{"operation":"document","citation":"CPF 320185011M","title":"OASIS PETROLEUM NORTH AMERICA — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-12-07","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(a), 195.402(c)(1), 195.402(c)(2), 195.402(c)(3), 195.402(d)(3), 195.402(e)(1), 195.403(a)(5), 195.410(a)(2), 195.428(a), 195.442(a), 195.446(a), 195.446(b)(1), 195.446(b)(3), 195.446(b)(4), 195.446(c)(2), 195.446(c)(3), 195.446(c)(4), 195.446(d), 195.446(d)(4), 195.446(e)(1), 195.446(e)(4), 195.446(e)(5), 195.446(f)(2), 195.452(b)(1), 195.452(b)(2), 195.452(f), 195.452(f)(1), 195.452(f)(4), 195.452(g), 195.452(h)(1), 195.452(h)(4)(i), 195.452(i)(1), 195.452(i)(2), 195.452(i)(3), 195.452(i)(4), 195.452(j)(4), 195.452(j)(5)(i), 195.452(j)(5)(iv), 195.452(m), 195.505(c), 195.54(b), 195.555, 195.569, 195.571, 195.573(a)(2), 195.573(e), 195.575, 195.579(c), 195.581(b), 195.64(a), 195.64(c)(1), 195.64(c)(2), 195.64(d).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320185011m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320185011m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320185011m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320185011M","body":"Notice of Amendment involving OASIS PETROLEUM NORTH AMERICA. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.402(c)(1),  195.402(c)(2),  195.402(c)(3),  195.402(d)(3),  195.402(e)(1),  195.403(a)(5),  195.410(a)(2),  195.428(a),  195.442(a),  195.446(a),  195.446(b)(1),  195.446(b)(3),  195.446(b)(4),  195.446(c)(2),  195.446(c)(3),  195.446(c)(4),  195.446(d),  195.446(d)(4),  195.446(e)(1),  195.446(e)(4),  195.446(e)(5),  195.446(f)(2),  195.452(b)(1),  195.452(b)(2),  195.452(f),  195.452(f)(1),  195.452(f)(4),  195.452(g),  195.452(h)(1),  195.452(h)(4)(i),  195.452(i)(1),  195.452(i)(2),  195.452(i)(3),  195.452(i)(4),  195.452(j)(4),  195.452(j)(5)(i),  195.452(j)(5)(iv),  195.452(m),  195.505(c),  195.54(b),  195.555,  195.569,  195.571,  195.573(a)(2),  195.573(e),  195.575,  195.579(c),  195.581(b),  195.64(a),  195.64(c)(1),  195.64(c)(2),  195.64(d). The case was opened on 2018-12-07 and is reported as closed as of 2019-03-26. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320185011M_Closure Letter_03262019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320185011M/320185011M_Closure%20Letter_03262019.pdf\n\n320185011M_Closure Letter_03262019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320185011M/320185011M_Closure%20Letter_03262019_text.pdf\n\n320185011M_Notice of Amendment_12072018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320185011M/320185011M_Notice%20of%20Amendment_12072018.pdf\n\n320185011M_Notice of Amendment_12072018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320185011M/320185011M_Notice%20of%20Amendment_12072018_text.pdf\n\n320185011M_Notice of Amendment_12072018_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 7, 2018\nMr. Jason Swaren\nVice President, Operations\nOasis Midstream Partners\n1001 Fannin St. Suite 1500\nHouston, TX 77002\nCPF 3-2018-5011M\nDear Mr. Swaren:\nFrom January 8 - 12, January 29 – February 2, February 12 – 16 and April 16 – 20, 2018,\nrepresentatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA),\npursuant to Chapter 601 of 49 United States Code, inspected Oasis Petroleum North\nAmerica’s (Oasis) procedures for Operation & Maintenance, Public Awareness, Operator\nQualification, Integrity Management, Control Room Management, Construction and\nEmergency Response in Houston, TX.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nOasis’ plans or procedures, as described below:\n1. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies. This manual shall\nbe reviewed at intervals not exceeding 15 months, but at least once each calendar\nyear, and appropriate changes made as necessary to insure that the manual is\neffective. This manual shall be prepared before initial operations of a pipeline\n\n\n\nsystem commence, and appropriate parts shall be kept at locations where\noperations and maintenance activities are conducted.\n(b) . . . .\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(1) . . . .\n(2) Gathering of data needed for reporting accidents under subpart B of this part in\na timely and effective manner.\n§195.54 Accident reports.\n(b) Whenever an operator receives any changes in the information reported or\nadditions to the original report on DOT Form 7000-1, it shall file a supplemental\nreport within 30 days.\nOasis’ Operation and Maintenance manual (O&M) was inadequate because it did not have\na procedure to file a supplemental report within 30 days after receiving any changes in\ninformation reported or additions to the original report on DOT Form 7000-1.\nSpecifically, procedure P-195.50 did not cover supplemental reporting requirements.\nOasis submitted updated procedure P-195.50 on 5/18/2018 that satisfactorily addressed\nthis item. No further action is required.\n2. §195.402(a) – See Above\n§195.64 National Registry of Pipeline and LNG Operators.\n(a) OPID Request. Effective January 1, 2012, each operator of a hazardous liquid or\ncarbon dioxide pipeline or pipeline facility must obtain from PHMSA an Operator\nIdentification Number (OPID). An OPID is assigned to an operator for the pipeline\nor pipeline system for which the operator has primary responsibility. To obtain an\nOPID or a change to an OPID, an operator must complete an OPID Assignment\nRequest DOT Form PHMSA F 1000.1 through the National Registry of Pipeline and\nLNG Operators in accordance with §195.58.\nOasis’ O&M manual was inadequate because it did not have a procedure to require the\nobtaining, and appropriate control of Operator Identification Numbers (OPIDs). Oasis\ndeveloped and submitted procedure P-195.64 on 3/29/2018 that satisfactorily addressed\nthis item. No further action is required.\n3. §195.402(a) – See Above\n§195.64 National Registry of Pipeline and LNG Operators.\n2\n\n\n\n(c) Changes. Each operator must notify PHMSA electronically through the National\nRegistry of Pipeline and LNG Operators at http://opsweb.phmsa.dot.gov, of certain\nevents.\n(1) An operator must notify PHMSA of any of the following events not later than 60\ndays before the event occurs:\n(i) Construction or any planned rehabilitation, replacement, modification,\nupgrade, uprate, or update of a facility, other than a section of line pipe, that\ncosts $10 million or more. If 60 day notice is not feasible because of an emergency,\nan operator must notify PHMSA as soon as practicable;\n(ii) Construction of 10 or more miles of a new or replacement hazardous liquid\nor carbon dioxide pipeline;\n(iii) Reversal of product flow direction when the reversal is expected to last more\nthan 30 days. This notification is not required for pipeline systems already\ndesigned for bi-directional flow; or\n(iv) A pipeline converted for service under § 195.5, or a change in commodity as\nreported on the annual report as required by § 195.49.\nOasis’ O&M manual was inadequate because it did not have a procedure to require\nnotification for facility construction of $10 million or more, 10 or more miles of pipeline,\nreversal of product flow or pipeline converted for service. Oasis developed and submitted\nprocedure P-195.64 on 3/29/2018 that satisfactorily addressed this item. No further action\nis required.\n4. §195.402(a) – See Above\n§195.64(c) – See Above\n(2) An operator must notify PHMSA of any following event not later than 60 days\nafter the event occurs:\n(i) A change in the primary entity responsible (i.e., with an assigned OPID) for\nmanaging or administering a safety program required by this part covering\npipeline facilities operated under multiple OPIDs.\n(ii) A change in the name of the operator;\n(iii) A change in the entity (e.g., company, municipality) responsible for operating\nan existing pipeline, pipeline segment, or pipeline facility;\n(iv) The acquisition or divestiture of 50 or more miles of pipeline or pipeline\n3\n\n\n\nsystem subject to this part; or\n(v) The acquisition or divestiture of an existing pipeline facility subject to this\npart.\nOasis’s O&M manual was inadequate because it did not have a procedure to require\nnotification for a change in primary entity responsible for administering a safety program,\nchange in name of operator, change in entity responsible for operations, the\nacquisition/divestiture of 50 or more miles of pipeline or the acquisition/divestiture of an\nexisting facility. Oasis developed and submitted procedure P-195.64 on 3/29/2018 that\nsatisfactorily addressed this item. No further action is required.\n5. §195.402(a) – See Above\n§195.64 National Registry of Pipeline and LNG Operators.\n(d) Reporting. An operator must use the OPID issued by PHMSA for all reporting\nrequirements covered under this subchapter and for submissions to the National\nPipeline Mapping System.\nOasis’ O&M manual was inadequate because it did not have a procedure to ensure that the\nOPID issued by PHMSA must be used on all reporting requirements and submissions to\nNPMS. Oasis developed and submitted procedure P-195.64 on 3/29/2018 that\nsatisfactorily addressed this item. No further action is required.\n6. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(1) Making construction records, maps, and operating history available as\nnecessary for safe operation and maintenance.\n(2) Gathering of data needed for reporting accidents under subpart B of this part\nin a timely and effective manner.\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\n§195.410 Line markers.\n(a) Except as provided in paragraph (b) of this section, each operator shall place and\nmaintain line markers over each buried pipeline in accordance with the following:\n4\n\n\n\n(2) The marker must state at least the following on a background of sharply\ncontrasting color:\n(i) The word \"Warning,\" \"Caution,\" or \"Danger\" followed by the words\n\"Petroleum (or the name of the hazardous liquid transported) Pipeline\", or\n\"Carbon Dioxide Pipeline,\" all of which, except for markers in heavily developed\nurban areas, must be in letters at least 1 inch (25 millimeters) high with an\napproximate stroke of 1/4 inch (6.4 millimeters).\n(ii) The name of the operator and a telephone number (including area code)\nwhere the operator can be reached at all times.\nOasis’ O&M manual was inadequate because it did not have a defined procedure to\naddress the content and format required on the line markers. Oasis submitted updated\nprocedure P-195.410 on 4/13/2018 which satisfactorily addressed this item. No further\naction is required.\n7. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . . .\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(1) Making construction records, maps, and operating history available as necessary\nfor safe operation and maintenance.\nOasis’ O&M manual was inadequate because it did not have a defined procedure to\naddress making construction records, maps, and operating history available as necessary\nfor safe operation and maintenance. Specifically, Procedure P-195.402(c)(1) did not state\nhow the maps and construction records are obtained by personnel. Oasis submitted\nupdated procedure P-195.402(c)(1) on 3/29/2018 which satisfactorily addressed this item.\nNo further action is required.\n8. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . . .\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\n5\n\n\n\neach of the requirements of this subpart and subpart H of this part.\n§195.428 Overpressure safety devices and overfill protection systems.\n(a) Except as provided in paragraph (b) of this section, each operator shall, at\nintervals not exceeding 15 months, but at least once each calendar year, or in the case\nof pipelines used to carry highly volatile liquids, at intervals not to exceed 7½ months,\nbut at least twice each calendar year, inspect and test each pressure limiting device,\nrelief valve, pressure regulator, or other item of pressure control equipment to\ndetermine that it is functioning properly, is in good mechanical condition, and is\nadequate from the standpoint of capacity and reliability of operation for the service\nin which it is used.\nOasis’ O&M manual was inadequate because it did not have a defined procedure to\nadequately detail the inspecting and testing of each pressure limiting device, relief valve,\npressure regulator, or other items of pressure control equipment. Specifically, procedure\nP-195.428(a) did not address inspection of thermal relief valves. Oasis submitted updated\nprocedures on 4/13/2018 that satisfactorily addressed this item. No further action is\nrequired.\n9. §195.402(c)(3) – See Above\n§195.555 What are the qualifications for supervisors?\nYou must require and verify that supervisors maintain a thorough knowledge of that\nportion of the corrosion control procedures established under §195.402(c)(3) for\nwhich they are responsible for insuring compliance.\nOasis’ O&M manual was inadequate because it did not have a defined procedure to\nrequire supervisors to maintain a thorough knowledge of corrosion control procedures they\nare responsible for, and verify that knowledge. Oasis submitted updated procedures on\n5/18/2018 that satisfactorily addressed this item. No further action is required.\n10. §195.402(c)(3) – See Above\n§195.569 Do I have to examine exposed portions of buried pipelines?\nWhenever you have knowledge that any portion of a buried pipeline is exposed, you\nmust examine the exposed portion for evidence of external corrosion if the pipe is\nbare, or if the coating is deteriorated. If you find external corrosion requiring\ncorrective action under §195.585, you must investigate circumferentially and\nlongitudinally beyond the exposed portion (by visual examination, indirect method,\nor both) to determine whether additional corrosion requiring remedial action exists\nin the vicinity of the exposed portion.\n6\n\n\n\nOasis’ O&M manual was inadequate because it did not have a defined procedure to\nrequire that exposed portions of buried pipeline be examined for external corrosion and\ncoating deterioration, and if external corrosion is found, further examination required to\ndetermine the extent of the corrosion. Specifically, procedure P-195.569 did not have\nsufficient details for the examination of exposed pipeline and did not address steps to take\nif corrosion is found. Oasis submitted updated procedures on 3/19/2018 that satisfactorily\naddressed this item. No further action is required.\n11. §195.402(c)(3) – See Above\n§195.571 What criteria must I use to determine the adequacy of cathodic\nprotection?\nCathodic protection required by this subpart must comply with one or more of the\napplicable criteria and other considerations for cathodic protection contained\nparagraphs 6.2.2, 6.2.3, 6.2.4, 6.2.5 and 6.3 in NACE SP 0169 (incorporated by\nreference, see §195.3).\nOasis’ O&M manual was inadequate because it did not have defined procedures requiring\nthat CP monitoring criteria be used that is acceptable per NACE SP 0169. Oasis\ndeveloped procedure P-195.571 which addresses IR drop and updated procedure\n195.573(a) with acceptable CP monitoring criteria which satisfactorily addressed this item.\nNo further action is required.\n12. §195.402(c)(3) – See Above\n§195.573 What must I do to monitor external corrosion control?\n(a) Protected pipelines. You must do the following to determine whether cathodic\nprotection required by this subpart complies with §195.571:\n(2) Identify not more than 2 years after cathodic protection is installed, the\ncircumstances in which a close-interval survey or comparable technology is\npracticable and necessary to accomplish the objectives of paragraph 10.1.1.3 of\nNACE SP 0169 (incorporated by reference, see §195.3).\nOasis’ O&M manual was inadequate because it did not have a defined procedure to\ndescribe the circumstances in which a CIS or comparable technology is practicable and\nnecessary no more than 2 years after a cathodic protection system has been installed.\nOasis submitted updated procedure P-195.573(a)(2) on 9/13/2018 that satisfactorily\naddressed this item. No further action is required.\n7\n\n\n\n13. §195.402(c)(3) – See Above\n§195.573 What must I do to monitor external corrosion control?\n(e) Corrective action. You must correct any identified deficiency in corrosion control\nas required by §195.401(b). However, if the deficiency involves a pipeline in an\nintegrity management program under §195.452, you must correct the deficiency as\nrequired by §195.452(h).\nOasis’s O&M manual was inadequate because it did not have a defined procedure to\nrequire correction of any identified deficiencies in corrosion control. Oasis submitted\nupdated procedure P195.573(a) on 3/29/2018 which satisfactorily addressed this item. No\nfurther action is required.\n14. §195.402(c)(3) – See Above\n§195.575 Which facilities must I electrically isolate and what inspections, tests, and\nsafeguards are required?\n(a) You must electrically isolate each buried or submerged pipeline from other\nmetallic structures, unless you electrically interconnect and cathodically protect the\npipeline and the other structures as a single unit.\n(b) You must install one or more insulating devices where electrical isolation of a\nportion of a pipeline is necessary to facilitate the application of corrosion control.\n(c) You must inspect and electrically test each electrical isolation to assure the\nisolation is adequate.\n(d) If you install an insulating device in an area where a combustible atmosphere is\nreasonable to foresee, you must take precautions to prevent arcing.\n(e) If a pipeline is in close proximity to electrical transmission tower footings, ground\ncables, or counterpoise, or in other areas where it is reasonable to foresee fault\ncurrents or an unusual risk of lightning, you must protect the pipeline against\ndamage from fault currents or lightning and take protective measures at insulating\ndevices.\nOasis’ O&M manual was inadequate because it did not have a defined procedure to give\nguidance for electrically isolating each buried or submerged pipeline from other metallic\nstructures or what inspections, tests, and safeguards are required. Oasis developed and\nsubmitted procedure P195.575 on 4/6/2018 which satisfactorily addressed this item. No\nfurther action is required.\n8\n\n\n\n15. §195.402(c)(3) – See Above\n§195.579 What must I do to mitigate internal corrosion?\n(c) Removing pipe. Whenever you remove pipe from a pipeline, you must inspect the\ninternal surface of the pipe for evidence of corrosion. If you find internal corrosion\nrequiring corrective action under §195.585, you must investigate circumferentially\nand longitudinally beyond the removed pipe (by visual examination, indirect method,\nor both) to determine whether additional corrosion requiring remedial action exists\nin the vicinity of the removed pipe.\nOasis’ O&M manual was inadequate because it did not have a defined procedure to\nrequire personnel to examine removed pipe for evidence of internal corrosion. Oasis\nsubmitted updated procedure P195.579(c) on 3/29/2018 which satisfactorily addressed this\nitem. No further action is required.\n16. §195.402(c)(3) – See Above\n§195.581 Which pipelines must I protect against atmospheric corrosion and what\ncoating material may I use?\n(b) Coating material must be suitable for the prevention of atmospheric corrosion.\nOasis’ O&M manual was inadequate because it did not have a defined procedure for the\nprotection of pipelines against atmospheric corrosion. Specifically, procedure P-195.581\ndid not address requirements for coating material to be suitable for the prevention of\natmospheric corrosion. Oasis submitted updated procedure P195.581 on 3/29/2018 which\nsatisfactorily addressed this item. No further action is required.\n17. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(d) Abnormal operation. The manual required by paragraph (a) of this section must\ninclude procedures for the following to provide safety when operating design limits\nhave been exceeded:\n(3) Correcting variations from normal operation of pressure and flow equipment and\ncontrols.\nOasis’ O&M manual was inadequate because it did not have a defined procedure for\ncorrecting variations from normal operation of pressure and flow equipment and controls.\nSpecifically, procedure 195.402(d) did not address the steps that should be taken or who\nwould perform the investigation. Oasis submitted updated procedures on 4/6/2018 that\nsatisfactorily addressed this item. No further action is required.\n9\n\n\n\n18. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(e) Emergencies. The manual required by paragraph (a) of this section must include\nprocedures for the following to provide safety when an emergency condition occurs:\n(1) Receiving, identifying, and classifying notices of events which need immediate\nresponse by the operator or notice to fire, police, or other appropriate public officials\nand communicating this information to appropriate operator personnel for\ncorrective action.\nOasis’ O&M manual was inadequate because it did not have a defined procedure for\nreceiving, identifying, and classifying notices of events which need immediate response by\nthe operator or notice to fire, police, or other appropriate public officials and\ncommunicating this information to appropriate operator personnel for corrective action\nduring an emergency condition. Specifically, the procedures did not include external\nnotifications and classification of external and internal notifications of incidents. Oasis\nsubmitted updated procedures on 5/7/2018 that satisfactorily addressed this item. No\nfurther action is required.\n19. §195.403 Emergency Response Training.\n(a) Each operator shall establish and conduct a continuing training program to\ninstruct emergency response personnel to:\n(5) Learn the potential causes, types, sizes, and consequences of fire and the\nappropriate use of portable fire extinguishers and other on-site fire control\nequipment, involving, where feasible, a simulated pipeline emergency condition.\nOasis’ O&M manual was inadequate because it did not have a defined procedure to\nconduct a continuing training program to instruct emergency response personnel.\nSpecifically, the training did not include provisions to learn the potential causes, types,\nsizes, and consequences of fire and the appropriate use of portable fire extinguishers and\nother on-site fire control equipment, involving, where feasible, a simulated pipeline\nemergency condition and how to receive, identify and classify notices of events which\nneed immediate response. Oasis submitted updated procedures on 5/7/2018 that\nsatisfactorily addressed this item. No further action is required.\n20. §195.442 Damage prevention program.\n(a) Except as provided in paragraph (d) of this section, each operator of a buried\npipeline must carry out, in accordance with this section, a written program to\nprevent damage to that pipeline from excavation activities. For the purpose of this\nsection, the term “excavation activities” includes excavation, blasting, boring,\n10\n\n\n\ntunneling, backfilling, the removal of aboveground structures by either explosive or\nmechanical means, and other earthmoving operations.\nOasis’ Damage Prevention Program was inadequate because it did not have a defined\nprocedure to prevent damage to the pipeline from excavation activities. Specifically,\nOasis failed to provide a process to specify how reports of third party damage are checked\nagainst One-Call tickets. Oasis submitted updated procedures on 9/13/2018 that\nsatisfactorily addressed this item. No further action is required.\n21. §195.446 Control room management.\n(a) General. This section applies to each operator of a pipeline facility with a\ncontroller working in a control room who monitors and controls all or part of a\npipeline facility through a SCADA system. Each operator must have and follow\nwritten control room management procedures that implement the requirements of\nthis section. The procedures required by this section must be integrated, as\nappropriate, with the operator's written procedures required by §195.402. An\noperator must develop the procedures no later than August 1, 2011, and must\nimplement the procedures according to the following schedule. The procedures\nrequired by paragraphs (b), (c)(5), (d)(2) and (d)(3), (f) and (g) of this section must be\nimplemented no later than October 1, 2011. The procedures required by paragraphs\n(c)(1) through (4), (d)(1), (d)(4), and (e) must be implemented no later than August 1,\n2012. The training procedures required by paragraph (h) must be implemented no\nlater than August 1, 2012, except that any training required by another paragraph of\nthis section must be implemented no later than the deadline for that paragraph.\n(b) Roles and responsibilities. Each operator must define the roles and\nresponsibilities of a controller during normal, abnormal, and emergency operating\nconditions. To provide for a controller's prompt and appropriate response to\noperating conditions, an operator must define each of the following:\n(1) A controller's authority and responsibility to make decisions and take actions\nduring normal operations;\nOasis’ Control Room Management (CRM) manual was inadequate because it did not have\na defined procedure to establish clear processes to describe each controller's physical\ndomain of responsibility for pipelines and other facility assets. Additionally, Oasis failed\nto require controllers to stay at the console to verify all SCADA commands that have been\ninitiated are fulfilled along with commands given via verbal communications. Oasis\nsubmitted updated procedures on 5/7/2018 that satisfactorily addressed this item. No\nfurther action is required.\n11\n\n\n\n22. §195.446(a) – Control room management. (see above)\n(b) Roles and responsibilities. Each operator must define the roles and\nresponsibilities of a controller during normal, abnormal, and emergency operating\nconditions. To provide for a controller's prompt and appropriate response to\noperating conditions, an operator must define each 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 actions\nand to communicate with others;\nOasis’ CRM manual was inadequate because it did not have a defined procedure to\ndescribe a controller's role during an emergency. Specifically, Oasis failed to develop a\nprocess to address the controller's responsibilities in the event the control room must be\nevacuated. Oasis submitted updated procedures on 5/14/2018 that satisfactorily addressed\nthis item. No further action is required.\n23. §195.446(a) – Control room management. (see above)\n(b) Roles and responsibilities. Each operator must define the roles and\nresponsibilities of a controller during normal, abnormal, and emergency operating\nconditions. To provide for a controller's prompt and appropriate response to\noperating conditions, an operator must define each of the following:\n(4) A method of recording controller shift-changes and any hand-over of\nresponsibility between controllers; and\nOasis’s CRM manual was inadequate because it did not have an adequate procedure to\nestablish clear processes for the hand-over of responsibility between controller’s.\nSpecifically, Oasis failed to require that the outgoing controller is responsible to answer\nthe phone during the shift change. Oasis submitted updated procedures on 5/7/2018 that\nsatisfactorily addressed this item. No further action is required.\n24. §195.446(a) – Control room management. (see above)\n(c) Provide adequate information. Each operator must provide its controllers with\nthe 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 field\nequipment when field equipment is added or moved and when other changes that\n12\n\n\n\naffect pipeline safety are made to field equipment or SCADA displays;\nOasis’ CRM manual was inadequate because it did not have a defined procedure to\nprovide adequate tools, processes and procedures necessary for the controllers to carry out\ntheir roles and responsibilities. Specifically, Oasis failed to do the following: 1) Oasis did\nnot have a process in place to adequately define and list safety-related points. 2) Oasis\nfailed to develop adequate processes to describe in detail the point to point process. 3)\nOasis failed to develop adequate processes for the thoroughness of the point-to-point\nverification. Oasis submitted updated procedures on 5/7/2018, 6/4/2018 and 9/13/2018\nthat satisfactorily addressed this item. No further action is required\n25. §195.446(a) – Control room management. (see above)\n(c) Provide adequate information. Each operator must provide its controllers with\nthe 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(3) Test and verify an internal communication plan to provide adequate means for\nmanual operation of the pipeline safely, at least once each calendar year, but at\nintervals not to exceed 15 months;\nOasis’ CRM manual was inadequate because it did not have an internal communication\nplan to provide adequate means for manual operation of the pipeline safely. Oasis\nsubmitted updated procedures on 5/14/2018 that satisfactorily addressed this item. No\nfurther action is required.\n26. §195.446(a) – Control room management. (see above)\n(c) Provide adequate information. Each operator must provide its controllers with\nthe 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(4) Test any backup SCADA systems at least once each calendar year, but at\nintervals not to exceed 15 months; and\nOasis’ CRM manual was inadequate because it did not have a defined procedure to\nprovide adequate tools, processes and procedures necessary for the controllers to carry out\ntheir roles and responsibilities. Specifically, Oasis failed to do the following: 1) Oasis\nfailed to provide a process for development work that takes place on the backup SCADA\nsystem. 2) Oasis failed to develop a process to adequately address and test the logistics of\ntransferring control to a backup control room. The original plan did not include a backup\ncontrol room but relied on mobile totes which were not covered in the procedures. Oasis\n13\n\n\n\nhas since updated the procedures to include a backup control room. 3) Oasis failed to\ndevelop a process to adequately address and test the logistics of returning operations back\nto the primary control room. Oasis submitted updated procedures on 5/14/2018 that\nsatisfactorily addressed this item. No further action is required.\n27. §195.446(a) – Control room management. (see above)\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:\nOasis’ CRM manual was inadequate because it did not have defined fatigue mitigation\nprocedures to address the operator-specific fatigue risks. Specifically, Oasis has a 7 on, 7\noff schedule which was not included as a fatigue risk. Additionally, Oasis failed to\nadequately address how the program reduces the risk associated with controller fatigue.\nOasis submitted updated procedures on 5/7/2018 that satisfactorily addressed this item.\nNo further action is required.\n28. §195.446(a) – Control room management. (see above)\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 for\nan emergency deviation from the maximum limit if necessary for the safe operation\nof a pipeline facility.\nOasis’ CRM manual was inadequate because it did not have defined procedures to reduce\nthe risk associated with controller fatigue that could inhibit a controller’s ability to carry\nout their roles and responsibilities. Specifically, Oasis failed to do the following: 1) Oasis\nfailed to provide an adequate means to document all scheduled and unscheduled HOS\nworked, including overtime and time spent performing duties other than control room\nduties. 2) Oasis failed to develop specific fatigue countermeasures for shifts longer than 8\nhours. 3) Oasis failed to develop an adequate process for approving deviations from the\nmaximum HOS limits. Oasis submitted updated procedures on 5/7/2018, 9/13/2018 and\n10/1/2018 that satisfactorily addressed this item. No further action is required.\n29. §195.446(a) – Control room management. (see above)\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:\n14\n\n\n\n(1) Review SCADA safety-related alarm operations using a process that ensures\nalarms are accurate and support safe pipeline operations;\nOasis’ CRM manual was inadequate because it did not have a defined procedure for\nreview of safety-related alarms that accounts for individual-specific controller\nqualification and performance. Additionally, Oasis failed to provide a list of safety related\nalarm set points. Oasis submitted updated procedures on 10/1/2018 that satisfactorily\naddressed this item. No further action is required.\n30. §195.446(a) – Control room management. (see above)\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(4) Review the alarm management plan required by this paragraph at least once each\ncalendar year, but at intervals not exceeding 15 months, to determine the\neffectiveness of the plan;\nOasis’ CRM manual was inadequate because it did not have a defined procedure to\ndetermine the effectiveness of the alarm management plan. Specifically, Oasis failed to do\nthe following: 1) Oasis failed to add to the procedures details on the method of review. 2)\nOasis failed to develop adequate criteria for review including chronic and recurring issues.\n3) Oasis failed to include a means of record keeping. Oasis submitted updated procedures\non 10/1/2018 that satisfactorily addressed this item. No further action is required.\n31. §195.446(a) – Control room management. (see above)\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(5) Monitor the content and volume of general activity being directed to and required\nof each controller at least once each calendar year, but at intervals not exceeding 15\nmonths, that will assure controllers have sufficient time to analyze and react to\nincoming alarms; and\nOasis’ CRM manual was inadequate because it did not have a defined procedure for\nidentifying and measuring the content and volume of general activity being directed to an\nindividual controller. Section 8.8 of the CRM states, \"This analysis should be performed\nonce a year, not to exceed 15 months...\" rather than it must be done. Additionally, Oasis\nuses the POEMS workload analysis software which is not mentioned in the procedures.\nOasis submitted updated procedures on 10/1/2018 that satisfactorily addressed this item.\n15\n\n\n\nNo further action is required.\n32. §195.446(a) – Control room management. (see above)\n(f) Change management. Each operator must assure that changes that could affect\ncontrol room operations are coordinated with the control room personnel by\nperforming each of the following:\n(2) Require its field personnel to contact the control room when emergency\nconditions exist and when making field changes that affect control room operations.\nOasis’ CRM manual was inadequate because it did not have a procedure to require field\npersonnel and SCADA support personnel to contact the control room when emergency\nconditions exist. Additionally, the CRM manual procedures that require field personnel\nand SCADA support personnel to contact the control room when making field changes\n(for example, moving a valve) that affect control room operations states that personnel\n\"should\" contact the control room rather than they “must” contact the control room. Oasis\nsubmitted updated procedures on 10/1/2018 that satisfactorily addressed this item. No\nfurther action is required.\n33. §195.452 Pipeline integrity management in high consequence areas.\n(b) What program and practices must operators use to manage pipeline integrity?\nEach operator of a pipeline covered by this section must:\n(1) Develop a written integrity management program that addresses the risks on each\nsegment of pipeline in the first column of the following table not later than the date in\nthe second column:\nPipeline Date\nCategory 1 March 31, 2002.\nCategory 2 February 18, 2003.\nCategory 3 1 year after the date the pipeline begins operation.\n§195.452 Pipeline integrity management in high consequence areas.\n(b) What program and practices must operators use to manage pipeline integrity?\nEach operator of a pipeline covered by this section must:\n(2) Include in the program an identification of each pipeline or pipeline segment in\nthe first column of the following table not later than the date in the second column:\nPipeline Date\nCategory 1 December 31, 2001.\n16\n\n\n\nCategory 2 November 18, 2002.\nCategory 3 Date the pipeline begins operation.\nOasis’ Integrity Management Program (IMP) was inadequate because it did not have a\nprocedure to require completion of segment identification for Category 3 pipelines prior to\nbeginning of operation. Oasis developed and submitted an updated procedure on\n5/18/2018, IMP section 8.4 which discusses identifying could affect segments on Category\n3 pipelines prior to commissioning. No further action is required.\n34. §195.452(b)(1) – Pipeline integrity management in high consequence areas. (see\nabove)\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions drawn\nfrom results of the integrity assessments, and other maintenance and surveillance\ndata, and evaluation of consequences of a failure on the high consequence area.\nOasis’ IMP was inadequate because it did not have a written facility integrity management\nplan. Oasis developed and submitted procedures on 5/18/2018 which satisfactorily\naddressed this item. No further action is required.\n35. §195.452(b)(1) – Pipeline integrity management in high consequence areas. (see\nabove)\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions drawn\nfrom results of the integrity assessments, and other maintenance and surveillance\ndata, and evaluation of consequences of a failure on the high consequence area. An\noperator must include, at minimum, each of the following elements in its written\nintegrity management program:\n(1) A process for identifying which pipeline segments could affect a high consequence\narea;\nOasis’ IMP was inadequate because it did not have a procedure to include an analysis of\noverland spread and water transport of hazardous liquids to determine the extent of\ncommodity spread a","truncated":true,"body_characters":63202}