{"operation":"document","citation":"CPF 520156003M","title":"FRONT RANGE PIPELINE, LLC. — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-07-28","effective_on":null,"summary":"CLOSED notice of amendment citing 195.446(b)(3), 195.446(c)(2), 195.446(c)(3), 195.446(d), 195.446(d)(4), 195.446(f)(1), 195.446(f)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520156003m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520156003m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520156003m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520156003M","body":"Notice of Amendment involving FRONT RANGE PIPELINE, LLC.. PHMSA's enforcement data identifies the cited regulations as 195.446(b)(3),  195.446(c)(2),  195.446(c)(3),  195.446(d),  195.446(d)(4),  195.446(f)(1),  195.446(f)(2). The case was opened on 2015-07-28 and is reported as closed as of 2016-02-23. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520156003M_Closure Letter_02232016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520156003M/520156003M_Closure%20Letter_02232016.pdf\n\n520156003M_Closure Letter_02232016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520156003M/520156003M_Closure%20Letter_02232016_text.pdf\n\n520156003M_notice of amendment_07282015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520156003M/520156003M_notice%20of%20amendment_07282015.pdf\n\n520156003M_notice of amendment_07282015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520156003M/520156003M_notice%20of%20amendment_07282015_text.pdf\n\n520156003M_Operator Response to Notice_08312015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520156003M/520156003M_Operator%20Response%20to%20Notice_08312015.pdf\n\n520156003M_Closure Letter_02232016_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nFebruary 23, 2016\nMr. John Traeger\nPresident\nFront Range Pipeline LLC\n803 HWY 212 S\nP.O. Box 909\nLaurel, MT 59044\nCPF 5-2015-6003M\nDear Mr. Traeger:\nBetween December 17, 2013 and June 26, 2014, 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 Front Range Pipeline LLC’s\n(Front Range) procedures for your Control Room Management (CRM) in Laurel, Montana. As\na result of the inspection, Front Range was issued a Notice of Amendment on July 28, 2015,\nwhich proposed amendment of your procedures.\nFront Range submitted its amended procedures on December 31, 2015. My staff reviewed the\namended procedures, and it appears that the inadequacies outlined in this Notice of\nAmendment have been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank\nyou for your cooperation.\nSincerely,\nFor Chris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\n\n520156003M_notice of amendment_07282015_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJuly 28, 2015\nMr. John Traeger\nPresident\nFront Range Pipeline LLC\n803 HWY 212 S\nP.O. Box 909\nLaurel, MT 59044\nCPF 5-2015-6003M\nDear Mr. Traeger:\nBetween December 17, 2013 and June 26, 2014, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\ninspected Front Range Pipeline LLC’s (Front Range) procedures for your Control Room\nManagement (CRM) in Laurel, Montana. Your CRM procedures also apply to the Cenex Pipeline,\nLLC (Cenex), OPID 2170. Cenex was issued a Notice of Amendment (CPF 5-2015-5016M),\ndated July 23, 2015 for apparent inadequacies in their CRM procedures.\nOn the basis of the inspection, PHMSA identified the same inadequacies within Front Range’s\nControl Room Management plans or procedures, as described below:\n\n\n\n1. §195.446 Control room management.\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(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 actions\nand to communicate with others.\nFront Range did not establish adequate written procedures to address a controller’s role during an\nemergency as required by §195.446(b) (3). During the inspection, it was determined that the\nprocedures in the Front Range CRM manual do not specifically address the controller’s\nresponsibilities in the event the control room must be evacuated. As a result, Front Range must\nmodify the procedures in the CRM manual to specifically address the controller’s responsibilities\nin the event the control room must be evacuated.\n2. §195.446 Control room management.\n(c) Provide adequate information. Each operator must provide its controllers with\nthe information, tools, processes and procedures necessary for the controllers to carry\nout the roles and responsibilities the operator has defined by performing each of the\nfollowing:\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.\nFront Range did not establish adequate written procedures for conducting a point-to-point\nverification as required by §195.446(c) (2). During the inspection, it was determined that the\nprocedures in the Front Range CRM manual do not fully define safety related points to include\neach of the following items:\n1. Points associated with all safety-related alarms and control points must be included.\n2. Procedures should be established to define which points are declared as safety-related.\n3. Operator should have a list (or database) of points that indicates whether or not each point\nis safety-related.\n4. 5. 6. 7. Procedures should also address criteria for treating points as safety-related.\nStation inlet and discharge pressures should fall into the safety-related category.\nPressure Regulator inlet and outlet pressures should fall into the safety-related category.\nSoft points (points created in SCADA software) should be considered when determining a\nlist of safety-related points.\n8. Examples of safety-related points are provided in FAQ C.01.\nIn addition, the CRM plan does not fully address the following issues concerning establishment\nand implementation of procedures for the thoroughness of the point-to-point verification:\n1. The procedure must define the extent of verification to include physical location of device,\ndata value or status, any alarm settings, and to assure that any test signals are injected at\nthe actual device in the field.\n2. The verification procedure must include a requirement to check a representative sampling\n2\n\n\n\n3. 4. 5. of impacted displays (FAQ C.03).\nIf the verification process includes partial simulation, the operator must establish a\nprocedure to define when simulation should be used in point-to-point verification (FAQ\nC.05).\nIf the verification process includes partial simulation, the operator must establish a\nprocedure to define what type(s) of simulation is/are applicable for specific instruments\nand equipment during point-to-point verification (FAQ C.05).\nThe process should verify the actual physical location and sequence among other devices\nand equipment at the location; and verify the data, information and any control or alarm\nfunctions to/from the point are being accurately represented on all SCADA displays on\nwhich it resides (FAQ C.02 and C.06).\nFurthermore, the plan does not specifically indicate the timeframe as to when the point-to-point\nverification must be completed. As a result, Front Range must modify the procedures in the CRM\nmanual to address these issues.\n3. §195.446 Control room management.\n(c) Provide adequate information. Each operator must provide its controllers with\nthe information, tools, processes and procedures necessary for the controllers to carry\nout the roles and responsibilities the operator has defined by performing each of the\nfollowing:\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.\nFront Range did not establish adequate written procedures for testing and verifying an internal\ncommunication plan as required by §195.446(c) (3). During the inspection, it was determined that\nthe procedures in the Front Range CRM manual do not include procedures to test and verify an\ninternal communication plan to provide adequate means for manual operation of the pipeline\nsafely, at least once each calendar year, but at intervals not to exceed 15 months. As a result, Front\nRange must modify the procedures in the CRM manual to include procedures to address this issue.\n4. §195.446 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.\nFront Range did not establish adequate written procedures to address the risk associated with\ncontroller fatigue as required by §195.456(d). During the inspection, it was determined that the\nprocedures in the Front Range CRM manual do not require the potential contribution of controller\nfatigue to incidents and accidents be quantified during investigations. As a result, Front Range\nmust modify the procedures in the Front Range CRM manual to address this issue, i.e. see FAQ\nD.12 and white paper entitled “Investigating the Possible Contribution of Fatigue to Pipeline\nMishaps” (http://primis.phmsa.dot.gov/crm/fm.htm) for fatigue factors that should be considered in\naccident/incident investigations. See instructions for incident report forms PHMSA F 7100.1,\n7100.2, and 7000-1, and requirements for reporting incident causes in accordance with 191.9,\n3\n\n\n\n191.15, and 195.54. Forms and instructions are available online at:\nhttp://www.phmsa.dot.gov/pipeline/library/forms.\n5. §195.446 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 of\na pipeline facility.\nFront Range did not establish adequate written procedures for determining a maximum limit on\ncontroller hours-of-service as required by §195.446(d) (4). During the inspection, it was\ndetermined that the procedures in the Front Range CRM manual do not clearly define the shift start\nand end times of the controllers. As a result, Front Range must modify the procedures in the Front\nRange CRM manual to clearly define the shift start and end times of the controllers.\n6. §195.446 Control room management.\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) Implement section 7 of API RP 1168 (incorporated by reference, see § 195.3) for\ncontrol room management change and require coordination between control room\nrepresentatives, operator's management, and associated field personnel when\nplanning and implementing physical changes to pipeline equipment or configuration.\nFront Range did not establish adequate written procedures for implementing section 7 of API RP\n1168 as required by §195.446(f)(1). During the inspection, it was determined that the procedures in\nthe Front Range CRM manual do not require implementation of section 7 of API RP 1168 for\ncontrol room management change and require coordination between control room representatives,\noperator's management, and associated field personnel when planning and implementing physical\nchanges to pipeline equipment or configuration. In addition, the CRM plan does not have a\nprocess/procedure to assure changes in field equipment (for example, moving a valve) that could\naffect control room operations are coordinate with the control room personnel.\nAs a result, Front Range must modify the procedures in the CRM manual to address these issues\nand incorporate the following:\n1. Procedures must manage SCADA and data communications maintenance or configuration\nactivities to assure controllers are aware of, review, and provide input, in advance of work.\n2. Records must demonstrate that field personnel have contacted the control room whenever\nrequired by procedure.\n3. When temporary changes are no longer necessary, return to normal constitutes the need to\ninvoke the change management procedure.\n4. Do the operator’s procedures include guidance or a description of what changes in field\nequipment would constitute the need to invoke change management provisions. Examples\ninclude but are not limited to: purchase or sale of physical assets; new equipment coming\n4\n\n\n\n5. 6. online; retired equipment going offline; and field maintenance activity affecting pipeline\ncontrol room operation (FAQs F.01 and F.02).\nEnsure there is a procedure to mandate that a control room representative will participate in\nmeetings where changes that could directly or indirectly affect control room operations\n(including routine maintenance and repairs) are being considered, designed and\nimplemented. The actual control room representative must have sufficient familiarity with\ncontrol room activities to adequately perform this task. The control room representative\nmust adequately communicate related information to impacted controllers.\nRecords should include meeting topics and communiqué created for controllers, i.e. see\nAPI RP-1168 section 7 for examples.\nBefore implementing changes, provide controllers with notification and training to assure\nthe controller’s ability to safely incorporate the proposed change into their operations, i.e.\nsee API RP-1168 section 7.3 for specific information.\n7. §195.446 Control room management.\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(2) Require its field personnel to contact the control room when emergency\nconditions exist and when making field changes that affect control room operations.\nFront Range did not establish adequate written procedures for requiring the field personnel to\ncontact the control room when emergency conditions exit as required by §195.446(f)(2). During\nthe inspection, it was determined that the procedures in the Front Range CRM manual do not\nrequire field personnel to contact the control room when emergency conditions exist and when\nmaking field changes that affect control room operations. As a result, Front Range must modify the\nprocedures in the CRM manual to address this issue and incorporate the following:\n1. 2. 3. 4. 5. 6. Field personnel must communicate with the control room immediately upon discovery of\nan emergency condition.\nRecords must demonstrate that field personnel have contacted the control room whenever\nemergency conditions existed.\nField personnel must communicate with the control room before any equipment is being\nput into local control or returned to remote control.\nField personnel must communicate with the control room before any equipment is being\ntaken out of service or returned to service.\nField personnel should alert the control room before personnel enter a SCADA-controlled\nfacility (including but not limited to compressor/pump stations, meter stations, main-line\nvalves, etc.), which is normally unattended.\nField personnel should be trained to call the controller when making field changes that\nhave the potential to affect control room operations.\n5\n\n\n\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. A similar\nNotice was sent to Cenex Pipeline LLC which utilizes the same CRM procedures as Front Range\nPipeline Company. Enclosed as part of this Notice is a document entitled Response Options for\nPipeline Operators in Compliance Proceedings. Please refer to this document and note the\nresponse options. Be advised that all material you submit in response to this enforcement action is\nsubject to being made publicly available. If you believe that any portion of your responsive\nmaterial qualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete\noriginal document you must provide a second copy of the document with the portions you believe\nqualify for confidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b). If you do not respond\nwithin 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the\nallegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find\nfacts as alleged in this Notice without further notice to you and to issue a Final Order.\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in this\nNotice, you may be ordered to amend your plans or procedures to correct the inadequacies (49\nC.F.R. § 190.237). If you are not contesting this Notice, we propose that you submit your\namended procedures to my office within 60 days of receipt of this Notice. This period may be\nextended by written request for good cause. Once the inadequacies identified herein have been\naddressed in your amended procedures, this enforcement action will be closed.\nIt is requested (not mandated) that Front Range Pipeline LLC maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Chris Hoidal, Director, Western Region, Pipeline and\nHazardous Materials Safety Administration. In correspondence concerning this matter, please refer\nto CPF 5-2015-6003M and, for each document you submit, please provide a copy in electronic\nformat whenever possible.\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\ncc: PHP-60 Compliance Registry\nPHP-500 M. Petronis (#148705)\n6","truncated":false,"body_characters":18192}