# TAMPA BAY PIPELINE CO. — Notice of Amendment

- **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:** Not available
- **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).
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- **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.

Official case documents:

220136006M_closure letter_08052014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220136006M/220136006M_closure%20letter_08052014.pdf

220136006M_closure letter_08052014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220136006M/220136006M_closure%20letter_08052014_text.pdf

220136006M_notice of amendment_09042013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220136006M/220136006M_notice%20of%20amendment_09042013_text.pdf

220136006M_notice of amendment_9042013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220136006M/220136006M_notice%20of%20amendment_9042013.pdf

220136006M_notice of amendment_9042013.pdf

.s. Depanmen
f Transportatiol
233 Peachtree Street Ste. 600
Atlanta, GA 30303
Pipeline and
Administration
Hazardous Materials Safety
NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
September 4, 2013
Mr. Robert L. Rose
President
Tampa Bay Pipeline Company
P.O. Box 35236
Sarasota, FL 34242
CPF 2-2013-6006M
Dear Mr. Rose:
On May 13-17, 2013, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), Southern Region, Office of Pipeline Safety (OPS) inspected the
Tampa Bay Pipeline Company (TBPL) control room in Tampa, Florida, pursuant to Chapter
601 of 49 United States Code.
On the basis of the inspection, PHMSA has identified apparent inadequacies within TBPL's
written Control Room Management (CRM) procedures, which were contained in TBPL's
Operations & Maintenance Procedure Manual (O&M Manual), as described below:
1. § 195.446 Control room management.
... (b) Roles and responsibilities. Each operator must define the roles and
conditions. To provide for a controller's prompt and appropriate response to
responsibilities of a controller during normal, abnormal, and emergency operating
operating conditions, an operator must define each of the following:
TBPL's CRM procedures did not adequately define the roles and responsibilities of a
controller during normal, abnormal, and emergency operating conditions.
O&M Manual Section 8.6.2 On-Shift Breaks stated, "Staffing levels do not allow specific
time for controller breaks away from pipeline control room. Operator performs routine
walk around inspection, is authorized food and drink in control room keeping items away
from work station, and has access to lavatory facility in the control room area." These
procedures, however, did not include an explanation of when and how the pipeline is
operated when the control room is unattended such as when controllers are in the
restroom, or performing routine walk around inspections, etc.



2. § 195.446 Control room management
... (c) Provide adequate information. Each operator must provide its controllers
with the information, tools, processes and procedures necessary for the controllers to
carry out the roles and responsibilities the operator has defined by performing each
of the following:
... (2) Conduct a point-to-point verification between SCADA displays and related
field equipment when field equipment is added or moved and when other changes
that affect pipeline safety are made to field equipment or SCADA displays;
TBPL's CRM procedures did not address the requirements to conduct a point-to-point
verification.
Subsequent to the PHMSA inspection, TBPL provided revised O&M Manual Section
8.6.1 point-to-point verification procedures, which required verification when safety
devices are replaced. But, the revised procedures did not specifically require verification
when like-for-like replacement of safety-related field instrumentation occurs.
3. § 195.446 Control room management
... (c) Provide adequate information. Each operator must provide its controllers
with the information, tools, processes and procedures necessary for the controllers to
carry out the roles and responsibilities the operator has defined by performing each
of the following:
•.• (4) Test any backup SCADA systems at least once each calendar year, but at
intervals not to exceed 15 months;
TBPL's CRM procedures did not require the backup SCADA system to be tested at least
once each calendar year at intervals not to exceed 15 months.
O&M Manual Section 8.14.2 stated, "Test any backup SCADA systems. TBPL has a
limited redundant SCADA node located at the operator's console. It is used primarily to
display remote site status and runs concurrently with primary system daily. Technically
this does not meet criteria as a backup SCADA system. " While this procedure said that
the secondary SCADA server did not technically meet criteria as a backup SCADA
system, TPL personnel explained during the PHMSA inspection that in the event of the
primary server failure, they would use the secondary SCADA server to monitor and
control the system. That said, neither this procedure nor any other procedure required the
backup SCADA system to be tested at least once each calendar year at intervals not to
exceed 15 months.
4. § 195.446 Control room management
... (d) Fatigue mitigation. Each operator must implement the following methods to
reduce the risk associated with controller fatigue that could inhibit a controller's
ability to carry out the roles and responsibilities the operator has defined:
•.. (1) Establish shift lengths and schedule rotations that provide controllers off-duty
time sufficient to achieve eight hours of continuous sleep;
TBPL's CRM procedures did not adequately establish shift lengths and schedule rotations
that provide controllers off-duty time sufficient to achieve eight hours of continuous sleep.
O&M Manual Section 8.6 did not adequately address how its fatigue mitigation program
would reduce the risk associated with controller fatigue, and did not address whether or
2



not controllers are "on-call." The procedures also did not explain how TBPL would
minimize interrupting the required eight hours of continuous sleep if the controllers were
"on-call." Moreover, if an "on-call" controller was required to report to the control room
on an unscheduled basis, the procedures did not address that the controller's commute
time should be counted as on-duty hours.
5. § 195.446 Control room management
•.• (d) Fatigue mitigation. Each operator must implement the following methods to
reduce the risk associated with controller fatigue that could inhibit a controller's
ability to carry out the roles and responsibilities the operator has defined:
... (4) Establish a maximum limit on controller hours-of-service, which may provide
for an emergency deviation from the maximum limit if necessary for the safe
operation of a pipeline facility.
TBPL's CRM procedures did not adequately establish maximum limits on controller
hours-of-service (HOS). That is CRM procedures in O&M Manual Section 8.6 did not
convey
- the specific fatigue countermeasures that TBPL should implement for controllers
working the ninth hour and beyond,
- any available fatigue countermeasures/tactics that TBPL could easily implement
such as breaks in the control room, standing, exercise, required walk-arounds, etc.'
- that the daily maximum HOS limit should be no more than 14 hours in any sliding
24-hour period,
- that the limitation on the number of allowed 18-hour (controller holdover) shifts per
controller is 1 in any sliding 5-day period,
- the specific fatigue countermeasures TBPL should implement for
- any and all shift duty hours worked after the first 8 hours,
- any and all hours worked between 2:00 a.m. and 6:00 a.m.,
- any and all night shifts immediately following three successive nights; and,
- a process for approving deviations from the maximum HOS limit.
Although subsequent to the PHMSA inspection TBPL provided revised procedures
addressing HOS deviations, the revised procedures did not specifically address handling
HOS deviations in advance of anticipated deviations, or, in cases where unforeseen
events occur, obtaining verbal and subsequent written approval at the first practical
moment after the deviation event.
6. § 195.446 Control room management
•.. (e) Alarm management. Each operator using a SCADA system must have a
written alarm management plan to provide for effective controller response to
alarms. An operator's plan must include provisions to:
•.• (1) Review SCADA safety-related alarm operations using a process that ensures
alarms are accurate and support safe pipeline operations;
' When a controller was asked by PHMSA inspectors about the frequency of yard walk-arounds in accordance
do walk-arounds.
with O&M Manual Section 8.6.2, "Operator performs routine walk around inspection, " he stated that he did not
3



TBPL's CRM procedures in O&M Manual Section 8.8.1 did not describe how TBPL
identified safety-related alarms and did not adequately describe a process that ensures
alarms are accurate and support safe pipeline operations. The procedure stated,
"8.7.3 Safety-Related Alarms
TBPL's designated alarm database, see TBPL SCADA Alarm Management File.
This digital file includes identified safety-related alarms. Controllers are trained to
understand which alarms are safety-related along with their individual implications.
Safety-related specific alarms are critical alarms and do not include low importance
alarms such as equipment efficiency alarms or measurement related alarms. 'For
purposes of Control Room Management, PHMSA considers safety-related to mean
any operational factor that is necessary to maintain pipeline integrity or that could
lead to the recognition of a condition that could impact the integrity of the pipeline,
or a developing abnormal or emergency situation'"
The above procedure and TBPL's policies did not adequately describe a process to ensure
alarms are accurate and support safe pipeline operations. That is, TBPL's CRM
procedures did not require the evaluation of each controller's ability to accurately perceive
SCADA display object characteristics (e.g., color, shape, text) that indicate the safety-
related alarms used in the operator's SCADA system.
7. § 195.446 Control room management
•.. (e) Alarm management. Each operator using a SCADA system must have a
written alarm management plan to provide for effective controller response to
alarms. An operator's plan must include provisions to:
... (3) Verify the correct safety-related alarm set-point values and alarm
descriptions when associated field instruments are calibrated or changed and at least
once each calendar year, but at intervals not to exceed 15 months;
TBPL's CRM procedures did not include a formal process to determine the correct
pressure and flow alarm set-points for each alarm priority and did not clearly address how,
and to what degree, controllers can change alarm limits, set-points, inhibit alarms, or take
points off-scan.
8. § 195.446 Control room management
..• (e) Alarm management. Each operator using a SCADA system must have a
written alarm management plan to provide for effective controller response to
alarms. An operator's plan must include provisions to:
..• (5) Monitor the content and volume of general activity being directed to and
required of each controller at least once each calendar year, but at intervals not
exceeding 15 months, that will assure controllers have sufficient time to analyze and
react to incoming alarms; and...
TBPL's CRM procedures did not explain how TBPL monitored the content and volume of
general activity being directed to, and required of, each controller. O&M Manual Section
8.12.5 only "parroted" the federal pipeline safety regulations.
4



9. § 195.446 Control room management
•.• (f) Change management. Each operator must assure that changes that could
affect control room operations are coordinated with the control room personnel by
performing each of the following:
•.• (1) Implement section 7 of API RP 1168 (incorporated by reference, see § 195.3)
for control room management change and require coordination between control
room representatives, operator's management, and associated field personnel when
planning and implementing physical changes to pipeline equipment or configuration;
TBPL's CRM procedures did not adequately require coordination between control room
representatives, operator's management, and associated field personnel when planning and
implementing physical changes to pipeline equipment or configuration.
O&M Manual Section 8.8 did not require that configuration changes to SCADA screens
relating to changes in field equipment must be made prior to the equipment changes going
into operation. Also, the procedures did not specifically convey that TBPL followed
section 7 of API RP 1168.
10. § 195.446 Control room management
... (g) Operating experience. Each operator must assure that lessons learned from
its operating experience are incorporated, as appropriate, into its control room
management procedures by performing each of the following:
... (2) Include lessons learned from the operator's experience in the training
program required by this section.
TBPL's CRM procedures were not in the detail required to assure that lessons learned
from TBPL's experience were included in its training program.
O&M Manual Section 8.9.4 did not describe examples of events from lessons learned to
be included in training; i.e., operating events (in addition to reportable incidents/accidents)
like near misses, leaks, operational and maintenance errors, etc.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. §60108(a) and 49 C.F.R. §190.237. Enclosed
as part of this Notice is a document entitled Response Options for Pipeline Operators in
Compliance Proceedings. Please refer to this document and note the response options. Be
advised that all material you submit in response to this enforcement action is subject to being
made publicly available. If you believe that any portion of your responsive material qualifies
for confidential treatment under 5 U.S.C. 552(b), along with the complete original document
you must provide a second copy of the document with the portions you believe qualify for
confidential treatment redacted and an explanation of why you believe the redacted
information qualifies for confidential treatment under 5 U.S.C. 552(b). If you do not respond
within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the
allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to
find facts as alleged in this Notice without further notice to you and to issue a Final Order.
5



If, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in
this Notice, you may be ordered to amend your plans or procedures to correct the
inadequacies (49 C.F.R. § 190.237). If you are not contesting this Notice, we propose that
you submit your amended procedures to my office within 60 days of receipt of this Notice.
This period may be extended by written request for good cause. Once the inadequacies
identified herein have been addressed in your amended procedures, this enforcement action
will be closed.
It is requested (not mandated) that Tampa Bay Pipeline Company maintain documentation of
the safety improvement costs associated with fulfilling this Notice of Amendment
(preparation/ revision of plans, procedures) and submit the total to Wayne T. Lemoi, Director,
Southern Region, Pipeline and Hazardous Materials Safety Administration. In
correspondence concerning this matter, please refer to CPF 2-2013-6006M and, for each
document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
Mall-le
Direetor, Office of Pipeline Safety
PHMSA Southern Region
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings

220136006M_closure letter_08052014_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
August 5, 2014
Mr. Robert L. Rose
President
Tampa Bay Pipeline Company
P.O. Box 35236
Sarasota, FL 34242
CPF 2-2013-6006M
Dear Mr. Rose:
On May 13-17, 2013, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), Southern Region, Office of Pipeline Safety (OPS) inspected the
Tampa Bay Pipeline Company (TBPL) control room in Tampa, Florida, pursuant to Chapter
601 of 49 United States Code. As a result of the inspection, PHMSA issued a Notice of
Amendment (NOA) on September 4, 2013.
The OPS Southern Region has received and reviewed several written responses to the NOA
from TBPL, including TBPL’s final response dated July 22, 2014. Based on our review of
these responses we have determined that TBPL has complied with the terms of the NOA.
This case is now closed and no further action is necessary with respect to the matters involved
in this case.
Please be advised that this letter refers only to the referenced NOA (CPF 2-2013-6006M) and
not to any other PHMSA cases, if any.
Sincerely,
Wayne T. Lemoi
Director, Office of Pipeline Safety
PHMSA Southern Region

220136006M_notice of amendment_09042013_text.pdf

NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
September 4, 2013
Mr. Robert L. Rose
President
Tampa Bay Pipeline Company
P.O. Box 35236
Sarasota, FL 34242
CPF 2-2013-6006M
Dear Mr. Rose:
On May 13-17, 2013, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), Southern Region, Office of Pipeline Safety (OPS) inspected the
Tampa Bay Pipeline Company (TBPL) control room in Tampa, Florida, pursuant to Chapter
601 of 49 United States Code.
On the basis of the inspection, PHMSA has identified apparent inadequacies within TBPL’s
written Control Room Management (CRM) procedures, which were contained in TBPL’s
Operations & Maintenance Procedure Manual (O&M Manual), as described below:
1. § 195.446 Control room management.
. . . (b) Roles and responsibilities. Each operator must define the roles and
responsibilities of a controller during normal, abnormal, and emergency operating
conditions. To provide for a controller's prompt and appropriate response to
operating conditions, an operator must define each of the following:
TBPL’s CRM procedures did not adequately define the roles and responsibilities of a
controller during normal, abnormal, and emergency operating conditions.
O&M Manual Section 8.6.2 On-Shift Breaks stated, “Staffing levels do not allow specific
time for controller breaks away from pipeline control room. Operator performs routine
walk around inspection, is authorized food and drink in control room keeping items away
from work station, and has access to lavatory facility in the control room area.” These
procedures, however, did not include an explanation of when and how the pipeline is
operated when the control room is unattended such as when controllers are in the
restroom, or performing routine walk around inspections, etc.



2. 3. 4. § 195.446 Control room management
. . . (c) Provide adequate information. Each operator must provide its controllers
with the information, tools, processes and procedures necessary for the controllers to
carry out the roles and responsibilities the operator has defined by performing each
of the following:
. . . (2) Conduct a point-to-point verification between SCADA displays and related
field equipment when field equipment is added or moved and when other changes
that affect pipeline safety are made to field equipment or SCADA displays;
TBPL’s CRM procedures did not address the requirements to conduct a point-to-point
verification.
Subsequent to the PHMSA inspection, TBPL provided revised O&M Manual Section
8.6.1 point-to-point verification procedures, which required verification when safety
devices are replaced. But, the revised procedures did not specifically require verification
when like-for-like replacement of safety-related field instrumentation occurs.
§ 195.446 Control room management
. . . (c) Provide adequate information. Each operator must provide its controllers
with the information, tools, processes and procedures necessary for the controllers to
carry out the roles and responsibilities the operator has defined by performing each
of the following:
. . . (4) Test any backup SCADA systems at least once each calendar year, but at
intervals not to exceed 15 months;
TBPL’s CRM procedures did not require the backup SCADA system to be tested at least
once each calendar year at intervals not to exceed 15 months.
O&M Manual Section 8.14.2 stated, “Test any backup SCADA systems. TBPL has a
limited redundant SCADA node located at the operator’s console. It is used primarily to
display remote site status and runs concurrently with primary system daily. Technically
this does not meet criteria as a backup SCADA system." While this procedure said that
the secondary SCADA server did not technically meet criteria as a backup SCADA
system, TPL personnel explained during the PHMSA inspection that in the event of the
primary server failure, they would use the secondary SCADA server to monitor and
control the system. That said, neither this procedure nor any other procedure required the
backup SCADA system to be tested at least once each calendar year at intervals not to
exceed 15 months.
§ 195.446 Control room management
. . . (d) Fatigue mitigation. Each operator must implement the following methods to
reduce the risk associated with controller fatigue that could inhibit a controller's
ability to carry out the roles and responsibilities the operator has defined:
. . . (1) Establish shift lengths and schedule rotations that provide controllers off-duty
time sufficient to achieve eight hours of continuous sleep;
TBPL’s CRM procedures did not adequately establish shift lengths and schedule rotations
that provide controllers off-duty time sufficient to achieve eight hours of continuous sleep.
O&M Manual Section 8.6 did not adequately address how its fatigue mitigation program
would reduce the risk associated with controller fatigue, and did not address whether or
2



5. 6. not controllers are “on-call.” The procedures also did not explain how TBPL would
minimize interrupting the required eight hours of continuous sleep if the controllers were
“on-call.” Moreover, if an “on-call” controller was required to report to the control room
on an unscheduled basis, the procedures did not address that the controller’s commute
time should be counted as on-duty hours.
§ 195.446 Control room management
. . . (d) Fatigue mitigation. Each operator must implement the following methods to
reduce the risk associated with controller fatigue that could inhibit a controller's
ability to carry out the roles and responsibilities the operator has defined:
. . . (4) Establish a maximum limit on controller hours-of-service, which may provide
for an emergency deviation from the maximum limit if necessary for the safe
operation of a pipeline facility.
TBPL’s CRM procedures did not adequately establish maximum limits on controller
hours-of-service (HOS). That is CRM procedures in O&M Manual Section 8.6 did not
convey
- the specific fatigue countermeasures that TBPL should implement for controllers
working the ninth hour and beyond,
- any available fatigue countermeasures/tactics that TBPL could easily implement
such as breaks in the control room, standing, exercise, required walk-arounds, etc.1
- that the daily maximum HOS limit should be no more than 14 hours in any sliding
24-hour period,
- that the limitation on the number of allowed 18-hour (controller holdover) shifts per
controller is 1 in any sliding 5-day period,
- the specific fatigue countermeasures TBPL should implement for
− any and all shift duty hours worked after the first 8 hours,
− any and all hours worked between 2:00 a.m. and 6:00 a.m.,
− any and all night shifts immediately following three successive nights; and,
- a process for approving deviations from the maximum HOS limit.
Although subsequent to the PHMSA inspection TBPL provided revised procedures
addressing HOS deviations, the revised procedures did not specifically address handling
HOS deviations in advance of anticipated deviations, or, in cases where unforeseen
events occur, obtaining verbal and subsequent written approval at the first practical
moment after the deviation event.
§ 195.446 Control room management
. . . (e) Alarm management. Each operator using a SCADA system must have a
written alarm management plan to provide for effective controller response to
alarms. An operator's plan must include provisions to:
. . . (1) Review SCADA safety-related alarm operations using a process that ensures
alarms are accurate and support safe pipeline operations;
1 When a controller was asked by PHMSA inspectors about the frequency of yard walk-arounds in accordance
with O&M Manual Section 8.6.2, “Operator performs routine walk around inspection,” he stated that he did not
do walk-arounds.
3



7. 8. TBPL’s CRM procedures in O&M Manual Section 8.8.1 did not describe how TBPL
identified safety-related alarms and did not adequately describe a process that ensures
alarms are accurate and support safe pipeline operations. The procedure stated,
“8.7.3 Safety-Related Alarms
TBPL’s designated alarm database, see TBPL SCADA Alarm Management File.
This digital file includes identified safety-related alarms. Controllers are trained to
understand which alarms are safety-related along with their individual implications.
Safety-related specific alarms are critical alarms and do not include low importance
alarms such as equipment efficiency alarms or measurement related alarms. ‘For
purposes of Control Room Management, PHMSA considers safety-related to mean
any operational factor that is necessary to maintain pipeline integrity or that could
lead to the recognition of a condition that could impact the integrity of the pipeline,
or a developing abnormal or emergency situation’”
The above procedure and TBPL’s policies did not adequately describe a process to ensure
alarms are accurate and support safe pipeline operations. That is, TBPL’s CRM
procedures did not require the evaluation of each controller’s ability to accurately perceive
SCADA display object characteristics (e.g., color, shape, text) that indicate the safety-
related alarms used in the operator’s SCADA system.
§ 195.446 Control room management
. . . (e) Alarm management. Each operator using a SCADA system must have a
written alarm management plan to provide for effective controller response to
alarms. An operator's plan must include provisions to:
. . . (3) Verify the correct safety-related alarm set-point values and alarm
descriptions when associated field instruments are calibrated or changed and at least
once each calendar year, but at intervals not to exceed 15 months;
TBPL’s CRM procedures did not include a formal process to determine the correct
pressure and flow alarm set-points for each alarm priority and did not clearly address how,
and to what degree, controllers can change alarm limits, set-points, inhibit alarms, or take
points off-scan.
§ 195.446 Control room management
. . . (e) Alarm management. Each operator using a SCADA system must have a
written alarm management plan to provide for effective controller response to
alarms. An operator's plan must include provisions to:
. . . (5) Monitor the content and volume of general activity being directed to and
required of each controller at least once each calendar year, but at intervals not
exceeding 15 months, that will assure controllers have sufficient time to analyze and
react to incoming alarms; and . . .
TBPL’s CRM procedures did not explain how TBPL monitored the content and volume of
general activity being directed to, and required of, each controller. O&M Manual Section
8.12.5 only “parroted” the federal pipeline safety regulations.
4



9. § 195.446 Control room management
. . . (f) Change management. Each operator must assure that changes that could
affect control room operations are coordinated with the control room personnel by
performing each of the following:
. . . (1) Implement section 7 of API RP 1168 (incorporated by reference, see § 195.3)
for control room management change and require coordination between control
room representatives, operator's management, and associated field personnel when
planning and implementing physical changes to pipeline equipment or configuration;
TBPL’s CRM procedures did not adequately require coordination between control room
representatives, operator's management, and associated field personnel when planning and
implementing physical changes to pipeline equipment or configuration.
O&M Manual Section 8.8 did not require that configuration changes to SCADA screens
relating to changes in field equipment must be made prior to the equipment changes going
into operation. Also, the procedures did not specifically convey that TBPL followed
section 7 of API RP 1168.
10. § 195.446 Control room management
. . . (g) Operating experience. Each operator must assure that lessons learned from
its operating experience are incorporated, as appropriate, into its control room
management procedures by performing each of the following:
. . . (2) Include lessons learned from the operator's experience in the training
program required by this section.
TBPL’s CRM procedures were not in the detail required to assure that lessons learned
from TBPL’s experience were included in its training program.
O&M Manual Section 8.9.4 did not describe examples of events from lessons learned to
be included in training; i.e., operating events (in addition to reportable incidents/accidents)
like near misses, leaks, operational and maintenance errors, etc.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. §60108(a) and 49 C.F.R. §190.237. Enclosed
as part of this Notice is a document entitled Response Options for Pipeline Operators in
Compliance Proceedings. Please refer to this document and note the response options. Be
advised that all material you submit in response to this enforcement action is subject to being
made publicly available. If you believe that any portion of your responsive material qualifies
for confidential treatment under 5 U.S.C. 552(b), along with the complete original document
you must provide a second copy of the document with the portions you believe qualify for
confidential treatment redacted and an explanation of why you believe the redacted
information qualifies for confidential treatment under 5 U.S.C. 552(b). If you do not respond
within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the
allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to
find facts as alleged in this Notice without further notice to you and to issue a Final Order.
5



If, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in
this Notice, you may be ordered to amend your plans or procedures to correct the
inadequacies (49 C.F.R. § 190.237). If you are not contesting this Notice, we propose that
you submit your amended procedures to my office within 60 days of receipt of this Notice.
This period may be extended by written request for good cause. Once the inadequacies
identified herein have been addressed in your amended procedures, this enforcement action
will be closed.
It is requested (not mandated) that Tampa Bay Pipeline Company maintain documentation of
the safety improvement costs associated with fulfilling this Notice of Amendment
(preparation/ revision of plans, procedures) and submit the total to Wayne T. Lemoi, Director,
Southern Region, Pipeline and Hazardous Materials Safety Administration. In
correspondence concerning this matter, please refer to CPF 2-2013-6006M and, for each
document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
Wayne T. Lemoi
Director, Office of Pipeline Safety
PHMSA Southern Region
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings
6
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