{"operation":"document","citation":"CPF 420191008M","title":"TENNESSEE GAS PIPELINE COMPANY — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-05-13","effective_on":null,"summary":"CLOSED notice of amendment citing 192.631(d)(4), 192.631(e)(5).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420191008m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420191008m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420191008m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420191008M","body":"Notice of Amendment involving TENNESSEE GAS PIPELINE COMPANY. PHMSA's enforcement data identifies the cited regulations as 192.631(d)(4),  192.631(e)(5). The case was opened on 2019-05-13 and is reported as closed as of 2019-11-04. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420191008M_Closure Letter_11042019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420191008M/420191008M_Closure%20Letter_11042019.pdf\n\n420191008M_Closure Letter_11042019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420191008M/420191008M_Closure%20Letter_11042019_text.pdf\n\n420191008M_Notice of Amendment_05132019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420191008M/420191008M_Notice%20of%20Amendment_05132019.pdf\n\n420191008M_Notice of Amendment_05132019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420191008M/420191008M_Notice%20of%20Amendment_05132019_text.pdf\n\n420191008M_Operator Response to Notice_08152019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420191008M/420191008M_Operator%20Response%20to%20Notice_08152019.pdf\n\n420191008M_Notice of Amendment_05132019_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMay 13, 2019\nGary Buchler\nVice President, Operations and Engineering\nTennessee Gas Pipeline Company\n1001 Louisiana Street\nHouston, Texas 77002\nCPF 4-2019-1008M\nDear Mr. Buchler:\nFrom September 17-21, 2018, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Tennessee\nGas Pipeline Company’s (TGP) procedures for Control Room Management in Houston, Texas.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nTGP’s plans or procedures, as described below:\n1. §192.631 Control room management.\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(4) Establish a maximum limit on controller hours-of-service, which may provide for\nan emergency deviation from the maximum limit if necessary for the safe operation\nof a pipeline facility.\n\n\n\nTGP’s written control room management procedure, HOU-GC-5, is inadequate because it does\nnot instruct controllers to use appropriate fatigue mitigation measures when working during certain\nhigh-risk hours. TGP’s procedure only requires that control room personnel utilize fatigue\nmitigation tactics between the hours of 2 am through 5 am. This requirement does not meet all of\nthe scenarios where fatigue mitigation must be used.\nPHMSA’s control room management FAQ section D.07 provides the following guidance for\ncontrollers working beyond the traditional 8-5, 5-day schedule.\n6. Fatigue mitigation tactics should be implemented during shifts/times of increased fatigue\nrisk, as shown by research and/or fatigue modeling, including:\na. Any and all shift duty hours worked after the first 8 hours.\nb. Any and all hours worked between 2:00 am and 6:00 am.\nc. Any and all successive night shifts following three successive nights.\nd. Any and all day or night shifts following four successive night shifts unless three\nnocturnal sleep cycles have been completed.\nTGP must amend their procedures to require fatigue mitigation tactics be employed during all\ntimes of increased risk, or provide justification demonstrating that this deviation from parameters\ndoes not elevate the fatigue risk.\n2. §192.631 Control room management.\n(e) Alarm management. Each operator using a SCADA system must have a written\nalarm management plan to provide for effective controller response to alarms. An\noperator's plan must include provisions to:\n(5) Monitor the content and volume of general activity being directed to and required\nof each controller at least once each calendar year, but at intervals not to exceed 15\nmonths, that will assure controllers have sufficient time to analyze and react to\nincoming alarms;\nTGP’s written control room management procedure HOU-GC-7a is inadequate because it does not\nprovide parameters or thresholds for determining whether controllers have sufficient time to\nanalyze and react to incoming alarms. TGP’s procedure describes the process for measuring and\ncalculating controller workloads, but fails to set thresholds or parameters for determining whether\nthese workloads are adequate. TGP must amend their procedures to include thresholds or\nparameters to determine whether the controller workloads are adequate.\n2\n\n\n\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 Compliance\nProceedings. Please refer to this document and note the response options. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for confidential\ntreatment under 5 U.S.C. 552(b), along with the complete original document you must provide a\nsecond copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 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 Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 30 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that TGP maintain documentation of the safety improvement costs\nassociated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures)\nand submit the total to Mary L. McDaniel, Director, Southwest Region, Pipeline and Hazardous\nMaterials Safety Administration. In correspondence concerning this matter, please refer to CPF\n4-2019-1008M and, for each document you submit, please provide a copy in electronic format\nwhenever possible.\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n3\n\n420191008M_Closure Letter_11042019_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 4, 2019\nGary Buchler\nVice President, Operations and Engineering\nTennessee Gas Pipeline Company\n1001 Louisiana Street\nHouston, Texas 77002\nCPF 4-2019-1008M\nDear Mr. Buchler:\nFrom September 17-21, 2018, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Tennessee\nGas Pipeline Company’s (TGP) procedures for Control Room Management in Houston, Texas.\nAs a result of the inspection, TGP was issued a Notice of Amendment on May 14, 2019, which\nproposed amendment of your procedures.\nTGP submitted its amended procedures on August 15, 2019. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":8237}