{"operation":"document","citation":"CPF 220136006M","title":"TAMPA BAY PIPELINE CO. — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-09-04","effective_on":null,"summary":"CLOSED notice of amendment citing 195.446(b), 195.446(c)(2), 195.446(c)(4), 195.446(d)(1), 195.446(d)(4), 195.446(e)(1), 195.446(e)(3), 195.446(e)(5), 195.446(f)(1), 195.446(g)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220136006m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220136006m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220136006m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220136006M","body":"Notice of Amendment involving TAMPA BAY PIPELINE CO.. PHMSA's enforcement data identifies the cited regulations as 195.446(b),  195.446(c)(2),  195.446(c)(4),  195.446(d)(1),  195.446(d)(4),  195.446(e)(1),  195.446(e)(3),  195.446(e)(5),  195.446(f)(1),  195.446(g)(2). The case was opened on 2013-09-04 and is reported as closed as of 2014-08-05. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220136006M_closure letter_08052014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220136006M/220136006M_closure%20letter_08052014.pdf\n\n220136006M_closure letter_08052014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220136006M/220136006M_closure%20letter_08052014_text.pdf\n\n220136006M_notice of amendment_09042013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220136006M/220136006M_notice%20of%20amendment_09042013_text.pdf\n\n220136006M_notice of amendment_9042013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220136006M/220136006M_notice%20of%20amendment_9042013.pdf\n\n220136006M_notice of amendment_9042013.pdf\n\n.s. Depanmen\nf Transportatiol\n233 Peachtree Street Ste. 600\nAtlanta, GA 30303\nPipeline and\nAdministration\nHazardous Materials Safety\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nSeptember 4, 2013\nMr. Robert L. Rose\nPresident\nTampa Bay Pipeline Company\nP.O. Box 35236\nSarasota, FL 34242\nCPF 2-2013-6006M\nDear Mr. Rose:\nOn May 13-17, 2013, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Southern Region, Office of Pipeline Safety (OPS) inspected the\nTampa Bay Pipeline Company (TBPL) control room in Tampa, Florida, pursuant to Chapter\n601 of 49 United States Code.\nOn the basis of the inspection, PHMSA has identified apparent inadequacies within TBPL's\nwritten Control Room Management (CRM) procedures, which were contained in TBPL's\nOperations & Maintenance Procedure Manual (O&M Manual), as described below:\n1. § 195.446 Control room management.\n... (b) Roles and responsibilities. Each operator must define the roles and\nconditions. To provide for a controller's prompt and appropriate response to\nresponsibilities of a controller during normal, abnormal, and emergency operating\noperating conditions, an operator must define each of the following:\nTBPL's CRM procedures did not adequately define the roles and responsibilities of a\ncontroller during normal, abnormal, and emergency operating conditions.\nO&M Manual Section 8.6.2 On-Shift Breaks stated, \"Staffing levels do not allow specific\ntime for controller breaks away from pipeline control room. Operator performs routine\nwalk around inspection, is authorized food and drink in control room keeping items away\nfrom work station, and has access to lavatory facility in the control room area.\" These\nprocedures, however, did not include an explanation of when and how the pipeline is\noperated when the control room is unattended such as when controllers are in the\nrestroom, or performing routine walk around inspections, etc.\n\n\n\n2. § 195.446 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 to\ncarry out the roles and responsibilities the operator has defined by performing each\nof the following:\n... (2) Conduct a point-to-point verification between SCADA displays and related\nfield equipment when field equipment is added or moved and when other changes\nthat affect pipeline safety are made to field equipment or SCADA displays;\nTBPL's CRM procedures did not address the requirements to conduct a point-to-point\nverification.\nSubsequent to the PHMSA inspection, TBPL provided revised O&M Manual Section\n8.6.1 point-to-point verification procedures, which required verification when safety\ndevices are replaced. But, the revised procedures did not specifically require verification\nwhen like-for-like replacement of safety-related field instrumentation occurs.\n3. § 195.446 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 to\ncarry out the roles and responsibilities the operator has defined by performing each\nof the following:\n•.• (4) Test any backup SCADA systems at least once each calendar year, but at\nintervals not to exceed 15 months;\nTBPL's CRM procedures did not require the backup SCADA system to be tested at least\nonce each calendar year at intervals not to exceed 15 months.\nO&M Manual Section 8.14.2 stated, \"Test any backup SCADA systems. TBPL has a\nlimited redundant SCADA node located at the operator's console. It is used primarily to\ndisplay remote site status and runs concurrently with primary system daily. Technically\nthis does not meet criteria as a backup SCADA system. \" While this procedure said that\nthe secondary SCADA server did not technically meet criteria as a backup SCADA\nsystem, TPL personnel explained during the PHMSA inspection that in the event of the\nprimary server failure, they would use the secondary SCADA server to monitor and\ncontrol the system. That said, neither this procedure nor any other procedure required the\nbackup SCADA system to be tested at least once each calendar year at intervals not to\nexceed 15 months.\n4. § 195.446 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;\nTBPL's CRM procedures did not adequately establish shift lengths and schedule rotations\nthat provide controllers off-duty time sufficient to achieve eight hours of continuous sleep.\nO&M Manual Section 8.6 did not adequately address how its fatigue mitigation program\nwould reduce the risk associated with controller fatigue, and did not address whether or\n2\n\n\n\nnot controllers are \"on-call.\" The procedures also did not explain how TBPL would\nminimize interrupting the required eight hours of continuous sleep if the controllers were\n\"on-call.\" Moreover, if an \"on-call\" controller was required to report to the control room\non an unscheduled basis, the procedures did not address that the controller's commute\ntime should be counted as on-duty hours.\n5. § 195.446 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.\nTBPL's CRM procedures did not adequately establish maximum limits on controller\nhours-of-service (HOS). That is CRM procedures in O&M Manual Section 8.6 did not\nconvey\n- the specific fatigue countermeasures that TBPL should implement for controllers\nworking the ninth hour and beyond,\n- any available fatigue countermeasures/tactics that TBPL could easily implement\nsuch as breaks in the control room, standing, exercise, required walk-arounds, etc.'\n- that the daily maximum HOS limit should be no more than 14 hours in any sliding\n24-hour period,\n- that the limitation on the number of allowed 18-hour (controller holdover) shifts per\ncontroller is 1 in any sliding 5-day period,\n- the specific fatigue countermeasures TBPL should implement for\n- any and all shift duty hours worked after the first 8 hours,\n- any and all hours worked between 2:00 a.m. and 6:00 a.m.,\n- any and all night shifts immediately following three successive nights; and,\n- a process for approving deviations from the maximum HOS limit.\nAlthough subsequent to the PHMSA inspection TBPL provided revised procedures\naddressing HOS deviations, the revised procedures did not specifically address handling\nHOS deviations in advance of anticipated deviations, or, in cases where unforeseen\nevents occur, obtaining verbal and subsequent written approval at the first practical\nmoment after the deviation event.\n6. § 195.446 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;\n' When a controller was asked by PHMSA inspectors about the frequency of yard walk-arounds in accordance\ndo walk-arounds.\nwith O&M Manual Section 8.6.2, \"Operator performs routine walk around inspection, \" he stated that he did not\n3\n\n\n\nTBPL's CRM procedures in O&M Manual Section 8.8.1 did not describe how TBPL\nidentified safety-related alarms and did not adequately describe a process that ensures\nalarms are accurate and support safe pipeline operations. The procedure stated,\n\"8.7.3 Safety-Related Alarms\nTBPL's designated alarm database, see TBPL SCADA Alarm Management File.\nThis digital file includes identified safety-related alarms. Controllers are trained to\nunderstand which alarms are safety-related along with their individual implications.\nSafety-related specific alarms are critical alarms and do not include low importance\nalarms such as equipment efficiency alarms or measurement related alarms. 'For\npurposes of Control Room Management, PHMSA considers safety-related to mean\nany operational factor that is necessary to maintain pipeline integrity or that could\nlead to the recognition of a condition that could impact the integrity of the pipeline,\nor a developing abnormal or emergency situation'\"\nThe above procedure and TBPL's policies did not adequately describe a process to ensure\nalarms are accurate and support safe pipeline operations. That is, TBPL's CRM\nprocedures did not require the evaluation of each controller's ability to accurately perceive\nSCADA display object characteristics (e.g., color, shape, text) that indicate the safety-\nrelated alarms used in the operator's SCADA system.\n7. § 195.446 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... (3) Verify the correct safety-related alarm set-point values and alarm\ndescriptions when associated field instruments are calibrated or changed and at least\nonce each calendar year, but at intervals not to exceed 15 months;\nTBPL's CRM procedures did not include a formal process to determine the correct\npressure and flow alarm set-points for each alarm priority and did not clearly address how,\nand to what degree, controllers can change alarm limits, set-points, inhibit alarms, or take\npoints off-scan.\n8. § 195.446 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\nexceeding 15 months, that will assure controllers have sufficient time to analyze and\nreact to incoming alarms; and...\nTBPL's CRM procedures did not explain how TBPL monitored the content and volume of\ngeneral activity being directed to, and required of, each controller. O&M Manual Section\n8.12.5 only \"parroted\" the federal pipeline safety regulations.\n4\n\n\n\n9. § 195.446 Control room management\n•.• (f) Change management. Each operator must assure that changes that could\naffect control 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)\nfor control room management change and require coordination between control\nroom representatives, operator's management, and associated field personnel when\nplanning and implementing physical changes to pipeline equipment or configuration;\nTBPL's CRM procedures did not adequately require coordination between control room\nrepresentatives, operator's management, and associated field personnel when planning and\nimplementing physical changes to pipeline equipment or configuration.\nO&M Manual Section 8.8 did not require that configuration changes to SCADA screens\nrelating to changes in field equipment must be made prior to the equipment changes going\ninto operation. Also, the procedures did not specifically convey that TBPL followed\nsection 7 of API RP 1168.\n10. § 195.446 Control room management\n... (g) Operating experience. Each operator must assure that lessons learned from\nits operating experience are incorporated, as appropriate, into its control room\nmanagement procedures by performing each of the following:\n... (2) Include lessons learned from the operator's experience in the training\nprogram required by this section.\nTBPL's CRM procedures were not in the detail required to assure that lessons learned\nfrom TBPL's experience were included in its training program.\nO&M Manual Section 8.9.4 did not describe examples of events from lessons learned to\nbe included in training; i.e., operating events (in addition to reportable incidents/accidents)\nlike near misses, leaks, operational and maintenance errors, etc.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. §60108(a) and 49 C.F.R. §190.237. Enclosed\nas part of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document\nyou must provide a second copy of the document with the portions you believe qualify for\nconfidential 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\nfind facts as alleged in this Notice without further notice to you and to issue a Final Order.\n5\n\n\n\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in\nthis Notice, you may be ordered to amend your plans or procedures to correct the\ninadequacies (49 C.F.R. § 190.237). If you are not contesting this Notice, we propose that\nyou submit your amended procedures to my office within 60 days of receipt of this Notice.\nThis period may be extended by written request for good cause. Once the inadequacies\nidentified herein have been addressed in your amended procedures, this enforcement action\nwill be closed.\nIt is requested (not mandated) that Tampa Bay Pipeline Company maintain documentation of\nthe safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/ revision of plans, procedures) and submit the total to Wayne T. Lemoi, Director,\nSouthern Region, Pipeline and Hazardous Materials Safety Administration. In\ncorrespondence concerning this matter, please refer to CPF 2-2013-6006M and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nMall-le\nDireetor, Office of Pipeline Safety\nPHMSA Southern Region\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n\n220136006M_closure letter_08052014_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 5, 2014\nMr. Robert L. Rose\nPresident\nTampa Bay Pipeline Company\nP.O. Box 35236\nSarasota, FL 34242\nCPF 2-2013-6006M\nDear Mr. Rose:\nOn May 13-17, 2013, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Southern Region, Office of Pipeline Safety (OPS) inspected the\nTampa Bay Pipeline Company (TBPL) control room in Tampa, Florida, pursuant to Chapter\n601 of 49 United States Code. As a result of the inspection, PHMSA issued a Notice of\nAmendment (NOA) on September 4, 2013.\nThe OPS Southern Region has received and reviewed several written responses to the NOA\nfrom TBPL, including TBPL’s final response dated July 22, 2014. Based on our review of\nthese responses we have determined that TBPL has complied with the terms of the NOA.\nThis case is now closed and no further action is necessary with respect to the matters involved\nin this case.\nPlease be advised that this letter refers only to the referenced NOA (CPF 2-2013-6006M) and\nnot to any other PHMSA cases, if any.\nSincerely,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\n\n220136006M_notice of amendment_09042013_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nSeptember 4, 2013\nMr. Robert L. Rose\nPresident\nTampa Bay Pipeline Company\nP.O. Box 35236\nSarasota, FL 34242\nCPF 2-2013-6006M\nDear Mr. Rose:\nOn May 13-17, 2013, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Southern Region, Office of Pipeline Safety (OPS) inspected the\nTampa Bay Pipeline Company (TBPL) control room in Tampa, Florida, pursuant to Chapter\n601 of 49 United States Code.\nOn the basis of the inspection, PHMSA has identified apparent inadequacies within TBPL’s\nwritten Control Room Management (CRM) procedures, which were contained in TBPL’s\nOperations & Maintenance Procedure Manual (O&M Manual), as described below:\n1. § 195.446 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:\nTBPL’s CRM procedures did not adequately define the roles and responsibilities of a\ncontroller during normal, abnormal, and emergency operating conditions.\nO&M Manual Section 8.6.2 On-Shift Breaks stated, “Staffing levels do not allow specific\ntime for controller breaks away from pipeline control room. Operator performs routine\nwalk around inspection, is authorized food and drink in control room keeping items away\nfrom work station, and has access to lavatory facility in the control room area.” These\nprocedures, however, did not include an explanation of when and how the pipeline is\noperated when the control room is unattended such as when controllers are in the\nrestroom, or performing routine walk around inspections, etc.\n\n\n\n2. 3. 4. § 195.446 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 to\ncarry out the roles and responsibilities the operator has defined by performing each\nof the following:\n. . . (2) Conduct a point-to-point verification between SCADA displays and related\nfield equipment when field equipment is added or moved and when other changes\nthat affect pipeline safety are made to field equipment or SCADA displays;\nTBPL’s CRM procedures did not address the requirements to conduct a point-to-point\nverification.\nSubsequent to the PHMSA inspection, TBPL provided revised O&M Manual Section\n8.6.1 point-to-point verification procedures, which required verification when safety\ndevices are replaced. But, the revised procedures did not specifically require verification\nwhen like-for-like replacement of safety-related field instrumentation occurs.\n§ 195.446 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 to\ncarry out the roles and responsibilities the operator has defined by performing each\nof the following:\n. . . (4) Test any backup SCADA systems at least once each calendar year, but at\nintervals not to exceed 15 months;\nTBPL’s CRM procedures did not require the backup SCADA system to be tested at least\nonce each calendar year at intervals not to exceed 15 months.\nO&M Manual Section 8.14.2 stated, “Test any backup SCADA systems. TBPL has a\nlimited redundant SCADA node located at the operator’s console. It is used primarily to\ndisplay remote site status and runs concurrently with primary system daily. Technically\nthis does not meet criteria as a backup SCADA system.\" While this procedure said that\nthe secondary SCADA server did not technically meet criteria as a backup SCADA\nsystem, TPL personnel explained during the PHMSA inspection that in the event of the\nprimary server failure, they would use the secondary SCADA server to monitor and\ncontrol the system. That said, neither this procedure nor any other procedure required the\nbackup SCADA system to be tested at least once each calendar year at intervals not to\nexceed 15 months.\n§ 195.446 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;\nTBPL’s CRM procedures did not adequately establish shift lengths and schedule rotations\nthat provide controllers off-duty time sufficient to achieve eight hours of continuous sleep.\nO&M Manual Section 8.6 did not adequately address how its fatigue mitigation program\nwould reduce the risk associated with controller fatigue, and did not address whether or\n2\n\n\n\n5. 6. not controllers are “on-call.” The procedures also did not explain how TBPL would\nminimize interrupting the required eight hours of continuous sleep if the controllers were\n“on-call.” Moreover, if an “on-call” controller was required to report to the control room\non an unscheduled basis, the procedures did not address that the controller’s commute\ntime should be counted as on-duty hours.\n§ 195.446 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.\nTBPL’s CRM procedures did not adequately establish maximum limits on controller\nhours-of-service (HOS). That is CRM procedures in O&M Manual Section 8.6 did not\nconvey\n- the specific fatigue countermeasures that TBPL should implement for controllers\nworking the ninth hour and beyond,\n- any available fatigue countermeasures/tactics that TBPL could easily implement\nsuch as breaks in the control room, standing, exercise, required walk-arounds, etc.1\n- that the daily maximum HOS limit should be no more than 14 hours in any sliding\n24-hour period,\n- that the limitation on the number of allowed 18-hour (controller holdover) shifts per\ncontroller is 1 in any sliding 5-day period,\n- the specific fatigue countermeasures TBPL should implement for\n− any and all shift duty hours worked after the first 8 hours,\n− any and all hours worked between 2:00 a.m. and 6:00 a.m.,\n− any and all night shifts immediately following three successive nights; and,\n- a process for approving deviations from the maximum HOS limit.\nAlthough subsequent to the PHMSA inspection TBPL provided revised procedures\naddressing HOS deviations, the revised procedures did not specifically address handling\nHOS deviations in advance of anticipated deviations, or, in cases where unforeseen\nevents occur, obtaining verbal and subsequent written approval at the first practical\nmoment after the deviation event.\n§ 195.446 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;\n1 When a controller was asked by PHMSA inspectors about the frequency of yard walk-arounds in accordance\nwith O&M Manual Section 8.6.2, “Operator performs routine walk around inspection,” he stated that he did not\ndo walk-arounds.\n3\n\n\n\n7. 8. TBPL’s CRM procedures in O&M Manual Section 8.8.1 did not describe how TBPL\nidentified safety-related alarms and did not adequately describe a process that ensures\nalarms are accurate and support safe pipeline operations. The procedure stated,\n“8.7.3 Safety-Related Alarms\nTBPL’s designated alarm database, see TBPL SCADA Alarm Management File.\nThis digital file includes identified safety-related alarms. Controllers are trained to\nunderstand which alarms are safety-related along with their individual implications.\nSafety-related specific alarms are critical alarms and do not include low importance\nalarms such as equipment efficiency alarms or measurement related alarms. ‘For\npurposes of Control Room Management, PHMSA considers safety-related to mean\nany operational factor that is necessary to maintain pipeline integrity or that could\nlead to the recognition of a condition that could impact the integrity of the pipeline,\nor a developing abnormal or emergency situation’”\nThe above procedure and TBPL’s policies did not adequately describe a process to ensure\nalarms are accurate and support safe pipeline operations. That is, TBPL’s CRM\nprocedures did not require the evaluation of each controller’s ability to accurately perceive\nSCADA display object characteristics (e.g., color, shape, text) that indicate the safety-\nrelated alarms used in the operator’s SCADA system.\n§ 195.446 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. . . (3) Verify the correct safety-related alarm set-point values and alarm\ndescriptions when associated field instruments are calibrated or changed and at least\nonce each calendar year, but at intervals not to exceed 15 months;\nTBPL’s CRM procedures did not include a formal process to determine the correct\npressure and flow alarm set-points for each alarm priority and did not clearly address how,\nand to what degree, controllers can change alarm limits, set-points, inhibit alarms, or take\npoints off-scan.\n§ 195.446 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\nexceeding 15 months, that will assure controllers have sufficient time to analyze and\nreact to incoming alarms; and . . .\nTBPL’s CRM procedures did not explain how TBPL monitored the content and volume of\ngeneral activity being directed to, and required of, each controller. O&M Manual Section\n8.12.5 only “parroted” the federal pipeline safety regulations.\n4\n\n\n\n9. § 195.446 Control room management\n. . . (f) Change management. Each operator must assure that changes that could\naffect control 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)\nfor control room management change and require coordination between control\nroom representatives, operator's management, and associated field personnel when\nplanning and implementing physical changes to pipeline equipment or configuration;\nTBPL’s CRM procedures did not adequately require coordination between control room\nrepresentatives, operator's management, and associated field personnel when planning and\nimplementing physical changes to pipeline equipment or configuration.\nO&M Manual Section 8.8 did not require that configuration changes to SCADA screens\nrelating to changes in field equipment must be made prior to the equipment changes going\ninto operation. Also, the procedures did not specifically convey that TBPL followed\nsection 7 of API RP 1168.\n10. § 195.446 Control room management\n. . . (g) Operating experience. Each operator must assure that lessons learned from\nits operating experience are incorporated, as appropriate, into its control room\nmanagement procedures by performing each of the following:\n. . . (2) Include lessons learned from the operator's experience in the training\nprogram required by this section.\nTBPL’s CRM procedures were not in the detail required to assure that lessons learned\nfrom TBPL’s experience were included in its training program.\nO&M Manual Section 8.9.4 did not describe examples of events from lessons learned to\nbe included in training; i.e., operating events (in addition to reportable incidents/accidents)\nlike near misses, leaks, operational and maintenance errors, etc.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. §60108(a) and 49 C.F.R. §190.237. Enclosed\nas part of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document\nyou must provide a second copy of the document with the portions you believe qualify for\nconfidential 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\nfind facts as alleged in this Notice without further notice to you and to issue a Final Order.\n5\n\n\n\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in\nthis Notice, you may be ordered to amend your plans or procedures to correct the\ninadequacies (49 C.F.R. § 190.237). If you are not contesting this Notice, we propose that\nyou submit your amended procedures to my office within 60 days of receipt of this Notice.\nThis period may be extended by written request for good cause. Once the inadequacies\nidentified herein have been addressed in your amended procedures, this enforcement action\nwill be closed.\nIt is requested (not mandated) that Tampa Bay Pipeline Company maintain documentation of\nthe safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/ revision of plans, procedures) and submit the total to Wayne T. Lemoi, Director,\nSouthern Region, Pipeline and Hazardous Materials Safety Administration. In\ncorrespondence concerning this matter, please refer to CPF 2-2013-6006M and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n6","truncated":false,"body_characters":32314}