{"operation":"document","citation":"CPF 12022072NOA","title":"PORTLAND PIPE LINE CORPORATION — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-11-17","effective_on":null,"summary":"CLOSED notice of amendment citing 195.446(e)(1), 195.446(e)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022072noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022072noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022072noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022072NOA","body":"Notice of Amendment involving PORTLAND PIPE LINE CORPORATION. PHMSA's enforcement data identifies the cited regulations as 195.446(e)(1),  195.446(e)(2). The case was opened on 2022-11-17 and is reported as closed as of 2023-02-16. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12022072NOA_Closure Letter_02162023_(21-199431).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022072NOA/12022072NOA_Closure%20Letter_02162023_(21-199431).pdf\n\n12022072NOA_Closure Letter_02162023_(21-199431)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022072NOA/12022072NOA_Closure%20Letter_02162023_(21-199431)_text.pdf\n\n12022072NOA_Notice of Amendment_11172022_(21-199431).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022072NOA/12022072NOA_Notice%20of%20Amendment_11172022_(21-199431).pdf\n\n12022072NOA_Notice of Amendment_11172022_(21-199431)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022072NOA/12022072NOA_Notice%20of%20Amendment_11172022_(21-199431)_text.pdf\n\n12022072NOA_Operator RtN and Request for Hearing_12152022_(21-199431).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022072NOA/12022072NOA_Operator%20RtN%20and%20Request%20for%20Hearing_12152022_(21-199431).pdf\n\n12022072NOA_Operator Withdrawal of Request for Hearing_01182023_(21-199431).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022072NOA/12022072NOA_Operator%20Withdrawal%20of%20Request%20for%20Hearing_01182023_(21-199431).pdf\n\n12022072NOA_Closure Letter_02162023_(21-199431)_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nFebruary 16, 2023\nMr. John Gillies\nPresident\nPortland Pipe Line Corporation\n30 Hill Street\nSouth Portland, Maine 04106\nCPF 1-2022-072-NOA\nDear Mr. Gillies:\nFrom July 6, 2021 through July 30, 2021, representatives from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\nconducted a pipeline safety inspection of Portland Pipe Line Corporation’s (Portland) procedures\nfor control room management of its South Portland, Maine control room. As a result of the\ninspection, Portland was issued a Notice of Amendment on November 17, 2022, which proposed\namendment of your procedures.\nPortland submitted its amended procedures on December 15, 2022. 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,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n\n12022072NOA_Notice of Amendment_11172022_(21-199431)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nNovember 17, 2022\nMr. John Gillies\nPresident\nPortland Pipe Line Corporation\n30 Hill Street\nSouth Portland, Maine 04106\nCPF 1-2022-072-NOA\nDear Mr. Gillies:\nFrom July 6, 2021, through July 30, 2021, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nPortland Pipe Line Corporation’s (Portland) procedures for control room management of its South\nPortland, Maine control room.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nPortland’s plans or procedures, as described below:\n1. § 195.446 Control Room Management\n(a) …\n(e) Alarm Management. Each operator using a SCADA system must\nhave a written alarm management plan to provide for effective\ncontroller response to alarms. An operator's plan must include\nprovisions to:\n(1) Review SCADA safety-related alarm operations using a process\nthat ensures alarms are accurate and support safe pipeline operations.\nPortland’s control room management program procedures were inadequate to ensure safe\noperation of a pipeline facility. Specifically, Portland’s written control room management\nprogram procedures for reviewing SCADA safety-related alarm operations failed to include a\nprocess that ensures alarms are accurate and support safe pipeline operations as required by\n§ 195.446(e)(1).\n\n\n\nDuring the inspection, PHMSA asked Portland Pipeline to produce procedures that demonstrate\nhow Portland ensures that alarms are accurate and support safe pipeline operations. Portland\ninitially referred to its Portland Montreal Pipe Line Control Room Management Procedures\n(CRM) (CRM Procedures), Section 5.1, Review SCADA Safety Related Alarm Operations. This\nsection stated that the Operations Manager will take steps necessary to review SCADA safety\nalarm operations to ensure alarms received and displayed to the Controller are accurate and support\nsafe pipeline operations. The section did not describe a process for achieving this objective. The\nprocedures failed to include details such as a process for identifying, tracking and correcting\ninaccurate or malfunctioning alarms, process considerations for safety related alarms to account\nfor different alarm designs or alarm types, and/or specific procedures for managing stale or\nunreliable data.\nPortland later referred to Section 6 Alarm Handling Methods of its PMPL Alarm Management\nProgram, SCADA Alarm Management, Rev 1, May 2012 (PMPL Alarm Plan). However, this\nsection lacked sufficient details to adequately address how Portland ensures that alarms are\naccurate and support safe pipeline operations.\nTherefore, Portland’s written control room management program procedures and alarm\nmanagement procedures were inadequate as they lacked sufficient details for complying with\n§ 195.446(e)(1). Portland must revise its control room management program procedures to\naddress this deficiency.\n2. § 195.446 Control Room Management\n(a) …\n(e) Alarm Management. Each operator using a SCADA system must\nhave a written alarm management plan to provide for effective\ncontroller response to alarms. An operator's plan must include\nprovisions to:\n(1) …\n(2) Identify at least once each calendar month points affecting safety\nthat have been taken off scan in the SCADA host, have had alarms\ninhibited, generated false alarms, or that have had forced or manual\nvalues for periods of time exceeding that required for associated\nmaintenance or operating activities;\nPortland’s control room management program procedures were inadequate to ensure safe\noperation of a pipeline facility. Specifically, Portland’s alarm management plan failed to include\nadequate provisions for conducting the monthly identification of points affecting safety required\nby § 195.446(e)(2).\nDuring the inspection, PHMSA asked Portland to produce procedures addressing a monthly\nidentification of points that have been taken off scan, have had alarms inhibited, generated false\nalarms, or that have had forced or manual values for periods of time exceeding that required for\nassociated maintenance or operating activities. Portland referred to its CRM Procedures, Section\n5.2, Review of SCADA Points. This section discussed a process for identifying, at least once each\ncalendar month, the alarm points affecting safety that have been taken off scan in the SCADA\n\n\n\nhost, have had alarms inhibited, generated false alarms, or that have had forced or manual values\nfor periods of time exceeding that required for associated maintenance or operating activities.\nHowever, the CRM Procedures failed to cross-reference or mention the SCADA Monthly\nChecklist located in the PMPL Alarm Plan, Appendix 13.5, which lists all the activities for\nchecking alarms. Furthermore, the PMPL Alarm Plan lacked a specific procedure for using the\nSCADA Monthly checklist. Thus, instead of a monthly review, Portland stated during the\ninspection that it just reviews a snapshot of the SCADA screen on a day and notes anything off\nscan, inhibited and forced/manual. There is no report of what was identified or details on\nsubsequent follow up actions.\nTherefore, Portland’s control room management program procedures were inadequate as they\nlacked specific details about how to conduct the monthly reviews pursuant to § 195.446(e)(2).\nPortland must clarify the process or procedure for using the SCADA Monthly Checklist and\nsubsequent report the subsequent actions.\nResponse 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 Enforcement\nProceedings.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. 552(b), along with the complete original document you must provide a second copy of the\ndocument with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 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 30 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.\nIt is requested (not mandated) that Portland Pipe Line Corporation maintain documentation of the\nsafety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director,\nEastern Region, Pipeline and Hazardous Materials Safety Administration, 840 Bear Tavern Road,\nSuite 300, West Trenton, NJ 08628. In correspondence concerning this matter, please refer to CPF\n1-2022-072-NOA and, for each document you submit, please provide a copy in electronic format\n\n\n\nwhenever possible. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should\nbe sent on USB flash drive accompanied by the original paper copy to the Eastern Region Office.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings","truncated":false,"body_characters":10976}