{"operation":"document","citation":"CPF 52022015NOA","title":"SOUTHWEST GAS CORP — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-06-02","effective_on":null,"summary":"CLOSED notice of amendment citing 192.631(a)(1), 192.631(b)(1), 192.631(b)(3), 192.631(c)(2), 192.631(c)(4), 192.631(c)(5), 192.631(e)(2), 192.631(e)(3), 192.631(e)(4), 192.631(e)(5), 192.631(e)(6), 192.631(f)(2), 192.631(h), 192.631(h)(6).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-52022015noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-52022015noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-52022015noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/52022015NOA","body":"Notice of Amendment involving SOUTHWEST GAS CORP. PHMSA's enforcement data identifies the cited regulations as 192.631(a)(1),  192.631(b)(1),  192.631(b)(3),  192.631(c)(2),  192.631(c)(4),  192.631(c)(5),  192.631(e)(2),  192.631(e)(3),  192.631(e)(4),  192.631(e)(5),  192.631(e)(6),  192.631(f)(2),  192.631(h),  192.631(h)(6). The case was opened on 2022-06-02 and is reported as closed as of 2025-04-04. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n52022015NOA_Closure Letter_04042025_(21-201158).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022015NOA/52022015NOA_Closure%20Letter_04042025_(21-201158).pdf\n\n52022015NOA_Closure Letter_04042025_(21-201158)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022015NOA/52022015NOA_Closure%20Letter_04042025_(21-201158)_text.pdf\n\n52022015NOA_Notice of Amendment_06022022_(21-201158).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022015NOA/52022015NOA_Notice%20of%20Amendment_06022022_(21-201158).pdf\n\n52022015NOA_Notice of Amendment_06022022_(21-201158)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022015NOA/52022015NOA_Notice%20of%20Amendment_06022022_(21-201158)_text.pdf\n\n52022015NOA_Operator Response to Notice_07052022_(21-201158).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022015NOA/52022015NOA_Operator%20Response%20to%20Notice_07052022_(21-201158).pdf\n\n52022015NOA_Notice of Amendment_06022022_(21-201158)_text.pdf\n\nNOTICE OF AMENDMENT\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 5-2022-015-NOA\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, inspected\nSouthwest Gas’s (SWG) written procedures for Gas Control in Las Vegas, Nevada.1\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nSWG’s plans or procedures, as described below:\n1. §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:\n1 As a preliminary note, SWG’s utilization of the terms “policies” and “procedures” is somewhat confusing. In\ngeneral, policies set parameters for decision-making but leave room for flexibility, and are intended to show the “why”\nbehind an action. Procedures, on the other hand, explain the “how” by providing step-by-step instructions for specific\ntasks.\n\n\n\n(1) A controller’s authority and responsibility to make decisions and take actions\nduring normal operations\nSWG’s written procedures are inadequate to assure the safe operation of a pipeline facility.\nSpecifically, SWG failed to adequately define the roles and responsibilities of its primary and\nsecondary controllers. SWG’s Gas Control Department Policy (issue date – December 31, 2018,\neffective date – January 31, 2019), Section 2.0 “Roles and Responsibilities,” Subsection 2.1.2\nidentifies a primary and secondary controller. During the inspection, SWG explained that the\nday shift always has a primary controller and secondary controller on shift, while the night shift\nonly has a primary controller. SWG further explained that during the day shift, both the primary\nand secondary controllers control the same assets from different consoles and are both logged\ninto the SCADA system at the same time. Consequently, both the primary and secondary\ncontroller can issue commands and acknowledge alarms simultaneously.\nFinally, SWG stated that sometimes the secondary controller becomes the primary controller\nwhen the primary controller must step away from the console. However, the policy fails to\nidentify a maximum time the primary controller can step away from the console before an\nofficial shift change has to occur, or what situations the secondary controller will respond to or\nacknowledge alarms or issue commands while the primary controller is away from the console.\nSWG must amend Section 2.0 “Roles and Responsibilities” to clearly explain the roles and\nresponsibilities for both the primary and secondary controllers, including establishing a\nmaximum time away from the console before a shift change must occur and listing what actions,\nif any, the secondary controller may take while the primary controller is not at the console.\nSWG’s revisions should also limit the number of simultaneous controller logins to each pipeline\nsystem and assign SCADA permissions to each individual to avoid potentially duplicative or\nconflicting commands.\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(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;\nSWG’s written procedures are inadequate to assure the safe operation of a pipeline facility.\nSpecifically, SWG’s Gas Control Department Procedures (issue date – March 31, 2019,\neffective date – April 30, 2019), Section 1.0 “Roles and Responsibilities” fails to address how\nthe system will be operated during an emergency event that requires evacuation. Page 1-5 states,\n\n\n\n“Redirect calls. Travel to South Operations Center and establish operations. Inform Gas Control\nSupervisor or designee prior to departure and upon arrival.” Despite the fact that the travel time\nto the South Operations Center, or backup control room, is approximately 25 minutes, the\nprocedure does not explain the controllers’ roles and responsibilities during those 25 minutes.\nFor example, during the day shift when both the primary and secondary controllers are on shift,\ndo the roles and responsibilities of each controller vary during an emergency event that requires\nevacuation? Additionally, if there is an emergency event at night that requires evacuation, who\nis responsible for monitoring the system during the 25 minutes of travel time, and what is his/her\nresponsibilities for issuing commands and/or responding to alarms?\nFurther, once the controller(s) arrives at the South Operations Center, what roles and\nresponsibilities does he or she have? Although SWG has the ability to operate or monitor their\nsystem from this remote location during an evacuation, its procedures fail to address it.\nSWG must amend their procedures to address the roles and responsibilities of each controller\nduring an evacuation to the back up control center and address the deficiencies outlined above.\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’s written procedures are inadequate to assure the safe operation of a pipeline facility.\nSpecifically, SWG failed to have an adequate procedure for conducting point-to-point\nverifications between SCADA displays and related field equipment when field equipment is\nadded or moved and when other changes that affect pipeline safety are made to field equipment\nor SCADA displays.\nSWG’s Gas Control Procedures (issue date – March 31, 2019, effective date – April 30, 2019),\nSection 3.3 “SCADA Point to Point Verification” is inadequate and requires amendment to meet\nthe requirements of § 192.631(c)(2) and §192.631(e)(1). Specifically, SWG does not sufficiently\naddress the following:\n• Section 3.3.1 does not address scheduling point-to-point verifications should only logic\nbe changed that affects points that can impact safety, regardless of whether a point is\nadded or deleted. (For example, calculated points that display volumes such as station\nthroughput and generate alarms that may require setpoint revisions due to logic versions,\n\n\n\nor valves that show an alarm condition when the proper commanded value has not been\nreached by a modified time);\n• Section 3.3.1 does not address the condition for when a point that can impact safety is\nmoved on a display, then the new position must be confirmed to be accurate for the\nprocess information;\n• Section 3.3.1 does not indicate that all safety-related alarm setpoints along with alarm\ndescriptors will be recorded along with all displays that have been verified;\n• Section 3.3.4 does not indicate that the protocol-specific register list will include all\npoints that can impact safety (at a minimum);\n• Section 3.3.4 does not indicate that the value allowed range on the display matches or\nagrees with the range of the point value;\n• Section 3.3.4 does not confirm how the value range for the input point is\nconfirmed. While a single point value test is fine for leaving a location on analog values,\nthis is not correct for an alarm state on digitals or logic driven points and associated\nresponses. In addition, a single value test does not allow all safety-related alarm states or\nvalues to be checked through to the SCADA system nor sufficiently describe how this\nprocess will confirm that all descriptors have been checked;2 and\n• Section 3.3.4 assumes that the value is accurate for all ranges and that the display range\nand the range of the devices are correct. However, transmitters do not have a perfect\ncurve and as such, the device should be calibrated through the full range, and the full\nrange response confirmed to be accurate.\nSWG must amend Section 3.3 “SCADA Point to Point Verification” to address the deficiencies\noutlined above and to clearly explain how point-to-point verifications will be conducted and\nproperly documented.\n4. §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(4) Test any backup SCADA systems at least once each calendar year, but at\nintervals not to exceed 15 months;\nSWG’s written procedures are inadequate to assure the safe operation of a pipeline facility.\nSpecifically, SWG failed to develop an adequate procedure for testing any backup SCADA\nsystem at least once each calendar year, but at intervals not to exceed 15 months.\n2 §192.631(e)(2) does not allow for any period of operation in the control room without alarm value setpoints or\nalarm descriptors having been confirmed to be accurate.\n\n\n\nSWG’s Gas Control Department Policy (issue date – December 31, 2018, effective date –\nJanuary 31, 2019), Section 4.0 “Required Procedures,” Subsection 4.4 “Secondary SCADA\nSystem Testing” paraphrases the regulation without providing any specifics on how the testing\nwill be conducted.\nSWG must develop an adequate procedure for testing any backup SCADA system. The\nprocedure must include, at a minimum, adequate representative sampling of functions to be\nperformed, verified, and documented during back-up operations.\n5. §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(5) Establish and implement procedures for when a different controller assumes\nresponsibility, including the content of information to be exchanged.\nSWG’s written procedures are inadequate to assure the safe operation of a pipeline facility.\nSpecifically, SWG failed to establish and implement an adequate procedure for when a different\ncontroller assumes responsibility, including the content of information to be exchanged.\nSWG’s Gas Control Department Procedures (issue date – March 31, 2019, effective date – April\n30, 2019), Section 3.0 “SCADA Operations,” Subsection 3.1 “Change in Gas Controller” fails to\nindicate who is responsible for completing the shift change form. Furthermore, the shift change\nform fails to document that both the primary and secondary controllers are part of the shift\nchange. Since the secondary controller is fully qualified and can step in and act as the primary\ncontroller when the primary controller temporarily leaves the console, the secondary controller\nmust be included in the shift change procedure, including the documentation acknowledging\nboth have received all the necessary information required during a shift change. Both controllers\nmust be present, and part of the shift change process.\nSWG must amend its shift change procedure to ensure that both controllers are part of the shift\nchange, including documentation, as outlined above.\n6. §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\n\n\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’s written procedures are inadequate to assure the safe operation of a pipeline facility.\nSpecifically, SWG failed to develop an adequate procedure for identifying at least once each\ncalendar month points affecting safety that have been taken off scan in the SCADA host, have\nhad 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.\nSWG’s SCADA Procedure (Issued Date – May 29, 2020, Effective Date – June 30, 2020,\nOriginal Release Date), Section 1.0 “Alarm Management Plan,” Subsection 1.6 “Required\nReviews,” Subsection 1.6.1 is code paraphrased without any specifics on how the monthly\nreview will be conducted. Further, the procedure fails to require documentation to include the\ndates when points were taken off scan, inhibited, forced or manual values, the duration of the\noutage, or when the points were restored.3\nSWG must amend its “Alarm Management Plan” procedures identified above to include specific\ninformation and instruction on how the monthly reviews will be conducted, including\ndocumentation requirements.\n7. §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’s written procedures are inadequate to assure the safe operation of a pipeline facility.\nSpecifically, SWG failed to develop an adequate procedure for verifying the correct safety-\nrelated alarm set-point values and alarm descriptions at least once each calendar year, but at\nintervals not to exceed 15 months.\nSWG’s SCADA Procedure (Issue Date 5/29/20, Effective Date 6/30/20), Section 1.0 “Alarm\nManagement Plan,” Subsection 1.6 “Required Reviews”, Subsection 1.6.2 states that\nEngineering Services will coordinate the verification and will “[p]rovide a list of all alarm limits\nand descriptions for safety related points to Division Operations for review and updates; [s]ubmit\n3 Without recording this information, an operator cannot identify deficiencies and address them pursuant to the\nrequirements in § 192.631(e)(6).\n\n\n\nalarm limit updates to Gas Control; and [d]ocument the review in the problem and change\napplication.”\nDuring the inspection, when asked to provide a list of all safety-related alarm set points and\nalarm descriptions, the operator stated it could be found in Section 1.6.2. However, that\ninformation cannot be found in SWG’s procedure. It is unclear how the operator can conduct a\nverification without an actual list or database of these items.\nSWG must amend the procedure to provide details regarding how they will conduct a\nverification of correct safety-related alarm set points and alarm descriptions, including a list of\nall alarm limits and descriptions to be utilized during this review.\n8. §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(4) Review the alarm management plan required by this paragraph at least once\neach calendar year, but at intervals not exceeding 15 months, to determine the\neffectiveness of the plan;\nSWG’s written procedures are inadequate to assure the safe operation of a pipeline facility.\nSpecifically, SWG failed to develop an adequate procedure for reviewing its alarm management\nplan at least once each calendar year, but at intervals not exceeding 15 months, to determine the\neffectiveness of the plan.\nSWG’s SCADA Procedure (Issue Date 5/29/20, Effective Date 6/30/20), Section 1.0 “Alarm\nManagement Plan,” Subsection 1.6.3 “Required Reviews” paraphrases the regulation and lacks\nany specific information or instruction, including metrics or criteria used to determine the\neffectiveness of the plan.\nSWG must amend its procedure to clearly explain how the review will be conducted and what\nmetrics will be used to determine the effectiveness of the plan.\n9. §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(5) Monitor the content and volume of general activity being directed to and\nrequired of each controller at least once each calendar year, but at intervals not to\n\n\n\nexceed 15 months, that will assure controllers have sufficient time to analyze and\nreact to incoming alarms;\nSWG’s written procedures are inadequate to assure the safe operation of a pipeline facility.\nSpecifically, SWG failed to have an adequate procedure for conducting workload analyses that\nwill assure controllers have sufficient time to analyze and react to incoming alarms. SWG’s Gas\nControl Department Procedures (Issue Date: 03/31/19; Effective Date: 04/30/19; Superseded\nDate: 01/31/19), Section 4.7 “Workload Analysis” fails to provide any specific information or\ninstruction for how the workload analysis will be conducted.\nFor example, the procedure fails to identify a clear process of measuring or monitoring the\ncontent and volume of general activity being directed to and required of each controller,\nincluding what criteria will be used to indicate acceptable controller performance (including\nprimary and secondary controllers, as applicable) in response to alarms.\nAdditionally, the procedure fails to identify any workload threshold that would lead to adding\ncontrollers and/or consoles or taking other corrective measures to provide for effective controller\nresponse to alarms. Furthermore, the procedure fails to include all general activities performed\nby controllers and instead only focuses on alarms.\nSWG must amend its procedures to address the deficiencies outlined above.\n10. §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(6) Address deficiencies identified through the implementation of paragraphs (e)(1)\nthrough (e)(5) of this section.\nSWG’s written procedures are inadequate to assure the safe operation of a pipeline facility.\nSpecifically, SWG failed to have an adequate procedure to address deficiencies identified\nthrough the implementation of §192.631(e)(1) through (e)(5). SWG’s SCADA Procedure (Issue\nDate 5/29/20, Effective Date 6/30/20), Section 1.0 “Alarm Management Plan,” Subsection 1.6.5\n“Required Reviews” only states that “Engineering Services and Gas Control will address\ndeficiencies identified through the above reviews.” The procedure fails to provide any\ninformation or instruction on how deficiencies will be identified, or criteria or guidelines for\nprioritizing the resolution and correction of deficiencies.\nSWG must amend its procedures to adequately address how the company will identify and\naddress deficiencies identified through the implementation of § 192.631(e)(1)-(5), including\namendments to address the deficiencies outlined above.\n\n\n\n11. §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;\nSWG’s written procedures are inadequate to assure the safe operation of a pipeline facility.\nSpecifically, SWG failed to have procedures which require field personnel to contact the control\nroom when emergency conditions exist and when making field changes that affect control room\noperations. For example, during the inspection, PHMSA reviewed SWG’s procedures for valve\ninspections,4 which failed to require field technicians to contact the control room prior to and\nupon completion of the valve inspection. The procedure fails to mention SCADA, control room,\nor controllers.\nAdditionally, while reviewing the procedure for pressure regulation inspection,5 PHMSA\ndiscovered that the procedure failed to require field personnel to contact the control room prior to\nand after completion of performing the inspection of the pressure regulators. The procedure fails\nto ensure that proper notification to the control room is made when testing includes field\ninstruments and SCADA components used is overpressure protection.\nSWG must review and amend any procedure that affects control room operations to ensure that\nfield personnel contacts the control room when making field changes.\n12. §192.631 Control room management.\n(a)…\n(h) Training. Each operator must establish a controller training program and review\nthe training program content to identify potential improvements at least once each\ncalendar year, but at intervals not to exceed 15 months.\nSWG’s written procedures are inadequate to assure the safe operation of a pipeline facility.\nSpecifically, SWG failed to have an adequate procedure for reviewing the training program\ncontent to identify potential improvements at least once each calendar year, but at intervals not to\nexceed 15 months.\n4 Valves Procedure: Prepared By: Gas Operations Support Staff Approved By: Jerry Schmitz Issue Date: 05/29/20\nEffective Date: 06/30/20 Superseded Date: 04/30/19), Section 2.4 - GENERAL INSPECTION AND\nMAINTENANCE REQUIREMENTS (POLYETHYLENE, STEEL PLUG, STEEL BALL, AND STEEL GATE.\n5 Pressure Regulation Procedure - Prepared by: Engineering Services; Approved by: Jerry Schmitz; Issue Date:\n05/29/20; Effective Date: 06/30/20; Superseded Date: 10/31/19.\n\n\n\nSWG’s Gas Control Policy (effective date 1/31/2019), Section 9 “Training,” Subsection 9.1.3\nstates: “The training program effectiveness will be reviewed annually, not to exceed 15 months.”\nThis procedure paraphrases the regulation, and does not provide any information or instruction,\nincluding metrics or criteria used to determine the effectiveness of the plan, or how a review of\nthe training program content will be conducted to identify any improvements.6\nSWG must amend Section 9.1.3 to provide specific information and instruction on how the\ntraining content will be reviewed and what metrics or criteria will be used to determine if the\ntraining is effective, and if the training proves ineffective, how improvements will be identified\nand implemented.\n13. §192.631 Control room management.\n(a)…\n(h) Training. Each operator must establish a controller training program and review\nthe training program content to identify potential improvements at least once each\ncalendar year, but at intervals not to exceed 15 months. An operator's program\nmust provide for training each controller to carry out the roles and responsibilities\ndefined by the operator. In addition, the training program must include the\nfollowing elements:\n(1) …\n(5) …\nSWG’s written procedures are inadequate to assure the safe operation of a pipeline facility.\nSpecifically, SWG failed to have an adequate training program for training controllers to carry\nout the roles and responsibilities as defined by the operator, including elements covered under\n§192.631(h)(1) through (h)(5).\nSouthwest Gas’s control room management procedures (Gas Control Policy, effective date\n1/31/2019; Section 9) are inadequate to assure safe operation of a pipeline facility. Specifically,\nSouthwest Gas failed to establish a controller training program that sufficiently incorporates the\nrequirements set forth in § 192.631(h).\nWhile SWG’s training program generally states the training elements that will be covered, the\nprogram fails to explain in sufficient detail how controllers will be trained on these elements.\nFor example, the training program fails to identify how controllers will be trained (e.g., types of\nexercises), or how they will be evaluated (e.g., assigning pass/fail criteria for training elements),\nincluding specifying how many times a controller can retake any failed training element before\nadditional training is required. Furthermore, the training fails to include details on stages or\nphases of the training program, including expected time frames to complete each stage.\n6 During the inspection, PHMSA asked the operator if any other document(s) explain how the effectiveness review is\nperformed. The operator responded that section 9.1.3 is the only location in their procedures where training\neffectiveness is mentioned.\n\n\n\nRegarding the training element to train controllers for responding to abnormal operating\nconditions (AOCs) that are likely to occur simultaneously or sequence pursuant to §\n192.631(h)(1), the operator failed to develop a list of these AOCs. It is unclear how controllers\nwill be trained on these conditions without first identifying the AOCs which are likely to occur\nsimultaneously or in sequence.\nSWG must develop an adequate training program that provides the details necessary to\nunderstand how controllers will be trained on the elements set forth in § 192.631(h)(1)-(5). The\nrevisions must address the deficiencies noted above, and require each controller to demonstrate\nproficiency in each of the roles and responsibilities identified by the operator as well as the\napplicable operator qualification (OQ) covered tasks.\n14. §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. In addition, the\ntraining program must include 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 by no later than January 23, 2018.\nSWG’s written procedures are inadequate to assure the safe operation of a pipeline facility.\nSpecifically, SWG failed to have an adequate procedure for conducting team training exercises.\nSWG’s Gas Control Policy (effective date 1/31/2019), Section 9 “Training,” Subsection 9.1.2\nstates, “Team Training will be provided at a frequency of every 3 years to Gas Controllers and\nthose who operationally collaborate with the Control Room during normal, unusual, and\nabnormal operating conditions. Team training will include lessons learned from company,\nhistorical or other gas-industry events. Those who operationally collaborate with Gas Controllers\ninclude [those who] [w]ork jointly with Gas Controllers during normal operations, unusual\noperating conditions, and abnormal operating conditions; [and those who] [c]ommunicate\ninformation to the Control Room that influences pipeline operations.”\nControl room team training and exercises are intended for controllers and other individuals who\nusually provide key information or decision-making input or otherwise influence operational\ncontrol.7 To properly conduct team training, the operator must identify those personnel who are\n7 See PHMSA Advisory Bulletin, ADB 2014-02 (explaining that operators are advised to regularly train their\ncontrollers and consider training controllers as teams in the recognition and response to emergency and unexpected\nconditions. This team training should include recognition of SCADA alarms and readings and understanding of leak\ndetection software).\n\n\n\nrequired to participate in team training. SWG’s procedure failed to identify the personnel either\nby role, title, or other means to ensure adequate personnel participation in team training.\nFurthermore, the procedure does not provide specific information or instruction on how team\ntraining will be conducted and documented.\nSWG must amend its procedure to address the deficiencies outlined above. PHMSA strongly\nencourages SWG to review PHMSA’s Frequently Asked Questions associated with Team\nTraining before amending its procedure.8\n15. §192.631 Control room management.\n(a) General.\n(1) This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline\nfacility through a SCADA system. Each operator must have and follow written\ncontrol room management procedures that implement the requirements of this\nsection…\nSWG’s written procedures are inadequate to assure the safe operation of a pipeline facility.\nSpecifically, SWG failed to have written control room management procedures that\nincorporated the requirements of § 192.631(i). Pursuant to §192.631(i), upon request, operators\nmust submit their procedures to PHMSA or, in the case of an intrastate pipeline facility regulated\nby a State, to the appropriate State agency.\nDuring the inspection, PHMSA reviewed SWG’s Gas Control Policy and Gas Control\nProcedures (effective date 1/31/2019, and 4/30/2019, respectively), both of which failed to\nexpressly include this requirement.\nSWG must amend its procedures to expressly include the requirements set forth in § 192.631(i).\n16. §192.631 Control room management.\n(a) General.\n(1) This section applies to each operator of a pipeline facility with a controller\nworking in a control room who monitors and controls all or part of a pipeline\nfacility through a SCADA system. Each operator must have and follow written\ncontrol room management procedures that implement the requirements of this\nsection…\nSWG’s written procedures are inadequate to assure the safe operation of a pipeline facility.\nSpecifically, SWG failed to have written control room management procedures that incorporated\nthe requirements of § 192.631(j)(1). Pursuant to §192.631(j)(1), an operator must maintain for\n8 PHMSA Control Room FAQs can be found here: https://www.phmsa.dot.gov/pipeline/control-room-\nmanagement/control-room-management-faqs (last accessed May 24, 2022).\n\n\n\nreview during inspection records that demonstrate compliance with the requirements of §\n192.631.\nDuring the inspection, PHMSA reviewed SWG’s Gas Control Policy and Gas Control\nProcedures (effective date 1/31/2019, and 4/30/2019, respectively), both of which failed to\nexpressly include records retention requirements.\nSWG must amend its procedures to expressly include the requirements set forth in §\n192.631(j)(1).\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\nCompliance 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\n60 days of receipt of this Notice. This period may be extended by written request for good\ncause. Once the inadequacies identified herein have been addressed in your amended\nprocedures, this enforcement action will be closed.\nIt is requested (not mandated) that Southwest Gas maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Dustin Hubbard, Director, Western Region, Pipeline\nand Hazardous Materials Safety Administration. In correspondence concerning this matter,\nplease refer to CPF 5-2022-015-NOA and, for each document you submit, please provide a copy\n\n\n\nin electronic format whenever possible.\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\ncc: PHP-60 Compliance Registry\nPHP-500 D. Fehling (#21-201158)\n\n52022015NOA_Closure Letter_04042025_(21-201158)_text.pdf\n\nVIA ELECTRONIC MAIL TO: jerry.schmitz@swgas.com\nApril 4, 2025\nMr. Jerome T. Schmitz\nVice President – Engineering\nSouthwest Gas Transmission\nLVA-581\n5241 Spring Mountain Road\nLas Vegas, Nevada 89150\nCPF 5-2022-015-NOA\nDear Mr. Schmitz:\nFrom May 10 through May 14, 2021, a representative from the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to chapter 601 of title 49, United States Code,\nconducted an on-site pipeline safety inspection of Southwest Gas Transmission’s written\nprocedures for Gas Control in Las Vegas, Nevada. As a result of the inspection, PHMSA issued\nto Southwest Gas Transmission, pursuant to 49 CFR § 190.206, a Notice of Amendment (NOA)\non June 22, 2022, which proposed amendment of your procedures. Southwest Gas Transmission\nsubmitted a response on July 5, 2022.\nPHMSA has determined that given the passage of time, it would be prudent to review the items\nidentified in the NOA during a future inspection rather than continue the current proceeding.\nPHMSA will address any remaining items with Southwest Gas Transmission at that time.\nAccordingly, this case is now withdrawn.\nThank you for your cooperation.\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\n\n\n\ncc: PHP-60 Compliance Registry\nPHP-500 D. Fehling (21-201158)","truncated":false,"body_characters":36851}