{"operation":"document","citation":"CPF 320196010M","title":"PARADIGM MIDSTREAM SERVICES - ND, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-11-26","effective_on":null,"summary":"CLOSED notice of amendment citing 195.446(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320196010m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320196010m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320196010m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320196010M","body":"Notice of Amendment involving PARADIGM MIDSTREAM SERVICES - ND, LLC. PHMSA's enforcement data identifies the cited regulation as 195.446(e). The case was opened on 2019-11-26 and is reported as closed as of 2020-01-08. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320196010M_Closure Letter_01082020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320196010M/320196010M_Closure%20Letter_01082020.pdf\n\n320196010M_Closure Letter_01082020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320196010M/320196010M_Closure%20Letter_01082020_text.pdf\n\n320196010M_Notice of Amendment_11262019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320196010M/320196010M_Notice%20of%20Amendment_11262019.pdf\n\n320196010M_Notice of Amendment_11262019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320196010M/320196010M_Notice%20of%20Amendment_11262019_text.pdf\n\n320196010M_Notice of Amendment_11262019_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 26, 2019\nMr. Troy Andrews\nChief Executive Officer\nParadigm Energy Partners\nLLC 545 East John Carpenter Freeway, Suite 800\nIrving, Texas 75062\nCPF 3-2019-6010M\nDear Mr. Andrews:\nOn January 24-26, 2017, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nParadigm Midstream Services – ND, LLC procedures for operations, maintenance, control\nroom, operator qualification and public awareness in Keene, North Dakota.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nParadigm’s plans or procedures, as described below:\n1. §195.446 Control room management.\n(e) Alarm management. Each operator using a SCADA system must have a\nwritten alarm management plan to provide for effective controller response to\nalarms. An operator's plan must include provisions to:\n(1) Review SCADA safety-related alarm operations using a process that\nensures alarms are accurate and support safe pipeline operations;\n(2) Identify at least once each calendar month points affecting safety that\nhave been taken off scan in the SCADA host, have had alarms inhibited,\ngenerated false alarms, or that have had forced or manual values for\nperiods of time exceeding that required for associated maintenance or\noperating activities;\n\n\n\n(3) Verify the correct safety-related alarm set-point values and alarm\ndescriptions when associated field instruments are calibrated or changed\nand at least once each calendar year, but at intervals not to exceed 15\nmonths;\n(4) Review the alarm management plan required by this paragraph at\nleast once each calendar year, but at intervals not exceeding 15 months, to\ndetermine the effectiveness of the plan;\n(5) Monitor the content and volume of general activity being directed to\nand required of each controller at least once each calendar year, but at\nintervals not exceeding 15 months, that will assure controllers have\nsufficient time to analyze and react to incoming alarms; and\n(6) Address deficiencies identified through the implementation of\nparagraphs (e)(1) through (e)(5) of this section.\nParadigm’s Control Room Management plan is missing sections on\nmaintenance, alarm philosophy, detailed design and other topical sections.\nAlso, there was no procedure for developing alarm set points. Finally, there is\nno procedure to address Item (3) above. Paradigm developed an alarm set\npoint procedure and maintenance section in a separate procedure from its alarm\nmanagement plan in response to this finding. It is not clear how the new\nprocedure and the existing alarm management procedures mesh to provide a\ncomprehensive alarm management plan. Paradigm must amend its alarm\nmanagement plan to include a procedure to: Verify the correct safety-related\nalarm set-point values and alarm descriptions when associated field instruments\nare calibrated or changed and at least once each calendar year, but at intervals\nnot to exceed 15 months. Paradigm must also clarify how various alarm\nmanagement procedures work together. It is recommended that Paradigm also\nreview the below list of topical areas for an alarm management plan and add\napplicable sections to its alarm management plan.\n Alarm philosophy\n Alarm identification\n Alarm rationalization, not necessarily alarm reduction.\n Detailed design\n Implementation\n Operation\n Maintenance\n Monitoring\n Assessment (including a method to confirm effective controller\nresponse)\n Internal audits\n2\n\n\n\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. 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).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged\nin this Notice without further notice to you and to issue an Order Directing Amendment. If\nyour plans or procedures are found inadequate as alleged in this Notice, you may be ordered to\namend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are\nnot contesting this Notice, we propose that you submit your amended procedures to my office\nwithin 60 days of receipt of this Notice. This period may be extended by written request for\ngood cause. Once the inadequacies identified herein have been addressed in your amended\nprocedures, this enforcement action will be closed.\nIt is requested (not mandated) that [Company name] maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision\nof plans, procedures) and submit the total to [Region Director's name], Director, [Region],\nPipeline and Hazardous Materials Safety Administration. In correspondence concerning this\nmatter, please refer to CPF 3-2019-6010M and, for each document you submit, please\nprovide a copy in electronic format whenever possible.\nSincerely,\nAllan C. Beshore\nDirector, Central Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\nCopy:\nMr. Tommy Janik, Chief Operating Officer\nParadigm Midstream Services – ND, LLC.\n545 East John Carpenter Freeway, Suite 800,\nIrving, TX 75062\n3\n\n320196010M_Closure Letter_01082020_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 8, 2020\nMr. Troy Andrews\nChief Executive Officer\nParadigm Energy Partners\nLLC 545 East John Carpenter Freeway, Suite 800\nIrving, Texas 75062\nRe: CPF 3-2019-6010M\nDear Mr. Andrews:\nOn January 24-26, 2017, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Paradigm\nMidstream Services – ND, LLC (Paradigm) procedures for operations, maintenance, control room,\noperator qualification and public awareness in Keene, North Dakota. As a result of the inspection,\nParadigm was issued a Notice of Amendment on November 26, 2019, which proposed amendment of\nyour procedures.\nPHMSA received Paradigm’s amended procedures on December 23, 2019. My staff reviewed these\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you for\nyour cooperation.\nSincerely,\nAllan C. Beshore\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\nCopy:\nMr. Tommy Janik, Chief Operating Officer\nParadigm Midstream Services – ND, LLC.\n545 East John Carpenter Freeway, Suite 800,\nIrving, TX 75062","truncated":false,"body_characters":8541}