authority to direct or supersede the\ntechnical actions of a controller readily available to controllers? (CR.CRMRR.OTHERAUTHORITYLIST.R) 192.631(b)(5)\n26. Others with Authority Implementation - Controllers Do records adequately document occurrences of\nwhen others authorized to direct or supersede the technical actions of a controller have done so?\n(CR.CRMRR.OTHERAUTHORITYIMPLEMENT.R) 192.631(b)(5)\n27. Others with Authority Implementation - Controllers Do others authorized to direct or supersede the\ntechnical actions of a controller demonstrate an understanding of the process to implement this authority?\n(CR.CRMRR.OTHERAUTHORITYIMPLEMENT.O) 192.631(b)(5)\nGD.2023.01 Page 5 of 79\n\n<<<PAGE 6>>>\n\nPHMSA - Gas Distribution - GD.2023.01 IA Question Set - January 2023\nCRM, SCADA, and Leak Detection - Supervisory Control and Data\nAcquisition\n1. Adequate Information (API 1165 Compliance) Do processes clearly define the types of changes to the\nSCADA system(s) that constitute additions, expansions, or replacements under the meaning of the CRM rule?\n(CR.SCADA.SYSTEMMOC.P) 192.631(c)(1)\n2. SCADA Displays Are there written processes to implement the API RP 1165 display standards to the SCADA systems that\nhave been added, expanded, or replaced since August 1, 2012? (CR.SCADA.DISPLAYCONFIG.P) 192.631(c)(1)\n3. SCADA API RP 1165 Human Factors Has section 4 of API RP 1165 regarding human factors engineering been\nimplemented? (CR.SCADA.1165HUMANFACTORS.O) 192.631(c)(1)\n4. SCADA Display Objects Has section 8 of API RP 1165 regarding display object characteristics been implemented?\n(CR.SCADA.DISPLAYOBJECTS.O) 192.631(c)(1)\n5. SCADA Display Dynamics Has Section 9 of API RP 1165 regarding display object dynamics been implemented?\n(CR.SCADA.DISPLAYDYNAMICS.R) 192.631(c)(1)\n6. SCADA Administration Have applicable paragraphs of section 11 of API RP 1165 administration been implemented?\n(CR.SCADA.ADMINISTRATION.R) 192.631(c)(1)\n7. SCADA Impracticality If any/all applicable paragraph(s) of API RP 1165 have not been implemented, has it been\ndemonstrated and documented that the unimplemented provisions are impractical for the SCADA system used?\n(CR.SCADA.1165IMPRACTICAL.R) 192.631(c)(1)\n8. Set Points Does the process adequately define safety-related points? (CR.SCADA.SETPOINT.P) 192.631(c)(2)\n9. Set Points Do records indicate safety-related points have been adequately implemented? (CR.SCADA.SETPOINT.R)\n192.631(c)(2)\nGD.2023.01 Page 6 of 79\n\n<<<PAGE 7>>>\n\nPHMSA - Gas Distribution - GD.2023.01 IA Question Set - January 2023\n10. Point-to-Point Verification Are there adequate processes to define and identify the circumstances which require a\npoint-to-point verification? (CR.SCADA.POINTVERIFY.P) 192.631(c)(2)\n11. Point-to-Point Verification Have required point-to-point verifications been performed? (CR.SCADA.POINTVERIFY.R)\n192.631(c)(2)\n12. Point-to-Point Verification Extent Are there adequate processes for the thoroughness of the point-to-point\nverification? (CR.SCADA.POINTVERIFYEXTENT.P) 192.631(c)(2)\n13. Point-to-Point Verification Extent Do records demonstrate adequate thoroughness of the point-to-point\nverification? (CR.SCADA.POINTVERIFYEXTENT.R) 192.631(c)(2)\n14. Point-to-Point Verification Interval Is there an adequate process for defining when the point-to-point\nverification must be completed? (CR.SCADA.POINTVERFIYINTVL.P) 192.631(c)(2)\n15. Point-to-Point Verification Interval Do records indicate the point-to-point verification has been completed at\nthe required intervals? (CR.SCADA.POINTVERFIYINTVL.R) 192.631(c)(2)\n16. Point-to-Point Verification Are point-to-point verifications performed adequately when required?\n(CR.SCADA.POINTVERIFY.O) 192.631(c)(2)\n17. Internal Communication Plan Has an internal communication plan been established and implemented that is\nadequate to manually operate the pipeline during a SCADA failure/outage? (CR.SCADA.COMMPLAN.P) 192.631(c)(3)\n18. Internal Communication Plan Has the internal communication plan been tested and verified for manual operation\nof the pipeline safely at least once each calendar year but at intervals not exceeding 15 months? (CR.SCADA.COMMPLAN.R)\n192.631(c)(3)\n19. Backup SCADA System Is there a backup SCADA system? (CR.SCADA.BACKUPSCADA.O) 192.631(c)\nGD.2023.01 Page 7 of 79\n\n<<<PAGE 8>>>\n\nPHMSA - Gas Distribution - GD.2023.01 IA Question Set - January 2023\n20. Backup SCADA Development Has the use of the backup SCADA system for development work been defined?\n(CR.SCADA.BACKUPSCADADEV.P) 192.631(c)(4)\n21. Backup SCADA Testing Is the backup SCADA system required to be tested at least once each calendar year at\nintervals not to exceed 15 months? (CR.SCADA.BACKUPSCADATEST.P) 192.631(c)(4)\n22. Backup SCADA Testing Is the backup SCADA system tested at least once each calendar year at intervals not to\nexceed 15 months? (CR.SCADA.BACKUPSCADATEST.R) 192.631(c)(4)\n23. Backup SCADA Verification Is testing required to verify adequate processes are in place for decision-making and\ninternal communications to successfully implement a transition from primary SCADA to backup SCADA, and back to primary\nSCADA? (CR.SCADA.BACKUPSCADAVERIFY.P) 192.631(c)(4)\n24. Backup SCADA Verification Does the testing verify that there are adequate processes in place for decision-making\nand internal communications to successfully implement a transition from primary SCADA to backup SCADA, and back to primary\nSCADA? (CR.SCADA.BACKUPSCADAVERIFY.R) 192.631(c)(4)\n25. Backup SCADA Adequacy If the back-up SCADA system is not designed to handle all the functionality of the main\nSCADA system, does the testing determine whether there are adequate procedures in place to account for displaced and/or\ndifferent available functions during back-up operations? (CR.SCADA.BACKUPSCADAADEQUACY.R) 192.631(c)(4)\n26. Backup SCADA Transfer Do processes adequately address and test the logistics of transferring control to a backup\ncontrol room? (CR.SCADA.BACKUPSCADATRANSFER.P) 192.631(c)(4)\n27. Backup SCADA Return to Primary Do procedures adequately address and test the logistics of returning\noperations back to the primary control room? (CR.SCADA.BACKUPSCADARETURN.P) 192.631(c)(4)\n28. Backup SCADA Testing Is a representative sampling of critical functions in the back-up SCADA system being tested\nto ensure proper operation in the event the backup system is needed? (CR.SCADA.BACKUPSCADAFUNCTIONS.R) 192.631(c)(4)\nGD.2023.01 Page 8 of 79\n\n<<<PAGE 9>>>\n\nPHMSA - Gas Distribution - GD.2023.01 IA Question Set - January 2023\nCRM, SCADA, and Leak Detection - Fatigue Management\n1. Fatigue Mitigation Does the fatigue mitigation process or procedures (plan) identify operator-specific fatigue risks?\n(CR.CRMFM.FATIGUEMITIGATION.P) 192.631(d)\n2. Fatigue Risk Reduction Does the fatigue mitigation plan adequately address how the program reduces the risk\nassociated with controller fatigue? (CR.CRMFM.FATIGUERISKS.P) 192.631(d)\n3. Fatigue Quantification Do processes require that the potential contribution of controller fatigue to incidents and\naccidents be quantified during investigations? (CR.CRMFM.FATIGUEQUANTIFY.P) 192.631(d)\n4. Fatigue Mitigation Manager Is there a designated fatigue risk manager who is responsible and accountable for\nmanaging fatigue risk and fatigue countermeasures, and someone (perhaps the same person) that is authorized to review and\napprove HOS emergency deviations? (CR.CRMFM.FATIGUEMANAGER.P) 192.631(d)\n5. Scheduled Shift Length Is the scheduled shift length less than or equal to 12 hours (not including shift hand-over) or\nis there a documented technical basis to show that shift lengths and schedule rotations are adequate to provide controllers off-\nduty time sufficient to achieve 8 hours of continuous sleep? (CR.CRMFM.SHIFTLENGTH.R) 192.631(d)(1)\n6. Establishing Shift Length Does the operator factor in all time the individual is working for the company when\nestablishing shift lengths and schedule rotations or is there a documented technical basis to show that shift lengths and schedule\nrotations are adequate to provide controllers off-duty time sufficient to achieve 8 hours of continuous sleep?\n(CR.CRMFM.SHIFTLENGTHTIME.R) 192.631(d)(1)\n7. Scheduled Time Off Between Shifts Are all scheduled periods of time off at least one hour longer than 8 hours\nplus commute time or is there a documented technical basis to show that shift lengths and schedule rotations are adequate to\nprovide controllers off-duty time sufficient to achieve 8 hours of continuous sleep? (CR.CRMFM.SCHEDULEDTIMEOFF.R)\n192.631(d)(1)\n8. On Call Controllers For controllers who are on call, do processes minimize interrupting the required 8 hours of\ncontinuous sleep or require a documented technical basis to show that shift lengths and schedule rotations are adequate to\nprovide controllers off-duty time sufficient to achieve 8 hours of continuous sleep? (CR.CRMFM.ONCALLCONTROLLER.P)\n192.631(d)\nGD.2023.01 Page 9 of 79\n\n<<<PAGE 10>>>\n\nPHMSA - Gas Distribution - GD.2023.01 IA Question Set - January 2023\n9. On Call Controllers For controllers who are on call, does the operator minimize interrupting the required 8 hours of\ncontinuous sleep or is there a documented technical basis to show that shift lengths and schedule rotations are adequate to\nprovide controllers off-duty time sufficient to achieve 8 hours of continuous sleep? (CR.CRMFM.ONCALLCONTROLLER.R)\n192.631(d)(1)\n10. Maximum Hours of Service Do processes limit the maximum HOS limit in any sliding 7-day period to no more than\n65 hours or is there a documented technical basis to show a reduction of the risk associated with controller fatigue?\n(CR.CRMFM.MAXHOS.P) 192.631(d)(4)\n11. Minimum Time Off After HOS Limit Reached After reaching the HOS limit in any sliding 7-day period, is the\nminimum time off at least 35 hours or is there a documented technical basis to show a reduction of the risk associated with\ncontroller fatigue? (CR.CRMFM.MINTIMEOFF.P) 192.631(d)(4)\n12. Documented Time Schedule Is there a formal system to document all scheduled and unscheduled HOS worked,\nincluding overtime and time spent performing duties other than control room duties? (CR.CRMFM.DOCSCHEDULE.P) 192.631(d)(4)\n13. Time Off Following Successive Days Worked For normal business hour type operations (i.e., five days per\nweek), are no more than five days worked in succession before at least two days off? (CR.CRMFM.DAYSOFF.P) 192.631(d)(4)\n14. Day Only Work Hours For normal business hour type operations (i.e., five days per week), do records indicate shift\nstart times no earlier than 6:00 a.m. and shift end times no later than 7:00 p.m.? (CR.CRMFM.WORKHOURS.R) 192.631(d)(4)\n15. Fatigue Countermeasures For shifts longer than 8 hours, have specific fatigue countermeasures been implemented\nfor the ninth and beyond hours? (CR.CRMFM.FATIGUECOUNTERMEASURES.P) 192.631(d)(4)\n16. Daily HOS Limit Do processes limit the daily maximum HOS limit no more than 14 hours in any sliding 24-hour period?\n(CR.CRMFM.DAILYHOSLIMIT.P) 192.631(d)(4)\n17. Number of Qualified Controllers Do operations include a sufficient number of qualified controllers?\n(CR.CRMFM.CONTROLLERNUMBERS.O) 192.631(d)\nGD.2023.01 Page 10 of 79\n\n<<<PAGE 11>>>\n\nPHMSA - Gas Distribution - GD.2023.01 IA Question Set - January 2023\n18. Off Duty Hours When Limits Reached Do processes ensure that controllers are provided with at least thirty-five\n(35) continuous off-duty hours when limits are reached following the most recent 35-hour (minimum) off-duty rest period or is\nthere a documented technical basis to show that the maximum limit on controller HOS is adequate to reduce the risk associated\nwith controller fatigue? (CR.CRMFM.OFFDUTYHOURS.P) 192.631(d)(4)\n19. Shift Holdover Does the shift holdover process conform to shift holdover guidelines or is there a documented technical\nbasis to show that the maximum limit on controller HOS is adequate to reduce the risk associated with controller fatigue?\n(CR.CRMFM.SHIFTHOLDOVER.P) 192.631(d)(4)\n20. Specific Fatigue Countermeasures During Times of Heightened Risk Do processes require specific\nfatigue countermeasures during applicable time periods, or is there a documented technical basis to show that the maximum limit\non controller HOS is adequate to reduce the risk associated with controller fatigue? (CR.CRMFM.SPECIFICCOUNTERMEASURES.P)\n192.631(d)(4)\n21. Deviations from HOS Limits Is there a formal process for approving deviations from the maximum HOS limits?\n(CR.CRMFM.HOSDEVIATIONS.P) 192.631(d)(4)\n22. Fatigue Education Does the program require that fatigue education/training is required for all controllers and control\nroom supervisors? (CR.CRMFM.FATIGUEEDUCATE.P) 192.631(d)(2) (192.631(d)(3))\n23. Fatigue Education Is fatigue education/training documented for all controllers and control room supervisors?\n(CR.CRMFM.FATIGUEEDUCATE.R) 192.631(d)(2) (192.631(d)(3))\n24. Review of Fatigue Education/Training Program Effectiveness Do processes require that the\neffectiveness of the fatigue education/training program be reviewed at least once each calendar year, not to exceed 15 months?\n(CR.CRMFM.FATIGUEREVIEW.P) 192.631(d)(2) (192.631(d)(3);192.605(a))\n25. Fatigue Mitigation Strategies Does fatigue education address fatigue mitigation strategies (countermeasures)?\n(CR.CRMFM.FATIGUESTRATEGY.P) 192.631(d)(2)\n26. Off-Duty Activity Impact on Fatigue Does fatigue education address how off-duty activities contribute to\nfatigue? (CR.CRMFM.OFFDUTY.P) 192.631(d)(2)\nGD.2023.01 Page 11 of 79\n\n<<<PAGE 12>>>\n\nPHMSA - Gas Distribution - GD.2023.01 IA Question Set - January 2023\n27. Fatigue Training Content Is the content of fatigue training adequate for training controllers and supervisors to\nrecognize the effects of fatigue? (CR.CRMFM.FATIGUECONTENT.P) 192.631(d)(3)\n28. Fatigue Training Content Has controller and supervisor training to recognize the effects of fatigue been\ndocumented? (CR.CRMFM.FATIGUECONTENT.R) 192.631(d)(3)\nCRM, SCADA, and Leak Detection - Alarm Management\n1. Alarm Procedures Is the alarm management plan a formal process that specifically identifies critical topical areas\nincluded in the program? (CR.CRMAM.ALARM.P) 192.631(e)\n2. Alarm Malfunction Is there a process to identify and correct inaccurate or malfunctioning alarms?\n(CR.CRMAM.ALARMMALFUNCTION.P) 192.631(e)(1)\n3. Alarm Review Does the review of safety-related alarms account for different alarm designs and all alarm types/priorities?\n(CR.CRMAM.ALARMREVIEW.P) 192.631(e)(1)\n4. Controller SCADA Performance Does the review of safety-related alarms account for console differences that could\naffect individual-specific controller qualification and performance? (CR.CRMAM.CONTROLLERPERFORMANCE.P) 192.631(h)\n(192.631(e)(1))\n5. Managing Stale or Unreliable Data Does the review of safety-related alarms include specific procedures and\npractices for managing stale or unreliable data? (CR.CRMAM.STALEDATA.P) 192.631(e)(1)\n6. Monthly Analysis of SCADA Data Do processes require the monthly identification, recording, review, and analysis\nof points that have been taken off scan, 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 activities?\n(CR.CRMAM.MONTHLYANALYSIS.P) 192.631(e)(2)\nGD.2023.01 Page 12 of 79\n\n<<<PAGE 13>>>\n\nPHMSA - Gas Distribution - GD.2023.01 IA Question Set - January 2023\n7. Correction of SCADA Problems Does the alarm management plan include a process for promptly correcting\nidentified problems and for returning these points to service? (CR.CRMAM.PROBLEMCORRECTION.P) 192.631(e)(2)\n8. Alarm Point Verification Do records verify that monthly reviews and analysis of alarm points have been performed?\n(CR.CRMAM.ALARMVERIFY.R) 192.631(e)(2)\n9. Alarm Setpoint Process Is there a formal process to determine the correct alarm setpoint values and alarm\ndescriptions? (CR.CRMAM.ALARMSETPOINTS.P) 192.631(e)(3)\n10. Controls on SCADA Settings Have procedures been established to clearly address how and to what degree\ncontrollers can change alarm limits or setpoints, or inhibit alarms, or take points off-scan? (CR.CRMAM.SETTINGCONTROL.P)\n192.631(e)(3)\n11. Alarm Value Verification Do records demonstrate verification of correct safety-related alarm set-point values and\nalarm descriptors when associated field instruments are calibrated or changed and at least once each calendar year, but at\nintervals not to exceed 15 months? (CR.CRMAM.ALARMVALUEVERIFY.R) 192.631(e)(3)\n12. Alarm Management Plan Review Are there processes to review the alarm management plan at least once each\ncalendar year, but at intervals not exceeding 15 months, in order to determine the effectiveness of the plan?\n(CR.CRMAM.PLANREVIEW.P) 192.631(e)(4)\n13. Alarm Management Plan Review Do records indicate review of the alarm management plan at least once each\ncalendar year, but at intervals not exceeding 15 months, in order to determine the effectiveness of the plan?\n(CR.CRMAM.PLANREVIEW.R) 192.631(e)(4)\n14. Measuring Work Load Does the CRM program have a means of identifying and measuring the work load (content and\nvolume of general activity) being directed to an individual controller? (CR.CRMAM.WORKLOAD.P) 192.631(e)(5)\n15. Monitoring Work Load Is the process of monitoring and analyzing general activity comprehensive?\n(CR.CRMAM.WORKLOADMONITORING.P) 192.631(e)(5)\nGD.2023.01 Page 13 of 79\n\n<<<PAGE 14>>>\n\nPHMSA - Gas Distribution - GD.2023.01 IA Question Set - January 2023\n16. Controller Reaction to Incoming Alarms Does the process have a means of determining that the controller has\nsufficient time to analyze and react to incoming alarms? (CR.CRMAM.CONTROLLERREACTION.P) 192.631(e)(5)\n17. Analysis of Controller Performance Has an analysis been performed to determine if controller(s) performance is\ncurrently adequate? (CR.CRMAM.PERFORMANCEANALYSIS.R) 192.631(e)(5)\n18. Alarm Deficiency Resolution Is there a process to address how deficiencies found in implementing 192.631(e)(1)\nthrough 192.631(e)(5) will be resolved? (CR.CRMAM.DEFICIENCIES.P) 192.631(e)(6)\n19. Alarm Management Deficiencies Do records indicate deficiencies found in implementing 192.631(e)(1) through\n192.631(e)(5) have been resolved? (CR.CRMAM.DEFICIENCIES.R) 192.631(e)(6)\nCRM, SCADA, and Leak Detection - Change Management\n1. Field Equipment Changes Is there a process to assure changes in field equipment that could affect control room\noperations are coordinated with the control room personnel? (CR.CRMCMGT.EQUIPMENTCHANGES.P) 192.631(f)(1)\n2. Controller Participation in System Changes Are control room representative(s) required to participate in\nmeetings where changes that could directly or indirectly affect the hydraulic performance or configuration of the pipeline (including\nroutine maintenance and repairs) are being considered, designed and implemented? (CR.CRMCMGT.CONTROLLERPARTICIPATE.P)\n192.631(f)(1) (192.631(f)(3))\n3. Controller Participation in System Changes Do records indicate that control room representative(s) participate\nin meetings where changes that could directly or indirectly affect the hydraulic performance or configuration of the pipeline\n(including routine maintenance and repairs) are being considered, designed and implemented?\n(CR.CRMCMGT.CONTROLLERPARTICIPATE.R) 192.631(f)(1) (192.631(f)(3))\n4. Emergency Contact with Control Room Is there a process requiring field personnel and SCADA support\npersonnel to contact the control room when emergency conditions exist? (CR.CRMCMGT.EMERGENCYCONTACT.P) 192.631(f)(2)\nGD.2023.01 Page 14 of 79\n\n<<<PAGE 15>>>\n\nPHMSA - Gas Distribution - GD.2023.01 IA Question Set - January 2023\n5. Coordination of Field Changes Does the process require field personnel and SCADA support personnel to contact\nthe control room when making field changes (for example, moving a valve) that affect control room operations?\n(CR.CRMCMGT.FIELDCONTACT.P) 192.631(f)(2)\n6. Coordination of Field Changes Do records indicate field personnel and SCADA support personnel contacted the\ncontrol room when making field changes (for example, moving a valve) that affect control room operations?\n(CR.CRMCMGT.FIELDCHANGES.R) 192.631(f)(2)\nCRM, SCADA, and Leak Detection - Operating Experience\n1. Reportable Incident (Review) Is there a formal, structured approach for reviewing and critiquing reportable events\nto identify lessons learned? (CR.CRMEXP.REPORTABLEINCIDENTREVIEW.P) 192.631(g)(1)\n2. Reportable Incident (Review) Do records indicate reviews of reportable events specifically analyzed all contributing\nfactors to determine if control room actions contributed to the event, and corrected any deficiencies?\n(CR.CRMEXP.REPORTABLEINCIDENTREVIEW.R) 192.631(g)(1)\n3. Lessons Learned Does the program require training on lessons learned from a broad range of events (reportable\nincidents/accidents, near misses, leaks, operational and maintenance errors, etc.), even though the control room may not have\nbeen at fault? (CR.CRMEXP.LESSONSLEARNED.P) 192.631(g)(2) (192.631(b)(5))\n4. Lessons Learned Has operating experience review training been conducted on lessons learned from a broad range of\nevents (reportable incidents/accidents, near misses, leaks, operational and maintenance errors, etc.)?\n(CR.CRMEXP.LESSONSLEARNED.R) 192.631(g)(2) (192.631(b)(5))\nCRM, SCADA, and Leak Detection - Training\n1. Controller Training Program Has a controller training program been established to provide training for each\ncontroller to carry out their roles and responsibilities? (CR.CRMTRAIN.CONTROLLERTRAIN.P) 192.631(h)\nGD.2023.01 Page 15 of 79\n\n<<<PAGE 16>>>\n\nPHMSA - Gas Distribution - GD.2023.01 IA Question Set - January 2023\n2. Controller Training Program Has a controller training program been implemented to provide training for each\ncontroller to carry out their roles and responsibilities? (CR.CRMTRAIN.CONTROLLERTRAIN.R) 192.631(h)\n3. Training Program Review Have processes been established to review the controller training program content to\nidentify potential improvements at least once each calendar year, but at intervals not to exceed 15 months?\n(CR.CRMTRAIN.TRAININGREVIEW.P) 192.631(h)\n4. Training Program Review Have processes been implemented to review the controller training program content to\nidentify potential improvements at least once each calendar year, but at intervals not to exceed 15 months?\n(CR.CRMTRAIN.TRAININGREVIEW.R) 192.631(h)\n5. Content of Training Program Does training content address all required material, including training each controller\nto carry out the roles and responsibilities that were defined by the operator? (CR.CRMTRAIN.TRAININGCONTENT.R) 192.631(h)\n6. List of AOCs for Training Has a list of the abnormal operating conditions that are likely to occur simultaneously or in\nsequence been established? (CR.CRMTRAIN.AOCLIST.R) 192.631(h)(1)\n7. Controller Training and Qualification Does the training program provide controller training on recognizing and\nresponding to abnormal operating conditions that are likely to occur simultaneously or in sequence?\n(CR.CRMTRAIN.TRAININGABNORMAL.P) 192.631(h)(1)\n8. Controller Training and Qualification Do records indicate the training program used a simulator or tabletop\nexercises to train controllers how to recognize and respond to abnormal operating conditions? (CR.CRMTRAIN.TRAINING.R)\n192.631(h)(2)\n9. Controller Training and Qualification Does the training program use a simulator or tabletop exercises to train\ncontrollers how to recognize and respond to abnormal operating conditions? (CR.CRMTRAIN.TRAINING.O) 192.631(h)(2)\n10. Communication Training Does the CRM program train controllers on their responsibilities for communication under\nthe operator's emergency response procedures? (CR.CRMTRAIN.COMMUNICATIONTRAINING.P) 192.631(h)(3)\nGD.2023.01 Page 16 of 79\n\n<<<PAGE 17>>>\n\nPHMSA - Gas Distribution - GD.2023.01 IA Question Set - January 2023\n11. Working Knowledge of Pipeline System Does the training program provide controllers a working knowledge of\nthe pipeline system, especially during the development of abnormal operating conditions? (CR.CRMTRAIN.SYSKNOWLEDGE.P)\n192.631(h)(4)\n12. List of Infrequently Used Pipeline Setups Has a list of pipeline operating setups that are periodically (but\ninfrequently) used been established? (CR.CRMTRAIN.INFREQOPSLIST.R) 192.631(h)(5)\n13. Review of Procedures Prior to Use Do processes specify that, for pipeline operating set-ups that are periodically\n(but infrequently) used, the controllers must be provided an opportunity to review relevant procedures in advance of their use?\n(CR.CRMTRAIN.INFREQOPSREVIEW.P) 192.631(h)(5)\n14. Control Room Team Training - Personnel Do processes establish who, regardless of location, operationally\ncollaborates with control room personnel? (CR.CRMTRAIN.TEAMTRAINPERSONNEL.P) 192.631(h)(6)\n15. Control Room Team Training - Frequency Do processes define the frequency of new and recurring team\ntraining? (CR.CRMTRAIN.TEAMTRAINFREQ.P) 192.631(h)(6)\n16. Control Room Team Training - Completeness Do processes address all operational modes and operational\ncollaboration/control? (CR.CRMTRAIN.TEAMTRAINCOMPLETE.P) 192.631(h)(6)\n17. Control Room Team Training - Operational Experience Do processes include incorporation of lessons\nlearned from actual historical events and other oil-gas industry events? (CR.CRMTRAIN.TEAMTRAINEXPERIENCE.P) 192.631(h)(6)\n18. Control Room Team Training - Exercises Do records indicate that training exercises were adequate and\ninvolved at least one qualified controller? (CR.CRMTRAIN.TEAMTRAINEXERCISE.R) 192.631(h)(6)\n19. Control Room Team Training - Exercises Does implementation of a control room team exercise demonstrate\nperformance in accordance with regulatory and process requirements? (CR.CRMTRAIN.TEAMTRAINEXERCISE.O) 192.631(h)(6)\nGD.2023.01 Page 17 of 79\n\n<<<PAGE 18>>>\n\nPHMSA - Gas Distribution - GD.2023.01 IA Question Set - January 2023\n20. Control Room Team Training - Identified Individuals Do records demonstrate that individuals identified\nas of January 23, 2018 received team training by January 23, 2019? (CR.CRMTRAIN.TEAMTRAINIDENTINDIVIDUAL.R)\n192.631(h)(6)\nCRM, SCADA, and Leak Detection - Compliance Validation and\nDeviations\n1. Submittal of Procedures Are there adequate processes to assure that the operator is responsive to requests from\napplicable agencies to submit their CRM procedures? (CR.CRMCOMP.SUBMITPROCEDURES.P) 192.631(i)\n2. Record of Procedure Submittals Has the operator been responsive to requests from applicable agencies to submit\ntheir CRM procedures? (CR.CRMCOMP.SUBMITPROCEDURES.R) 192.631(i)\n3. CRM Coordinator Is there an individual that is responsible and accountable for compliance with requests from PHMSA or\nother applicable agencies? (CR.CRMCOMP.CRMCOORDINATOR.R) 192.631(i)\n4. CRM Records Management Are records management processes adequate to assure records are sufficient to\ndemonstrate compliance with the CRM rule? (CR.CRMCOMP.RECORDS.P) 192.631(j)(1)\n5. CRM Records Are records sufficient to demonstrate compliance with the CRM rule? (CR.CRMCOMP.RECORDS.R)\n192.631(j)(1)\n6. Electronic Records Are electronic records properly stored, safeguarded, and readily retrievable?\n(CR.CRMCOMP.ELECTRONICRECORDS.R) 192.631(j)(1)\n7. CRM Deviations Are there processes to demonstrate and provide a documented record that every deviation from any\nCRM rule requirement was necessary for safe operation? (CR.CRMCOMP.DEVIATIONS.P) 192.631(j)(2)\nGD.2023.01 Page 18 of 79\n\n<<<PAGE 19>>>\n\nPHMSA - Gas Distribution - GD.2023.01 IA Question Set - January 2023\n8. Deviation Records Were all deviations documented in a way that demonstrates they were necessary for safe operation?\n(CR.CRMCOMP.DEVIATIONS.R) 192.631(j)(2)\nDesign and Construction - Construction\n1. Plastic Pipe Joints Does the process require plastic pipe joints to be designed and installed in accordance with 192.281?\n(DC.CO.PLASTICJOINT.P) 192.273(b) (192.281(a);192.281(b);192.281(c);192.281(d);192.281(e);192.303)\n2. Plastic pipe - Qualifying Joining Procedures Does the process require plastic pipe joining procedures to be\nqualified in accordance with §192.283, prior to making plastic pipe joints? (DC.CO.PLASTICJOINTPROCEDURE.P) 192.273(b)\n(192.283(a);192.283(b);192.283(c))\n3. Plastic pipe - Qualifying Joining Procedures Have plastic pipe joining procedures been qualified in accordance\nwith 192.283? (DC.CO.PLASTICJOINTPROCEDURE.R) 192.273(b) (192.283(a);192.283(b);192.283(c))\n4. Plastic pipe - Qualifying Personnel to Make Joints Is a process in place to ensure that personnel making\njoints in plastic pipelines are qualified? (DC.CO.PLASTICJOINTQUAL.P) 192.285(d) (192.285(a);192.285(b);192.285(c);192.805)\n5. Plastic pipe - Qualifying Personnel to Make Joints Do records indicate persons making joints in plastic\npipelines are qualified in accordance with 192.285? (DC.CO.PLASTICJOINTQUAL.R) 192.285(d)\n(192.285(a);192.285(b);192.285(c);192.807(a);192.807(b))\n6. Qualification of Personnel Inspecting Joints in Plastic Pipelines Is a process in place to assure that\npersons who inspect joints in plastic pipes are qualified? (DC.CO.PLASTICJOINTINSP.P) 192.287 (192.805(h))\n7. Qualification of Personnel Inspecting Joints in Plastic Pipelines Do records indicate persons inspecting\nthe making of plastic pipe joints have been qualified? (DC.CO.PLASTICJOINTINSP.R) 192.287 (192.807(a);192.807(b))\nGD.2023.01 Page 19 of 79\n\n<<<PAGE 20>>>\n\nPHMSA - Gas Distribution - GD.2023.01 IA Question Set - January 2023\n8. Trenchless Installation of Plastic Transmission and Main Pipelines For plastic pipe Transmission and\nMain pipelines installed by trenchless excavation, does the process include steps that need to be taken to provide sufficient\nclearance for installation and maintenance activities from other underground utilities and/or structures at the time of installation?\n(DC.CO.PLASTICTRENCHLESS.P) 192.329(a) (192.303)\n9. Trenchless Installation of Plastic Transmission and Main Pipelines For plastic pipe Transmission and\nMain pipelines installed by trenchless excavation, do field observations confirm lines are being installed with sufficient clearance for\ninstallation and maintenance activities from other underground utilities and/or structures? (DC.CO.PLASTICTRENCHLESS.O)\n192.329(a) (192.303)\n10. Trenchless Installation of Plastic Service Lines For plastic service lines installed by trenchless excavation,\ndoes the process include steps that need to be taken to provide sufficient clearance for installation and maintenance activities fro","truncated":true,"body_characters":162512}