MID-CONTINENT FRACTIONATION AND STORAGE, L.L.C. — Notice of Amendment

party submissionOfficial PDF320165002M_Operator Response to Notice_04012016.pdf#

320165002M_Closure Letter_06272016_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED June 27, 2016 Ms. Stephanie Timmermeyer Vice President - Safety and Regulatory Compliance Mid-Continent Fractionation and Storage, LLC 525 Central Park Drive Oklahoma City, OK 73105 CPF 3-2016-5002M Dear Ms. Timmenneyer: On June 22-30, 2015, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected MidContinent Fractionation and Storage, LLC's (MidCon) procedures for Control Room Management in Conway, Kansas. As a result of the inspection, MidCon was issued a Notice of Amendment on March 16, 2016, which proposed amendment of the procedures. MidCon submitted its amended procedures on April 1, 2016 and submitted additional amendments on June 21, 2016. My staff reviewed the amended procedures and it appears that the inadequacies outlined in this Notice of Amendment have been corrected. This letter is to inform you no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, Allan C. Beshore Director, Central Region, OPS Pipeline and Hazardous Materials Safety Administration#

320165002M_Notice of Amendment_03162016_text.pdf, page 1Official PDFNOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT REQUESTED March 16, 2016 Ms. Stephanie Timmermeyer Vice President – Safety and Regulatory Compliance Mid-Continent Fractionation and Storage, LLC 525 Central Park Drive Oklahoma City, OK 73105 CPF 3-2016-5002M Dear Ms. Timmermeyer: On June 22-30, 2015, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Mid- Continent Fractionation and Storage, LLC’s procedures for Control Room Management in Conway, Kansas. On the basis of the inspection, PHMSA has identified the apparent inadequacies found within Mid-Continent Fractionation and Storage, LLC’s (MidCon’s) plans or procedures, as described below: 1. §195.402 Procedural manual for operations, maintenance, and emergencies (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (15) Implementing the applicable control room management procedures required by § 195.446. and;#

320165002M_Notice of Amendment_03162016_text.pdf, page 2§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: (1) A controller's authority and responsibility to make decisions and take actions during normal operations; MidCon’s CRM procedure on defining what the controllers do during temporary impromptu changes in responsibilities requires more detail. The procedure on page 9 indicates that if a controller needs to leave for any reason (i.e.; breaks), a controller at another console will only observe and listen for the alarms at the vacant console, and then notify the absent controller in the event of an abnormal operating condition. However, Conway personnel indicated that the notification to the other controller will be done on all alarms. Procedure must be changed to reflect what Conway actually does. 2) §195.402(c)(15) – See Above §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: (2) Educate controllers and supervisors in fatigue mitigation strategies and how off- duty activities contribute to fatigue The CRM plan did not indicate what the training includes. More detail must be added to clearly show how MidCon trains their personnel on fatigue mitigation. 3) §195.402(c)(15) – See Above §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; 2#

320165002M_Notice of Amendment_03162016_text.pdf, page 3MidCon’s Alarm Management Philosophy contains different types of alarms and defines the priorities. However, synthetic or calculated alarms are not addressed in the alarm management plan. MidCon must provide written procedures on synthetic or calculated alarms including a process for review to ensure these alarms are accurate and support safe pipeline operations. 4) §195.402(c)(15) – See Above §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: (6) Address deficiencies identified through the implementation of paragraphs (e)(1) through (e)(5) of this section. MidCon’s CRM plan does not have procedures on how they are going to address the deficiencies identified within the alarm management plan. The CRM procedures must be expanded to better define how and when they are going to correct deficiencies identified within the plan reviews. 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. 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 90 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. 3#

320165002M_Notice of Amendment_03162016_text.pdf, page 4It is requested (not mandated) that Mid-Continent Fractionation and Storage, LLC’s maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Allan C. Beshore, Director, Central Region, OPS, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 3-2016-5002M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Allan C. Beshore Director, Central Region, OPS Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings 4#