# MISSISSIPPI HUB, LLC — Notice of Amendment

- **operation:** document
- **citation:** CPF 32021055NOA
- **title:** MISSISSIPPI HUB, LLC — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2021-09-10
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 192.631(a)(1), 192.631(c)(3), 192.631(e)(2).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-32021055noa.json
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-32021055noa
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/32021055NOA
**body:**

Notice of Amendment involving MISSISSIPPI HUB, LLC. PHMSA's enforcement data identifies the cited regulations as 192.631(a)(1),  192.631(c)(3),  192.631(e)(2). The case was opened on 2021-09-10 and is reported as closed as of 2021-11-16. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

32021055NOA_Closure Letter_11162021_(20-179020).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021055NOA/32021055NOA_Closure%20Letter_11162021_(20-179020).pdf

32021055NOA_Closure Letter_11162021_(20-179020)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021055NOA/32021055NOA_Closure%20Letter_11162021_(20-179020)_text.pdf

32021055NOA_Notice of Amendment_09102021_(20-179020).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021055NOA/32021055NOA_Notice%20of%20Amendment_09102021_(20-179020).pdf

32021055NOA_Notice of Amendment_09102021_(20-179020)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021055NOA/32021055NOA_Notice%20of%20Amendment_09102021_(20-179020)_text.pdf

32021055NOA_Operator Response to Notice and Request for Time Extension_10072021_(20-179020).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021055NOA/32021055NOA_Operator%20Response%20to%20Notice%20and%20Request%20for%20Time%20Extension_10072021_(20-179020).pdf

32021055NOA_Closure Letter_11162021_(20-179020)_text.pdf

VIA ELECTRONIC MAIL TO: paul.bieniawski@enstorinc.com & todd.cash@enstorinc.com
November 16, 2021
Paul Bieniawski
Chief Executive Officer
Enstor Mississippi Hub
10375 Richmond Avenue, Suite 1900
Houston, TX 77042
Re: CPF 3-2021-055-NOA
Dear Mr. Bienaiwski:
From November 2 through 6, 2021, a representative from the Pipeline and Hazardous Materials
Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted a
remote pipeline safety inspection of Enstor Mississippi Hub procedures in Control Room
Management. As a result of the inspection, Enstor Mississippi Hub was issued a Notice of
Amendment on September 10, 2020, which proposed amendment of your procedures.
Enstor Mississippi Hub submitted its amended procedures on November 10, 2021. My staff
reviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of
Amendment have been corrected.
This letter is to inform you no further action is necessary and this case is now closed. Thank you
for your cooperation.
Sincerely,
Gregory A. Ochs
Director, Central Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Todd Cash, Director Compliance todd.cash@enstorinc.com

32021055NOA_Notice of Amendment_09102021_(20-179020)_text.pdf

NOTICE OF AMENDMENT
VIA ELECTRONIC MAIL TO: paul.bieniawski@enstorinc.com & todd.cash@enstorinc.com
September 10, 2021
Paul Bieniawski
Chief Executive Officer
Enstor Mississippi Hub
10375 Richmond Avenue, Suite 1900
Houston, TX 77042
CPF 3-2021-055-NOA
Dear Mr. Bienaiwski:
From November 2 through6, 2020, a representative of the Pipeline and Hazardous Materials
Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected
Enstor Mississippi Hub (Enstor) procedures for Control Room Management in Katy, Texas.
This Notice is in response to PHMSA’s Control Room Management (CRM) Initiative, which is a
national level program that includes inspectors from every region. As a result, you may have
received this Notice from a different Regional Director than typical because the CRM Initiative
inspections are currently separate from the standard inspection program. Notices and
correspondence from other types of inspections will remain unchanged.
On the basis of the inspection, PHMSA has identified the apparent inadequacies found within
Mississippi Hub’s plans or procedures, as described below:
1. § 192.631 Control room management.
(a) General. (1) 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, except that for each control room where an operator’s activities are
limited to either or both of:



Enstor’s O&M Procedure 1120 CRM Plan was inadequate because it failed to provide
information to define what constitutes additions, expansions, or replacements to the SCADA
system required by § 192.631 (c)(1). Section 7.3 of O&M Procedure 1120 simply restated the
regulation. While Enstor had adopted the ROC CRM plan, it did not employ the ROC SCADA
system for its pipeline remote operations. Enstor used its own SCADA system and the ROC
controllers remotely logged in to Enstor’s SCADA system. Therefore, the SCADA system was
managed by Enstor and its procedures are required to be compliant with the regulation.
The procedure must be amended to provide definitions of additions, expansion, or replacements
of the SCADA system, as well as examples of these conditions to provide adequate information
of when to implement the required sections of API 1165.
2. § 192.631 Control room management.
(a) General. (1) 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, except that for each control room where an operator’s activities are
limited to either or both of:
Enstor’s O&M Procedure 1120 was inadequate because it failed to provide an adequate process
for when a point-to-point must be completed and instruction on how to complete a point-to-point
verification as required by § 192.631(c)(2). Section 7.4 of O&M Procedure 1120, and form
1100-27 provided the compliance procedure and documentation for point-to-point verifications.
The procedure did not include instructions on how to complete the form, and the form did not
provide enough detail to demonstrate thoroughness of the point-to-point verification. The point-
to-point needs to include verification of field to control room HMI data and status, alarm set
points, alarm messaging, alarm attributes (color, blinking, audio), tag name, who conducted the
point to point, correct end device and location, date of completion and screen verification for all
screens where the point presents.
The procedure also did not define when and under what conditions a point-to-point needs to be
conducted.
3. § 192.631 Control room management.
(a) General. (1) 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, except that for each control room where an operator’s activities are
limited to either or both of:
Enstor’s O&M procedure 1109 was inadequate because it failed to provide a clear process to test
the SCADA backup system in coordination with the ROC SCADA back up test. Enstor’s
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SCADA system was separate from ROC’s SCADA system and needed to be tested per Section §
192.631(c)(4). During ROC’s back up test, Enstor utilized a laptop to connect with their main
SCADA server. While the test was successful, the documentation of the ROC SCADA back up
test did not include any consideration for the Enstor laptop, and Enstor did not have
documentation of the test. The ROC procedure was silent in the coordination of the testing of
the two systems.
The procedure needs to be amended to consider either coordination with ROC during their test or
a separate test of the Mississippi Hub back up SCADA. The procedure needs to include any
logistical considerations, backup server testing, assessments of monitoring as well as verification
of alarming and command functions. It must also include documentation of the test including
any findings, corrective actions and lessons learned. The tests must be completed once each
calendar year not to exceed 15 months.
The procedure must be amended to include situations and conditions under which a point-to-
point must be conducted as well as instructions and forms with detail to provide a thorough
point-to-point verification.
4. § 192.631 Control room management.
(a) General. (1) 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, except that for each control room where an operator’s activities are
limited to either or both of:
The ROC CRM Plan dated July 7, 2020 was not adequate because it relied heavily on self-
reporting fatigue. Section 6.12, Countermeasures for 9-12-hour days, relied on the controller
self-reporting fatigue. It did not provide a countermeasure for supervisors or others working in
the control room to monitor and report a person suspected or observed to be fatigued. In sections
3.5 and 3.6, Roles and Responsibilities of the Control Room Manager, it stated in items 4 and 6,
respectively, "[m]anage fatigue risk and fatigue countermeasures". While these are important
and appropriate roles and responsibilities for managers, manage is different than monitor,
recognize and respond. The section expressly states in Section § 192.631(d)(3) to "train
controllers and supervisors to recognize the effects of fatigue". The procedure did not offer a
requirement for managers, supervisors, or other controllers to monitor, identify and
respond/report others. Fatigue management and identification, while it is a responsibility of the
controllers for themselves, is also a responsibility all members of the control room.
The procedure needs to be amended to include roles and responsibilities for all control room
employees to monitor, identify and respond to fatigue of the individual and others.
3



5. § 192.631 Control room management.
(a) General. (1) 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, except that for each control room where an operator’s activities are
limited to either or both of:
Enstor’s procedure was not adequate because it did not include a list of abnormal operating
conditions (AOC's) that are likely to occur simultaneously or in sequence, as required by section
§ 192.631(h)(1). The operator’s third party (ROC) control room manager indicated these
considerations were included in the training documents. Upon review of the training
documentation, it was identified that the training material does cover AOCs that happen in
sequence, but nothing in the training materials discussed how to address ones that occur
simultaneously. Additionally, while ROC may have a standard list, it is also necessary to
identify asset specific conditions (Enstor) that may occur outside of the generic examples
provided by the third-party contractor.
The procedure needs to be amended to include a list or examples of abnormal operating
conditions likely to occur simultaneously or in sequence. The list needs to consider conditions
specific to Mississippi Hub operations.
6. § 192.631 Control room management.
(a) General. (1) 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, except that for each control room where an operator’s activities are
limited to either or both of:
Enstor’s procedures were inadequate to provide requirements of what information the controllers
needed to record and document in their log that demonstrates compliance with the requirements
of this section per § 192.631(j)(1). When attempting to determine if field personnel and others
were contacting the control room prior to implementing physical changes to pipeline equipment
or configuration, inspectors were not able to make determinations through the controller logs. In
reviewing the procedures, it was identified in sections 5.5, 5.5.1, 5.6 and 7.6 Enstor’s O&M
Manual 1120, dated 1/14/2020, that field personnel were required to contact the control room
prior to making changes to the field. Procedures for annual valve maintenance, annual relief
valve calibration/maintenance, and testing ESDs all require contacting the control center prior to
commencing work. Section 5.7.1 of O&M Manual 1120 required documenting work activities
and/or other pertinent information that transpired during the shift, including but not limited to
"operational activities (e.g. operations, maintenance, communications, notifications)".
Documenting this type of maintenance, as well as other activities on the pipeline, is an important
record for activities on the pipeline that can support compliance with other sections of the
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regulations, supports trouble shooting issues as well as responding to abnormal conditions or
emergencies if they develop.
Enstor’s procedure needs to be amended to include information that must be recorded and
documented in the controller log to demonstrate compliance with the requirements of section §
192.631.
7. § 192.631 Control room management.
(a) . . . .
(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;
Enstor’s CRM Plan was inadequate to provide guidance to the controller when performing
manual operations through actual or test condition as required. Remote Operation Control
(ROC) began providing Enstor with control room services on August 6, 2019. Enstor’s Control
Room Management (CRM) procedure adopted ROC’s CRM Plan dated July 31, 2020. Section
4.6 of the plan set forth times when manual operation of the pipeline must be initiated. While the
procedure addressed the requirement for field personnel to call the control room and provide
field operating information, it did not provide guidance on what the controller should do with the
information. There was no language in the procedure related to how to document the field
information, how to incorporate the information into safely operating the system, or how to
maintain the information as a record. Form 11.13 was the document of record for the required
test and included questions related to the manual operation conditions and requirements. This
form did not have space to document the field information called in to the controller
The procedure must be amended to provide direction and tools for the controller to document
field information, and to incorporate that information into the safe manual operation of the
pipeline in the event of SCADA failure or if a shutdown of the SCADA system becomes
necessary.
8. § 192.631 Control room management.
(a) . . . .
(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:
(1) . . . .
(2) Identify at least once each calendar month points affecting safety that have been
taken off scan in the SCADA host, have had alarms inhibited, generated false
5



alarms, or that have had forced or manual values for periods of time exceeding that
required for associated intervals not to exceed 15 months;
Enstor’s Alarm Management procedure was inadequate because it failed to define all points
affecting safety. The procedure does identify safety related alarms. Safety related points often
support the definition of safety related alarms, but a safety related point, for operational reasons,
can stand on its own without alarming. Several regulatory sections depend upon the operator
defining points affecting safety and safety related alarms to meet the compliance requirement;
these included §§ 192.631(c)(2), 192.631(e)(1), 192.631(e)(2), and 192.631(e)(3). Because
Enstor utilized their own SCADA system, they did not share the ROC Alarm Management Plan,
or the identified safety related points and alarms contained therein.
Also noted in the procedure was that Enstor did not identify a designation for identifying safety
related alarms in their SCADA database.
The procedure needs to be amended to identify the safety related points, safety related alarms
and how to distinguish whether a point or alarm is safety related in the master SCADA database.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as
part of this Notice is a document entitled Response Options for Pipeline Operators in
Compliance Proceedings.
Please refer to this document and note the response options. Be advised that all material you
submit in response to this enforcement action is subject to being made publicly available. If you
believe that any portion of your responsive material qualifies for confidential treatment under 5
U.S.C. 552(b), along with the complete original document you must provide a second copy of
the document with the portions you believe qualify for confidential treatment redacted and an
explanation of why you believe the redacted information qualifies for confidential treatment
under 5 U.S.C. 552(b).
Following the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under §190.211. If you do not respond within 30 days of
receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this
Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in
this Notice without further notice to you and to issue an Order Directing Amendment. If your
plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend
your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not
contesting this Notice, we propose that you submit your amended procedures to my office within
30 days of receipt of this Notice. This period may be extended by written request for good
cause. Once the inadequacies identified herein have been addressed in your amended
procedures, this enforcement action will be closed.
It is requested (not mandated) that Enstor Mississippi Hub maintain documentation of the safety
improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of
plans, procedures) and submit the total to Gregory A. Ochs, Director, Central, Pipeline and
6



Hazardous Materials Safety Administration. In correspondence concerning this matter, please
refer to CPF 3-2021-055-NOA and, for each document you submit, please provide a copy in
electronic format whenever possible.
Sincerely,
Gregory A. Ochs
Director, Central Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Todd Cash, Director Compliance todd.cash@enstorinc.com
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings
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