{"operation":"document","citation":"CPF 120171014M","title":"PORTLAND NATURAL GAS TRANSMISSION SYSTEM — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-06-06","effective_on":null,"summary":"CLOSED notice of amendment citing 192.631(a)(1), 192.631(b)(4), 192.631(g)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120171014m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120171014m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120171014m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120171014M","body":"Notice of Amendment involving PORTLAND NATURAL GAS TRANSMISSION SYSTEM. PHMSA's enforcement data identifies the cited regulations as 192.631(a)(1),  192.631(b)(4),  192.631(g)(2). The case was opened on 2017-06-06 and is reported as closed as of 2018-01-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120171014M_Closure Letter_01022018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171014M/120171014M_Closure%20Letter_01022018.pdf\n\n120171014M_Closure Letter_01022018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171014M/120171014M_Closure%20Letter_01022018_text.pdf\n\n120171014M_Notice of Amendment_06062017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171014M/120171014M_Notice%20of%20Amendment_06062017.pdf\n\n120171014M_Notice of Amendment_06062017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120171014M/120171014M_Notice%20of%20Amendment_06062017_text.pdf\n\n120171014M_Notice of Amendment_06062017_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nJune 6, 2017\nMr. Stanley Chapman III\nPresident, US Gas Pipelines\nTransCanada\n700 Louisiana, Suite 700\nHouston, TX 77002\nCPF 1-2017-1014M\nDear Mr. Chapman:\nFrom September 27 to September 29, 2016, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected Portland Natural Gas Transmission System’s (Portland) Control Room Management\nProcedures in Calgary, Alberta, Canada.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nPortland’s plans or procedures, as described below:\n1. §192.631 Control Room Management\n(a) General\n(1) 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, except that\nfor each control room where an operator's activities are limited to either or both of:\n…\nPortland’s Control Room Management Procedure, Gas Control Shift Change Procedure, Revision\n5.0, dated 8/12/2016 (Procedure), is inadequate in that it does not require qualified controllers to\nmonitor the SCADA system in accordance with §192.631(b)(4).\n\n\n\nCPF 1-2017-1014M\n§192.631(b)(4) states:\n“(b) Roles and responsibilities. Each operator must define the roles and responsibilities of a\ncontroller during normal, abnormal, and emergency operating conditions. To provide for a\ncontroller's prompt and appropriate response to operating conditions, an operator must\ndefine each of the following:\n…\n(4) A method of recording controller shift-changes and any hand-over of responsibility\nbetween controllers.”\nDuring the inspection, the PHMSA inspector reviewed Portland’s Procedure for Gas Control Shift\nChange. Section 5.0 Shift Change Procedure, Subsection Full Shift Change states in part “…\nUnder this condition, an unqualified Controller shall not assume operational responsibility unless\nthey are working under the guidance of a qualified Controller.”\nSubsection Impromptu Shift Change, states in part “…An unqualified backup Controller shall\nmonitor the system but not invoke or modify controls without the consent of the on-duty\ncontroller”.\nThus, the Portland procedures allow an unqualified controller to monitor, but not operate, a console\nif the console is unmanned. Since monitoring the SCADA system is a component of the controller's\nresponsibility, it may not be performed by a non-qualified controller unless s/he is under the\nguidance of a qualified controller.\n2. §192.631 Control Room Management\n(a) General\n(1) 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, except that\nfor each control room where an operator's activities are limited to either or both of:\n…\nPortland’s Control Room Management Procedures are inadequate in that they fail to provide\nguidance for incorporating lessons learned from the operator’s experience, other than reportable\naccidents/incidents, into the training program, in accordance with 192.631(g)(2).\n§192.631(g)(2) states:\n“(g) Operating experience. Each operator must assure that lessons learned from its operating\nexperience are incorporated, as appropriate, into its control room management procedures\nby performing each of the following:\n(2) Include lessons learned from the operator's experience in the training program required\nby this section.”\nDuring the inspection, the PHMSA inspector reviewed the following documents identified by\n120171014M_Notice of Amendment_06062017_text Page 2 of 4\n\n\n\nCPF 1-2017-1014M\nPortland as pertinent to the requirements of §192.631(g)(2):\n1. 2. 3. Gas Control Emergency Preparedness Plan, Revision 11, dated 7/18/2016, Table Step 4.2;\nGas Control Process Manual, Revision 19, dated 7/14/2016, Sec. 8; and\nO&M Manual for Sec. 192.631, Revision 12, dated 12/15/2015, Item 15\nThe O&M Manual for 192.631 Item 15 states:\n“For any Incident as defined in O&M Procedure 191.05 a review is performed in accordance with\nO&M Procedures 192.615 or 192.617 to determine if control room actions contributed to the event.\na. If it is determined that control room actions contributed to the event, steps are taken to correct\ndeficiencies related to the controller’s actions in Control Room Management Procedures.\nb. Lessons learned from an incident review are incorporated into the Control Room training\nprogram.”\nNone of these procedures include provisions to incorporate lessons learned into the control room\ntraining program from operator experience other than reportable incidents/accidents. Other\nrelevant experiences where lessons learned could be drawn from and implemented into the training\nprogram include events such as:\nNon-Reportable Events including small leaks\nAny Other source of Operator experience.\n1. 2. Audit Findings\n3. Near Miss Events\n4. Response to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Compliance\nProceedings. Please refer to this document and note the response options. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for confidential\ntreatment under 5 U.S.C. 552(b), along with the complete original document you must provide a\nsecond copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 60 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\n120171014M_Notice of Amendment_06062017_text Page 3 of 4\n\n\n\nCPF 1-2017-1014M\nIt is requested (not mandated) that Portland maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to Robert Burrough, Acting Director, PHMSA Eastern Region,\n820 Bear Tavern Road, Suite 103, West Trenton, NJ 08628. Please refer to CPF 1- 2017-1014M\non each document you submit, and whenever possible provide a signed PDF copy in electronic\nformat. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should be sent on\na CD accompanied by the original paper copy to the Eastern Region Office.\nSincerely,\nRobert Burrough\nActing Director, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n120171014M_Notice of Amendment_06062017_text Page 4 of 4\n\n120171014M_Closure Letter_01022018_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nJanuary 2, 2018\nMr. Stanley Chapman III\nPresident, US Gas Pipelines\nTransCanada\n700 Louisiana, Suite 700\nHouston, TX 77002\nCPF 1-2017-1014M\nDear Mr. Chapman:\nFrom September 27 to September 29, 2016; 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 Portland Natural Gas Transmission System’s\nControl Room Management Procedures in Calgary, Alberta, Canada. As a result of the inspection,\nTransCanada was issued a Notice of Amendment on June 6, 2017; which proposed amendment of\nyour procedures.\nTransCanada submitted its amended procedures on December 21, 2017. My staff reviewed the\namended procedures, and it appears that the inadequacies outlined in this Notice of Amendment\nhave been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":10157}