{"operation":"document","citation":"CPF 32021023NOA","title":"SUNCOR ENERGY (USA) PIPELINE CO. — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-05-06","effective_on":null,"summary":"CLOSED notice of amendment citing 195.446(b)(4), 195.446(c)(2), 195.446(c)(3), 195.446(d), 195.446(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021023noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021023noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021023noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32021023NOA","body":"Notice of Amendment involving SUNCOR ENERGY (USA) PIPELINE CO.. PHMSA's enforcement data identifies the cited regulations as 195.446(b)(4),  195.446(c)(2),  195.446(c)(3),  195.446(d),  195.446(e). The case was opened on 2021-05-06 and is reported as closed as of 2021-09-09. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32021023NOA_Closure Letter_09092021_(20-173060).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021023NOA/32021023NOA_Closure%20Letter_09092021_(20-173060).pdf\n\n32021023NOA_Closure Letter_09092021_(20-173060)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021023NOA/32021023NOA_Closure%20Letter_09092021_(20-173060)_text.pdf\n\n32021023NOA_Notice of Amendment_05062021_(20-173060).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021023NOA/32021023NOA_Notice%20of%20Amendment_05062021_(20-173060).pdf\n\n32021023NOA_Notice of Amendment_05062021_(20-173060)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021023NOA/32021023NOA_Notice%20of%20Amendment_05062021_(20-173060)_text.pdf\n\n32021023NOA_Notice of Amendment_05062021_(20-173060)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: nthonen@suncor.com and jgrothmann@suncor.com\nMay 6, 2021\nMs. Nancy Thonen\nPresident\nSuncor Energy (USA) Pipeline Co.\n717 17th Street, Suite 2900\nDenver, CO 80202\nCPF 3-2021-023-NOA\nDear Ms. Thonen,\nFrom August 10 through 14, 2020, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nSuncor Energy (USA) Pipeline Company (Suncor) procedures for Control Room Management in\nSherwood Park, Alberta, Canada. The procedures inspected include assets for Suncor’s USA\ninterstate hazardous liquid pipelines operated from the control room located in Alberta, Canada.\nThis Notice is in response to PHMSA’s Control Room Management (CRM) Initiative, which is a\nnational level program that includes inspectors from every region. As a result, you may have\nreceived this Notice from a different Regional Director than typical because the CRM Initiative\ninspections are currently separate from the standard inspection program. Notices and\ncorrespondence from other types of inspections will remain unchanged.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nSuncor’s plans or procedures, as described below:\n\n\n\n1. 2. § 195.446 Control room management.\n(a) . . . .\n(b) Each operator must define the roles and responsibilities of a controller during\nnormal, abnormal, and emergency operating conditions. To provide for a\ncontrollers’ prompt and appropriate response to operating conditions, an operator\nmust define each of the following:\n(1) . . . .\n(4) A method of recording controller shift-changes and any hand-over of\nresponsibility between controllers;\nSuncor’s CRM Program (PLGOS00001) Section 2 - Roles and Responsibilities Approved\nApril 1, 2020, were inadequate because the procedures did not address how the transition\nwill occur if a controller is unable to continue or assume responsibility for any\nreason. Section 2.8.8.3 provides a brief statement about the need to conduct a shift\nturnover/TOR in the event a controller needs to leave due to illness, fatigue or other\nreasons. During the inspection, Suncor outlined steps that a manager may take to fill the\nshift that could include shutting down the pipeline, calling an off-shift employee in to\nwork or reallocating a current controller to the console. The procedure did not address\nany of these choices and the related TOR.\nThe procedure must be amended to include the full process of hand-over of responsibility\nbetween controllers and recording the shift changes when a controller needs to leave due\nto illness, fatigue or other reasons.\n§ 195.446 Control room management.\n(a) . . . .\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 had defined by performing each\nof the following:\n(1) . . . .\n(2) Conduct a point-to-point verification between SCADA displays and related field\nequipment when field equipment is added or moved and when other changes that\naffect pipeline safety are made to field equipment or SCADA displays;\nSuncor’s CRM Program (PLGOS00001) Section 3 - Providing Adequate Information\nApproved April 1, 2020, was inadequate because in section 3.3.7 it stated, \"[f]or point-to-\npoint verification, a representative sample is defined as more than fifty percent of screens\non which the point appears.” During the inspection, Suncor personnel stated that for\npoint-to-points \"they check all displays.\" Sampling is not permissible for point-to-point\nverification, with a limited exception for maintenance of a single established point, such\nas after a like for like replacement of a transmitter.\nSuncor mistakenly relied on an original inspection protocol C2-3 which states, “[t]he\nverification procedure must include a requirement to check a representative sampling of\n2\n\n\n\n3. impacted displays.” This statement references FAQ C.03, which relates to changes made\nto SCADA screens only.\nThe procedure must be amended to provide a more definitive and limited use of\nsampling, if at all, when conducting point-to-point verifications between SCADA\ndisplays and related field equipment.\n§ 192.446 Control room management.\n(a) . . . .\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(1) . . . .\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;\nSuncor’s CRM Program (PLGOS00001) Section 3 - Providing Adequate Information\nApproved April 1, 2020, was inadequate because the procedure did not establish a\nmethod for a controller to incorporate the manual field information into the overall\nSCADA operation. Manually collected information from the field should be aggregated\nin a format that replaces the information normally provided from the SCADA\nsystem. PLOP00015, Emergency Operating Procedure Section 5, provides steps to take\nin the event of Complete Pipeline Loss of Control - SCADA Failure, SPCC Emergency\nEvacuation. Step 5.6 states that if SPCC SCADA is not available or has inaccurate data,\nthen, \"direct field staff to monitor stations locally and contact SPCC with hourly updates\nor in the case of abnormal or emergency condition until SCADA is returned to service\nand /or data is confirmed accurate.\" This procedure does not direct the controller to log\nthis information and does not provide information for where to log the manual field\ninformation. Procedure PLOP00012 Operational Log Tool (OLT) Log Entry, in Section\n1, defines when a controller should enter information into the OLT. Step 1.3 requires\nentries for \"calls from field personnel and details of calls\"; it does not call out specific\nrequirements for logging manual operation event calls. Additionally, PLOP00012 is not\nreferenced in (PLGOS00001) Section 3 or in PLOP000015. Should the operator choose\nto manually operate its system, it is critical that information regarding the pipeline\noperating conditions during this time is readily available for a controller to review and\nincorporate into the overall operation of the pipeline.\nThe procedure must be amended to provide an adequate process in the manual operation\nplan to document manual field information and incorporate this into the safe operation of\nthe pipeline. These steps must also be included in the test and verification of the plan that\noccurs at least once each calendar year, not to exceed 15 months.\n3\n\n\n\n4. 5. § 192.446 Control room management.\n(a) . . . .\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:\nSuncor’s CRM Program (PLGOS00001) Section 5 - Fatigue Risk Management System\nApproved April 9, 2020, was inadequate because it did not identify operator-specific\nrisks. Section 5.2.3.2 identifies \"[t]he specific fatigue risks for the Control Centre\", and\nlists fatigue related occurrences related to tasks, but these do not relate to activities,\nhealth conditions, or life style choices that can contribute to controller fatigue. Section\n5.2.3.3 provides the statement, “[f]atigue management training addresses how off duty\nactivities, personal choices and sleep disorders can contribute to fatigue and represent the\ntype of specific fatigue risks a controller faces.” Suncor has not identified the operator\nspecific fatigue risks.\nThe procedure must be amended to identify risks associated with fatigue (general and\noperator specific) that could inhibit a controller’s ability to carry out the roles and\nresponsibilities defined by the operator.\n§ 195.446 Control room management.\n(a) . . . .\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:\nSuncor’s CRM Program (PLGOS00001) Approved April 9, 2020, was inadequate\nbecause it did not reference API 1130 or the ATMOS LDS system or related\nprocedures. Section § 195.444 requires compliance with API 1130 for computational\nleak detection monitoring (CPM) leak detection systems (incorporated by reference §\n195.3). ATMOS LDS is the primary leak monitoring/detection/alarm tool that is linked\nto SCADA to provide alarms and alerts related to potential pipeline leaks. Additionally,\nthe controllers are provided a separate screen at the console specifically for ATMOS LDS\ninformation that can inform the controller with more information about the ATMOS\nalarms. This information was not provided in the procedure.\nThe procedure needs to be amended to include the reference to API 1130 as well as the\nATMOS LDS system and related procedures.\n4\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 as\npart of this Notice is a document entitled Response Options for Pipeline Operators in\nEnforcement 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 for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you\nmust 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 information\nqualifies 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 of\nreceipt 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 in\nthis Notice without further notice to you and to issue an Order Directing Amendment. If your\nplans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend\nyour plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not\ncontesting this Notice, we propose that you submit your amended procedures to my office within\n30 days of receipt of this Notice. This period may be extended by written request for good\ncause. Once the inadequacies identified herein have been addressed in your amended\nprocedures, this enforcement action will be closed.\nIt is requested (not mandated) that Suncor maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to Gregory A. Ochs, Director, Central, Pipeline and Hazardous\nMaterials Safety Administration. In correspondence concerning this matter, please refer to CPF\n3-2021-023-NOA and, for each document you submit, please provide a copy in electronic format\nwhenever possible.\nSincerely,\nGregory A. Ochs\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\ncc: James Grothman, Compliance jgrothmann@suncor.com\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n5\n\n32021023NOA_Closure Letter_09092021_(20-173060)_text.pdf\n\nVIA ELECTRONIC MAIL TO: nthonen@suncor.com and jgrothmann@suncor.com\nSeptember 9, 2021\nMs. Nancy Thonen\nPresident\nSuncor Energy (USA) Pipeline Co.\n717 17th Street, Suite 2900\nDenver, CO 80202\nRe: CPF 3-2021-023-NOA\nDear Ms. Thonen:\nFrom August 10 through 14, 2020, a representative from the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted a\nremote pipeline safety inspection of Suncor Energy (USA) Pipeline Co. (Suncor) procedures in\nSherwood Park, Alberta, Canada. As a result of the inspection, Suncor was issued a Notice of\nAmendment on May 6, 2021, which proposed amendment of your procedures.\nSuncor submitted its amended procedures on September 3, 2021. My staff reviewed the\namended procedures, and it appears that the inadequacies outlined in this Notice of Amendment\nhave been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nGregory A. Ochs\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":14061}