{"operation":"document","citation":"CPF 32022034NOA","title":"SPIRE MISSOURI INC. EAST — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-02-25","effective_on":null,"summary":"CLOSED notice of amendment citing 195.446(a), 195.446(b), 195.446(b)(2), 195.446(b)(3), 195.446(b)(4), 195.446(b)(5), 195.446(c)(1), 195.446(c)(2), 195.446(c)(4), 195.446(d)(1), 195.446(e)(1), 195.446(e)(2), 195.446(e)(3), 195.446(e)(4), 195.446(e)(5), 195.446(f)(1), 195.446(f)(2), 195.446(h), 195.446(h)(1), 195.446(h)(6).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32022034noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32022034noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32022034noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32022034NOA","body":"Notice of Amendment involving SPIRE MISSOURI INC. EAST. PHMSA's enforcement data identifies the cited regulations as 195.446(a),  195.446(b),  195.446(b)(2),  195.446(b)(3),  195.446(b)(4),  195.446(b)(5),  195.446(c)(1),  195.446(c)(2),  195.446(c)(4),  195.446(d)(1),  195.446(e)(1),  195.446(e)(2),  195.446(e)(3),  195.446(e)(4),  195.446(e)(5),  195.446(f)(1),  195.446(f)(2),  195.446(h),  195.446(h)(1),  195.446(h)(6). The case was opened on 2022-02-25 and is reported as closed as of 2023-08-15. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32022034NOA_Closure Letter_08152023_(21-203212).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022034NOA/32022034NOA_Closure%20Letter_08152023_(21-203212).pdf\n\n32022034NOA_Closure Letter_08152023_(21-203212)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022034NOA/32022034NOA_Closure%20Letter_08152023_(21-203212)_text.pdf\n\n32022034NOA_Notice of Amendment_02252022_(21-203212).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022034NOA/32022034NOA_Notice%20of%20Amendment_02252022_(21-203212).pdf\n\n32022034NOA_Notice of Amendment_02252022_(21-203212)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022034NOA/32022034NOA_Notice%20of%20Amendment_02252022_(21-203212)_text.pdf\n\n32022034NOA_Operator Response to Notice_03252022_(21-203212).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022034NOA/32022034NOA_Operator%20Response%20to%20Notice_03252022_(21-203212).pdf\n\n32022034NOA_Notice of Amendment_02252022_(21-203212)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: craig.hoeferlin@spireenergy.com and\nBob.Gardner@spireenergy.com\nFebruary 25, 2022\nMr. Craig Hoeferlin\nVice President, Operations Services and SMS\nSpire Missouri Inc. East\n700 Market Street\nSt. Louis, Missouri 63101\nCPF 3-2022-034-NOA\nDear Mr. Hoeferlin:\nFrom May 17 to May 23, 2021, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected remotely\nSPIRE STL (Spire or Spire STL) and SPIRE NGL (Spire or Spire NLG) procedures for Control\nRoom Management in St. Louis, Missouri.\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 correspondence\nfrom other types of inspections will remain unchanged.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nSpire’s plans or procedures, as described below:\n\n\n\n1. 2. § 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\nSpire CRM Procedure Revision 1.4 3/15/2021 (Spire’s CRM Plan) was inadequate\nbecause it did not have a procedure for determining a control room. Spire offered a\nstatement in Section 1.2, Application and Scope, that states “the plan applies to any Spire\nemployee working in a Control Room who monitors and controls all or part of the assets\nlisted in section 1.1 through a SCADA system.\" These assets were Spire STL and Spire\nNGL. Spire NGL OPID 11032 included an underground storage field that maintains an\noperator control center to monitor and manage the storage field. Spire STL OPID 39886\nhad transmission stations with PLC or RTU's that may or may not have been able to\nmanage the flow of gas outside the fence by an individual through manipulating the\nPLC. These assets were part of both pipelines. Therefore, if they were operated\nindependently, outside of the Control Room direction, they would become control rooms\nand the individuals would need to be qualified as controllers.\nSpire needs to amend their procedure to equitably evaluate all such facilities to determine\nif it is a control room and falls under the requirements for Control Room Management.\n§ 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…\n(b) Roles and responsibilities. Each operator must define the roles and\nresponsibilities of a controller during normal, abnormal, and emergency operating\nconditions…\nSpire’s CRM Plan was inadequate because the procedure did not define the controller’s\ndomain of responsibility required by § 195.446(b) as they related to third party operators\ncritical to pipeline operations. Section 1.2 of the CRM Plan identified Spire STL and\nSpire NGL as the assets being monitored and controlled by the control room. Integral to\nthe pipeline operations are third party operators Phillips at the Hartford Terminal and\nConoco-Phillips East Terminal. These third-party terminals function as a holding/storage\nfacilities and product is directed to and from these facilities by the Spire controllers.\nAdditionally, the Catalan Propane Plant (propane vaporization) is connected to the\npipeline and direction for vaporization comes from the Utility. The controller’s physical\n2\n\n\n\n3. domain is not well defined, and the controller’s roles and responsibilities related to these\nthird-party assets and how the controller interacts and directs the pipeline operations to\nand from these facilities. Furthermore, there was no reference to the Spire STL system\noperated on the same console.\nThe procedure needs to be amended to provide clear roles and responsibilities related to\nthese facilities as well as include the assets of Spire STL into the CRM Plan.\n§ 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…\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, and operator must define each of the following:\n(2) A controller’s role when an abnormal operating condition is detected, even if the\ncontroller is not the first to detect the condition, including the controller’s\nresponsibility to take specific actions and to communicate with others;\nSpire’s CRM Plan was not adequate to define the controller's role when an abnormal\noperating condition was detected, even if the controller was not the first to detect the\ncondition, including the controller's responsibility to take specific actions and to\ncommunicate with others as required by § 195.446(b)(2). Section 4.3.2 of the CRM Plan\naddressed Abnormal Operating Conditions roles, responsibilities, and authority for\ncontrollers when an abnormal condition was detected either by the controller or from\nanother source (field/public). The procedure references SOP #12 which was incorrect. It\nshould have been SOP #10, Abnormal Condition Report, which gave direction on when\nand how to fill out the report, how the report got distributed, as well as when to elevate\ninformation to higher levels within the organization.\nThe procedure and SOP did not provide details when the controllers should log into their\nlogbook and what they should record during an Abnormal Operation (AO) event. The\noperator identified this as an expectation of controllers, but it is not covered in\nprocedure. There was no requirement for supervisory review of AO, nor a timeline for\nsuch a review once a controller completed the form described in SOP #10. There was no\ndetail of who determines the cause or whether further action was required to prevent\nrecurrence.\nAdditionally, Step 7 of the SOP required the controller to self-report if the controller or\ncontrol room contributed to the AO. If the answer is “yes”, the system will prompt a\nreview of the controller's fatigue level by the Manager of Gas Control using form\n3\n\n\n\n4. GC006. Depending upon an individual to self-report is not adequate. An independent\nreview of AO needs to be completed to determine if the controller's actions contributed.\nThe procedure needs to be amended to define the controller's role when an abnormal\noperating condition was detected, even if the controller was not the first to detect the\ncondition, including the controller's responsibility to take specific actions and to\ncommunicate with others.\n§ 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…\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, and 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\nactions and to communicate with others;\nSpire’s CRM Plan was not adequate because it did not define the controllers' authority\nand responsibility to make decisions, take actions, and communicate with others upon\nbeing notified of, upon detection of, and during an emergency or if a leak or rupture is\nsuspected, as required by § 195.446(b)(3). Section 4.3.3 of the CRM Plan did not address\nthe Spire NGL system in an emergency. The procedure only described actions for Spire\nSTL emergencies, such as referencing the Spire STL Pipeline Emergency Plan and\nProcedure and the Spire STL Pipeline Emergency Call Checklist.\nThe procedure also referenced SOP #12, which was incorrect. It should have been SOP\n#8, Emergency Procedures HVL. This procedure was a partial cut and paste from the\nLaclede Pipeline emergency procedure. This procedure described the role of the Gas\nControl Supervisor, which was not a role in the Control Room. There was a section that\nappeared to be related to underground storage emergencies that directed persons to\ncontact central dispatching or the control room. There was also SOP #17, UGS Propane\nSystem Emergency Shutdown (ESD), which provided 4 steps for the controller to shut\ndown the system via ESD. This SOP was not referenced in the Emergency Plan section\n4.3.3. Also, there were no steps for communicating or documenting this event.\nThe procedure needs to be amended to include the controllers' authority and\nresponsibility to make decisions, take actions, and communicate with others upon being\nnotified of, upon detection of, and during an emergency or if a leak or rupture is\nsuspected. This must include both Spire STL and Spire NGL.\n4\n\n\n\n5. 6. § 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…\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, and operator must define each of the following:\n(3) A controller’s role during an emergency, even if the controller is not the first\nto detect the emergency, including the controller’s responsibility to take specific\nactions and to communicate with others;\nSpire’s CRM Plan was not adequate to address the controller's responsibilities in the\nevent of an emergency per § 195.446(b)(3) for when the control room must be evacuated.\nSection 4.3.3 authorized the controller to \"start the process of moving primary control\nroom operations to Backup Control Room” which then referenced SOP #6, Move\nPrimary Operation to the Backup Control Center. The procedure failed to provide the\nsteps to be taken \"if an evacuation of the primary control room, or the building housing\nthe primary control room triggers the use of this procedure.” There was unessential\ninformation in the middle of the procedure that was not beneficial to supporting the\ncontroller to move from the primary to the backup control center, and it ends incomplete\nstating \"if an evacuation of the primary control room, or the building housing the primary\ncontrol room triggers the use of this procedure, the following steps should be\ntaken.\" Additionally, it was not clear if an evacuation of the control room always\nresulted in moving to the backup control center or a temporary move to a safe location for\na short period of time.\nThe procedure needs to be amended to address the controller's responsibilities in the\nevent the control room must be evacuated. Some considerations may include factors for\ndetermining the need to evacuate, who makes the decision to evacuate and relocate to the\nbackup control center, how is this communicated, and how internal communications are\nmanaged during the relocation.\n§ 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. . . .\n(b) Roles and responsibilities. Each operator must define the roles and\n5\n\n\n\n7. responsibilities of a controller during normal, abnormal, and emergency operating\nconditions. To provide for a controller’s prompt and appropriate response to\noperating conditions, and operator must define each of the following:\n(4) A method for recording controller shift-changes and any hand-over of\nresponsibility between controllers…\nSpire’s CRM Plan was inadequate because the procedure in Section 5.6 did not\nadequately define the roles and responsibilities of a controller before leaving the console\nfor any reason, as required per § 195.446(b)(4). Spire, when fully staffed, had a fully\nqualified controller available 24/7 to assist if a controller must step away from the\nconsole. Section 5.6 states: “If taking over for less than 30 minutes this can be done by\nadding a note in the operator logbook located in Clear SCADA. It must consist of the\nemployee number of the controller taking over, along with the date/time. When the\ncontroller on duty returns, they must enter a note with their employee number and the\ndate/time they resumed control of the pipeline.\" The procedure does not mention what is\nrequired for the hand-over of responsibility before the controller leaves the console, for\nexample: no unacknowledged, high priority, or safety related alarms in place, whether set\npoints/commands sent must be completed, or whether verbal commands to field\npersonnel are acknowledged. It also did not define the role and responsibilities of the\nperson left to monitor the system when limited shift change had occurred. For example,\nshould the person only monitor the system, take total control of the system, answer\nphones, call the absent controller if alarms present, etc.\nThe procedure needs to be amended to provide the roles and responsibilities of the\ncontrollers before leaving the console for any reason.\n§ 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…\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, and operator must define each of the following:\n(5) The roles, responsibilities and qualifications of others who have authority to\ndirect or supersede the specific technical actions of controllers.\nSpire's CRM Plan was inadequate because, while Section 4.2 identified that the Manager\nof Gas Control could Supersede and/or Direct the the technical actions of a controller, the\nprocedure did not define the qualifications or requirements of this individual holding the\ntitle, as required by § 195.446(b)(5). It also identified a Director of Gas Ops & Control,\nwhich is no longer a role in the control room.\n6\n\n\n\n8. 9. Additionally, the procedure did not include the responsibilities of those authorized to\ndirect or supersede the technical actions or a controller to implement their authority and\ndocument the event.\nThe procedure must be amended to include the qualification elements for those\nauthorized to direct or supersede the technical actions of a controller that are sufficient\nfor those individuals to understand the implications of the scope of potential actions. It\nmust also include the responsibilities of those authorized to direct or supersede the\ntechnical actions or a controller to implement their authority and document the event.\n§ 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…\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) Implement API RP 1165 (incorporated by reference, see § 195.4) whenever a\nSCADA system is added, expanded or replaced, unless the operator demonstrates\nthat certain provisions of API RP 1165 are not practical for the SCADA system\nused;\nSpire’s CRM Plan was inadequate because section 5.2 of the CRM Plan did not provide\ndefinitions or examples of what constitutes “added,” “expanded,” or “replaced” to\ndetermine when API RP 1165 must be implemented per § 195.446(c)(1). The console\nwas originally set up for gas transmission, and then the hazardous liquid system was\nadded. While the gas transmission control room did not have to fully implement API RP\n1165 when the liquid was brought over and into the console control room, full\nimplementation was required.\nAdditionally, Spire did not have a procedure to verify that API RP 1165 had been\nimplemented or to maintain compliance for new screens or points added.\nThe procedure needs to be amended to include definitions and examples, as well as a\nprocess to audit current screens and new or modified screens going forward.\n§ 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\n7\n\n\n\n10. appropriate, with the operator’s written procedures required by § 195.402…\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\naffect pipeline safety are made to field equipment or SCADA displays;\nSpire's CRM Plan was inadequate to support conducting a thorough point-to-point\nverification required by § 195.446(c)(2). Section 5.3 of the CRM plan references SOP #2\nfor \"the procedure for the point-to-point verification and full documentation of all point-\nto-point verification.” SOP #2 provided some high-level directions on how to complete a\nPoint-to-Point in the Clear SCADA system. It directed to use form GC002 if \"[t]he Point\nto Point functionality does not work in Clear SCADA.\" The SOP also provided\ninstruction in the event verification of a point failed. However, there was no requirement\nto document the failure other than to indicate NA or report to the Manager of Gas\nControl. It did not include a procedure to perform a successful verification after the issue\nis resolved.\nSOP #2 procedure directs the controller to open the P2P file in SCADA and enter the\nvalue or condition provided by the field operator. SCADA auto populates the SCADA\nvalue. A records review identified that auto populated value or condition was different, at\ntimes, than what the field indicated. Verification should provide the same result between\nthe field and SCADA. The procedure also requires a field operator to set up an alarm\ncondition and then the controller is directed to document the alarm description and if the\nalarm is received. However, the set point when the alarm is triggered was not required, nor\nthe alarm priority or any other alarm properties. The SOP procedure required checking\n\"all points on SCADA screens for any given station.\" However, there is no instruction for\nhow to identify all the screens or document they were checked.\nThe procedure needs to be amended to provide more instruction to support a more\nthorough verification and documentation of point-to-point checks.\n§ 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…\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:\n8\n\n\n\n11. (4) Test any backup SCADA systems at least once each calendar year, but at\nintervals not to exceed 15 months…\nSpire’s CRM Plan was inadequate to verify a thorough test of the SCADA backup control\ncenter per § 195.446(c)(4). The process did not provide clear and complete guidance on\nthe steps to move to and return from the backup center. It did not provide instruction on\nwhat facility functions and equipment needed to be checked at the backup center as well\nas the function of SCADA screens, commands, alarms and digital and analog points. The\nprocedure did not include methods or tools to document the checks. The procedure also\ndid not include testing the function of the primary and secondary servers fail over for\nboth the control room and backup center.\nThe procedure needs to be amended to provide instructions to facilitate more thorough\ntesting of the backup control center and servers.\n§ 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…\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(1) Establish shift lengths and schedule rotations that provide controllers off-duty\ntime sufficient to achieve eight hours of continuous sleep;\nSpire’s CRM Plan was inadequate because it did not explain the different shift schedules\nor establish a process to track all hours of service for all qualified controllers as required\nin § 195.446(d)(1). Controllers are salaried and the schedules are geared toward ensuring\nthe controllers work the appropriate number of pay hours at the end of the year. The\ncontrol room manager approved the pay card/time sheets but did not track all actual hours\nworked, separately, for compliance with hours of service and the appropriate rest periods.\nAdditionally, the manager of the control room, a qualified controller, has not been\ntracking his hours of service.\nThe procedure needs to be amended to define all shift schedules for controllers and\ninclude a process to track all hours worked to manage operator defined hours of service\nand related rest periods.\n9\n\n\n\n12. 13. § 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…\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(1) Review SCADA safety-related alarm operations using a process that ensures\nalarms are accurate and support safe pipeline operations;\nSpire's CRM Plan failed include a process that defines safety related points to ensure\nalarms are accurate to support safe pipeline operations as required by\n§ 195.446(e)(1). Section 7.2 of the procedure identified all pressures and odorizers (for\ngas only) as safety related points. However, the procedure identified Hi and HiHi\npressures, Lo and LoLo pressures, pressure rate of change (ROC) and odorizer pump\nfailure as safety related alarms. Pump failure is considered a Priority 2 high priority\nsafety related alarm, as identified in section 7.3 (example for a Priority 2 alarm). A\nreview of the SCADA Master Data Base identified Calculated Digital Points on Spire\nSTL for Valve Status, and Gas Detect as Safety Related. The SCADA Master Data Base\nfor Spire NGL Analog Calculated Points identified that a Rate of Change (ROC)\ndesignator was not safety related. These points were not defined in the procedure.\nSpire’s definition of safety related alarms provides consideration for other conditions in\npipeline operations that were not considered in the procedure. Examples of these alarm\nconditions not identified in the procedure include communications failure, fire detect,\natmosphere, and ESD.\nThe procedure must be amended to include a process for considering all conditions that\ncould be safety related and include them in the procedure.\n§ 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…\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(1) Review SCADA safety-related alarm operations using a process that ensures\nalarms are accurate and support safe pipeline operations;\n10\n\n\n\n14. Spire’s CRM Plan was inadequate because it did not provide a sustainable process to\nreview safety-related alarm operations to ensure alarms are accurate and support safe\npipeline operations as required by § 195.446(e)(1).\nSection 7.3 of the plan provided direction for controllers to verbally communicate or mail\nthe control room leadership or SCADA support when they identified inaccurate,\nmalfunctioning, stale, or unreliable alarms or data. The procedure assumes action is\ntaken to correct these alarm and data deficiencies. The procedure does not offer guidance\non documenting these messages, who is responsible to follow up, or how the issues will\nbe tracked through correction.\nSection 195.446(e)(6) requires the operator to address deficiencies identified through the\nimplementation of paragraphs (e)(1) – (e)(6). Without a method and process to track\nidentified alarm and data issues, the operator cannot confirm and ensure alarms are\naccurate and support safe pipeline operations.\nThe procedure needs to be amended to provide a process for identifying, documenting,\ncorrecting, and reviewing safety-related alarm operations to ensure alarms are accurate\nand support safe pipeline operations.\n§ 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…\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(2) Identify at least once each calendar month points affecting safety that have been\ntaken off scan in the SCADA host, have had alarms inhibited, generated false\nalarms, or that have had forced or manual values for period of time exceeding that\nrequired for associated maintenance or operating activities;\nSpire's CRM Plan was inadequate because it did not provide sufficient provisions for\nperforming a thorough review, at least once each month of points taken off scan, alarms\ninhibited, placed in forced or manual and false alarms, as required by § 195.446(e)(2).\nMissing information was the date the point was taken off-scan, inhibited or forced or\nmanual to determine how long the point has been altered from normal. False alarms were\nreviewed and addressed on an individual basis, but there was no procedure requirement\nfor summary and evaluation of points that may be recurring false alarms. There was also\nno procedure for identifying, reporting, or documenting false alarms.\n11\n\n\n\n15. 16. Spire reviewed each month the top 10 alarms to reduce nuisance alarms. The procedure\ndescribed “working with the SCADA group and controllers as necessary.” There were no\nother details as to which alarms got assigned, how they were assigned, or expectations for\nfollow-up or tracking.\nThe operator needs to amend the procedure to include more details to determine if\nthe time a point was taken off-scan, inhibited or placed in forced/manual exceeded that\nrequired for associated maintenance or operating activities. The procedure also needs to\ninclude a process for identifying, reporting, and evaluating false alarms. The current\nalarm review practice for all alarm reviews being conducted monthly with criteria for\nreview, follow-up, and documentation must be included in the amended process.\n§ 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…\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(3) Verify the correct safety-related alarm set-point values and alarm descriptions\nwhen associated field instruments are calibrated or changed and at least once each\ncalendar year, but at intervals not to exceed 15 months;\nSpire’s CRM Plan was inadequate because it did not address the requirement to verify the\ncorrect alarm set point values and descriptions when field instruments are calibrated or\nchange as required by section § 195.446 (e)(3). Section 7.4 of the CRM Plan only covered\nthe requirement for annual review of safety related alarm set points and descriptions, but\ndid not address the requirement when field instruments are calibrated or changed.\nThe procedure must be amended to include the requirement to verify the correct alarm set\npoint values and descriptions when field instruments are calibrated or changed, as well as\nonce each calendar year not to exceed 15 months.\n§ 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…\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\n12\n\n\n\n17. operator’s plan must include provisions to:\n(4) Review the alarm management plan required by this paragraph at least once\neach calendar year, but at intervals not exceeding 15 months, to determine the\neffectiveness of the plan;\nSpire's CRM Plan to review the alarm management plan to determine effectiveness, as\nrequired by § 195.446(e)(4), was inadequate. The procedure in section 7.5 was very high\nlevel and described forming a committee to incorporate historical and current operating\nissues and incidents or near misses that could be addressed by adjusting the plan.\nThe plan established two metrics: average alarms per hour – 6 or fewer, and maximum\nalarms per 10-minute period – 5 or fewer. It states: “These guidelines allow controllers to\nrespond to appropriate events.\" The plan also stated it would review historical and current\noperating issues and incidents or near misses that could be addressed by adjusting the plan.\nWhat the operator would glean from this information and how it would be used to\ndetermine effectiveness of the Alarm Management Plan was not stated. The operator did\nnot define the criteria for determining effectiveness of the Alarm Management Plan.\nTherefore, the procedure needs to be amended.\n§ 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…\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\nrequired of each controller at least once each calendar year, but at intervals not\nexceeding 15 months, that will assure controllers have sufficient time to analyze and\nreact to incoming alarms…\nSpire's CRM Plan was not adequate because it did not provide the content and volume of\ngeneral activities tasked to the controller to assure controllers have sufficient time to\nanalyze and react to incoming alarms, as required by § 195.446(e)(5). The procedure did\nnot provide a criterion to define sufficient time nor the process to collectively evaluate\nthe activities identified.\nThe procedure needs to be amended to identify the content and volume of general\nactivities tasked to the controller, the shift periods that will be evaluated, process used to\nevaluate the activities, and the criteria used to assure the controller has sufficient time to\nanalyze and react to incoming alarms.\n13\n\n\n\n18. 19. § 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…\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(1) Implement section 7 of API RP 1168 (incorporated by reference, see § 195.3) for\ncontrol room management change and require coordination between control room\nrepresentatives, operator’s ma","truncated":true,"body_characters":51308}