{"operation":"document","citation":"CPF 32022044NOA","title":"SOUTHERN STAR CENTRAL GAS PIPELINE, INC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-04-28","effective_on":null,"summary":"CLOSED notice of amendment citing 192.631(a)(1), 192.631(b)(4), 192.631(b)(5), 192.631(c)(1), 192.631(c)(2), 192.631(c)(3), 192.631(d)(2), 192.631(d)(3), 192.631(e)(2), 192.631(e)(3), 192.631(e)(5), 192.631(e)(6), 192.631(f)(1), 192.631(f)(2), 192.631(f)(3), 192.631(g)(1)(i), 192.631(h).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32022044noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32022044noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32022044noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32022044NOA","body":"Notice of Amendment involving SOUTHERN STAR CENTRAL GAS PIPELINE, INC. PHMSA's enforcement data identifies the cited regulations as 192.631(a)(1),  192.631(b)(4),  192.631(b)(5),  192.631(c)(1),  192.631(c)(2),  192.631(c)(3),  192.631(d)(2),  192.631(d)(3),  192.631(e)(2),  192.631(e)(3),  192.631(e)(5),  192.631(e)(6),  192.631(f)(1),  192.631(f)(2),  192.631(f)(3),  192.631(g)(1)(i),  192.631(h). The case was opened on 2022-04-28 and is reported as closed as of 2023-01-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32022044NOA_Closure Letter_01102023_(21-201001).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022044NOA/32022044NOA_Closure%20Letter_01102023_(21-201001).pdf\n\n32022044NOA_Closure Letter_01102023_(21-201001)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022044NOA/32022044NOA_Closure%20Letter_01102023_(21-201001)_text.pdf\n\n32022044NOA_Notice of Amendment_04282022_(21-201001).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022044NOA/32022044NOA_Notice%20of%20Amendment_04282022_(21-201001).pdf\n\n32022044NOA_Notice of Amendment_04282022_(21-201001)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022044NOA/32022044NOA_Notice%20of%20Amendment_04282022_(21-201001)_text.pdf\n\n32022044NOA_Operator Response to Notice_05272022_(21-201001).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022044NOA/32022044NOA_Operator%20Response%20to%20Notice_05272022_(21-201001).pdf\n\n32022044NOA_Closure Letter_01102023_(21-201001)_text.pdf\n\nVIA ELECTRONIC MAIL TO: shawn.patterson@southernstar.com and\ncraig.thomas@southernstar.com\nJanuary 10, 2023\nMr. Shawn L. Patterson\nPresident and Chief Executive Officer\nSouthern Star Central Gas Pipeline, Inc.\n4700 State Route 56\nBox 20010\nOwensboro, KY 42301\nRe: CPF 3-2022-044-NOA\nDear Mr Patterson:\nFrom October 18 to November 8, 2021, a representative from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,\nconducted a remote pipeline safety inspection of Southern Star Central Gas Pipeline, Inc’s\n(Southern Star) Control Room Management procedures in Owensboro, Kentucky. As a result of\nthe inspection, Southern Star was issued a Notice of Amendment on April 28, 2022, which\nproposed amendment of your procedures.\nSouthern Star submitted its amended procedures on November 15, 2022. My staff reviewed the\namended procedures, and it appears that the inadequacies outlined in this Notice of Amendment\nhave been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nGregory A. Ochs\nDirector, Central Region OPS\nPipeline and Hazardous Materials Safety Administration\n\n32022044NOA_Notice of Amendment_04282022_(21-201001)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: jimmy.staton@southernstar.com and craig.thomas@southernstar.com\nApril 28, 2022\nMr. Jimmy Staton\nPresident/CEO\nSouthern Star Central Gas Pipeline, Inc.\n4700 State Route 56\nBox 20010\nOwensboro, KY 42301\nCPF 3-2022-044 NOA\nDear Mr. Staton:\nFrom October 18 to November 8, 2021, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected\nSouthern Star Central Gas Pipeline, Inc’s (Southern Star) Control Room Management (CRM)\nprocedures and records in Owensboro, Kentucky.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nSouthern Star’s plans or procedures, as described below:\n1. § 192.631 Control room management.\n(a) General.\n(1) This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline facility\nthrough a SCADA system. Each operator must have and follow written control room\nmanagement procedures that implement the requirements of this section…\nSouthern Star’s CRM Procedure was inadequate to provide a process for determination of a\ncontrol room. Procedure 40.18.00.08, Control Room, and SCADA Access Policy Procedure\nSection 2.1.2 stated, “No other control rooms exist on the pipeline that are able to send remote\ncommands to control field equipment, acknowledge alarms alerting individuals of certain\n\n\n\nconditions, or any other type of control room actions as defined under SSCGP procedure\n40.01.01, ‘Roles and Responsibilities During Normal Operations,’ or 40.01.02, ‘Roles and\nResponsibilities During Abnormal/Emergency Operations.’” While the operator provided criteria\nfor control room determination, they did not provide a process to assess current and new\nfacilities.\nThe procedure must be amended to include a process and criteria to consistently determine if the\nfacility is capable of independently controlling and monitoring assets rendering the facility a\ncontrol room.\n2. § 192.631 Control room management.\n(a) General.\n(1) This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline\nfacility through a SCADA system. Each operator must have and follow written\ncontrol room management procedures that implement the requirements of this\nsection 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, an operator must define each of the following:\nSouthern Star’s CRM procedure was inadequate because it did not define Primary Controller and\nSecondary Controller positions. It also did not define the independent roles and responsibilities\nof these positions when they are operating on the same shift and on different consoles as required\nby § 192.631(b). There was a lack of definition for the role of Primary and Secondary during\nshift change. Procedure 40.01.01 identified various tasks performed by the controllers and stated\n\"[W]hen multiple controllers are on the console, one (1) controller shall be responsible for this\ntask.\" It also stated, \"[A]ll tasks can be performed from any of the three consoles[.]\" Section\n6.1 of Procedure 40.14.01 also mentioned a secondary controller and \"lead controller\nrole.\" Since there were three consoles in the control room, and all consoles had identical\ncapabilities, the procedure did not disallow anyone outside the Primary Controller to operate,\nmonitor, and take action on the system. It is unclear if the Secondary Controller could send set\npoints, acknowledge alarms or coordinate with field personnel. If the Second Controller has\nsuch authority, it was not clear when this was allowed.\nThe procedure needs to be amended to define the various controller levels and their related roles,\nresponsibilities and authority when two controllers are on shift at independent consoles.\n3. § 192.631 Control room management.\n(a) General.\n(1) This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline\nfacility through a SCADA system. Each operator must have and follow written\ncontrol room management procedures that implement the requirements of this\nsection…\n2\n\n\n\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, an operator must define each of the following:\n(1) ….\n(4) A method of recording controller shift-changes and any hand-over of\nresponsibility between controllers;\nSouthern Star’s procedure 40.11.01.15 was inadequate in providing a method of recording shift-\nchanges as required per §192.631(b)(4). While the procedure provided an extensive list of items\nto discuss during shift change, it did not provide instruction on how to consistently incorporate\nthe discussion points, from the procedure, into the shift change form. Also missing from the\nprocedure was the expectation of what was to be covered when the alarm box section on the\nform is checked, who was responsible to develop and prepare the shift change form, who was\nresponsible to receive the shift change, how abnormal operations were identified within the\nform, what is the meaning of the TRUE/FALSE and YES/NO identifiers, and when/how a\nnotation was taken off the form. Where information did not fit within the categories specified on\nthe form, the procedure did not explain how to enter it. For example, weather forecasts, SCADA\ncommunication concerns, pigging and third-party incidents.\nThe procedure needs to be amended to provide a method of recording shift changes with\ninstruction to consistently incorporate the discussion points from the procedure.\n4. § 192.631 Control room management\n(a) General.\n(1) This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline\nfacility through a SCADA system. Each operator must have and follow written\ncontrol room management procedures that implement the requirements of this\nsection…\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, an operator must define each of the following:\n(5) The roles, responsibilities and qualifications of others with the authority to\ndirect or supersede the specific technical actions of a controller.\nSouthern Star’s procedures were inadequate to define the roles, responsibilities and qualifications\nof others with the authority to direct or supersede the specific technical actions of a controller as\nrequired by §192.631(b)(5).\nThe operator’s procedure Section 1.3 of policy 40.01.00.02 stated, “[Q]ualified control room\nsupervision and management can invoke the authority to direct or supersede the specific\ntechnical actions of a controller in control of the pipeline.” Procedure 40.01.01.15 stated in a\nnote box, “[O]perator gas qualified Gas Control leadership (Manager/Leader) has the authority to\nsupersede a controller.” The qualification is not specific, but assumed to be controller\nqualified. Missing from the procedure was definitions for supersede and direct. These words\n3\n\n\n\nwere used synonymously, but while similar are not equal. Additionally, the training documents\nfor this issue stated, \"[S]outhern Star has determined that the only people who have the authority\nto tell a gas controller what he must do are themselves, OQ (operationally qualified)\ncontrollers.\" This conflicts with procedures. This was substantiated during the controller\ninterview, when the controller responded to the question, \"Who can direct or supersede a\ncontroller?\" with, \"any qualified controller can supersede or direct another controller.\"\nThe procedure did not provide the conditions of how and when a person with supersede authority\nimplements their authority. The procedure described actions for the controller when the\nsuperseder individual intervened: \"[I]f an individual with Supersede authority directs a\ncontroller’s actions the controller must fully understand the directive.” The procedure included\nwhat was to occur once the directive was given: “[I]f the controller does not understand or\ndisagrees with the directive and it becomes a Supersede event, the controller should note\nelectronically describing the Supersede event.\" The procedure left the documentation choice to\nthe controller, rather than prescribe how this event was to be documented for future inspection or\nreview.\nThe procedure needed to be amended to define the roles and responsibilities for those authorized\nto supersede the actions of a controller, as well as the controller when that occurs. Additionally,\nthe training needed to be amended to be consistent with the procedure.\nThe operator provided amendments to procedures that satisfactorily addressed the issues in this\nitem. Additionally, the training document was amended 01/25/2022 to be consistent with the\nprocedure regarding who can direct or supersede the technical actions of a controller. No further\naction required for this specific requirement.\n5. § 192.631 Control room management.\n(a) General.\n(1) This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline\nfacility through a SCADA system. Each operator must have and follow written\ncontrol room management procedures that implement the requirements of this\nsection…\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 sections 1, 4, 8, 9, 11.1 and 11.3 of API RP 1165 (incorporated by\nreference, see §192.7) whenever a SCADA system is added, expanded or replaced,\nunless the operator demonstrates that certain provisions of sections 1, 4, 8, 9, 11.1\nand 11.3 of API RP 1165 are not practical for the SCADA system used.\nSouthern Star’s procedure was inadequate because it did not define SCADA system additions,\nexpansions or replacements when the stated sections of API 1165 must be implemented as\nrequired by §192.631(c)(1).\n4\n\n\n\nProcedure 40.05.01.05 stated, “[A]ny SCADA system addition, expansion, or replacement\n(vendor change, acquisitions, or mergers) will require implementation of API RP 1165.\" Section\n6.1.2 of the procedure added, “[R] Routine upgrades, such as SCADA version upgrades, SCADA\nhardware changes, or any other SCADA system changes, will be verified that the\nscope of the SCADA change did not impact display parameters and does not require API 1165\nimplementation.” These examples were vague and broad based. For example, changing like for\nlike equipment for maintenance would require implementation of the required sections of API\n1165. Also, there was no process defined for verification of compliance with the required\nsections of API 1165.\nThe procedure needs to be amended to define SCADA system additions, expansions or\nreplacements with examples of each. Amendments to the procedure must also include the\nprocess to verify compliance with sections 1, 4, 8, 9, 11.1 and 11.3 of API 1165.\n6. § 192.631 Control room management.\n(a) General.\n(1) This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline\nfacility through a SCADA system. Each operator must have and follow written\ncontrol room management procedures that implement the requirements of this\nsection…\n(c) Provide adequate information. Each operator must provide its controllers and\nwith the information, tools, processes and procedures necessary for the controllers\nto carry out the roles and responsibilities the operator has defined by performing\neach of the following:\n(1) …\n(2) Conduct a point-to-point verification between SCADA displays and related\nfield equipment when field equipment is added or moved and when other changes\nthat affect pipeline safety are made to field equipment of SCADA displays;\nSouthern Star’s procedure 40.12.02.08 failed to provide a process to provide thorough point-to-\npoint verifications as required by §192.631(c)(2). Procedure 40.12.02.08 section 4.1.2 did not\naccount for verification of calculated points in SCADA. Instructions to complete the verification\nform were inadequate as evidenced by records review. The form utilized for documentation was\nnot complete. Missing were as-found/as-left, the field person was not identified, and verification\nof SCADA tag to end device was missing, as well as verification of all screens for points.\nSection 4.1.5 allowed the controllers to adjust the set point pressure to allow for an analogue\nvalue to cross the alarm threshold rather than test the set point at the established correct and\nverified set point value.\nThe procedure needs to be amended to include all safety related points including calculated\npoints as well as instructions to complete the form and additional verification and documentation\nrequirements. It also must disallow changing the set point value for testing purposes and test to\nthe established set point value in SCADA.\n5\n\n\n\n7. § 192.631 Control room management.\n(a) General.\n(1) This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline\nfacility through a SCADA system. Each operator must have and follow written\ncontrol room management procedures that implement the requirements of this\nsection…\n(c) Provide adequate information. Each operator must provide its controllers and\nwith the information, tools, processes and procedures necessary for the controllers\nto carry out the roles and responsibilities the operator has defined by performing\neach of the following:\n(1) ….\n(3) Test and verify an internal communication plan to provide adequate means of\nmanual operation of the pipeline safely, at least once each calendar year, but at\nintervals not to exceed 15 months.\nSouthern Star's procedure was inadequate because they did not have a detail plan that defines\ntheir practice when they test the manual operation of the pipeline during a SCADA\nfailure/outage. There was a document with all facilitates identified that is used to document and\ntrack flows and pressures on the system. This document is not referenced in the\nprocedure. Section 7.0 of Procedure 40.08.01.06 provided a detail test plan that is instructive for\ntesting.\nThe procedure needs to be amended to provide a detailed plan to manually operate the system\nsafely as well as a process to test the plan.\n8. § 192.631 Control room management.\n(a) General.\n(1) This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline\nfacility through a SCADA system. Each operator must have and follow written\ncontrol room management procedures that implement the requirements of this\nsection…\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) ….\n(2) Educate controllers and supervisors in fatigue mitigation strategies and how\noff-duty activities contribute to fatigue;\n(3) Train controllers and supervisors to recognize the effects of fatigue;\nSouthern Star’s procedures were inadequate because they did not proceduralize its practice of\nsupervisors completing periodic refresher fatigue education training every 36 months. There is\nalso additional fatigue training, completed by controllers, that is not being documented in the\noperator’s Learning Management System (LMS).\n6\n\n\n\nThe procedure needs to be amended to include the practice requirement of supervisor refresher\nfatigue training as well as to capture and record all fatigue training provided to controllers and\nsupervisors.\n9. § 192.631 Control room management.\n(a) General.\n(1) This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline\nfacility through a SCADA system. Each operator must have and follow written\ncontrol room management procedures that implement the requirements of this\nsection…\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) ….\n(6) Address deficiencies identified through the implementation of paragraphs (e)(1)\nthrough (e)(5) of this section.\nSouthern Star’s procedures were inadequate to provide a process and tools to track inaccurate,\nmalfunctioning and out of service field equipment to identify, report and promptly correct issues.\nSection 9.6.1 of procedure 40.12.01.17 provided a table for alarm remediation time based on\nalarm priority. Section 9.1.1 of the same procedure stated, “[I]dentify and correct inaccurate or\nmalfunctioning alarms by use of the following processes[,]” followed by a list of alarm reports\nthat were available to run for review on a periodic or ad hoc basis. This is a high-level process\nmanaged by leadership and does not address how the controller handles inaccurate,\nmalfunctioning, or stale alarms. Section 9.1.5.2 stated, “[B]ogus/unreliable data displayed in\nSCADA will be reported by the controller as it occurs through email or phone.” Section 9.1.6.2\nstated, “[E]nsure any deficiencies not corrected in the prioritized timeframe are evaluated for\npriority and risk by Gas Control Management.”\nEmails and phone calls were communication methods for controllers to report malfunctioning or\ninaccurate alarms or other deficiencies, but how those issues were collected, documented and\ntracked to ensure compliance with the table in section 9.6.1 is missing from the procedure. The\nmonthly and ad hoc reports may provide additional information, and some of the reports\nidentified in section 9.1.1 could have provided insight into deficiencies, but not without review\nof other information and if the deficiency was corrected. Also, the remediation times in section\n9.6.1 were not “prompt,” considering that critical alarm priority “critical” remediation was 14\ndays and high, medium and low were 30 days.\nThis issue was further evidenced upon review of controller shift change documents, which were\ndeveloped from controller logs. Several instances noted by controllers that the field personnel\ntold them to “ignore” the alarm for a variety of reasons. This was not an acceptable practice.\nEffective alarm handling includes inhibiting, taking off scan and forced or manual points or\nvalues, thus the reporting requirement in §192.631(e)(2), to manage these conditions. Controllers\nshould never be in a position to ignore alarms. While the procedure provided who can and\ncannot take points off-scan, inhibit alarms or place points in manual or forced conditions, it does\n7\n\n\n\nnot provide when this action may be appropriate. It did describe conditions in 12.1.1 that such\nconditions require a Management of Change.\nThe procedure needs to be amended to include a process to provide a method and tools to report,\ndocument, track, review and promptly correct deficiencies identified in through the\nimplementation of paragraphs (e)(1) through (e)(5) of this section. This must include the roles\nand responsibilities for reporting, documenting, tracking, reviewing and correcting these\ndeficiencies. The procedure also needs to include appropriate considerations when points\naffecting safety should be taken off-scan, have alarms inhibited or points and alarms place in\nforced or manual. Where appropriate, the procedure must include language discouraging or\ndisallowing alarms to be ignored.\n10. § 192.631 Control room management.\n(a) General.\n(1) This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline\nfacility through a SCADA system. Each operator must have and follow written\ncontrol room management procedures that implement the requirements of this\nsection…\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) ….\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 periods of time exceeding that\nrequired for associated maintenance or operating activities.\nSouthern Star’s procedure was inadequate because while it defined the reports to be gathered, it\ndid not provide how the information collected will be analyzed, verified, documented and\naddress deficiencies. The procedure assigned the Manager or Designee responsible for this task,\nbut did not define who else in engaged in the review. There were no Key Performance Indicators\n(KPI) to determine criteria for success or how they would report compliance with their procedure\n9.6.1 in section 40.12.01.17.\nThe procedure needs to be amended to include the process for what information will be\nevaluated, analyzed, reviewed and documented. KPIs need to be developed and established for\ncriteria to indicate performance of alarm management. The procedure also needs to include who\nis responsible (individual or team) for the process. This process must connect to the alarm\ntracking process identified in Item 9.\n11. § 192.631 Control room management.\n(a) General.\n(1) This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline\n8\n\n\n\nfacility through a SCADA system. Each operator must have and follow written\ncontrol room management procedures that implement the requirements of this\nsection…\n(e) Each operator using a SCADA system must have a written alarm management\nplan to provide for effective controller response to alarms. An operator’s plan must\ninclude provisions to:\n(1) ….\n(3) Verify correct safety-related alarm set-point values and alarm descriptions at\nleast once each calendar year, but at intervals not to exceed 15 months;\nSouthern Star’s procedure is inadequate to determine the correct alarm set-point as required by\n§ 192.631(e)(3). The operator stated there was a process to rationalize alarms, but the operator\nabandoned that solution and moved to TiPS Logmate, a third-party alarm management\ntool/application. The operator was in the process of using this application to re-rationalize all\nalarms with an Alarm Team. Procedure 40.12.01.13 was very high level and did not thoroughly\ndefine the metric related to severity, impact and response time to establish priority and set point\nfor safety related alarms.\nThe procedure needs to be amended to define the process using the operators selected tool to\nrationalize alarms consistently and thoroughly. The procedure must include metrics related to\nseverity, impact and response time for alarm conditions to establish priority and set points for\nsafety related alarms. The priorities must be consistent with the established priorities in the\nAlarm Management Plan.\n12. § 192.631 Control room management.\n(a) General.\n(1) This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline\nfacility through a SCADA system. Each operator must have and follow written\ncontrol room management procedures that implement the requirements of this\nsection…\n(e) Each operator using a SCADA system must have a written alarm management\nplan to provide for effective controller response to alarms. An operator’s plan must\ninclude provisions to:\n(1) ….\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 to\nexceed 15 months, that will assure controllers have sufficient time to analyze and\nreact to incoming alarms;\nSouthern Star’s procedure 40.12.01.13 was inadequate to provide a process to identify all tasks\nperformed by controllers and methods for measuring the content and volume of general activity\nbeing directed to an individual controller. The process is detailed in Appendix B, but this was\nnot referenced in the procedure. The background information of hourly controller activity\ndocumentation, used to produce the summary, was not required to be maintained as needed to\n9\n\n\n\nsupport summary results. The procedure did not accommodate refreshing the task list as control\nroom activities can change over time.\nThe procedure needs to be amended to include a method to identify all tasks/work activity\nperformed by the controller as well as a path to review the task list and update as needed. All\ndocuments related to the review must also be documented and maintained as part of the record\nthat was used to measure the content and volume of general activity being directed to an\nindividual controller.\n13. § 192.631 Control room management.\n(a) General.\n(1) This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline\nfacility through a SCADA system. Each operator must have and follow written\ncontrol room management procedures that implement the requirements of this\nsection…\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) Establish communications between control room representatives, operator’s\nmanagement, and associated field personnel when planning and implementing\nphysical changes to pipeline equipment or configuration;\n(2) Seek control room or control room management participation in planning prior\nto implementation of significant pipeline hydraulic or configuration changes.\n(3) Seek control room or control room management participation in planning prior\nto implementation of significant pipeline hydraulic or configuration changes.\nSouthern Star's procedures are inadequate because they do not address all the elements that may\nimpact control room operations through the process of defining how changes will be coordinated\nwith the control room and how those changes will be incorporated and implemented in the\ncontrol room as required by §192.631(f)(1) and §193.631(f)(3).\nSouthern Star did not have an overarching change management process for the company. They\nentered projects into the Enterprise Project Management System. This system was primarily\nused to track projects. The control room used it to keep updated on projects that may affect them\nand system operations from a system planning perspective.\nInformation about changes that may affect control room operations are provided during a weekly\nProjects Update Conference call. Gas Control personnel provided comments to any projects that\nhave potential to impact control room operations. Documentation of this weekly meeting\nincluding attendees and items discussed are recorded and available from project management.\nProcedure 40.15.01.12 section 3.1.1 provided examples of changes that have the potential to\naffect control room personnel. While this is important, the language of §192.631(f) states,\n“[C]hanges that could affect control room operations.” Section 7.1.2 requires a Management of\nChange (MOC) be completed for \"any SCADA display changes or changes that could directly or\nindirectly affect the hydraulic performance or configuration of the pipeline,\" and section 12.2.2\n10\n\n\n\nof procedure 40.12.01.17 requires a Management of Change (MOC) for alarm additions,\nremoval, inhibiting and set point changes; off-scan, manual and forced and not included.\nSeveral MOC's were reviewed during the inspection. It became apparent that the MOC was\nprimarily being used as a communication tool of changes to the controllers, which is an\nimportant element of the MOC process. Verification that all elements that could impact the\ncontrol room were being addressed through the MOC was missing. An example is MOC 484,\n476, 485 all related to the Welda to Ottawa 36-inch line where the old line was being retired after\na new line installed. During the inspection it appeared the pressure exceeded MAOP. Upon\ninvestigation, the field said the numbers were \"bogus\" and to ignore the information. On\n10/22/2021, during the inspection, an MOC was written to inhibit these alarms. This issue of\nignoring alarms was previously addressed in Item 9 of this document. An MOC procedure\nshould consider all groups, elements, procedures, training and systems impacted by a change.\nThere is a commissioning process, inside the project management process, where SCADA gets\nnotified of required changes. This commissioning process is not detailed in the procedure.\nThe procedure needs to be amended to detail the commissioning process and consider how the\nMOC will be used to make sure a more in-depth look at how the change will affect control room\noperations. Additionally, the MOC process should be all encompassing to evaluate how any\nchange can affect the control room, even if the initiation of the change doesn’t start with the\ncommissioning process. The process must also address the controller training and\ncommunication elements.\n14. § 192.631 Control room management.\n(a) General.\n(1) This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline\nfacility through a SCADA system. Each operator must have and follow written\ncontrol room management procedures that implement the requirements of this\nsection…\n(g) Operating experience. Each operator must assure that lessons learned from its\noperating experience are incorporated, as appropriate, into its control room\nmanagement procedures by performing each of the following:\n(1) Review incidents that must be reported pursuant to 49 CFR part 191 to\ndetermine if control room actions contributed to the event and, if so, correct, where\nnecessary, deficiencies related to:\n(i) Controller fatigue;\nSouthern Star’s procedures were inadequate because they did provide a process to evaluate\nwhether controller fatigue contributed to an event for incidents that must be reported pursuant to\n49 CFR part 191 as required by § 192.631(g)(1)(i).\nThe operator provided a form, SSCGP Emergency Response Evaluation Form B, for control\nroom incident investigation. The form was not referenced within the company procedures and\nthere was not a methodology/instruction to demonstrate consistency in the completion of the\n11\n\n\n\nform. Also missing from the procedure was criteria for when this form must be used with the\nemergency response investigation procedures and how the requirements of § 192.631(g)(1) are to\nbe completed.\nThe procedure must be amended to reference the SSCGP Emergency Response Evaluation Form\nB and provide guidance on when and how to complete the form.\nThe operator did provide amended forms that include a structure to evaluate controller fatigue\nand the control room requirements in § 192.631(g)(1). References to procedure modifications\nwere not provided.\n15. § 192.631 Control room management.\n(a) General.\n(1) This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline\nfacility through a SCADA system. Each operator must have and follow written\ncontrol room management procedures that implement the requirements of this\nsection…\n(h) Training. Each operator must establish a controller training program and\nreview the training program content to identify potential improvements at least\nonce each calendar year, but at intervals not to exceed 15 months. An operator’s\nprogram must provide for training each controller to carry out the roles and\nresponsibilities defined by the operator…\nSouthern Star's Gas Control Training Procedure 40.14.01.16 was inadequate because it did not\ninclude the documentation used to validate completion of all required training courses and\nassessments of controller progress to verify the controller was progressing through the training\nprogram. Also, any evaluator of controllers for operator qualification needs to be a qualified\nevaluator. This was also missing from the procedure.\nThe procedure needs to be amended to include the training completion and assessment forms and\ndocuments, as well as the requirement to retain these documents for review and inspection. The\nprocedure also needs to include the operator qualification (OQ) requirement for the Gas\nControllers.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in\nEnforcement Proceedings.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under\n5 U.S.C. § 552(b), along with the complete original document you must provide a second copy\nof the document with the portions you believe qualify for confidential treatment redacted and an\n12\n\n\n\nexplanation of why you believe the redacted information qualifies for confidential treatment\nunder 5 U.S.C. § 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under § 190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis Notice without further notice to you and to issue an Order Directing Amendment. If your\nplans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend\nyour plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not\ncontesting this Notice, we propose that you submit your amended procedures to my office within\n30 days of receipt of this Notice. This period may be extended by written request for good\ncause. Once the inadequacies identified herein have been addressed in your amended\nprocedures, this enforcement action will be closed.\nIt is requested that Southern Star maintain documentation of the safety improvement costs\nassociated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures)\nand submit the total to Gregory A. Ochs, Director, Central Region, Pipeline and Hazardous\nMaterials Safety Administration. In correspondence concerning this matter, please refer to CPF\n3-2022-044 NOA and, for each document you submit, please provide a copy in electronic format\nwhenever possible.\nSincerely,\nGregory A. Ochs\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Thomas Craig, Manager Integrity Management & PHMSA Compliance,\ncraig.thomas@southernstar.com\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n13","truncated":false,"body_characters":38909}