{"operation":"document","citation":"CPF 52022014WL","title":"SOUTHWEST GAS CORP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-06-02","effective_on":null,"summary":"CLOSED warning letter citing 192.631(a)(2), 192.631(b)(4), 192.631(c)(2), 192.631(e)(2), 192.631(e)(3), 192.631(f)(2), 192.631(h)(2), 192.631(j)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-52022014wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-52022014wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-52022014wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/52022014WL","body":"Warning Letter involving SOUTHWEST GAS CORP. PHMSA's enforcement data identifies the cited regulations as 192.631(a)(2),  192.631(b)(4),  192.631(c)(2),  192.631(e)(2),  192.631(e)(3),  192.631(f)(2),  192.631(h)(2),  192.631(j)(1). The case was opened on 2022-06-02 and is reported as closed as of 2022-06-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n52022014WL_Operator Response to Notice_07052022_(21-201158).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022014WL/52022014WL_Operator%20Response%20to%20Notice_07052022_(21-201158).pdf\n\n52022014WL_Warning Letter_06022022_(21-201158).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022014WL/52022014WL_Warning%20Letter_06022022_(21-201158).pdf\n\n52022014WL_Warning Letter_06022022_(21-201158)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022014WL/52022014WL_Warning%20Letter_06022022_(21-201158)_text.pdf\n\n52022014WL_Warning Letter_06022022_(21-201158)_text.pdf\n\nWARNING LETTER\nVIA E-MAIL TO MR. JEROME T. SCHMITZ\nJune 2, 2022\nMr. Jerome T. Schmitz\nVice President – Engineering\nSouthwest Gas Transmission\nLVA-581\n5241 Spring Mountain Road\nLas Vegas, Nevada 89150\nCPF 5-2022-014-WL\nDear Mr. Schmitz:\nFrom May 10 through May 14, 2021, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.),\ninspected Southwest Gas Transmission’s (SWG) Las Vegas Control Room in Las Vegas,\nNevada.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. §192.631 Control room management.\n(a) General.\n(1) …\n\n\n\n(2) The procedures required by this section must be integrated, as appropriate, with\noperating and emergency procedures required by §§192.605 and 192.615. 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 must\nbe implemented no later than October 1, 2011. The procedures required by\nparagraphs (c)(1) through (4), (d)(1), (d)(4), and (e) must be implemented no later\nthan August 1, 2012. The training procedures required by paragraph (h) must be\nimplemented no later than August 1, 2012, except that any training required by\nanother paragraph of this section must be implemented no later than the deadline\nfor that paragraph.\nSWG failed to integrate and implement Team Training procedures into its operating and\nemergency procedures required by §§192.605 and 192.615. Pursuant to §192.631(h)(6),\noperators must implement team training requirements no later than January 23, 2018. According\nto SWG’s Gas Control Policy (issued date: December 31, 2018; effective date: January 31,\n2019), in the “Manual Section Revision Review and Approval Record,” Team Training was not\nadded to the control room training program until October/November 2018.\n2. §192.631 Control room management.\n(a) …\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;\nSWG failed to provide for a controller’s prompt and appropriate response to operating conditions\nby defining a method of recording controller shift-changes and any hand-over responsibility\nbetween controllers.\nSpecifically, SWG failed to properly document shift change records associated with shift\nchanges that occurred on:\n1. June 10, 2018; December 25, 2019; October 5, 2020 – Records failed to document\nincoming and outgoing controller names consistently. Some records had primary\ncontrollers listed only while others had secondary controllers listed.\n2. October 15, 2020 – Day Shift: Outgoing controller did not sign shift change. No\nacknowledgement by incoming controller that all items were covered during the\nhandover.\n3. October 15, 2020 – Night Shift: Outgoing controller did not sign shift change. No\nacknowledgement by incoming controller that all items were covered during the\nhandover.\n\n\n\n4. October 16, 2020 - Day Shift: Outgoing controller did not sign shift change. No\nacknowledgement by incoming controller that all items were covered during the\nhandover.\n5. October 16, 2020 – Night Shift: Outgoing controller did not sign shift change. No\nacknowledgement by incoming controller that all items were covered during the\nhandover.\n6. October 17, 2020 - Day Shift: Outgoing controller did not sign shift change. No\nacknowledgement by incoming controller that all items were covered during the\nhandover.\n7. October 18, 2020 - Day Shift: Outgoing controller did not sign shift change. No\nacknowledgement by incoming controller that all items were covered during the\nhandover.\n8. November 8, 2020 – Day Shift: No acknowledgement by incoming controller that all\nitems were covered during the handover.\n9. April 21, 2021 – Night Shift: No acknowledgement by incoming controller that all items\nwere covered during the handover.\n3. §192.631 Control room management.\n(a) …\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;\nSWG failed to provide its controllers with the information, tools, processes and procedures\nnecessary to carry out controllers’ roles and responsibilities by failing to conduct a point-to-point\nverification between SCADA displays and related field equipment when field equipment is\nadded or moved and when other changes that affect pipeline safety are made.\nSWG’s records failed to demonstrate the extent of verification, including physical location of\ndevice, data value or status, any alarm settings, and to assure that any test signals are injected at\nthe actual device in the field. For example, records dated December 6, 2018, and June 18, 2019\nfailed to include or demonstrate set point values or alarm levels, and failed to document the\nlocation of the device. Furthermore, the records were insufficient to demonstrate that the\nSCADA displays were checked and the range of the analog device and the range of the display\nfor a given point are similar, making sure that values other than the point checked are correct.\n4. §192.631 Control room management.\n(a) …\n(e) Alarm management. Each operator using a SCADA system must have a written\n\n\n\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;\nSWG failed to 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 alarms, or that\nhave had forced or manual values for periods of time exceeding that required for associated\nmaintenance or operating activities.\nSpecifically, SWG’s monthly alarm review records failed to indicate if corrective actions were\ntaken associated with points affecting safety. For example, SWG’s records failed to document\nwhat corrective actions occurred, when they were conducted, or whether those safety points were\nreturned to service. The records only stated, \"I either had no findings associated with the review\nof attached spreadsheets, or took the appropriate action to resolve any issues.\"\n5. §192.631 Control room management.\n(a)…\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(3) Verify the correct safety-related alarm set-point values and alarm descriptions at\nleast once each calendar year, but at intervals not to exceed 15 months;\nSWG failed to verify the correct safety-related alarm set-point values and alarm descriptions at\nleast once each calendar year, but at intervals not to exceed 15 months.\nSWG failed to produce a list or database of safety-related alarm set-point values and alarm\ndescriptions during the inspection. It’s unclear how the operator can conduct a verification\nwithout an actual list or database of these items.\n6. §192.631 Control room management.\n(a) …\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) …\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;\n\n\n\nSWG failed to assure that changes that could affect control room operations are coordinated with\ncontrol room personnel by requiring its field personnel to contact the control room when\nemergency conditions exist and when making field changes that affect control room operations.\nSWG’s records for pressure stations and meter set assembly and valve inspections failed to\nconfirm that the control room was contacted prior to and after completing the inspections.\nRecords reviewed included:\n1. September 15, 2020, Horizon Ridge East Pls Run 1 Temp inspection.\n2. May 13, 2020, Tcat1 Stat Insp - Wigwam Pls/Gibson Run 2.\n7. §192.631 Control room management.\n(a) …\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(2) Use of a computerized simulator or non-computerized (tabletop) method for\ntraining controllers to recognize abnormal operating conditions;\nSWG failed to establish a controller training program that included the use of a computerized\nsimulator or tabletop method for training controllers to recognize abnormal operating conditions\npursuant to § 192.631(h)(2).\nWhile reviewing training records for the newest controller, the records failed to indicate or\ndemonstrate the controller had an adequate understanding of recognizing abnormal operating\nconditions. The records only indicated that the controller took the training. No grading or\npass/fail criterion was established to demonstrate proficiency in the training module.\n8. §192.631 Control room management.\n(a)…\ninspection:\n(j) Compliance and deviations. An operator must maintain for review during\n(1) Records that demonstrate compliance with the requirements of this section;\nSWG failed to provide for review during the inspection training records showing adequate\ncompetency of training modules identified in the training program (Gas Control Department\nPolicy, Issue Date: December 31, 2018, Section 9 – Training), and the Gas Controller Catalog -\nGas Control Technician Training Program, which has no date when it was established, issued, or\nimplemented.\n\n\n\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$239,142 per violation per day the violation persists, up to a maximum of $2,391,142 for a\nrelated series of violations. For violation occurring on or after May 3, 2021 and before March\n21, 2022, the maximum penalty may not exceed $225,134 per violation per day the violation\npersists, up to a maximum of $2,251,334 for a related series of violations. For violation\noccurring on or after January 11, 2021 and before May 3, 2021, the maximum penalty may not\nexceed $222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for\na related series of violations. For violation occurring on or after July 31, 2019 and before\nJanuary 11, 2021, the maximum penalty may not exceed $218,647 per violation per day the\nviolation persists, up to a maximum of $2,186,465 for a related series of violations. For violation\noccurring on or after November 27, 2018 and before July 31, 2019, the maximum penalty may\nnot exceed $213,268 per violation per day, with a maximum penalty not to exceed $2,132,679.\nFor violation occurring on or after November 2, 2015 and before November 27, 2018, the\nmaximum penalty may not exceed $209,002 per violation per day, with a maximum penalty not\nto exceed $2,090,022.\nWe have reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the items identified in this letter. Failure to do so will result in\nSouthwest Gas being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2022-014-WL. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nDustin Hubbard\nDirector, Western Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 D. Fehling (#21-201158)","truncated":false,"body_characters":14485}