{"operation":"document","citation":"CPF 32024021NOA","title":"CRESTWOOD MIDSTREAM PARTNERS LP — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2024-06-05","effective_on":null,"summary":"OPEN notice of amendment citing 195.446(a), 195.446(b)(2), 195.446(b)(3), 195.446(b)(4), 195.446(b)(5), 195.446(c)(2), 195.446(d)(4), 195.446(e)(1), 195.446(e)(2), 195.446(e)(6), 195.446(g)(1), 195.446(h)(6).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32024021noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32024021noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32024021noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32024021NOA","body":"Notice of Amendment involving CRESTWOOD MIDSTREAM PARTNERS LP. PHMSA's enforcement data identifies the cited regulations as 195.446(a),  195.446(b)(2),  195.446(b)(3),  195.446(b)(4),  195.446(b)(5),  195.446(c)(2),  195.446(d)(4),  195.446(e)(1),  195.446(e)(2),  195.446(e)(6),  195.446(g)(1),  195.446(h)(6). The case was opened on 2024-06-05 and is reported as open. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32024021NOA_Notice of Amendment_06052024_(21-199489).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024021NOA/32024021NOA_Notice%20of%20Amendment_06052024_(21-199489).pdf\n\n32024021NOA_Notice of Amendment_06052024_(21-199489)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024021NOA/32024021NOA_Notice%20of%20Amendment_06052024_(21-199489)_text.pdf\n\n32024021NOA_Operator Response to Notice_07052024_(21-199489).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024021NOA/32024021NOA_Operator%20Response%20to%20Notice_07052024_(21-199489).pdf\n\n32024021NOA_Notice of Amendment_06052024_(21-199489)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: gregory.mcilwain@energytransfer.com;\ntodd.nardozzi@energytransfer.com; eric.amundsen@energytransfer.com;\nJune 5, 2024\nGregory McIlwain\nPresident/CEO\nEnergy Transfer Company\n8111 Westchester\nDallas, TX 75225\nCPF 3-2024-021-NOA\nDear Mr. McIlwain:\nFrom March 29 to January 11, 2023, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.),\ninspected Crestwood Midstream Partners, LP/Colt Connector Pipeline’s (Colt Hub) control room\nfor Control Room Management (CRM) procedures in Crestwood, North Dakota, by video\nconference inspection. Colt Hub is a subsidiary of Crestwood Midstream Partners, LP. On\nNovember 3, 2023, Crestwood Midstream Partners, LP was acquired by Energy Transfer\nCompany.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within Colt\nHub’s plans or procedures. The items inspected and the inadequacies are described below:\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 of\nthis section.\n\n\n\nColt Hub’s CRM Program Manual, updated August 2020, Rev 20200820 (CRMP), section 107,\nentitled “Annual Review of CRM and Alarm Management Plan Procedures,” stated \"[t]his\ncontrol room and alarm management plan will be reviewed by the Operations Supervisor once\nper calendar year not to exceed 15 months. The annual review will be documented and\nretained.\" Colt Hub’s procedure did not contain a written process to ensure that control room\nmanagement procedures and associated procedures are reviewed, and that the necessary\nchanges are made to ensure that the procedures are effective as required by §§ 195.402(a),\n195.402(c)(13), 195.402(c)(15), and 195.402(d)(5). The CRMP referenced Form 107 in\nAppendix F, however, Appendix F was related to the Applicability Survey and Appendix A\nwas related to Forms. In addition, CRMP section 107, did not contain a written process for\nversion managements (for example, track and control changes) for the CRM procedures and\nassociated procedures. Furthermore, CRMP section 107, lacked details on the draft, approval,\nand publication process. Also, there was no information on promulgating new procedures (or\nupdating an existing one).\nThe procedure needs to be amended to correct the format of the procedures to ensure consistency\nand accuracy, including date and version designation. Additionally, the procedures need to be\namended to include: a written process to ensure CRM procedures and associated operating\nprocedures are reviewed and that the necessary changes are made to ensure they are effective;\nand a written process on version management (for example, track and control changes) for the\nCRM procedures and their associated procedures.\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 of\nthis section. . . .\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(2) A controller's role when an abnormal operating condition is detected, even if the\ncontroller is not the first to detect the condition, including the controller's\nresponsibility to take specific actions and to communicate with others.\nColt Hub’s CRMP was not adequate to demonstrate compliance with defining the controller’s\nrole when an abnormal operating condition is detected. Section 203 of the CRMP, entitled\n“R&Rs – Primary Controller Responsibilities and Level of Authority,” referenced the O&M\nManual, but not the specific section within the O&M that is applicable for abnormal operations.\nIn addition, O&M section 3.11, entitled “Return to Normal Operations,” did not mention what\nthe controller must monitor until return to normal.\n\n\n\nThe procedure needs to be amended to reference the specific section within the O&M that is\napplicable for abnormal operations. Additionally, O&M section 3.11 needs to be amended to\ninclude a description of what the controller must monitor until return to normal.\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 of\nthis section. . . .\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 condition, an operator must define each of the following:\n(1) . . . .\n(3) A controller’s role during an emergency, even if the controller is not the first to\ndetect the emergency, including the controller’s responsibility to take specific\nactions and to communicate with others.\nColt Hub’s CRMP was not adequate. Specifically, Section 203, R&Rs – Primary Controller\nResponsibilities and Level of Authority, referenced the O&M Manual, but not the specific\nsection within the O&M which was applicable to emergency response. During the inspection,\nColt Hub produced Leak Detection Standard Operating Procedure (SOP)#16, Revision no: 4\nApproved and Effective 10/4/2018 (Leak Detection), which stated the Maximum Allowable\nOperating Pressure (MAOP) was 1440 psi. This was incorrect; Colt Hub’s stated MAOP is 1480\npsi. Also, Crestwood used a spreadsheet, entitled \"Pipeline Leak Detection Pump Log Master,”\nwith calculated flow rates but did not describe when it found a variance the actions to be taken\nincluding documentation. This document was not referenced in the CRMP.\nThe procedure needs to be amended to include a reference to the specific section of the O&M\nManual applicable to emergency response. SOP #16 also needs to be amended to correct any\ninaccuracies in stated MAOP and provide instruction for the action a controller must take when a\nvariance is identified in the Pipeline Leak Detection Pump Log Master, including documentation,\nand provide a reference to this document in the CRMP.\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 of\nthis section. . . .\n(b) Roles and responsibilities. Each operator must define the roles and\nresponsibilities of a controller during normal, abnormal, and emergency operating\n\n\n\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(3) A controller's role during an emergency, even if the controller is not the first to\ndetect the emergency, including the controller's responsibility to take specific\nactions and to communicate with others.\nColt Hub’s CRMP was not adequate to define the controllers’ roles and responsibility to take\nspecific action during an emergency when the control room must be evacuated. Specifically,\nsection 203, entitled “R&Rs – Primary Controller Responsibilities and Level of Authority\nController Responsibility During Evacuation,” did not contain a detailed written process for the\ncontroller's roles and responsibilities when the control room must be evacuated. The process did\nnot describe who the controller must contact, such as supervisor(s), field personnel, and so forth.\nFurthermore, Section 203 did not reference applicable shut down and manual operation\nprocedures required during the period of evacuation, nor did it address whether a controller\nneeds approval to shut down and/or start up the pipeline. The procedure did not describe the\nitems (laptop, logbooks, control room management procedures, emergency procedures,\ncell/radio, etc.) that controllers must bring with them when they leave the control room to\nmaintain some level of operation. This information is important to include because the operator\ndoes not have a physical back-up control room. Overall, the CRMP, section 203, did not give\nsufficient instructions for controller’s role and responsibilities in the event of evacuation of the\ncontrol room.\nThe procedure must be amended to provide a detailed written process with sufficient instructions\nof the controller’s roles and responsibilities and the controller’s specific actions when faced with\nthe decision or need to evacuate the control room.\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 of\nthis section. . . .\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(3) A controller's role during an emergency, even if the controller is not the first to\ndetect the emergency, including the controller's responsibility to take specific\nactions and to communicate with others.\nColt Hub’s CRMP was not adequate to define the controller’s roles and responsibility during the\nemergency condition of loss of communications. During the inspection, Crestwood produced its\nprocedure entitled “Crestwood Crude Logistics Abnormal Operating Conditions -Coms Loss”\n(Crestwood Coms Loss Procedure). Crestwood Coms Loss Procedure section 3, “Actions To Be\n\n\n\nTaken,” did not describe who would be involved in loss of communication, such as SCADA\npersonnel or IT personnel. In addition, section 3 stated, \"[w]hen the source for the Coms Failure\nhas been resolved, the Terminal Operator will make the necessary alarm acknowledgement and\nESD system re-sets and proceed with resuming operations.\" However, this statement was\ninconsistent with O&M section 3.11, “Abnormal Operations,” which stated that \"[a]fter the cause\nof the abnormal condition has been identified and corrected, [the controller must] notify the\nPipeline Supervisor or designee, who must authorize the resumption of full operation.”\nCrestwood’s Coms Loss Procedure was not referenced in its Colt Hub CRMP.\nThe Colt Hub CRMP must be amended to reference the Crestwood Coms Loss Procedure.\nAdditionally, the procedure must be amended to describe the steps a controller must take during\na loss of communications response, and who would be involved in such a response. This must\ninclude how long a controller should wait during loss of communications before acting,\nrecognizing there is a period when they may return without intervention. The procedure must\nalso correctly reflect who is authorized for restart operations after a shutdown.\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 of\nthis section. . . .\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; and\nColt Hub’s CRMP was not adequate to define a method of recording controller shift-changes and\nany hand-over of responsibility between controllers. Specifically, during the inspection, Colt\nHub mentioned that, in practice, the controllers must sign a logbook and then log in to SCADA\nto transfer roles and responsibilities to the incoming controller. However, Colt Hub’ CRMP\nsection 204, entitled “R&Rs – Shift Change Information & Accountability, Defining Minimum\nShift Change Information Requirements,” did not contain information about logging into\nSCADA.\nColt Hubs CRMP section 204, entitled, “R&Rs – Shift Change Information & Accountability,”\nreferenced Appendix A, CRM Form 204 EQ Shift Change Information (Form 204), to record\ninformation. During the inspection, a PHMSA inspector noticed multiple Forms 204, dated May\n4, 2018, evening; December 20, 2018, morning; February 17, 2019, morning; July 15, 2019,\nevening; January 1, 2020, evening; and July 11, 2020, evening, lacked details and had\ninconsistent entries between each form. Crestwood provided for inspection a logbook that\n\n\n\nincluded more details about activities that occurred during a shift, but this logbook was not\nreferenced in the CRMP as a requirement to review at shift change.\nThe procedures need to be amended to provide instructions on the method of recording controller\nshift-changes and any hand-over of responsibility between controllers related to how controllers\nare to log on/log off SCADA during shift changes, and the steps to complete the designated shift\nchange documentation form to provide consistency in the process. As part of the procedure, the\nform(s) used for shift change need to be referenced and a template provided, as well as retention\ntime and location.\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 of\nthis section. . . .\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(5) The roles, responsibilities and qualifications of others who have the authority to\ndirect or supersede the specific technical actions of controllers.\nColt Hub’s CRMP was not adequate to define the roles, responsibilities and qualifications of\nothers who have the authority to direct or supersede the specific technical actions of controllers.\nSpecifically, during the inspection, Crestwood indicated that it did not allow other employees to\nhave authority to direct or supersede the specific technical action of a controller. However, Colt\nHub’s CRMP, section 203, entitled “R&Rs – Primary Controller Responsibilities and Level of\nAuthority, Control Center/Room Coordinator and/or Supervisor Directing or Advising a\nController on Actions to Take to Complete a Safety Related Tasks,” stated, “[a]n Operations\nSupervisor may direct or advise a controller on specific actions to complete a safety related task if\nthe Operations Supervisor is also a qualified controller.” Section 203 did not include any\nstatement or position related to who can supersede the specific technical actions of a controller,\nnor under what conditions direct or supersede could occur or how the action would be\nimplemented and documented.\nThe procedure needs to be amended to include a statement related to who, if anyone, can\nsupersede the specific technical actions of a controller. It must also include the qualification\nrequirements of such person, the conditions or events that would require implementing directing\nor superseding the technical actions of a controller, and how the event would be documented.\n\n\n\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 of\nthis section. . . .\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 each\nof the following:\n(1) . . . .\n(2) Conduct a point-to-point verification between SCADA displays and related field\nequipment when field equipment is added or moved and when other changes that\naffect pipeline safety are made to field equipment or SCADA displays.\nColt Hub’s CRMP was not adequate to provide instructions and documentation requirements\nwhen conducting a point-to-point verification between SCADA displays and related field\nequipment when field equipment was added or moved. Section 303 of the CRMP Point-to-Point\nVerification Process failed to include the following: (1) tag verification to end point device; (2)\nproximity verification with other devices in the field (for example, transmitter is upstream of\nvalve in field and illustrated correctly in SCADA); (3) whether the point was verified under\nsimulated or live conditions; and (4) the set point alarm verification, including the correct\npriority, color of the priority, and alarm description. Section 303 also did not contain a statement\nregarding soft or calculated points and the associated verification.\nThe procedure must be amended to provide a process to thoroughly conduct and document a\npoint-to-point verification between SCADA displays and related field equipment when field\nequipment is added or moved and when other changes that affect pipeline safety are made to\nfield equipment or SCADA displays. Also, if the point is a calculated point, verification of\ncorrect result and associated alarming must be included.\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 of\nthis section. . . .\n(b) . . . . (d) Fatigue mitigation. Each operator must implement the following\nmethods to reduce the risk associated with controller fatigue that could inhibit a\ncontroller's ability to carry out the roles and responsibilities the operator has\ndefined:\n(1) . . . .\n\n\n\n(4) Establish a maximum limit on controller hours-of-service, which may provide\nfor an emergency deviation from the maximum limit if necessary for the safe\noperation of a pipeline facility.\nColt Hub’s CRMP was not adequate to establish a maximum limit on controller hours-of-service,\nwhich may provide for an emergency deviation from the maximum limit if necessary for the safe\noperation of a pipeline facility. Specifically, section 402 of the CRMP, entitled “Shift Lengths,\nSchedules, and Off Duty Time,” allowed 7 continuous days of work with 84 hours of work and\n36 hours of rest. However, Crestwood indicated that its schedule is not set up for, nor would it\noperate under, these hours of service. Section 402 did not provide a description of their shift\nschedule (i.e., a modified Dupont schedule). The procedure seems to suggest that during certain\ntimes, including outages, they would move to a different type of shift schedule. The hours-of-\nservice limits do not appear to represent Colt Hub’s actual work practices.\nThe CRMP, section 403, entitled “Deviation and Exception Process for Hours-of-Service\nLimits,” stated, “[o]perations Supervisor or designee may approve deviations to this manual.”\nSection 403 did not describe that the supervisor must approve deviation in advance for\nanticipated deviations or, in cases where unforeseen events occur, verbal and subsequent written\napproval should be obtained at the first practical moment after the event.\nAdditionally, section 404, entitled “Fatigue Mitigation,” mentioned designated periods within the\nshift when fatigue mitigation measures should be implemented, but it did not mention when and\nhow a controller should document the fatigue countermeasures employed.\nThe procedure needs to be amended to include the shift schedule implemented in the control\nroom and representative hours of service limits. The procedure must also be amended to require\ndocumenting the fatigue countermeasures used and when they are used. Additionally, the\nprocedure needs to be amended to include the requirements that hours-of-service deviations be\nreviewed and approved prior to the event, if possible, or at the first practical moment after the\nevent.\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 of\nthis section. . . .\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. An\noperator's plan must include provisions to:\n(1) Review SCADA safety-related alarm operations using a process that ensures\nalarms are accurate and support safe pipeline operations.\n\n\n\nColt Hub’s CRMP, under section 507, entitled “Review of Safety Related Alarms [195.446(e)(1-\n3)], False, Stale or Inaccurate Alarms,” was not adequate to ensure alarms were accurate and\nsupported safe pipeline operations. Specifically, the section 507 of the CRMP did not contain a\nformal process to report inaccurate and malfunctioning alarms. Section 507, stated, \"Mangan\nInc., as the Colt Hub’s Subject Matter Expert (SME) works closely with the controllers and\nOperations Supervisor and takes the appropriate action when requested to resolve false, stale,\nmalfunctioning, or inaccurate data. Controllers are empowered to contact Mangan Inc. directly\nand to inform the Operations Supervisor.\" However, there was no information or reference to the\nMangan, Inc. process, how the deficiencies were tracked, how correction progress was\nmonitored, how it was managed to correction, and/or documentation expectations. Also, the\nprocedure mentioned \"stale\" and “inaccurate\" alarms, but did not define them.\nThe procedure needs to be amended to define the steps a controller needs to take when a false,\nstale, inaccurate or malfunctioning alarm is identified, which includes initial response,\ndocumentation, contact of the appropriate parties to investigate and resolve, and follow-up to\nensure closure of the issues.\n11. § 195.446 Control room management\n(a) General. This section applies to each operator of a pipeline facility with a\ncontroller working in a control room who monitors and controls all or part of a\npipeline facility through a SCADA system. Each operator must have and follow\nwritten control room management procedures that implement the requirements of\nthis section. . . .\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. An\noperator's plan must include provisions to:\n(1) Review SCADA safety-related alarm operations using a process that ensures\nalarms are accurate and support safe pipeline operations.\nColt Hub’s CRMP was not adequate because it did not identify safety-related points. It did identify\nin sections 504 and 505 that safety-related alarms are Priority 100, Priority 200, and Priority 300,\nand it only provided limited examples of these points. Without a determination of priority, this\nprocedure indicates that all points are safety-related. A review of the Determination of Alarm\nRationalization/Priority provided different priority assignments as P1, P2, P3, and P4 in Table 1:\nSeverity Table. It is unclear whether the two priority sets are the same and just mislabeled or if\nthey represent something different in the alarm rationalization/prioritization process and\ndesignation. Additionally, there were alarm levels suggested in Section 504 of the CRMP, but not\ndescribed. How something is determined to be safety-related is unclear, as safety-related points\nrelate to multiple priorities. For example, if a discharge pressure transmitter is a safety-related\npoints, it is unclear whether all alarm levels are considered to be safety-related or only the HIHI\nPriority.\n\n\n\nThe procedure must be amended to define the practice of how a point and alarm is determined to\nbe safety related. The procedure also must include a broad example that identifies the safety-\nrelated points for the pipeline systems covered by the CRM Plan and how these are implemented\nin the SCADA Master Database and presented to the controller.\n12. § 195.446 Control room management\n(a) General. This section applies to each operator of a pipeline facility with a\ncontroller working in a control room who monitors and controls all or part of a\npipeline facility through a SCADA system. Each operator must have and follow\nwritten control room management procedures that implement the requirements of\nthis section. . . .\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. 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.\nColt Hub’s CRMP was not adequate to identify, at least once each calendar month, points\naffecting safety that have been taken off scan in the SCADA host, have had alarms inhibited,\ngenerated false alarms, or that have had forced or manual values for periods of time exceeding\nthat required for associated maintenance or operating activities. The CRMP lacked a process for\nmonthly identification, recording, review, and analysis of points that have been taken off scan,\nhave had alarms inhibited, generated false alarms, or that have had forced or manual values for\nperiods of time exceeding that required for associated maintenance or operating activities.\nAdditionally, the procedure did not require deficiencies identified to be corrected and analysis to\nbe documented.\nThe procedure must be amended to require identification, recording, analysis, and correction of\nidentified deficiencies of points that have been taken off scan, have had alarms inhibited,\ngenerated false alarms, or that have had forced or manual values for periods of time exceeding\nthat required for associated maintenance or operating activities. A record of the monthly results\nmust be maintained.\n13. 195.446 Control room management\n(a) General. This section applies to each operator of a pipeline facility with a\ncontroller working in a control room who monitors and controls all or part of a\npipeline facility through a SCADA system. Each operator must have and follow\nwritten control room management procedures that implement the requirements of\nthis section. . . .\n\n\n\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. 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.\nColt Hub’s CRMP was not adequate to address deficiencies identified through the\nimplementation of paragraphs (e)(1) through (e)(5) of this section. Specifically, CRMP section\n510 simply stated, “[d]eficiencies identified shall be documented for compliance with\nrequirements, and shall be kept by Operations Supervisor in memorandum or other acceptable\nform or inspection form. Form # 510 CRM Action Items Plan can also be used.”\n§ 195.446(e)requires much more than identification and documentation; to address the identified\ndeficiencies, action is required to correct the deficiencies. CRMP section 500 addressed the\nrequirements of §§ 195.446(e)(1) through (e)(5), and each requirement has the potential to\nidentify deficiencies that require correction to ensure alarms are managed to demonstrate\ncompliance. Each method to address the deficiency may be different depending upon the finding.\nThe procedure must be amended to address how identified deficiencies will be\naddressed for each of the various sections in §§ 195.446(e)(1) through (e)(5).\n14. § 195.446 Control room management\n(a) General. This section applies to each operator of a pipeline facility with a\ncontroller working in a control room who monitors and controls all or part of a\npipeline facility through a SCADA system. Each operator must have and follow\nwritten control room management procedures that implement the requirements of\nthis section. . . .\n(b) . . . .\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 accidents that must be reported pursuant to §195.50 and 195.52 to\ndetermine if control room actions contributed to the event and, if so, correct, where\nnecessary, deficiencies related to: (i) Controller fatigue; (ii) Field equipment; (iii)\nThe operation of any relief device; (iv) Procedures; (v) SCADA system\nconfiguration; and (vi) SCADA system performance.\nColt Hub’s CRMP was not adequate to review accidents that must be reported pursuant to §195.50\nand § 195.52 to determine if control room actions contributed to the event and, if so, correct, where\nnecessary, deficiencies to the stated elements. Specifically, CRMP section 700 did not provide a\nprocess on how reviews will be conducted and who is responsible for those reviews to determine if\ncontrol room actions contributed to the event. Section 700 stated, “[t]he company will use O&M\nprocedures to support a root cause investigation,” and “[t]he company may use the concepts and\nprocedures described in ‘Investigating the Possible Contribution of Fatigue to Pipeline Mishaps’\n\n\n\nwhite paper.” If there is a corporate review process for reportable incident review, it was not\nreferenced. Such a procedure typically will address the items in § 195.446 (1)(i)-(vi). The CRMP\nprocedure only addressed fatigue.\nThe procedure also did not address who will conduct the review of reportable accidents, pursuant\nto § 195.50 and § 195.52, nor did it address how the review will be conducted, in order.to\ndetermine whether control room actions contributed to the event and, if so, correct, where\nnecessary, deficiencies related to: (i) Controller fatigue; (ii) Field equipment; (iii) The operation\nof any relief device; (iv) procedures; (v) SCADA system configuration; and (vi) SCADA system\nperformance.\nCRMP section 702 stated the operator would, “[i]nclude lessons learned from all events into the\nCRM training Program as appropriate.” The procedure indicated Form 702-1, “Incident\nInvestigation Due to Potential Fatigue,” appears to limit lessons learned to only fatigue.\nThe procedure must be amended to provide a detailed process of (1) how reviews will be\nconducted and who is responsible and accountable for the review of reportable events to\ndetermine if control room actions contributed to the event; and (2) how to correct identified\ndeficiencies where necessary. If there is a corporate review process, this must be referenced and\nshould include the appropriate coordination with the control room, especially in determination of\nlessons learned. If that process is not adequate to address the compliance requirements of this\nsection, then amendments must be made to either the CRMP, the corporate plan, or both. Even if\nthe controller did not “cause the event,” at a minimum in the amended procedures, consideration\nmust be given to review of SCADA event log and a review of controller schedules to determine\nif control room actions contributed to the event.\n15. § 195.446 Control room management\n(a) General. This section applies to each operator of a pipeline facility with a\ncontroller working in a control room who monitors and controls all or part of a\npipeline facility through a SCADA system. Each operator must have and follow\nwritten control room management procedures that implement the requirements of\nthis section. . . .\n(b) . . . .\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. In addition, the training program must\ninclude the following elements:\n(1) . . . .\n(6) Control room team training and exercises that include both controllers and other\nindividuals, defined by the operator, who would reasonably be expected to\noperationally collaborate with controllers (control room personnel) during normal,\nabnormal or emergency situations. Operators must comply with the team training\nrequirements under this paragraph no later than January 23, 2018.\n\n\n\nColt Hub’s CRMP was not adequate to provide training program content and a detailed process\nfor team training of both controllers and other individuals, as defined by the operator, who would\nreasonably be expected to operationally collaborate with controllers (control room personnel)\nduring normal, abnormal or emergency situations. Specifically, in CRMP Section 803, there was\nsimply a bullet point that stated, “Team Training.” The CRMP did not establish who, regardless\nof location, operationally collaborates with control room personnel. It also did not define the\nfrequency of training, for example, initial training and recurring training. The CRMP also did not\nprovide detail on topics and content that would be required for team training, which must include\nsome type of soft skill training as well as training on the three modes of normal, abnormal, and\nemergency.\nThe procedure must be amended to include a list of who, regardless of location, operationally\ncollaborates with control room personnel, a detailed process for team training that includes\ncontent or reference to other materials, all three modes of normal, abnormal, and emergency\nsituations, a requirement that at least one controller must participate in all team training sessions,\nand a frequency for initial and recurring training.\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\n30 days of receipt of this Notice. This period may be extended by written request for good cause.\nOnce the inadequacies identified herein have been addressed in your amended procedures, this\nenforcement action will be closed.\nIt is requested that Crestwood Midstream Partners, LP’s/Colt Connector Pipeline’s (Colt Hub)\n\n\n\nmaintain documentation of the safety improvement costs associated with fulfilling this Notice of\nAmendment (preparation/revision of plans, procedures) and submit the total to Gregory Ochs,\nDirector, Central Region, Pipeline and Hazardous Materials Safety Administration. In\ncorrespondence concerning this matter, please refer to CPF 3-2024-021-NOA and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nGregory Ochs\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\ncc: Eric Amundsen/ SVP Operations eric.amundsen@energytransfer.com\nTodd Nardozzi/ Director – Regulatory Compliance todd.nardozzi@energytransfer.com\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings","truncated":false,"body_characters":39554}