{"operation":"document","citation":"CPF 320175007M","title":"FLINT HILLS RESOURCES, LC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-09-01","effective_on":null,"summary":"CLOSED notice of amendment citing 195.444, 195.446(b)(1), 195.446(b)(3), 195.446(c)(1), 195.446(c)(2), 195.446(c)(3), 195.446(c)(4), 195.446(e)(1), 195.446(g)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320175007m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320175007m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320175007m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320175007M","body":"Notice of Amendment involving FLINT HILLS RESOURCES, LC. PHMSA's enforcement data identifies the cited regulations as 195.444,  195.446(b)(1),  195.446(b)(3),  195.446(c)(1),  195.446(c)(2),  195.446(c)(3),  195.446(c)(4),  195.446(e)(1),  195.446(g)(1). The case was opened on 2017-09-01 and is reported as closed as of 2017-09-01. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320175007M_Notice of Amendment_09012017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320175007M/320175007M_Notice%20of%20Amendment_09012017.pdf\n\n320175007M_Notice of Amendment_09012017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320175007M/320175007M_Notice%20of%20Amendment_09012017_text.pdf\n\n320175007M_Notice of Amendment_09012017_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nSeptember 1, 2017\nMr. Bob O’Hair\nExecutive Vice President\nKoch Pipeline Company L.P.\nNorthern Operations Group\n4111 East 37th Street North\nP.O. Box 2975\nWichita KS, 67201\nCPF 3-2017-5007M\nDear Mr. O’Hair:\nOn February 22 through 26, 2016, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) Central Region and the Minnesota Office of Pipeline Safety\npursuant to Chapter 601 of 49 United States Code inspected the Pipeline Control Room\nManagement (CRM) Plan for Koch Pipeline Company L.P. (KPL), Northern Operations Group\n(NOG), in Wichita, Kansas.\nOn the basis of the inspection, PHMSA has identified apparent inadequacies found within\nKPL’s NOG procedures, as described below:\nOn the basis of the inspection, PHMSA has identified apparent inadequacies found within the\nCRM procedures, as described below:\n1) §195.446(b) Roles and Responsibilities\nEach operator must define the roles and responsibilities of a controller during\nnormal, abnormal, and emergency operating conditions. To provide for a controller’s\nprompt and appropriate response to operating conditions, an operator must define\neach of the following:\n\n\n\n(1) A controller's authority and responsibility to make decisions and take actions\nduring normal operations;\nKPL procedures do not adequately define the duration of a brief period that the\nController may leave the Pipeline Control Center (PCC) when there are no operational\ntasks in progress and do not adequately define the communication tools that the\nControllers will use to contact each other during a break.\nKPL has revised its procedures. PHMSA has reviewed KPL’s amended procedures\nand considers this item closed.\n2) §195.446(b) Roles and Responsibilities\nEach operator must define the roles and responsibilities of a controller during\nnormal, abnormal, and emergency operating conditions. To provide for a controller’s\nprompt and appropriate response to operating conditions, an operator must define\neach of the following:\n(3) A controller's role during an emergency, even if the controller is not the first to\ndetect the emergency, including the controller's responsibility to take specific\nactions and to communicate with others;\nKPL’s procedure inadequately defines: the process to shut down the pipeline by a\nqualified controller, in the event the qualified controller is incapacitated; the actions\nthat Controllers must take in an immediate emergency; the authority of the Controller\nto control the pipeline during communication outages of 15 minutes or greater. This\nprocedure also inadequately addresses multiple communication outages.\nKPL has revised its procedures. PHMSA has reviewed KPL’s amended procedures\nand considers this item closed.\n3) §195.446(c) Provide adequate information\nEach operator must provide its controllers with the information, tools, processes and\nprocedures necessary for the controllers to carry out the roles and responsibilities the\noperator has defined by performing each of the following:\n(1) Implement API RP 1165 (incorporating 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\nused;\n2\n\n\n\nKPL’s procedure does not define whether the existing SCADA system adheres to API\nRP 1165 requirements.\nKPL has revised its procedures. PHMSA has reviewed KPL’s amended procedures\nand considers this item closed.\n4) §195.446(c) Provide adequate information\nEach operator must provide its controllers with the information, tools, processes and\nprocedures necessary for the controllers to carry out the roles and responsibilities the\noperator has defined by performing each of the following:\n(2) Conduct a point-to-point verification between SCADA displays and related field\nequipment when field equipment is added or moved and when other changes that\naffect pipeline safety are made to field equipment or SCADA displays.\nKPL’s procedure inadequately describes the process of point-to-point verification from\nthe SCADA display to field equipment and back to the SCADA display.\nKPL has revised its procedures. PHMSA has reviewed KPL’s amended procedures\nand considers this item closed.\n5) §195.446(c) Provide adequate information\nEach operator must provide its controllers with the information, tools, processes and\nprocedures necessary for the controllers to carry out the roles and responsibilities the\noperator has defined by performing each of the following:\n(3) Test and verify an internal communication plan to provide adequate means for\nmanual operations of the pipeline safely, at least once each calendar year, but at\nintervals not to exceed 15 months;\nKPL’s procedure inadequately addresses the testing and verification of manual\noperations of critical operating pipelines\nKPL has revised its procedures. PHMSA has reviewed KPL’s amended procedures\nand considers this item closed.\n6) §195.446(c) Provide adequate information\nEach operator must provide its controllers with the information, tools, processes and\nprocedures necessary for the controllers to carry out the roles and responsibilities the\noperator has defined by performing each of the following:\n3\n\n\n\n(4) Test any backup SCADA systems at least once each calendar year, but at\nintervals not to exceed 15 months; and\nKPL’s procedures inadequately address testing and documentation of the backup\nSCADA system in the basement of the Wichita, Kansas control room.\nKPL has revised its procedures. PHMSA has reviewed KPL’s amended procedures\nand considers this item closed.\n7) §195.446(e) Alarm management\nEach operator using a SCADA system must have a written alarm management plan\nto provide for effective controller response to alarms. An operator's plan must\ninclude provisions to:\n(1) Review SCADA safety-related alarm operations using a process that ensures\nalarms are accurate and support safe pipeline operations;\nKPL’s procedure inadequately addresses determining if safety-related alarm data is\nstale or has not changed.\nKPL has revised its procedures. PHMSA has reviewed KPL’s amended procedures\nand considers this item closed.\n8) §195.446(g) Operating Experience\nEach operator must assure that lessons learned from its operating experience are\nincorporated, as appropriate, into its control room management procedures by\nperforming each of the following:\n(1) Review accidents that must be reported pursuant to §195.50 and 195.52 to\ndetermine if control room actions contributed to the event and, if so, correct,\nwhere necessary, deficiencies related to:\nKPL’s procedure inadequately addresses documentation of the review to determine if a\nController is or is not responsible for a reportable event. The process to determine\nwhether a Controller contributed to a release or the Control Room was involved with a\nreportable event was not defined.\nKPL has revised its procedures. PHMSA has reviewed KPL’s amended procedures\nand considers this item closed.\n9) §195.444 CPM Leak Detection\nEach computational pipeline monitoring (CPM) leak detection system installed on a\n4\n\n\n\nhazardous liquid pipeline transporting liquid in single phase (without gas in the\nliquid) must comply with API 1130 in operating, maintaining, testing, record\nkeeping, and dispatcher training of the system.\nKPL’s procedure inadequately addresses the documentation requirement of the initial\nand annual API 1130 leak detection testing. KPL lacks an adequate procedure that\naddresses configuration changes for leak detection and the review needed to assure\nleak detection remains accurate.\nKPL has revised its procedures. PHMSA has reviewed KPL’s amended procedures\nand considers this item closed.\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 thirty (30) days of receipt of this Notice, this constitutes a waiver of your right to\ncontest the allegations in this Notice and authorizes the Associate Administrator for Pipeline\nSafety to find facts as alleged in this Notice without further notice to you and to issue a Final\nOrder.\nIn correspondence concerning this matter, please refer to CPF 3-2017-5007M and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSubsequent to PHMSA’s inspection, KPL provided revised procedures. Central Region\npersonnel have reviewed the revised procedures and determined that the revisions satisfy the\ndeficiencies identified in all of the above items. Therefore, no further action is required and\nthis enforcement action is considered closed.\nSincerely,\nAllan C. Beshore\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n5","truncated":false,"body_characters":10365}