# OASIS PETROLEUM NORTH AMERICA — Notice of Amendment

- **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:** Not available
- **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).
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- **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.

Official case documents:

320185011M_Closure Letter_03262019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320185011M/320185011M_Closure%20Letter_03262019.pdf

320185011M_Closure Letter_03262019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320185011M/320185011M_Closure%20Letter_03262019_text.pdf

320185011M_Notice of Amendment_12072018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320185011M/320185011M_Notice%20of%20Amendment_12072018.pdf

320185011M_Notice of Amendment_12072018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320185011M/320185011M_Notice%20of%20Amendment_12072018_text.pdf

320185011M_Notice of Amendment_12072018_text.pdf

NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
December 7, 2018
Mr. Jason Swaren
Vice President, Operations
Oasis Midstream Partners
1001 Fannin St. Suite 1500
Houston, TX 77002
CPF 3-2018-5011M
Dear Mr. Swaren:
From January 8 - 12, January 29 – February 2, February 12 – 16 and April 16 – 20, 2018,
representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA),
pursuant to Chapter 601 of 49 United States Code, inspected Oasis Petroleum North
America’s (Oasis) procedures for Operation & Maintenance, Public Awareness, Operator
Qualification, Integrity Management, Control Room Management, Construction and
Emergency Response in Houston, TX.
On the basis of the inspection, PHMSA has identified the apparent inadequacies found within
Oasis’ plans or procedures, as described below:
1. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a
manual of written procedures for conducting normal operations and maintenance
activities and handling abnormal operations and emergencies. This manual shall
be reviewed at intervals not exceeding 15 months, but at least once each calendar
year, and appropriate changes made as necessary to insure that the manual is
effective. This manual shall be prepared before initial operations of a pipeline



system commence, and appropriate parts shall be kept at locations where
operations and maintenance activities are conducted.
(b) . . . .
(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:
(1) . . . .
(2) Gathering of data needed for reporting accidents under subpart B of this part in
a timely and effective manner.
§195.54 Accident reports.
(b) Whenever an operator receives any changes in the information reported or
additions to the original report on DOT Form 7000-1, it shall file a supplemental
report within 30 days.
Oasis’ Operation and Maintenance manual (O&M) was inadequate because it did not have
a procedure to file a supplemental report within 30 days after receiving any changes in
information reported or additions to the original report on DOT Form 7000-1.
Specifically, procedure P-195.50 did not cover supplemental reporting requirements.
Oasis submitted updated procedure P-195.50 on 5/18/2018 that satisfactorily addressed
this item. No further action is required.
2. §195.402(a) – See Above
§195.64 National Registry of Pipeline and LNG Operators.
(a) OPID Request. Effective January 1, 2012, each operator of a hazardous liquid or
carbon dioxide pipeline or pipeline facility must obtain from PHMSA an Operator
Identification Number (OPID). An OPID is assigned to an operator for the pipeline
or pipeline system for which the operator has primary responsibility. To obtain an
OPID or a change to an OPID, an operator must complete an OPID Assignment
Request DOT Form PHMSA F 1000.1 through the National Registry of Pipeline and
LNG Operators in accordance with §195.58.
Oasis’ O&M manual was inadequate because it did not have a procedure to require the
obtaining, and appropriate control of Operator Identification Numbers (OPIDs). Oasis
developed and submitted procedure P-195.64 on 3/29/2018 that satisfactorily addressed
this item. No further action is required.
3. §195.402(a) – See Above
§195.64 National Registry of Pipeline and LNG Operators.
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(c) Changes. Each operator must notify PHMSA electronically through the National
Registry of Pipeline and LNG Operators at http://opsweb.phmsa.dot.gov, of certain
events.
(1) An operator must notify PHMSA of any of the following events not later than 60
days before the event occurs:
(i) Construction or any planned rehabilitation, replacement, modification,
upgrade, uprate, or update of a facility, other than a section of line pipe, that
costs $10 million or more. If 60 day notice is not feasible because of an emergency,
an operator must notify PHMSA as soon as practicable;
(ii) Construction of 10 or more miles of a new or replacement hazardous liquid
or carbon dioxide pipeline;
(iii) Reversal of product flow direction when the reversal is expected to last more
than 30 days. This notification is not required for pipeline systems already
designed for bi-directional flow; or
(iv) A pipeline converted for service under § 195.5, or a change in commodity as
reported on the annual report as required by § 195.49.
Oasis’ O&M manual was inadequate because it did not have a procedure to require
notification for facility construction of $10 million or more, 10 or more miles of pipeline,
reversal of product flow or pipeline converted for service. Oasis developed and submitted
procedure P-195.64 on 3/29/2018 that satisfactorily addressed this item. No further action
is required.
4. §195.402(a) – See Above
§195.64(c) – See Above
(2) An operator must notify PHMSA of any following event not later than 60 days
after the event occurs:
(i) A change in the primary entity responsible (i.e., with an assigned OPID) for
managing or administering a safety program required by this part covering
pipeline facilities operated under multiple OPIDs.
(ii) A change in the name of the operator;
(iii) A change in the entity (e.g., company, municipality) responsible for operating
an existing pipeline, pipeline segment, or pipeline facility;
(iv) The acquisition or divestiture of 50 or more miles of pipeline or pipeline
3



system subject to this part; or
(v) The acquisition or divestiture of an existing pipeline facility subject to this
part.
Oasis’s O&M manual was inadequate because it did not have a procedure to require
notification for a change in primary entity responsible for administering a safety program,
change in name of operator, change in entity responsible for operations, the
acquisition/divestiture of 50 or more miles of pipeline or the acquisition/divestiture of an
existing facility. Oasis developed and submitted procedure P-195.64 on 3/29/2018 that
satisfactorily addressed this item. No further action is required.
5. §195.402(a) – See Above
§195.64 National Registry of Pipeline and LNG Operators.
(d) Reporting. An operator must use the OPID issued by PHMSA for all reporting
requirements covered under this subchapter and for submissions to the National
Pipeline Mapping System.
Oasis’ O&M manual was inadequate because it did not have a procedure to ensure that the
OPID issued by PHMSA must be used on all reporting requirements and submissions to
NPMS. Oasis developed and submitted procedure P-195.64 on 3/29/2018 that
satisfactorily addressed this item. No further action is required.
6. §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:
(1) Making construction records, maps, and operating history available as
necessary for safe operation and maintenance.
(2) Gathering of data needed for reporting accidents under subpart B of this part
in a timely and effective manner.
(3) Operating, maintaining, and repairing the pipeline system in accordance with
each of the requirements of this subpart and subpart H of this part.
§195.410 Line markers.
(a) Except as provided in paragraph (b) of this section, each operator shall place and
maintain line markers over each buried pipeline in accordance with the following:
4



(2) The marker must state at least the following on a background of sharply
contrasting color:
(i) The word "Warning," "Caution," or "Danger" followed by the words
"Petroleum (or the name of the hazardous liquid transported) Pipeline", or
"Carbon Dioxide Pipeline," all of which, except for markers in heavily developed
urban areas, must be in letters at least 1 inch (25 millimeters) high with an
approximate stroke of 1/4 inch (6.4 millimeters).
(ii) The name of the operator and a telephone number (including area code)
where the operator can be reached at all times.
Oasis’ O&M manual was inadequate because it did not have a defined procedure to
address the content and format required on the line markers. Oasis submitted updated
procedure P-195.410 on 4/13/2018 which satisfactorily addressed this item. No further
action is required.
7. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) . . . .
(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:
(1) Making construction records, maps, and operating history available as necessary
for safe operation and maintenance.
Oasis’ O&M manual was inadequate because it did not have a defined procedure to
address making construction records, maps, and operating history available as necessary
for safe operation and maintenance. Specifically, Procedure P-195.402(c)(1) did not state
how the maps and construction records are obtained by personnel. Oasis submitted
updated procedure P-195.402(c)(1) on 3/29/2018 which satisfactorily addressed this item.
No further action is required.
8. §195.402 Procedural manual for operations, maintenance, and emergencies.
(a) . . . .
(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:
(3) Operating, maintaining, and repairing the pipeline system in accordance with
5



each of the requirements of this subpart and subpart H of this part.
§195.428 Overpressure safety devices and overfill protection systems.
(a) Except as provided in paragraph (b) of this section, each operator shall, at
intervals not exceeding 15 months, but at least once each calendar year, or in the case
of pipelines used to carry highly volatile liquids, at intervals not to exceed 7½ months,
but at least twice each calendar year, inspect and test each pressure limiting device,
relief valve, pressure regulator, or other item of pressure control equipment to
determine that it is functioning properly, is in good mechanical condition, and is
adequate from the standpoint of capacity and reliability of operation for the service
in which it is used.
Oasis’ O&M manual was inadequate because it did not have a defined procedure to
adequately detail the inspecting and testing of each pressure limiting device, relief valve,
pressure regulator, or other items of pressure control equipment. Specifically, procedure
P-195.428(a) did not address inspection of thermal relief valves. Oasis submitted updated
procedures on 4/13/2018 that satisfactorily addressed this item. No further action is
required.
9. §195.402(c)(3) – See Above
§195.555 What are the qualifications for supervisors?
You must require and verify that supervisors maintain a thorough knowledge of that
portion of the corrosion control procedures established under §195.402(c)(3) for
which they are responsible for insuring compliance.
Oasis’ O&M manual was inadequate because it did not have a defined procedure to
require supervisors to maintain a thorough knowledge of corrosion control procedures they
are responsible for, and verify that knowledge. Oasis submitted updated procedures on
5/18/2018 that satisfactorily addressed this item. No further action is required.
10. §195.402(c)(3) – See Above
§195.569 Do I have to examine exposed portions of buried pipelines?
Whenever you have knowledge that any portion of a buried pipeline is exposed, you
must examine the exposed portion for evidence of external corrosion if the pipe is
bare, or if the coating is deteriorated. If you find external corrosion requiring
corrective action under §195.585, you must investigate circumferentially and
longitudinally beyond the exposed portion (by visual examination, indirect method,
or both) to determine whether additional corrosion requiring remedial action exists
in the vicinity of the exposed portion.
6



Oasis’ O&M manual was inadequate because it did not have a defined procedure to
require that exposed portions of buried pipeline be examined for external corrosion and
coating deterioration, and if external corrosion is found, further examination required to
determine the extent of the corrosion. Specifically, procedure P-195.569 did not have
sufficient details for the examination of exposed pipeline and did not address steps to take
if corrosion is found. Oasis submitted updated procedures on 3/19/2018 that satisfactorily
addressed this item. No further action is required.
11. §195.402(c)(3) – See Above
§195.571 What criteria must I use to determine the adequacy of cathodic
protection?
Cathodic protection required by this subpart must comply with one or more of the
applicable criteria and other considerations for cathodic protection contained
paragraphs 6.2.2, 6.2.3, 6.2.4, 6.2.5 and 6.3 in NACE SP 0169 (incorporated by
reference, see §195.3).
Oasis’ O&M manual was inadequate because it did not have defined procedures requiring
that CP monitoring criteria be used that is acceptable per NACE SP 0169. Oasis
developed procedure P-195.571 which addresses IR drop and updated procedure
195.573(a) with acceptable CP monitoring criteria which satisfactorily addressed this item.
No further action is required.
12. §195.402(c)(3) – See Above
§195.573 What must I do to monitor external corrosion control?
(a) Protected pipelines. You must do the following to determine whether cathodic
protection required by this subpart complies with §195.571:
(2) Identify not more than 2 years after cathodic protection is installed, the
circumstances in which a close-interval survey or comparable technology is
practicable and necessary to accomplish the objectives of paragraph 10.1.1.3 of
NACE SP 0169 (incorporated by reference, see §195.3).
Oasis’ O&M manual was inadequate because it did not have a defined procedure to
describe the circumstances in which a CIS or comparable technology is practicable and
necessary no more than 2 years after a cathodic protection system has been installed.
Oasis submitted updated procedure P-195.573(a)(2) on 9/13/2018 that satisfactorily
addressed this item. No further action is required.
7



13. §195.402(c)(3) – See Above
§195.573 What must I do to monitor external corrosion control?
(e) Corrective action. You must correct any identified deficiency in corrosion control
as required by §195.401(b). However, if the deficiency involves a pipeline in an
integrity management program under §195.452, you must correct the deficiency as
required by §195.452(h).
Oasis’s O&M manual was inadequate because it did not have a defined procedure to
require correction of any identified deficiencies in corrosion control. Oasis submitted
updated procedure P195.573(a) on 3/29/2018 which satisfactorily addressed this item. No
further action is required.
14. §195.402(c)(3) – See Above
§195.575 Which facilities must I electrically isolate and what inspections, tests, and
safeguards are required?
(a) You must electrically isolate each buried or submerged pipeline from other
metallic structures, unless you electrically interconnect and cathodically protect the
pipeline and the other structures as a single unit.
(b) You must install one or more insulating devices where electrical isolation of a
portion of a pipeline is necessary to facilitate the application of corrosion control.
(c) You must inspect and electrically test each electrical isolation to assure the
isolation is adequate.
(d) If you install an insulating device in an area where a combustible atmosphere is
reasonable to foresee, you must take precautions to prevent arcing.
(e) If a pipeline is in close proximity to electrical transmission tower footings, ground
cables, or counterpoise, or in other areas where it is reasonable to foresee fault
currents or an unusual risk of lightning, you must protect the pipeline against
damage from fault currents or lightning and take protective measures at insulating
devices.
Oasis’ O&M manual was inadequate because it did not have a defined procedure to give
guidance for electrically isolating each buried or submerged pipeline from other metallic
structures or what inspections, tests, and safeguards are required. Oasis developed and
submitted procedure P195.575 on 4/6/2018 which satisfactorily addressed this item. No
further action is required.
8



15. §195.402(c)(3) – See Above
§195.579 What must I do to mitigate internal corrosion?
(c) Removing pipe. Whenever you remove pipe from a pipeline, you must inspect the
internal surface of the pipe for evidence of corrosion. If you find internal corrosion
requiring corrective action under §195.585, you must investigate circumferentially
and longitudinally beyond the removed pipe (by visual examination, indirect method,
or both) to determine whether additional corrosion requiring remedial action exists
in the vicinity of the removed pipe.
Oasis’ O&M manual was inadequate because it did not have a defined procedure to
require personnel to examine removed pipe for evidence of internal corrosion. Oasis
submitted updated procedure P195.579(c) on 3/29/2018 which satisfactorily addressed this
item. No further action is required.
16. §195.402(c)(3) – See Above
§195.581 Which pipelines must I protect against atmospheric corrosion and what
coating material may I use?
(b) Coating material must be suitable for the prevention of atmospheric corrosion.
Oasis’ O&M manual was inadequate because it did not have a defined procedure for the
protection of pipelines against atmospheric corrosion. Specifically, procedure P-195.581
did not address requirements for coating material to be suitable for the prevention of
atmospheric corrosion. Oasis submitted updated procedure P195.581 on 3/29/2018 which
satisfactorily addressed this item. No further action is required.
17. §195.402 Procedural manual for operations, maintenance, and emergencies.
(d) Abnormal operation. The manual required by paragraph (a) of this section must
include procedures for the following to provide safety when operating design limits
have been exceeded:
(3) Correcting variations from normal operation of pressure and flow equipment and
controls.
Oasis’ O&M manual was inadequate because it did not have a defined procedure for
correcting variations from normal operation of pressure and flow equipment and controls.
Specifically, procedure 195.402(d) did not address the steps that should be taken or who
would perform the investigation. Oasis submitted updated procedures on 4/6/2018 that
satisfactorily addressed this item. No further action is required.
9



18. §195.402 Procedural manual for operations, maintenance, and emergencies.
(e) Emergencies. The manual required by paragraph (a) of this section must include
procedures for the following to provide safety when an emergency condition occurs:
(1) Receiving, identifying, and classifying notices of events which need immediate
response by the operator or notice to fire, police, or other appropriate public officials
and communicating this information to appropriate operator personnel for
corrective action.
Oasis’ O&M manual was inadequate because it did not have a defined procedure for
receiving, identifying, and classifying notices of events which need immediate response by
the operator or notice to fire, police, or other appropriate public officials and
communicating this information to appropriate operator personnel for corrective action
during an emergency condition. Specifically, the procedures did not include external
notifications and classification of external and internal notifications of incidents. Oasis
submitted updated procedures on 5/7/2018 that satisfactorily addressed this item. No
further action is required.
19. §195.403 Emergency Response Training.
(a) Each operator shall establish and conduct a continuing training program to
instruct emergency response personnel to:
(5) Learn the potential causes, types, sizes, and consequences of fire and the
appropriate use of portable fire extinguishers and other on-site fire control
equipment, involving, where feasible, a simulated pipeline emergency condition.
Oasis’ O&M manual was inadequate because it did not have a defined procedure to
conduct a continuing training program to instruct emergency response personnel.
Specifically, the training did not include provisions to learn the potential causes, types,
sizes, and consequences of fire and the appropriate use of portable fire extinguishers and
other on-site fire control equipment, involving, where feasible, a simulated pipeline
emergency condition and how to receive, identify and classify notices of events which
need immediate response. Oasis submitted updated procedures on 5/7/2018 that
satisfactorily addressed this item. No further action is required.
20. §195.442 Damage prevention program.
(a) Except as provided in paragraph (d) of this section, each operator of a buried
pipeline must carry out, in accordance with this section, a written program to
prevent damage to that pipeline from excavation activities. For the purpose of this
section, the term “excavation activities” includes excavation, blasting, boring,
10



tunneling, backfilling, the removal of aboveground structures by either explosive or
mechanical means, and other earthmoving operations.
Oasis’ Damage Prevention Program was inadequate because it did not have a defined
procedure to prevent damage to the pipeline from excavation activities. Specifically,
Oasis failed to provide a process to specify how reports of third party damage are checked
against One-Call tickets. Oasis submitted updated procedures on 9/13/2018 that
satisfactorily addressed this item. No further action is required.
21. §195.446 Control room management.
(a) General. This section applies to each operator of a pipeline facility with a
controller working in a control room who monitors and controls all or part of a
pipeline facility through a SCADA system. Each operator must have and follow
written control room management procedures that implement the requirements of
this section. The procedures required by this section must be integrated, as
appropriate, with the operator's written procedures required by §195.402. An
operator must develop the procedures no later than August 1, 2011, and must
implement the procedures according to the following schedule. The procedures
required by paragraphs (b), (c)(5), (d)(2) and (d)(3), (f) and (g) of this section must be
implemented no later than October 1, 2011. The procedures required by paragraphs
(c)(1) through (4), (d)(1), (d)(4), and (e) must be implemented no later than August 1,
2012. The training procedures required by paragraph (h) must be implemented no
later than August 1, 2012, except that any training required by another paragraph of
this section must be implemented no later than the deadline for that paragraph.
(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;
Oasis’ Control Room Management (CRM) manual was inadequate because it did not have
a defined procedure to establish clear processes to describe each controller's physical
domain of responsibility for pipelines and other facility assets. Additionally, Oasis failed
to require controllers to stay at the console to verify all SCADA commands that have been
initiated are fulfilled along with commands given via verbal communications. Oasis
submitted updated procedures on 5/7/2018 that satisfactorily addressed this item. No
further action is required.
11



22. §195.446(a) – Control room management. (see above)
(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:
(3) A controller's role during an emergency, even if the controller is not the first to
detect the emergency, including the controller's responsibility to take specific actions
and to communicate with others;
Oasis’ CRM manual was inadequate because it did not have a defined procedure to
describe a controller's role during an emergency. Specifically, Oasis failed to develop a
process to address the controller's responsibilities in the event the control room must be
evacuated. Oasis submitted updated procedures on 5/14/2018 that satisfactorily addressed
this item. No further action is required.
23. §195.446(a) – Control room management. (see above)
(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:
(4) A method of recording controller shift-changes and any hand-over of
responsibility between controllers; and
Oasis’s CRM manual was inadequate because it did not have an adequate procedure to
establish clear processes for the hand-over of responsibility between controller’s.
Specifically, Oasis failed to require that the outgoing controller is responsible to answer
the phone during the shift change. Oasis submitted updated procedures on 5/7/2018 that
satisfactorily addressed this item. No further action is required.
24. §195.446(a) – Control room management. (see above)
(c) Provide adequate information. Each operator must provide its controllers with
the information, tools, processes and procedures necessary for the controllers to
carry out the roles and responsibilities the operator has defined by performing each
of the following:
(2) Conduct a point-to-point verification between SCADA displays and related field
equipment when field equipment is added or moved and when other changes that
12



affect pipeline safety are made to field equipment or SCADA displays;
Oasis’ CRM manual was inadequate because it did not have a defined procedure to
provide adequate tools, processes and procedures necessary for the controllers to carry out
their roles and responsibilities. Specifically, Oasis failed to do the following: 1) Oasis did
not have a process in place to adequately define and list safety-related points. 2) Oasis
failed to develop adequate processes to describe in detail the point to point process. 3)
Oasis failed to develop adequate processes for the thoroughness of the point-to-point
verification. Oasis submitted updated procedures on 5/7/2018, 6/4/2018 and 9/13/2018
that satisfactorily addressed this item. No further action is required
25. §195.446(a) – Control room management. (see above)
(c) Provide adequate information. Each operator must provide its controllers with
the information, tools, processes and procedures necessary for the controllers to
carry out the roles and responsibilities the operator has defined by performing each
of the following:
(3) Test and verify an internal communication plan to provide adequate means for
manual operation of the pipeline safely, at least once each calendar year, but at
intervals not to exceed 15 months;
Oasis’ CRM manual was inadequate because it did not have an internal communication
plan to provide adequate means for manual operation of the pipeline safely. Oasis
submitted updated procedures on 5/14/2018 that satisfactorily addressed this item. No
further action is required.
26. §195.446(a) – Control room management. (see above)
(c) Provide adequate information. Each operator must provide its controllers with
the information, tools, processes and procedures necessary for the controllers to
carry out the roles and responsibilities the operator has defined by performing each
of the following:
(4) Test any backup SCADA systems at least once each calendar year, but at
intervals not to exceed 15 months; and
Oasis’ CRM manual was inadequate because it did not have a defined procedure to
provide adequate tools, processes and procedures necessary for the controllers to carry out
their roles and responsibilities. Specifically, Oasis failed to do the following: 1) Oasis
failed to provide a process for development work that takes place on the backup SCADA
system. 2) Oasis failed to develop a process to adequately address and test the logistics of
transferring control to a backup control room. The original plan did not include a backup
control room but relied on mobile totes which were not covered in the procedures. Oasis
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has since updated the procedures to include a backup control room. 3) Oasis failed to
develop a process to adequately address and test the logistics of returning operations back
to the primary control room. Oasis submitted updated procedures on 5/14/2018 that
satisfactorily addressed this item. No further action is required.
27. §195.446(a) – Control room management. (see above)
(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:
Oasis’ CRM manual was inadequate because it did not have defined fatigue mitigation
procedures to address the operator-specific fatigue risks. Specifically, Oasis has a 7 on, 7
off schedule which was not included as a fatigue risk. Additionally, Oasis failed to
adequately address how the program reduces the risk associated with controller fatigue.
Oasis submitted updated procedures on 5/7/2018 that satisfactorily addressed this item.
No further action is required.
28. §195.446(a) – Control room management. (see above)
(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:
(4) Establish a maximum limit on controller hours-of-service, which may provide for
an emergency deviation from the maximum limit if necessary for the safe operation
of a pipeline facility.
Oasis’ CRM manual was inadequate because it did not have defined procedures to reduce
the risk associated with controller fatigue that could inhibit a controller’s ability to carry
out their roles and responsibilities. Specifically, Oasis failed to do the following: 1) Oasis
failed to provide an adequate means to document all scheduled and unscheduled HOS
worked, including overtime and time spent performing duties other than control room
duties. 2) Oasis failed to develop specific fatigue countermeasures for shifts longer than 8
hours. 3) Oasis failed to develop an adequate process for approving deviations from the
maximum HOS limits. Oasis submitted updated procedures on 5/7/2018, 9/13/2018 and
10/1/2018 that satisfactorily addressed this item. No further action is required.
29. §195.446(a) – Control room management. (see above)
(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:
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(1) Review SCADA safety-related alarm operations using a process that ensures
alarms are accurate and support safe pipeline operations;
Oasis’ CRM manual was inadequate because it did not have a defined procedure for
review of safety-related alarms that accounts for individual-specific controller
qualification and performance. Additionally, Oasis failed to provide a list of safety related
alarm set points. Oasis submitted updated procedures on 10/1/2018 that satisfactorily
addressed this item. No further action is required.
30. §195.446(a) – Control room management. (see above)
(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:
(4) Review the alarm management plan required by this paragraph at least once each
calendar year, but at intervals not exceeding 15 months, to determine the
effectiveness of the plan;
Oasis’ CRM manual was inadequate because it did not have a defined procedure to
determine the effectiveness of the alarm management plan. Specifically, Oasis failed to do
the following: 1) Oasis failed to add to the procedures details on the method of review. 2)
Oasis failed to develop adequate criteria for review including chronic and recurring issues.
3) Oasis failed to include a means of record keeping. Oasis submitted updated procedures
on 10/1/2018 that satisfactorily addressed this item. No further action is required.
31. §195.446(a) – Control room management. (see above)
(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:
(5) Monitor the content and volume of general activity being directed to and required
of each controller at least once each calendar year, but at intervals not exceeding 15
months, that will assure controllers have sufficient time to analyze and react to
incoming alarms; and
Oasis’ CRM manual was inadequate because it did not have a defined procedure for
identifying and measuring the content and volume of general activity being directed to an
individual controller. Section 8.8 of the CRM states, "This analysis should be performed
once a year, not to exceed 15 months..." rather than it must be done. Additionally, Oasis
uses the POEMS workload analysis software which is not mentioned in the procedures.
Oasis submitted updated procedures on 10/1/2018 that satisfactorily addressed this item.
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No further action is required.
32. §195.446(a) – Control room management. (see above)
(f) Change management. Each operator must assure that changes that could affect
control room operations are coordinated with the control room personnel by
performing each of the following:
(2) Require its field personnel to contact the control room when emergency
conditions exist and when making field changes that affect control room operations.
Oasis’ CRM manual was inadequate because it did not have a procedure to require field
personnel and SCADA support personnel to contact the control room when emergency
conditions exist. Additionally, the CRM manual procedures that require field personnel
and SCADA support personnel to contact the control room when making field changes
(for example, moving a valve) that affect control room operations states that personnel
"should" contact the control room rather than they “must” contact the control room. Oasis
submitted updated procedures on 10/1/2018 that satisfactorily addressed this item. No
further action is required.
33. §195.452 Pipeline integrity management in high consequence areas.
(b) What program and practices must operators use to manage pipeline integrity?
Each operator of a pipeline covered by this section must:
(1) Develop a written integrity management program that addresses the risks on each
segment of pipeline in the first column of the following table not later than the date in
the second column:
Pipeline Date
Category 1 March 31, 2002.
Category 2 February 18, 2003.
Category 3 1 year after the date the pipeline begins operation.
§195.452 Pipeline integrity management in high consequence areas.
(b) What program and practices must operators use to manage pipeline integrity?
Each operator of a pipeline covered by this section must:
(2) Include in the program an identification of each pipeline or pipeline segment in
the first column of the following table not later than the date in the second column:
Pipeline Date
Category 1 December 31, 2001.
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Category 2 November 18, 2002.
Category 3 Date the pipeline begins operation.
Oasis’ Integrity Management Program (IMP) was inadequate because it did not have a
procedure to require completion of segment identification for Category 3 pipelines prior to
beginning of operation. Oasis developed and submitted an updated procedure on
5/18/2018, IMP section 8.4 which discusses identifying could affect segments on Category
3 pipelines prior to commissioning. No further action is required.
34. §195.452(b)(1) – Pipeline integrity management in high consequence areas. (see
above)
(f) What are the elements of an integrity management program? An integrity
management program begins with the initial framework. An operator must
continually change the program to reflect operating experience, conclusions drawn
from results of the integrity assessments, and other maintenance and surveillance
data, and evaluation of consequences of a failure on the high consequence area.
Oasis’ IMP was inadequate because it did not have a written facility integrity management
plan. Oasis developed and submitted procedures on 5/18/2018 which satisfactorily
addressed this item. No further action is required.
35. §195.452(b)(1) – Pipeline integrity management in high consequence areas. (see
above)
(f) What are the elements of an integrity management program? An integrity
management program begins with the initial framework. An operator must
continually change the program to reflect operating experience, conclusions drawn
from results of the integrity assessments, and other maintenance and surveillance
data, and evaluation of consequences of a failure on the high consequence area. An
operator must include, at minimum, each of the following elements in its written
integrity management program:
(1) A process for identifying which pipeline segments could affect a high consequence
area;
Oasis’ IMP was inadequate because it did not have a procedure to include an analysis of
overland spread and water transport of hazardous liquids to determine the extent of
commodity spread a
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