{"operation":"document","citation":"CPF 220136008M","title":"TAMPA AIRPORT PIPELINE CORPORATION — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-09-09","effective_on":null,"summary":"CLOSED notice of amendment citing 195.446(c)(1), 195.446(c)(2), 195.446(c)(5), 195.446(d)(1), 195.446(d)(4), 195.446(e)(1), 195.446(e)(3), 195.446(e)(5).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220136008m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220136008m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220136008m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220136008M","body":"Notice of Amendment involving TAMPA AIRPORT PIPELINE CORPORATION. PHMSA's enforcement data identifies the cited regulations as 195.446(c)(1),  195.446(c)(2),  195.446(c)(5),  195.446(d)(1),  195.446(d)(4),  195.446(e)(1),  195.446(e)(3),  195.446(e)(5). The case was opened on 2013-09-09 and is reported as closed as of 2014-09-17. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220136008M_closure letter_09172014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220136008M/220136008M_closure%20letter_09172014.pdf\n\n220136008M_closure Letter_09172014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220136008M/220136008M_closure%20Letter_09172014_text.pdf\n\n220136008M_notice of amendment_09092013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220136008M/220136008M_notice%20of%20amendment_09092013.pdf\n\n220136008M_notice of amendment_09092013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220136008M/220136008M_notice%20of%20amendment_09092013_text.pdf\n\n220136008M_closure Letter_09172014_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nSeptember 17, 2014\nMr. Robert L. Rose\nPresident\nTampa Airport Pipeline Corporation\nP.O. Box 35236\nSarasota, FL 34242\nCPF 2-2013-6008M\nDear Mr. Rose:\nOn May 15-17, 2013, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Southern Region, Office of Pipeline Safety (OPS) inspected the\nTampa Airport Pipeline Corporation (TAPC) control room in Tampa, Florida, pursuant to\nChapter 601 of 49 United States Code. As a result of the inspection, the OPS Southern\nRegion issued a Notice of Amendment (NOA) to TAPC on September 9, 2013.\nSubsequent to the NOA, TAPC amended its control room procedures and provided the OPS\nSouthern Region with documentation of those amendments. Based on our review of the\nactions taken by TAPC to amend its procedures and the supporting documentation, we have\ndetermined that TAPC has complied with the terms of the NOA and that no further action is\nnecessary with regards to the NOA. This case is now closed.\nPlease be advised that this letter refers only to the above referenced order\n(CPF 2-2013-6008M) and not to any other PHMSA cases, if any.\nSincerely,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\n\n220136008M_notice of amendment_09092013_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nSeptember 9, 2013\nMr. Robert L. Rose\nPresident\nTampa Airport Pipeline Corporation\nP.O. Box 35236\nSarasota, FL 34242\nCPF 2-2013-6008M\nDear Mr. Rose:\nOn May 15-17, 2013, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Southern Region, Office of Pipeline Safety (OPS) inspected the\nTampa Airport Pipeline Corporation (TAPC) control room in Tampa, Florida, pursuant to\nChapter 601 of 49 United States Code.\nOn the basis of the inspection, PHMSA has identified apparent inadequacies within TAPC’s\nwritten Control Room Management (CRM) procedures, which were contained in TAPC’s\nOperations & Maintenance Procedure Manual (O&M Manual), as described below:\n1. § 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. . . (1) Implement API RP 1165 (incorporated by reference, see § 195.3) whenever a\nSCADA system is added, expanded or replaced, unless the operator demonstrates\nthat certain provisions of API RP 1165 are not practical for the SCADA system used;\nTAPC’s CRM procedures did not clearly define the types of changes to its SCADA\nsystem that would constitute additions, expansions, or replacements that require\nAPI RP 1165 to be implemented unless the operator demonstrates that certain provisions\nof API RP 1165 are not practical for the SCADA system used.\nTAPC’s O&M Manual Section 8.3 did not describe in adequate detail those changes that\nimpact display parameters (such as display symbols, color palettes or anything that affects\nthe controller-machine interface) and would require TAPC to implement API RP 1165.\n\n\n\n2. 3. Section 8.3 also did not explain in adequate detail how TAPC’s SCADA system (which is\nbeing upgraded1) will comply with API RP 1165 nor did TAPC include this requirement\nin its SCADA upgrade contract specifications. In lieu of the preceding, TAPC did not\ndemonstrate that certain provisions of API RP 1165 will not be practical for its upgraded\nSCADA system.\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. . . (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;\nTAPC’s CRM procedures did not address the requirement to conduct a point-to-point\nverification between SCADA displays and related field equipment when field equipment\nis added or moved and when other changes that affect pipeline safety are made to field\nequipment or SCADA displays.\nSubsequent to the PHMSA inspection, TAPC provided new point-to-point verification\nprocedures (O&M Manual Section 8.5.1) to the PHMSA inspector that required\nverification when safety devices are replaced, but the new procedures did not require\nverification when 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. . . (5) Implement section 5 of API RP 1168 (incorporated by reference, see § 195.3)\nto establish procedures for when a different controller assumes responsibility,\nincluding the content of information to be exchanged.\nTAPC’s CRM procedures did not have all the checklist items specified in API RP 1168\nSection 5 and referenced a non-existent “Operators Shift Change Form.”\nSubsequent to the PHMSA inspection, TAPC provided revised procedures (TAPC O&M\nProcedure Manual rev. May 30, 2013) but the new procedures were not clear as to which\nform is to be used during shift change. Also, although one of the new referenced forms\ncontained the items listed in API RP 1168 Section 5, the form did not require annotation\nby the controller of “no change” rather than not covering a topic in the event certain\noperational aspects are not important to an incoming controller.\n1 TAPC personnel informed the PHMSA inspector that TAPC has contracted with Curry Controls to upgrade its\nSCADA system to conform to API 1165 in 2013. As of August 29, 2013, the upgrade is in the design phase.\n2\n\n\n\n4. 5. 6. § 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;\nTAPC’s CRM procedures in O&M Manual Section 8.7 did not adequately address how its\nfatigue mitigation program would reduce the risk associated with controller fatigue.\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.\nTAPC’s CRM procedures did not adequately establish maximum limits on controller\nhours-of-service (HOS).\nTAPC’s procedures did not specifically convey that, for its 8-hour shift, it conforms to the\nfollowing shift holdover guideline: one 16-hour (double shift) (17 hours with hand-over\ntime), or two 10-hour shifts (11 hours with hand-over time) in any sliding 7-day period.\nSubsequent to the PHMSA inspection, TAPC provided revised procedures (TAPC O&M\nProcedure Manual rev. May 30, 2013) that provided for two 10-hour shifts (11 hours with\nhand-over time), but the revised procedures did not restrict this to a sliding 7-day period.\nTAPC’s procedures did not contain any specific fatigue countermeasures that should be\nimplemented for the below-listed shift 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\n- Any and all day or night shifts following four successive night shifts unless three\nnocturnal sleep cycles have been completed\nTAPC did not have a documented technical basis to show that the operator’s maximum\nlimit on controller HOS is adequate to reduce the risk associated with controller fatigue,\nand did not have a formal procedure for approving deviations from the maximum HOS\nlimits.\nSubsequent to the PHMSA inspection, TAPC provided revised procedures (TAPC O&M\nProcedure Manual rev. May 30, 2013) with general requirements for documenting\ndeviations from procedures and the CRM rule, but the revised procedures did not have a\nformal HOS deviation procedure.\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:\n3\n\n\n\n7. 8. . . . (1) Review SCADA safety-related alarm operations using a process that ensures\nalarms are accurate and support safe pipeline operations;\nTAPC’s CRM procedures in O&M Manual Section 8.8.1 did not describe how TAPC\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“8.8.1 Safety-Related Alarms\nTAPC’s designated alarm database, see TAPC Alarm Management Plan. This\nplan includes identified safety-related alarms. Controllers are trained to\nunderstand which alarms are safety-related along with their individual\nimplications. Safety-related specific alarms are critical alarms and do not\ninclude low importance alarms such as equipment efficiency alarms or\nmeasurement related alarms. For purposes of Control Room Management,\nPHMSA considers safety-related to mean any operational factor that is\nnecessary to maintain pipeline integrity or that could lead to the recognition of a\ncondition that could impact the integrity of the pipeline, or a developing\nabnormal or emergency situation.”\nThe above procedure and TAPC’s policies did not require the evaluation each controller’s\nability to accurately perceive SCADA display object characteristics (e.g., color, shape,\ntext) that indicate safety-related 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;\nTAPC’s CRM procedures did not require the verification of the correct safety-related\nalarm set-point values and alarm descriptions when associated field instruments are\ncalibrated or changed.\nSubsequent to the PHMSA inspection, TAPC provided revised procedures (TAPC O&M\nProcedure Manual rev. May 30, 2013) but the new procedures were not clear that any\ncalibration or change to field instruments required verification of alarm set-points and\nalarm descriptions.\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 . . .\n4\n\n\n\nTAPC’s CRM procedures did not convey how TAPC monitors the content and volume of\ngeneral activity being directed to and required of each controller. O&M Manual section\n8.11.5 only “parroted” the federal pipeline safety regulations.\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.\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 Airport Pipeline Corporation maintain\ndocumentation of the safety improvement costs associated with fulfilling this Notice of\nAmendment (preparation/ revision of plans, procedures) and submit the total to\nWayne T. Lemoi, Director, Southern Region, Pipeline and Hazardous Materials Safety\nAdministration. In correspondence concerning this matter, please refer to\nCPF 2-2013-6008M and, for each document you submit, please provide a copy in electronic\nformat whenever possible.\nSincerely,\nWayne T. Lemoi\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n5","truncated":false,"body_characters":15513}