{"operation":"document","citation":"CPF 32023013NOA","title":"BOARDWALK PETROCHEMICAL PIPELINE, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2023-07-20","effective_on":null,"summary":"CLOSED notice of amendment citing 195.446(a), 195.446(b)(3), 195.446(c)(1), 195.446(c)(2), 195.446(c)(3), 195.446(d), 195.446(e)(1), 195.446(e)(5), 195.446(e)(6), 195.446(f)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32023013noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32023013noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32023013noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32023013NOA","body":"Notice of Amendment involving BOARDWALK PETROCHEMICAL PIPELINE, LLC. PHMSA's enforcement data identifies the cited regulations as 195.446(a),  195.446(b)(3),  195.446(c)(1),  195.446(c)(2),  195.446(c)(3),  195.446(d),  195.446(e)(1),  195.446(e)(5),  195.446(e)(6),  195.446(f)(1). The case was opened on 2023-07-20 and is reported as closed as of 2023-12-07. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32023013NOA_Closure Letter_12072023_(22-250434).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023013NOA/32023013NOA_Closure%20Letter_12072023_(22-250434).pdf\n\n32023013NOA_Closure Letter_12072023_(22-250434)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023013NOA/32023013NOA_Closure%20Letter_12072023_(22-250434)_text.pdf\n\n32023013NOA_Notice of Amendment_07202023_(22-250434).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023013NOA/32023013NOA_Notice%20of%20Amendment_07202023_(22-250434).pdf\n\n32023013NOA_Notice of Amendment_07202023_(22-250434)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023013NOA/32023013NOA_Notice%20of%20Amendment_07202023_(22-250434)_text.pdf\n\n32023013NOA_Operator Response to Notice_08172023_(22-250434).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023013NOA/32023013NOA_Operator%20Response%20to%20Notice_08172023_(22-250434).pdf\n\n32023013NOA_Closure Letter_12072023_(22-250434)_text.pdf\n\nVIA ELECTRONIC MAIL TO: stan.horton@bwpipelines.com; tina.baker@bwpipelines.com\nDecember 7, 2023\nMr. Stanley Horton\nPresident/CEO\nBoardwalk Petrochemical Pipeline, LLC\n9 Greenway Plaza, Suite 2800\nHouston, TX 77036\nRE: CPF 3-2022-013-NOA\nDear Mr. Horton:\nFrom September 19 through September 23, 2022, a representative from the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United\nStates Code, conducted an on-site pipeline safety inspection of Boaredwalk Petrochemical\nPipeline, LLC (Boardwalk) procedures in Sulphur, Louisiana. As a result of the inspection,\nBoardwalk was issued a Notice of Amendment on July 2023, which proposed amendment of\nyour procedures.\nBoardwalk submitted its amended procedures on August 17, 2023. My staff reviewed the\namended procedures, and it appears that the inadequacies outlined in this Notice of Amendment\nhave been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nGregory A. Ochs\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Tina Baker, Manager Compliance Service, tina.baker@bwpipelines.com\n\n32023013NOA_Notice of Amendment_07202023_(22-250434)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: stan.horton@bwpipelines.com; tina.baker@bwpipelines.com\nJuly 20, 2023\nMr. Stanley Horton\nPresident/CEO\nBoardwalk Petrochemical Pipeline, LLC\n9 Greenway Plaza, Suite 2800\nHouston, TX 77036\nCPF 3-2023-013-NOA\nDear Mr. Horton:\nFrom September 19 to September 23, 2022, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code\n(U.S.C.), inspected, by means of video conference, Boardwalk Petrochemical Pipeline, LLC’s\n(Boardwalk) procedures for Control Room Management (CRM) in Sulphur Springs, Louisiana.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within\nBoardwalk’s plans or procedures. The items inspected and the inadequacies are described\nbelow:\n1. § 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\nof this section. The procedures required by this section must be integrated as\nappropriate, with the operator’s written procedures required by § 195.402. An\noperator must develop the procedures no later than August 1, 2011, and must\nimplement the procedures according to the following schedule. The procedures\nrequired by paragraphs (b), (c)(5), (d)(2) and (d)(3), (f) and (g) of this section\nmust be implemented no later than October 1, 2011. The procedures required\nby paragraphs (c)(1) through (4), (d)(1), (d)(4), and (e) must be implemented no\nlater than August 1, 2012. The training procedures required by paragraph (h)\n\n\n\nmust be implemented no later than August 1, 2012, except that any training\nrequired by another paragraph of this section must be implemented no later\nthan the deadline for that paragraph.\n(b) Roles and Responsibilities. Each operator must define the roles and\nresponsibilities of a controller during normal, abnormal and emergency\noperation conditions. To provide for a controller’s prompt and appropriate\nresponse to operating conditions, and operator must define each of the following:\n(1) ….\n(3) A controllers role during an emergency, even if the controller is not the first to\ndetect the emergency, including the controllers responsibility to take specific\nactions and to communicate with others;\nBoardwalk's procedures CRM Plan 7/27/2022 Rev 5.30 and BWP 6618-HL were not adequate to\nsupport control room evacuation. Missing from the procedure were steps relating to muster point\nlocations, and who decides to return to the primary control room or go to the backup control\nroom. Also, the plan included utilizing the qualified manager of the control room to monitor the\nsystem remotely on a laptop computer. This required quick notification of the manager to allow\nfor monitoring during the controller absence. Missing from the procedure was a step related to\ncalling the manager to remotely monitor the system.\nThe procedure needs to be amended to include additional information related to muster points,\nwho makes the decision to return to the primary control room or go to back up control room, and\na step to call the manager to remotely monitor the system.\nFollowing the inspection, Boardwalk followed up with amended procedures. Upon review, the\namended procedures were determined adequate. No further action is required.\n2. § 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\nof this section. The procedures required by this section must be integrated as\nappropriate, with the operator’s written procedures required by §195.402. An\noperator must develop the procedures no later than August 1, 2011, and must\nimplement the procedures according to the following schedule. The procedures\nrequired by paragraphs (b), (c)(5), (d)(2) and (d)(3), (f) and (g) of this section\nmust be implemented no later than October 1, 2011. The procedures required\nby paragraphs (c)(1) through (4), (d)(1), (d)(4), and (e) must be implemented no\nlater than August 1, 2012. The training procedures required by paragraph (h)\nmust be implemented no later than August 1, 2012, except that any training\nrequired by another paragraph of this section must be implemented no later\nthan the deadline for that paragraph.\n(b) ….\n\n\n\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\neach of the following:\n(1) Implement API RP 1165 (incorporated by reference, see §195.3) whenever a\nSCADA system is added, expanded or replaced, unless the operator\ndemonstrates that certain provisions of API RP 1165 are not practical for the\nSCADA system used;\nBoardwalk’s CRM Plan Rev 5.30 7/27/2022 was not adequate to define addition, expansion or\nreplacement to demonstrate compliance when implementing API 1165. In addition to\ndefinitions, there were no examples to provide support of the definitions and future control room\n/ SCADA activities.\nThe procedure needs to be amended to provide definitions and examples of addition, expansion,\nand replacement of a SCADA system to implement API 1165.\nFollowing inspection, Boardwalk followed up with amended procedures. Upon review, the\namended procedures were determined adequate. No further action is required.\n3. § 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\nof this section. The procedures required by this section must be integrated as\nappropriate, with the operator’s written procedures required by §195.402. An\noperator must develop the procedures no later than August 1, 2011, and must\nimplement the procedures according to the following schedule. The procedures\nrequired by paragraphs (b), (c)(5), (d)(2) and (d)(3), (f) and (g) of this section\nmust be implemented no later than October 1, 2011. The procedures required\nby paragraphs (c)(1) through (4), (d)(1), (d)(4), and (e) must be implemented no\nlater than August 1, 2012. The training procedures required by paragraph (h)\nmust be implemented no later than August 1, 2012, except that any training\nrequired by another paragraph of this section must be implemented no later\nthan the deadline for that paragraph.\n(b) ….\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\neach of the following:\n(1) ….\n(2) Conduct point-to-point verification between SCADA displays and related field\nequipment when field equipment is added or removed and when other changes\nthat affect pipeline safety are made to field equipment or SCADA displays;\n\n\n\nBoardwalk’s CRM Plan Rev 5.30 7/27/2022 was not adequate to define and prioritize leak\nalarms as safety-related. A review of the SCADA alarm database for both analogue and status\npoints revealed there were a few additional alarms identified as safety-related that were not\nincluded in the procedure. Boardwalk also provided Rate of Change (ROC) alarms for pressures\nand flows. The benchmark value was not designed with any priority or set point parameters for\nalarming. Because Appendix 8, of the CRM Plan, identified that pressure and flow ROC can be\nan indication for a leak, some alarming level should be considered as safety-related; none was\nprovided.\nThe procedure needs to be amended to provide some consideration for leak detection\npoints/alarms and ROC as safety-related, as well as include the additional tags identified in the\nSCADA database noted as safety-related (if the operator determines them to be safety-related).\n4. § 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\nof this section. The procedures required by this section must be integrated as\nappropriate, with the operator’s written procedures required by §195.402. An\noperator must develop the procedures no later than August 1, 2011, and must\nimplement the procedures according to the following schedule. The procedures\nrequired by paragraphs (b), (c)(5), (d)(2) and (d)(3), (f) and (g) of this section\nmust be implemented no later than October 1, 2011. The procedures required\nby paragraphs (c)(1) through (4), (d)(1), (d)(4), and (e) must be implemented no\nlater than August 1, 2012. The training procedures required by paragraph (h)\nmust be implemented no later than August 1, 2012, except that any training\nrequired by another paragraph of this section must be implemented no later\nthan the deadline for that paragraph.\n(b) ….\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\neach of the following:\n(1) ….\n(3) Test and verify an internal communication plan to provide adequate means for\nmanual operation of the pipeline safely, at least once each calendar year, but at\nintervals not to exceed 15 months;\nBoardwalk’s CRM Plan Rev 5.30 7/27/2022 Section 4.9 and Task 6650 was not adequate to test\nand verify their internal communication plan for the manual operation of the pipeline. While the\nprocedure was well thought out, the procedure was missing: a consistent method to record the\ninformation related to shut down to ensure everything was in the desired appropriate state for\nshutdown, a process to document information over a long outage timeframe over multiple\n\n\n\ncontrollers shifts, and a process for monitoring and reporting leaks, abnormal operations and\nemergencies.\nThe procedure needs to be amended to provide a consistent method to record the information\nrelated to shut down to ensure everything was in the desired appropriate state for shutdown. The\nprocedure must include steps to document information over a long outage timeframe over\nmultiple controllers shifts and a process for monitoring and reporting leaks, abnormal operations\nand emergencies.\n5. § 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\nof this section. The procedures required by this section must be integrated as\nappropriate, with the operator’s written procedures required by §195.402. An\noperator must develop the procedures no later than August 1, 2011, and must\nimplement the procedures according to the following schedule. The procedures\nrequired by paragraphs (b), (c)(5), (d)(2) and (d)(3), (f) and (g) of this section\nmust be implemented no later than October 1, 2011. The procedures required\nby paragraphs (c)(1) through (4), (d)(1), (d)(4), and (e) must be implemented no\nlater than August 1, 2012. The training procedures required by paragraph (h)\nmust be implemented no later than August 1, 2012, except that any training\nrequired by another paragraph of this section must be implemented no later\nthan the deadline for that paragraph.\n(b) ….\n(d) Fatigue mitigation. Each operator must implement the following methods to\nreduce the risk associated with controller fatigue that could inhibit a controllers’\nability to carry out the roles and responsibilities the operator has defined:\nBoardwalk’s CRM Plan Rev 5.30 7/27/2022 was not adequate to identify the risks associated\nwith controller fatigue to reduce the risk through mitigation strategies. Boardwalk did not\nspecifically state and define fatigue risks in Section 5 of the CRM Plan, other than noting\ncommute time as a possible risk. Section 9.5 of the CRM Plan identified fatigue risks but\naddresses them as Fatigue Mitigation Training. Boardwalk also had Task List 6605 Fatigue\nMitigation Guidelines. This task list covered fatigue mitigation countermeasures.\nThe procedure needs to be amended to identify fatigue risks for the controllers that can then\nsupport fatigue mitigation and training.\nFollowing inspection, Boardwalk followed up with amended procedures. Upon review, the\namended procedures were determined adequate. No further action is required.\n\n\n\n6. § 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\nof this section. The procedures required by this section must be integrated as\nappropriate, with the operator’s written procedures required by §195.402. An\noperator must develop the procedures no later than August 1, 2011, and must\nimplement the procedures according to the following schedule. The procedures\nrequired by paragraphs (b), (c)(5), (d)(2) and (d)(3), (f) and (g) of this section\nmust be implemented no later than October 1, 2011. The procedures required\nby paragraphs (c)(1) through (4), (d)(1), (d)(4), and (e) must be implemented no\nlater than August 1, 2012. The training procedures required by paragraph (h)\nmust be implemented no later than August 1, 2012, except that any training\nrequired by another paragraph of this section must be implemented no later\nthan the deadline for that paragraph.\n(b) ….\n(d) Fatigue mitigation. Each operator must implement the following methods to\nreduce the risk associated with controller fatigue that could inhibit a controllers’\nability to carry out the roles and responsibilities the operator has defined:\nBoardwalk’s CRM Plan Section 5 was inadequate because it did not require the manager of the\ncontrol room, who is OQ qualified and can be called into service to monitor the pipeline, to track\nhis hours of work in SchedulePro, a time tracking application. Even though the manager does\nnot work a shift, he is someone identified in procedure who can be called upon to monitor the\nsystem in the event the control room must be evacuated and or controllers need to relocate to the\nbackup control center. Tracking hours worked for all qualified controllers who can be pulled\ninto service is important. The manager is bound by the hours-of-service standards that apply to\nall controllers. If the manager is required to monitor and control the system, for any reason, his\nhours of service must be considered for fatigue and or deviation from the hours of service.\nThe procedure must be amended to include tracking time and hours of service for all personnel\nwho are qualified and could be pulled into service to monitor and control the pipeline system.\n7. § 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\nof this section. The procedures required by this section must be integrated as\nappropriate, with the operator’s written procedures required by §195.402. An\noperator must develop the procedures no later than August 1, 2011, and must\nimplement the procedures according to the following schedule. The procedures\nrequired by paragraphs (b), (c)(5), (d)(2) and (d)(3), (f) and (g) of this section\n\n\n\nmust be implemented no later than October 1, 2011. The procedures required\nby paragraphs (c)(1) through (4), (d)(1), (d)(4), and (e) must be implemented no\nlater than August 1, 2012. The training procedures required by paragraph (h)\nmust be implemented no later than August 1, 2012, except that any training\nrequired by another paragraph of this section must be implemented no later\nthan the deadline for that paragraph.\n(b) ….\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.\nAn operator’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;\nBoardwalk’s CRM Plan was not adequate because it did not provide a specific process for\nmanaging stale or unreliable data to ensure alarms are accurate and support safe pipeline\noperations. Boardwalk's Display Standards and Style Guide: Liquids Control 7/27/2022\nprovided a definition of stale data icons. This offered a very good definition of stale data and\nhow the indicator was generated and presented to the controller. Task List 6619 mentioned\nmalfunctioning or loss of communication, but it did not include stale data, which may be a subset\nof both or something totally different. Therefore, it warranted independent\nconsideration. Section 2.0 of the CRM Plan did not offer definitions for malfunctioning,\ninaccurate, stale or unreliable alarms. The procedure offered no guidance to the controller on\nhow to recognize stale or unreliable data or what to do if identified through alarms or other\nmeans.\nThe procedure must be amended to include guideance for the controller on alarm response and\nhandling of stale and unreliable data. Additionally, it should provide more definition around\nmalfunctioning, loss of communication, stale and unreliable alarms as they are different in nature\nand require different responses.\nFollowing inspection, Boardwalk followed up with amended procedures. Upon review, these\nprocedures were determined adequate. No further action is required.\n8. § 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\nof this section. The procedures required by this section must be integrated as\nappropriate, with the operator’s written procedures required by §195.402. An\noperator must develop the procedures no later than August 1, 2011, and must\nimplement the procedures according to the following schedule. The procedures\nrequired by paragraphs (b), (c)(5), (d)(2) and (d)(3), (f) and (g) of this section\nmust be implemented no later than October 1, 2011. The procedures required\n\n\n\nby paragraphs (c)(1) through (4), (d)(1), (d)(4), and (e) must be implemented no\nlater than August 1, 2012. The training procedures required by paragraph (h)\nmust be implemented no later than August 1, 2012, except that any training\nrequired by another paragraph of this section must be implemented no later\nthan the deadline for that paragraph.\n(b) ….\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.\nAn operator’s plan must include provisions to:\n(1) ….\n(5) Monitor content and volume of general activity being directed to and required of\neach controller at least once each calendar year, but at intervals not exceeding 15\nmonths, that will assure controllers have sufficient time to analyze and react to\nincoming alarms;\nBoardwalk's CRM Plan was not adequate because it did not define the criteria to determine if the\ncontroller has sufficient time to analyze and react to incoming alarms. Boardwalk’s plan states\nin Task List 6611 that if the controller activity review concludes that any aspect of the controller\nworkload is \"excessive,\" adjustments will be made. However, the procedure did not define\ncriteria for determining “excessive” Controller workload. From all the information gathered and\nanalyzed, there should be some criteria that is the driver for determining \"excessive\" or\n\"sufficient.\"\nThe procedure needs to be amended to define the criteria that will be used to identify the\ncontroller has sufficient time to analyze and react to incoming alarms.\n9. § 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\nof this section. The procedures required by this section must be integrated as\nappropriate, with the operator’s written procedures required by §195.402. An\noperator must develop the procedures no later than August 1, 2011 and must\nimplement the procedures according to the following schedule. The procedures\nrequired by paragraphs (b), (c)(5), (d)(2) and (d)(3), (f) and (g) of this section\nmust be implemented no later than October 1, 2011. The procedures required\nby paragraphs (c)(1) through (4), (d)(1), (d)(4), and (e) must be implemented no\nlater than August 1, 2012. The training procedures required by paragraph (h)\nmust be implemented no later than August 1, 2012, except that any training\nrequired by another paragraph of this section must be implemented no later\nthan the deadline for that paragraph.\n(b) ….\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.\n\n\n\nAn operator’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.\nBoardwalk’s CRM procedures for addressing deficiencies identified through the implementation\nof paragraphs (e)(1) - (5) was not adequate. Section 6.9 of the CRM Plan addressed deficiencies\nfound implementing §§ 195.446(e)(1) through 195.446(e)(5) and identified Form BWP-HL 6640\nAlarm Management Deficiency Review. The procedure stated that Boardwalk “[w]ill promptly\ncorrect specific issues commensurate with their importance to safety.” It also stated that\ndocumentation should also record the basis for the selection and scheduling of corrective\naction. During the inspection, a review of the form was completed. The review demonstrated\nthat documenting a deficiency was very similar to documenting a deviation. These are not the\nsame.\nThe operator used GMS tickets, a subset of MAXIMO, to assign alarm or equipment repairs to\nthe field, such as malfunctioning or inaccurate alarms. This practice was not defined in the CRM\nprocedure or their Task 6619 for handling malfunctioning and inaccurate alarms. MOC's were\nalso used for alarm changes, which could be required due to identified deficiencies. The\nprocedure did not include who is responsible for reviewing these work orders to resolution.\nThe CRM procedure and Task needs to be amended to identify types of deficiencies that could\narise while implementing §§ 195.446(e)(1) through (5), and how the deficiencies, when\nidentified, will be recorded and tracked to resolution. The procedure must include a periodic\nreview process to support tracking to resolution.\n10. § 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\nof this section. The procedures required by this section must be integrated as\nappropriate, with the operator’s written procedures required by §195.402. An\noperator must develop the procedures no later than August 1, 2011, and must\nimplement the procedures according to the following schedule. The procedures\nrequired by paragraphs (b), (c)(5), (d)(2) and (d)(3), (f) and (g) of this section\nmust be implemented no later than October 1, 2011. The procedures required\nby paragraphs (c)(1) through (4), (d)(1), (d)(4), and (e) must be implemented no\nlater than August 1, 2012. The training procedures required by paragraph (h)\nmust be implemented no later than August 1, 2012, except that any training\nrequired by another paragraph of this section must be implemented no later\nthan the deadline for that paragraph.\n(b) ….\n(f) Change Management. Each operator must assure that changes that could affect\ncontrol room operations are coordinated with the control room personnel by\n\n\n\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\nroom representatives, operator’s management, and associated field personnel\nwhen planning and implementing physical changes to pipeline equipment or\nconfiguration;\nBoardwalk's CRM procedure was not adequate to substantiate that the OMS MAXIMO system is\nthe overarching management of change used by the company. While it appears in many Task\nLists as a way to initiate and track different types of changes or work requests, it appeared to be\nmore of a practice used by the company rather than a policy or procedure. It was clear from\nTask List 6602 that information for changes that involved SCADA came through the OMS\nsystem. But changes that were not SCADA related, yet could still affect control room\noperations, were initiated through OMS – they were not defined in procedure. Section 7 of the\nCRM Plan required pipeline operations, engineering, and construction to contact the control\ncenter when making field changes that affect the operations of the control center. It provided\noptions of communications as telephone, text, email, memorandum, mail, or another method\nfound acceptable. It did not include the OMS MAXIMO system. Yet, it was referenced as the\ncommunication change method in Task List 6602 as well as in other procedures that required\ncontrollers to review the OMS system, as in BWP 6638-HL and BWP-6649-HL.\nBoardwalk's procedure needs to be amended to include how it is getting information from the\nOMS system related to changes initiated outside the control room and internal changes initiated\nwithin the control room for both SCADA and non-SCADA changes.\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 5\nU.S.C. § 552(b), along with the complete original document you must provide a second copy of\nthe document with the portions you believe qualify for confidential treatment redacted and an\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\n\n\n\nthirty 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 Boardwalk 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 Ochs, Director, Central Region, Pipeline and Hazardous\nMaterials Safety Administration. In correspondence concerning this matter, please refer to CPF\n3-2023-013-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\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\ncc: Tina Baker, Manager Compliance Service, tina.baker@bwpipelines.com","truncated":false,"body_characters":32465}