# SPIRE MISSOURI INC. EAST — Notice of Amendment

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

Official case documents:

32022034NOA_Closure Letter_08152023_(21-203212).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022034NOA/32022034NOA_Closure%20Letter_08152023_(21-203212).pdf

32022034NOA_Closure Letter_08152023_(21-203212)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022034NOA/32022034NOA_Closure%20Letter_08152023_(21-203212)_text.pdf

32022034NOA_Notice of Amendment_02252022_(21-203212).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022034NOA/32022034NOA_Notice%20of%20Amendment_02252022_(21-203212).pdf

32022034NOA_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

32022034NOA_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

32022034NOA_Notice of Amendment_02252022_(21-203212)_text.pdf

NOTICE OF AMENDMENT
VIA ELECTRONIC MAIL TO: craig.hoeferlin@spireenergy.com and
Bob.Gardner@spireenergy.com
February 25, 2022
Mr. Craig Hoeferlin
Vice President, Operations Services and SMS
Spire Missouri Inc. East
700 Market Street
St. Louis, Missouri 63101
CPF 3-2022-034-NOA
Dear Mr. Hoeferlin:
From May 17 to May 23, 2021, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected remotely
SPIRE STL (Spire or Spire STL) and SPIRE NGL (Spire or Spire NLG) procedures for Control
Room Management in St. Louis, Missouri.
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
Spire’s plans or procedures, as described below:



1. 2. § 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
Spire CRM Procedure Revision 1.4 3/15/2021 (Spire’s CRM Plan) was inadequate
because it did not have a procedure for determining a control room. Spire offered a
statement in Section 1.2, Application and Scope, that states “the plan applies to any Spire
employee working in a Control Room who monitors and controls all or part of the assets
listed in section 1.1 through a SCADA system." These assets were Spire STL and Spire
NGL. Spire NGL OPID 11032 included an underground storage field that maintains an
operator control center to monitor and manage the storage field. Spire STL OPID 39886
had transmission stations with PLC or RTU's that may or may not have been able to
manage the flow of gas outside the fence by an individual through manipulating the
PLC. These assets were part of both pipelines. Therefore, if they were operated
independently, outside of the Control Room direction, they would become control rooms
and the individuals would need to be qualified as controllers.
Spire needs to amend their procedure to equitably evaluate all such facilities to determine
if it is a control room and falls under the requirements for Control Room Management.
§ 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…
(b) Roles and responsibilities. Each operator must define the roles and
responsibilities of a controller during normal, abnormal, and emergency operating
conditions…
Spire’s CRM Plan was inadequate because the procedure did not define the controller’s
domain of responsibility required by § 195.446(b) as they related to third party operators
critical to pipeline operations. Section 1.2 of the CRM Plan identified Spire STL and
Spire NGL as the assets being monitored and controlled by the control room. Integral to
the pipeline operations are third party operators Phillips at the Hartford Terminal and
Conoco-Phillips East Terminal. These third-party terminals function as a holding/storage
facilities and product is directed to and from these facilities by the Spire controllers.
Additionally, the Catalan Propane Plant (propane vaporization) is connected to the
pipeline and direction for vaporization comes from the Utility. The controller’s physical
2



3. domain is not well defined, and the controller’s roles and responsibilities related to these
third-party assets and how the controller interacts and directs the pipeline operations to
and from these facilities. Furthermore, there was no reference to the Spire STL system
operated on the same console.
The procedure needs to be amended to provide clear roles and responsibilities related to
these facilities as well as include the assets of Spire STL into the CRM Plan.
§ 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…
(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, and operator must define each of the following:
(2) A controller’s role when an abnormal operating condition is detected, even if the
controller is not the first to detect the condition, including the controller’s
responsibility to take specific actions and to communicate with others;
Spire’s CRM Plan was not adequate to define the controller's role when an abnormal
operating condition was detected, even if the controller was not the first to detect the
condition, including the controller's responsibility to take specific actions and to
communicate with others as required by § 195.446(b)(2). Section 4.3.2 of the CRM Plan
addressed Abnormal Operating Conditions roles, responsibilities, and authority for
controllers when an abnormal condition was detected either by the controller or from
another source (field/public). The procedure references SOP #12 which was incorrect. It
should have been SOP #10, Abnormal Condition Report, which gave direction on when
and how to fill out the report, how the report got distributed, as well as when to elevate
information to higher levels within the organization.
The procedure and SOP did not provide details when the controllers should log into their
logbook and what they should record during an Abnormal Operation (AO) event. The
operator identified this as an expectation of controllers, but it is not covered in
procedure. There was no requirement for supervisory review of AO, nor a timeline for
such a review once a controller completed the form described in SOP #10. There was no
detail of who determines the cause or whether further action was required to prevent
recurrence.
Additionally, Step 7 of the SOP required the controller to self-report if the controller or
control room contributed to the AO. If the answer is “yes”, the system will prompt a
review of the controller's fatigue level by the Manager of Gas Control using form
3



4. GC006. Depending upon an individual to self-report is not adequate. An independent
review of AO needs to be completed to determine if the controller's actions contributed.
The procedure needs to be amended to define the controller's role when an abnormal
operating condition was detected, even if the controller was not the first to detect the
condition, including the controller's responsibility to take specific actions and to
communicate with others.
§ 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…
(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, and 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;
Spire’s CRM Plan was not adequate because it did not define the controllers' authority
and responsibility to make decisions, take actions, and communicate with others upon
being notified of, upon detection of, and during an emergency or if a leak or rupture is
suspected, as required by § 195.446(b)(3). Section 4.3.3 of the CRM Plan did not address
the Spire NGL system in an emergency. The procedure only described actions for Spire
STL emergencies, such as referencing the Spire STL Pipeline Emergency Plan and
Procedure and the Spire STL Pipeline Emergency Call Checklist.
The procedure also referenced SOP #12, which was incorrect. It should have been SOP
#8, Emergency Procedures HVL. This procedure was a partial cut and paste from the
Laclede Pipeline emergency procedure. This procedure described the role of the Gas
Control Supervisor, which was not a role in the Control Room. There was a section that
appeared to be related to underground storage emergencies that directed persons to
contact central dispatching or the control room. There was also SOP #17, UGS Propane
System Emergency Shutdown (ESD), which provided 4 steps for the controller to shut
down the system via ESD. This SOP was not referenced in the Emergency Plan section
4.3.3. Also, there were no steps for communicating or documenting this event.
The procedure needs to be amended to include the controllers' authority and
responsibility to make decisions, take actions, and communicate with others upon being
notified of, upon detection of, and during an emergency or if a leak or rupture is
suspected. This must include both Spire STL and Spire NGL.
4



5. 6. § 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…
(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, and 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;
Spire’s CRM Plan was not adequate to address the controller's responsibilities in the
event of an emergency per § 195.446(b)(3) for when the control room must be evacuated.
Section 4.3.3 authorized the controller to "start the process of moving primary control
room operations to Backup Control Room” which then referenced SOP #6, Move
Primary Operation to the Backup Control Center. The procedure failed to provide the
steps to be taken "if an evacuation of the primary control room, or the building housing
the primary control room triggers the use of this procedure.” There was unessential
information in the middle of the procedure that was not beneficial to supporting the
controller to move from the primary to the backup control center, and it ends incomplete
stating "if an evacuation of the primary control room, or the building housing the primary
control room triggers the use of this procedure, the following steps should be
taken." Additionally, it was not clear if an evacuation of the control room always
resulted in moving to the backup control center or a temporary move to a safe location for
a short period of time.
The procedure needs to be amended to address the controller's responsibilities in the
event the control room must be evacuated. Some considerations may include factors for
determining the need to evacuate, who makes the decision to evacuate and relocate to the
backup control center, how is this communicated, and how internal communications are
managed during the relocation.
§ 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. . . .
(b) Roles and responsibilities. Each operator must define the roles and
5



7. responsibilities of a controller during normal, abnormal, and emergency operating
conditions. To provide for a controller’s prompt and appropriate response to
operating conditions, and operator must define each of the following:
(4) A method for recording controller shift-changes and any hand-over of
responsibility between controllers…
Spire’s CRM Plan was inadequate because the procedure in Section 5.6 did not
adequately define the roles and responsibilities of a controller before leaving the console
for any reason, as required per § 195.446(b)(4). Spire, when fully staffed, had a fully
qualified controller available 24/7 to assist if a controller must step away from the
console. Section 5.6 states: “If taking over for less than 30 minutes this can be done by
adding a note in the operator logbook located in Clear SCADA. It must consist of the
employee number of the controller taking over, along with the date/time. When the
controller on duty returns, they must enter a note with their employee number and the
date/time they resumed control of the pipeline." The procedure does not mention what is
required for the hand-over of responsibility before the controller leaves the console, for
example: no unacknowledged, high priority, or safety related alarms in place, whether set
points/commands sent must be completed, or whether verbal commands to field
personnel are acknowledged. It also did not define the role and responsibilities of the
person left to monitor the system when limited shift change had occurred. For example,
should the person only monitor the system, take total control of the system, answer
phones, call the absent controller if alarms present, etc.
The procedure needs to be amended to provide the roles and responsibilities of the
controllers before leaving the console for any reason.
§ 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…
(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, and operator must define each of the following:
(5) The roles, responsibilities and qualifications of others who have authority to
direct or supersede the specific technical actions of controllers.
Spire's CRM Plan was inadequate because, while Section 4.2 identified that the Manager
of Gas Control could Supersede and/or Direct the the technical actions of a controller, the
procedure did not define the qualifications or requirements of this individual holding the
title, as required by § 195.446(b)(5). It also identified a Director of Gas Ops & Control,
which is no longer a role in the control room.
6



8. 9. Additionally, the procedure did not include the responsibilities of those authorized to
direct or supersede the technical actions or a controller to implement their authority and
document the event.
The procedure must be amended to include the qualification elements for those
authorized to direct or supersede the technical actions of a controller that are sufficient
for those individuals to understand the implications of the scope of potential actions. It
must also include the responsibilities of those authorized to direct or supersede the
technical actions or a controller to implement their authority and document the event.
§ 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…
(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:
(1) Implement API RP 1165 (incorporated by reference, see § 195.4) whenever a
SCADA system is added, expanded or replaced, unless the operator demonstrates
that certain provisions of API RP 1165 are not practical for the SCADA system
used;
Spire’s CRM Plan was inadequate because section 5.2 of the CRM Plan did not provide
definitions or examples of what constitutes “added,” “expanded,” or “replaced” to
determine when API RP 1165 must be implemented per § 195.446(c)(1). The console
was originally set up for gas transmission, and then the hazardous liquid system was
added. While the gas transmission control room did not have to fully implement API RP
1165 when the liquid was brought over and into the console control room, full
implementation was required.
Additionally, Spire did not have a procedure to verify that API RP 1165 had been
implemented or to maintain compliance for new screens or points added.
The procedure needs to be amended to include definitions and examples, as well as a
process to audit current screens and new or modified screens going forward.
§ 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
7



10. appropriate, with the operator’s written procedures required by § 195.402…
(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
affect pipeline safety are made to field equipment or SCADA displays;
Spire's CRM Plan was inadequate to support conducting a thorough point-to-point
verification required by § 195.446(c)(2). Section 5.3 of the CRM plan references SOP #2
for "the procedure for the point-to-point verification and full documentation of all point-
to-point verification.” SOP #2 provided some high-level directions on how to complete a
Point-to-Point in the Clear SCADA system. It directed to use form GC002 if "[t]he Point
to Point functionality does not work in Clear SCADA." The SOP also provided
instruction in the event verification of a point failed. However, there was no requirement
to document the failure other than to indicate NA or report to the Manager of Gas
Control. It did not include a procedure to perform a successful verification after the issue
is resolved.
SOP #2 procedure directs the controller to open the P2P file in SCADA and enter the
value or condition provided by the field operator. SCADA auto populates the SCADA
value. A records review identified that auto populated value or condition was different, at
times, than what the field indicated. Verification should provide the same result between
the field and SCADA. The procedure also requires a field operator to set up an alarm
condition and then the controller is directed to document the alarm description and if the
alarm is received. However, the set point when the alarm is triggered was not required, nor
the alarm priority or any other alarm properties. The SOP procedure required checking
"all points on SCADA screens for any given station." However, there is no instruction for
how to identify all the screens or document they were checked.
The procedure needs to be amended to provide more instruction to support a more
thorough verification and documentation of point-to-point checks.
§ 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…
(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:
8



11. (4) Test any backup SCADA systems at least once each calendar year, but at
intervals not to exceed 15 months…
Spire’s CRM Plan was inadequate to verify a thorough test of the SCADA backup control
center per § 195.446(c)(4). The process did not provide clear and complete guidance on
the steps to move to and return from the backup center. It did not provide instruction on
what facility functions and equipment needed to be checked at the backup center as well
as the function of SCADA screens, commands, alarms and digital and analog points. The
procedure did not include methods or tools to document the checks. The procedure also
did not include testing the function of the primary and secondary servers fail over for
both the control room and backup center.
The procedure needs to be amended to provide instructions to facilitate more thorough
testing of the backup control center and servers.
§ 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…
(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:
(1) Establish shift lengths and schedule rotations that provide controllers off-duty
time sufficient to achieve eight hours of continuous sleep;
Spire’s CRM Plan was inadequate because it did not explain the different shift schedules
or establish a process to track all hours of service for all qualified controllers as required
in § 195.446(d)(1). Controllers are salaried and the schedules are geared toward ensuring
the controllers work the appropriate number of pay hours at the end of the year. The
control room manager approved the pay card/time sheets but did not track all actual hours
worked, separately, for compliance with hours of service and the appropriate rest periods.
Additionally, the manager of the control room, a qualified controller, has not been
tracking his hours of service.
The procedure needs to be amended to define all shift schedules for controllers and
include a process to track all hours worked to manage operator defined hours of service
and related rest periods.
9



12. 13. § 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…
(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) Review SCADA safety-related alarm operations using a process that ensures
alarms are accurate and support safe pipeline operations;
Spire's CRM Plan failed include a process that defines safety related points to ensure
alarms are accurate to support safe pipeline operations as required by
§ 195.446(e)(1). Section 7.2 of the procedure identified all pressures and odorizers (for
gas only) as safety related points. However, the procedure identified Hi and HiHi
pressures, Lo and LoLo pressures, pressure rate of change (ROC) and odorizer pump
failure as safety related alarms. Pump failure is considered a Priority 2 high priority
safety related alarm, as identified in section 7.3 (example for a Priority 2 alarm). A
review of the SCADA Master Data Base identified Calculated Digital Points on Spire
STL for Valve Status, and Gas Detect as Safety Related. The SCADA Master Data Base
for Spire NGL Analog Calculated Points identified that a Rate of Change (ROC)
designator was not safety related. These points were not defined in the procedure.
Spire’s definition of safety related alarms provides consideration for other conditions in
pipeline operations that were not considered in the procedure. Examples of these alarm
conditions not identified in the procedure include communications failure, fire detect,
atmosphere, and ESD.
The procedure must be amended to include a process for considering all conditions that
could be safety related and include them in the procedure.
§ 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…
(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) Review SCADA safety-related alarm operations using a process that ensures
alarms are accurate and support safe pipeline operations;
10



14. Spire’s CRM Plan was inadequate because it did not provide a sustainable process to
review safety-related alarm operations to ensure alarms are accurate and support safe
pipeline operations as required by § 195.446(e)(1).
Section 7.3 of the plan provided direction for controllers to verbally communicate or mail
the control room leadership or SCADA support when they identified inaccurate,
malfunctioning, stale, or unreliable alarms or data. The procedure assumes action is
taken to correct these alarm and data deficiencies. The procedure does not offer guidance
on documenting these messages, who is responsible to follow up, or how the issues will
be tracked through correction.
Section 195.446(e)(6) requires the operator to address deficiencies identified through the
implementation of paragraphs (e)(1) – (e)(6). Without a method and process to track
identified alarm and data issues, the operator cannot confirm and ensure alarms are
accurate and support safe pipeline operations.
The procedure needs to be amended to provide a process for identifying, documenting,
correcting, and reviewing safety-related alarm operations to ensure alarms are accurate
and support safe pipeline operations.
§ 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…
(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:
(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
alarms, or that have had forced or manual values for period of time exceeding that
required for associated maintenance or operating activities;
Spire's CRM Plan was inadequate because it did not provide sufficient provisions for
performing a thorough review, at least once each month of points taken off scan, alarms
inhibited, placed in forced or manual and false alarms, as required by § 195.446(e)(2).
Missing information was the date the point was taken off-scan, inhibited or forced or
manual to determine how long the point has been altered from normal. False alarms were
reviewed and addressed on an individual basis, but there was no procedure requirement
for summary and evaluation of points that may be recurring false alarms. There was also
no procedure for identifying, reporting, or documenting false alarms.
11



15. 16. Spire reviewed each month the top 10 alarms to reduce nuisance alarms. The procedure
described “working with the SCADA group and controllers as necessary.” There were no
other details as to which alarms got assigned, how they were assigned, or expectations for
follow-up or tracking.
The operator needs to amend the procedure to include more details to determine if
the time a point was taken off-scan, inhibited or placed in forced/manual exceeded that
required for associated maintenance or operating activities. The procedure also needs to
include a process for identifying, reporting, and evaluating false alarms. The current
alarm review practice for all alarm reviews being conducted monthly with criteria for
review, follow-up, and documentation must be included in the amended process.
§ 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…
(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:
(3) Verify the correct safety-related alarm set-point values and alarm descriptions
when associated field instruments are calibrated or changed and at least once each
calendar year, but at intervals not to exceed 15 months;
Spire’s CRM Plan was inadequate because it did not address the requirement to verify the
correct alarm set point values and descriptions when field instruments are calibrated or
change as required by section § 195.446 (e)(3). Section 7.4 of the CRM Plan only covered
the requirement for annual review of safety related alarm set points and descriptions, but
did not address the requirement when field instruments are calibrated or changed.
The procedure must be amended to include the requirement to verify the correct alarm set
point values and descriptions when field instruments are calibrated or changed, as well as
once each calendar year not to exceed 15 months.
§ 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…
(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
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17. 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;
Spire's CRM Plan to review the alarm management plan to determine effectiveness, as
required by § 195.446(e)(4), was inadequate. The procedure in section 7.5 was very high
level and described forming a committee to incorporate historical and current operating
issues and incidents or near misses that could be addressed by adjusting the plan.
The plan established two metrics: average alarms per hour – 6 or fewer, and maximum
alarms per 10-minute period – 5 or fewer. It states: “These guidelines allow controllers to
respond to appropriate events." The plan also stated it would review historical and current
operating issues and incidents or near misses that could be addressed by adjusting the plan.
What the operator would glean from this information and how it would be used to
determine effectiveness of the Alarm Management Plan was not stated. The operator did
not define the criteria for determining effectiveness of the Alarm Management Plan.
Therefore, the procedure needs to be amended.
§ 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…
(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…
Spire's CRM Plan was not adequate because it did not provide the content and volume of
general activities tasked to the controller to assure controllers have sufficient time to
analyze and react to incoming alarms, as required by § 195.446(e)(5). The procedure did
not provide a criterion to define sufficient time nor the process to collectively evaluate
the activities identified.
The procedure needs to be amended to identify the content and volume of general
activities tasked to the controller, the shift periods that will be evaluated, process used to
evaluate the activities, and the criteria used to assure the controller has sufficient time to
analyze and react to incoming alarms.
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18. 19. § 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…
(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:
(1) Implement section 7 of API RP 1168 (incorporated by reference, see § 195.3) for
control room management change and require coordination between control room
representatives, operator’s ma
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