{"operation":"document","citation":"CPF 520186008M","title":"TESORO ALASKA PIPELINE COMPANY LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-03-16","effective_on":null,"summary":"CLOSED notice of amendment citing 195.446(a), 195.446(c), 195.446(e)(1), 195.446(j).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520186008m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520186008m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520186008m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520186008M","body":"Notice of Amendment involving TESORO ALASKA PIPELINE COMPANY LLC. PHMSA's enforcement data identifies the cited regulations as 195.446(a),  195.446(c),  195.446(e)(1),  195.446(j). The case was opened on 2018-03-16 and is reported as closed as of 2018-07-05. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520186008M_Notice of Amendment_03162018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520186008M/520186008M_Notice%20of%20Amendment_03162018.pdf\n\n520186008M_Notice of Amendment_03162018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520186008M/520186008M_Notice%20of%20Amendment_03162018_text.pdf\n\n520186008M_Operator Response To Notice and Request for Hearing_04202018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520186008M/520186008M_Operator%20Response%20To%20Notice%20and%20Request%20for%20Hearing_04202018.pdf\n\n520186008M_Region Withdrawal of Notice Letter_07052018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520186008M/520186008M_Region%20Withdrawal%20of%20Notice%20Letter_07052018.pdf\n\n520186008M_Region Withdrawal of Notice Letter_07052018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520186008M/520186008M_Region%20Withdrawal%20of%20Notice%20Letter_07052018_text.pdf\n\n520186008M_Notice of Amendment_03162018_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMarch 16, 2018\nMr. Don Sorenson\nSenior Vice President, Logistics\nTesoro Alaska Pipeline Company LLC\n19100 Ridgewood Parkway\nSan Antonio, TX 78259\nCPF 5-2018-6008M\nDear Mr. Sorenson:\nOn several occasions between September 11, 2017 and September 20, 2017, a representative\nof the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline\nSafety (OPS), pursuant to Chapter 601 of 49 United States Code, inspected Tesoro Alaska\nPipeline Company LLC (Tesoro) procedures for Control Room Management (CRM) in\nNikiski and Anchorage, Alaska.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nTesoro’s plans or procedures, as described below:\n\n\n\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.\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:\nTesoro’s Preventative Maintenance (SAP) system inventory was inadequate for not listing the\nsafety-related point for the pressure transmitter, PT 002a located at the Anchorage terminal.\nPT 002a was not part of the SAP system inventory. There are four safety-related points in the\nsystem, at the time of the inspection, only the three Nikiski Terminal safety-related points\nwere listed in the SAP system inventory. Operational procedures must insure that preventative\nmaintenance tasks for safety related points are completed and tracked in a comprehensive,\nreliable, and repeatable manner. The tracking of preventative maintenance tasks for the three\nsafety related points at the Nikiski facility in one system separate from the system used for the\nsingle Anchorage safety related points increases the likelihood that the four points will not be\nmaintained in a like manner.\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.\n…\n(e) Alarm management. Each operator using a SCADA system must have a\nwritten alarm management plan to provide for effective controller response to\nalarms. An 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;\nThe Tesoro document, WP123, specifies that alarm reviews will be completed by the alarm\nreview team which includes, as one of its members, the Alarm System Coordinator. Section 6\nof WP123 identifies specific roles and responsibilities of the Alarm System Coordinator;\nhowever, the document fails to identify which Tesoro staff positions or personnel are deemed\ncompetent to fill this role.\n2\n\n\n\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.\n. . . .\n(j) Compliance and deviations. An operator must maintain for review during\ninspection:\n(1) Records that demonstrate compliance with the requirements of this section;\nand\n(2) Documentation to demonstrate that any deviation from the procedures\nrequired by this section was necessary for the safe operation of the pipeline\nfacility.\nTesoro CRM Procedure 10.2 identifies the following key personnel required for completion of\nthe Tesoro CRM Annual Review Form:\nDOT Compliance Manager\nLogistics Regional Manager\nShift Leaders\nController\nThe Tesoro procedures do not demonstrate a link between the Logistics Regional Manager\nand what person/position fills that role at the Nikiski location. Further, the signature blocks of\nthe Tesoro Control Room Management Review form do not identify the four staff positions\n(DOT Compliance Manager, Logistics Regional Manager, Shift Leaders, and Controller) for\nthe persons placing their signatures as reviewers.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed\nas part of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document\nyou must provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b).\n3\n\n\n\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\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations in\nthis Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as\nalleged in this Notice without further notice to you and to issue an Order Directing\nAmendment. If your plans or procedures are found inadequate as alleged in this Notice, you\nmay be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. §\n190.206). If you are not contesting this Notice, we propose that you submit your amended\nprocedures to my office within 60 days of receipt of this Notice. This period may be extended\nby 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 Tesoro Alaska Pipeline Company LLC maintain\ndocumentation of the safety improvement costs associated with fulfilling this Notice of\nAmendment (preparation/revision of plans, procedures) and submit the total to Kim West,\nActing Director, Western Region, Pipeline and Hazardous Materials Safety Administration. In\ncorrespondence concerning this matter, please refer to CPF 5-2018-6008M and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nKim West\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 M. Chard (#155158)\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n4\n\n520186008M_Region Withdrawal of Notice Letter_07052018_text.pdf\n\nWITHDRAWAL of NOTICE LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJuly 5, 2018\nMr. Don Sorenson\nSenior Vice President, Logistics\nTesoro Alaska Pipeline Company LLC\n19100 Ridgewood Parkway\nSan Antonio, TX 78259\nCPF 5-2018-6008M\nDear Mr. Sorenson:\nOn March 16, 2018, Tesoro Alaska Pipeline Company LLC was issued a Notice of Amendment\nletter for the case number referenced above. This Notice cited Tesoro Alaska Pipeline Company\nLLC for:\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. The procedures required by this section must be integrated, as\nappropriate, with the operator's written procedures required by § 195.402.\n…\n(c) Provide adequate information. Each operator must provide its controllers with the\ninformation, 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:\nTesoro’s Preventative Maintenance (SAP) system inventory was inadequate for not listing the\nsafety-related point for the pressure transmitter, PT 002a located at the Anchorage terminal. PT\n\n\n\n002a was not part of the SAP system inventory. There are four safety-related points in the system,\nat the time of the inspection, only the three Nikiski Terminal safety-related points were listed in\nthe SAP system inventory. Operational procedures must insure that preventative maintenance\ntasks for safety related points are completed and tracked in a comprehensive, reliable, and\nrepeatable manner. The tracking of preventative maintenance tasks for the three safety related\npoints at the Nikiski facility in one system separate from the system used for the single Anchorage\nsafety related points increases the likelihood that the four points will not be maintained in a like\nmanner.\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. The procedures required by this section must be integrated, as\nappropriate, with the operator's written procedures required by § 195.402.\n…\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;\nThe Tesoro document, WP123, specifies that alarm reviews will be completed by the alarm\nreview team which includes, as one of its members, the Alarm System Coordinator. Section 6 of\nWP123 identifies specific roles and responsibilities of the Alarm System Coordinator; however,\nthe document fails to identify which Tesoro staff positions or personnel are deemed competent to\nfill this role.\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. The procedures required by this section must be integrated, as\nappropriate, with the operator's written procedures required by §195.402.\n. . . .\n(j) Compliance and deviations. An operator must maintain for review during\ninspection:\n(1) Records that demonstrate compliance with the requirements of this section; and\n(2) Documentation to demonstrate that any deviation from the procedures required\nby this section was necessary for the safe operation of the pipeline facility.\n2\n\n\n\nTesoro CRM Procedure 10.2 identifies the following key personnel required for completion of the\nTesoro CRM Annual Review Form:\nDOT Compliance Manager\nLogistics Regional Manager\nShift Leaders\nController\nThe Tesoro procedures do not demonstrate a link between the Logistics Regional Manager and\nwhat person/position fills that role at the Nikiski location. Further, the signature blocks of the\nTesoro Control Room Management Review form do not identify the four staff positions (DOT\nCompliance Manager, Logistics Regional Manager, Shift Leaders, and Controller) for the persons\nplacing their signatures as reviewers.\nOn June 7, 2018 Tesoro Alaska Pipeline Company LLC responded that they had listed the pressure\ntransmitter located at the Anchorage terminal in the preventative maintenance (SAP) system for the\nNikiski facility. Although the Tesoro Alaska Pipeline Company LLC previously tracked this\npressure transmitter separately from safety-related points in the Nikiski facility, all four safety-\nrelated points in the system are now listed in the SAP system inventory. Tesoro Alaska Pipeline\nCompany LLC responded that they have amended the Annual Control Room Management\n(“CRM”) and Alarm Management Plan review forms to identify the functional titles (e.g., Alarm\nSystem Coordinator) of the personnel conducting the review and signing the form. This will enable\na reader to identify both the name and staff position of each of the four reviewers required by the\nTesoro Alaska Pipeline Company’s CRM procedure. My staff reviewed the amended forms that\nTesoro Alaska Pipeline Company LLC provided.\nThis letter is to inform you that PHMSA hereby withdraws the Notice and that the case is now\nclosed.\nSincerely,\nKim West\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 M. Chard (#155158)\n3","truncated":false,"body_characters":15151}