{"operation":"document","citation":"CPF 22021001NOA","title":"TENNESSEE GAS PIPELINE COMPANY — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-05-26","effective_on":null,"summary":"CLOSED notice of amendment citing 192.631(e)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-22021001noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-22021001noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-22021001noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/22021001NOA","body":"Notice of Amendment involving TENNESSEE GAS PIPELINE COMPANY. PHMSA's enforcement data identifies the cited regulation as 192.631(e)(2). The case was opened on 2021-05-26 and is reported as closed as of 2022-02-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n22021001NOA_Closure Letter_02022022_(20-176853).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22021001NOA/22021001NOA_Closure%20Letter_02022022_(20-176853).pdf\n\n22021001NOA_Closure Letter_02022022_(20-176853)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/22021001NOA/22021001NOA_Closure%20Letter_02022022_(20-176853)_text.pdf\n\n22021001NOA_Notice of Amendment_05262021_(20-176853).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22021001NOA/22021001NOA_Notice%20of%20Amendment_05262021_(20-176853).pdf\n\n22021001NOA_Notice of Amendment_05262021_(20-176853)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/22021001NOA/22021001NOA_Notice%20of%20Amendment_05262021_(20-176853)_text.pdf\n\n22021001NOA_Operator Response to Notice_06232021_(20-176853).pdf: https://primis.phmsa.dot.gov/enforcement-documents/22021001NOA/22021001NOA_Operator%20Response%20to%20Notice_06232021_(20-176853).pdf\n\n22021001NOA_Closure Letter_02022022_(20-176853)_text.pdf\n\nDELIVERY METHOD – VIA FEDERAL EXPRESS\nFebruary 2, 2022\nMr. Kenneth Grubb\nChief Operating Officer\nTennessee Gas Pipeline Company\nKinder Morgan, Inc.\n1001 Louisiana Street, Suite 1000\nHouston, TX 77002\nCPF 2-2021-001-NOA\nDear Mr. Grubb:\nFrom April 27, 2020 through May 1, 2020, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) inspected Tennessee Gas Pipeline Company’s (TGP) Control\nRoom Management Program and records in Houston, Texas, pursuant to Chapter 601 of 49 United\nStates Code. TGP is a subsidiary of Kinder Morgan (KM). As a result of the inspection, TGP was\nissued a Notice of Amendment (NOA) on May 26, 2021, which proposed amendments of TGP’s\nprocedures.\nTGP submitted its amended procedures on June 23, 2021. PHMSA has reviewed the amended\nprocedures, and it appears that the inadequacies outlined in the NOA have been corrected.\nPlease be advised that this letter refers only to the referenced NOA (CPF 2-2021-001-NOA) and\nnot to any other PHMSA cases, if any.\nSincerely,\nJames A. Urisko\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\n\n22021001NOA_Notice of Amendment_05262021_(20-176853)_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMay 26, 2021\nMr. Kenneth Grubb\nChief Operating Officer\nTennessee Gas Pipeline Company\n1001 Louisiana Street, Suite 1000\nHouston, TX 77002\nCPF 2-2021-001-NOA\nDear Mr. Grubb:\nFrom April 27, 2020 through May 1, 2020, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) inspected Tennessee Gas Pipeline Company’s (TGP)\nControl Room Management Program and records in Houston, Texas, pursuant to Chapter 601 of\n49 United States Code. TGP is a subsidiary of Kinder Morgan (KM).\nOn the basis of the inspection, PHMSA has identified the apparent inadequacy found within\nTGP’s procedures, as described below:\n1. § 192.631 Control room management.\n(a) …\n(e) Alarm management. Each operator using a SCADA system must have a written\nalarm management plan to provide for effective controller response to alarms. An\noperator's plan must include provisions to:\n(1) ….\n(2) Identify at least once each calendar month points affecting safety that have been\ntaken off scan in the SCADA host, have had alarms inhibited, generated false alarms,\nor that have had forced or manual values for periods of time exceeding that required\nfor associated maintenance or operating activities;\n\n\n\nTGP's written alarm management plan (AMP) did not require, at intervals of at least once\neach calendar month, identification of points affecting safety that generated false alarms.\nAt the time of PHMSA’s inspection, TGP incorporated Version 6.1 of KM’s AMP, titled\n“Alarm Management Plan For Control Room Operations,” dated March 10, 2020, which\nreferenced multiple appendices including Appendix C, titled “Appendix C - SCADA Alarm\nManagement Reports.” Section VI of the AMP, titled “Alarm Audits,” requires TGP\npersonnel to, on a monthly basis, \"review the alarm system to identify and address safety-\nrelated points that have been taken off scan, have been inhibited, have manual values or have\nhad false alarms. (see Appendix C).\" In Appendix C, TGP listed fourteen (14) different\ntypes of alarms to be analyzed for the above-referenced monthly reviews. The listed types of\nalarms to be analyzed did not include false alarms. During the inspection, PHMSA personnel\nprovided an example of a false alarm: an alarm that can mislead a controller to believe a\ncondition exists, but that does not exist due to field personnel conducting routine operations\n& maintenance without contacting the control room and which generated a safety alarm in\nthe Control Room. TGP personnel agreed that this scenario would not be captured in any of\nits fourteen different types of alarms to be analyzed per Appendix C.\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\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 for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you\nmust 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 information\nqualifies for confidential treatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis Notice without further notice to you and to issue an Order Directing Amendment. If your\nplans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend\nyour plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not\ncontesting this Notice, we propose that you submit your amended procedures to my office within\n60 days of receipt of this Notice. This period may be extended by written request for good\ncause. Once the inadequacies identified herein have been addressed in your amended\nprocedures, this enforcement action will be closed.\nIt is requested (not mandated) that Tennessee Gas 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 Director, Office of Pipeline\nSafety, PHMSA Southern Region. In correspondence concerning this matter, please refer to\n2\n\n\n\nCPF 2-2021-001-NOA and, for each document you submit, please provide a copy in electronic\nformat whenever possible.\nSincerely,\nJames A. Urisko\nDirector, Office of Pipeline Safety\nPHMSA Southern Region\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n3","truncated":false,"body_characters":7583}