{"operation":"document","citation":"CPF 52022049NOA","title":"MOUNTAINWEST PIPELINE, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-12-19","effective_on":null,"summary":"CLOSED notice of amendment citing 192.631(c)(2), 192.631(c)(5), 192.631(e)(1), 192.631(e)(3), 192.631(e)(6), 192.631(f)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-52022049noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-52022049noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-52022049noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/52022049NOA","body":"Notice of Amendment involving MOUNTAINWEST PIPELINE, LLC. PHMSA's enforcement data identifies the cited regulations as 192.631(c)(2),  192.631(c)(5),  192.631(e)(1),  192.631(e)(3),  192.631(e)(6),  192.631(f)(2). The case was opened on 2022-12-19 and is reported as closed as of 2023-04-18. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n52022049NOA_Closure Letter_04182023_(22-232643).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022049NOA/52022049NOA_Closure%20Letter_04182023_(22-232643).pdf\n\n52022049NOA_Closure Letter_04182023_(22-232643)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022049NOA/52022049NOA_Closure%20Letter_04182023_(22-232643)_text.pdf\n\n52022049NOA_Notice of Amendment_12192022_(22-232643).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022049NOA/52022049NOA_Notice%20of%20Amendment_12192022_(22-232643).pdf\n\n52022049NOA_Notice of Amendment_12192022_(22-232643)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022049NOA/52022049NOA_Notice%20of%20Amendment_12192022_(22-232643)_text.pdf\n\n52022049NOA_Operator Response to Notice_01112023_(22-232643).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52022049NOA/52022049NOA_Operator%20Response%20to%20Notice_01112023_(22-232643).pdf\n\n52022049NOA_Notice of Amendment_12192022_(22-232643)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA E-MAIL TO MS. COLLEEN LARKIN BELL\nDecember 19, 2022\nMs. Colleen Larkin Bell\nPresident\nMountain West Pipeline, LLC\n333 South State Street\nP.O. Box 45360\nSalt Lake City, UT 84145-0360\nCPF 5-2022-049-NOA\nDear Ms. Bell:\nFrom February 28 through March 4, 2022, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,\ninspected Mountain West Pipeline, LLC’s (Mountain West, formerly Dominion Questar)\nprocedures for Control Room Management in Salt Lake City, Utah.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nMountain’s plans or procedures, as described below:\n1. § 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.\n\n\n\nMountain West’s procedures are inadequate to assure safe operation of a pipeline facility.\nSpecifically, CRM Plan 2.8 Shift Changes and Handover Responsibilities fails to require that\nboth outgoing and incoming controllers document the transfer of operational information on the\nDEQP Control Hand-over Sheet. Instead, CRM Plan 2.8 requires only that a verbal review of\nthe DEQP Control Hand-over Sheet be conducted.1 Mountain West must amend its procedures\nto provide for the documentation of the transfer of operational information on the DEQP Control\nHand-over Sheet.\n2. § 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;\nMountain West’s procedures are inadequate to assure safe operation of a pipeline facility.\nSpecifically, Mountain West’s CRM Plan Section 1 does not define the term “point.” Although\nMountain West includes definitions for the terms “safety-related” and “safety-related alarm,” its\nprocedures fail to define the term “point” – a related term that is required to operate the SCADA\nsystem. Additionally, Mountain West’s CRM Plan Section 3.2 does not define the time period\nby which point-to-point verification must be completed.\nMountain West must amend its procedures to define the term “point” as it pertains to Mountain\nWest pipeline operations, and define a time period by which point-to-point verifications must be\ncompleted when field equipment is added or moved, or when other changes that affect pipeline\nsafety are made to field equipment or SCADA displays.\n3. § 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) Review SCADA safety-related alarm operations using a process that ensures\nalarms are accurate and support safe pipeline operations;\nMountain West’s procedures are inadequate to assure safe operation of a pipeline facility.\nSpecifically, Mountain West’s CRM Plan Section 5.3 fails to provide for review of all SCADA\nsafety-related alarms that the SCADA system generates. During the inspection, PHMSA learned\n1 See 49 C.F.R. § 192.631(j)(1) (requiring operators to maintain for review during inspection records that demonstrate\ncompliance with the requirements of this section).\n\n\n\nthat the Mountain West SCADA system allows alarms to annunciate and then clear themselves\nfrom the alarm screen without controller action. The Mountain West CRM Plan provides for\nreview of only those alarms that remain unresolved at the end of each month. This method of\nalarm management and alarm review, however, fails to provide the company with a full\nunderstanding of how the SCADA system is operating and fails to provide the controller with\nfull situational awareness of pipeline operations.\nAdditionally, the existing Mountain West SCADA style guide fails to include a naming\nconvention for points and alarms. Mountain West must amend its procedures to provide a\nprocess that ensures alarms are accurate and support safe pipeline operations, including requiring\nthat all alarms be acknowledged by a controller, and not auto-deleted. Further, Mountain West\nmust amend its procedures by updating its style guide to include naming conventions for points\nand alarms.\n4. § 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;\nMountain West’s procedures are inadequate to assure safe operation of a pipeline facility.\nSpecifically, Mountain West’s CRM plan does not contain a written procedure for the\ndetermination of SCADA safety-related alarm set-point values or a written procedure describing\nhow safety-related alarm descriptions are designated. Consequently, it is unclear how Mountain\nWest verifies correct set-point values and alarm descriptions pursuant to the requirements set\nforth in § 192.631(e)(3). Mountain West must amend its procedures to identify the method and\nprocedure by which safety-related alarm set-point values and safety-related alarm descriptions\nare established.\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(6) Address deficiencies identified through the implementation of paragraphs (e)(1)\nthrough (e)(5) of this section.\nMountain West’s procedures are inadequate to assure safe operation of a pipeline facility.\nSpecifically, Mountain West’s CRM plan Section 5.7 lacks specificity on how identified\ndeficiencies will be documented and tracked through to full remediation. Mountain West must\n\n\n\namend its procedures to provide for the identification and documentation of CRM Plan\ndeficiencies from identification through to full remediation.\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;\nMountain West’s procedures are inadequate to assure safe operation of a pipeline facility.\nSpecifically, Mountain West’s CRM Plan Section 6.1 fails to include maintenance activities in\nthe list of activities field staff should notify gas control room personnel about. Mountain West\nmust amend its procedures to include all activities conducted by field personnel that affect\ncontrol room operations in the list contained in CRM Plan Section 6.1.\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\n30 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.\n\n\n\nIt is requested (not mandated) that Mountain West Pipeline 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 5-2022-049-NOA and, for each document you submit, please provide a copy\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 J. Dunphy (#22-232643)\n\n52022049NOA_Closure Letter_04182023_(22-232643)_text.pdf\n\nVIA E-MAIL TO MS. AMY SHANK\nApril 18, 2023\nMs. Amy Shank\nVice President - Safety & Operational Discipline\nWilliams-Mountain West Pipeline\nOne Williams Center\nP.O. Box 645\nTulsa, OK 74172\nCPF 5-2022-049-NOA\nClosure Letter\nDear Ms. Shank:\nFrom February 28 through March 4, 2022, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Mountain West\nPipeline, LLC’s (Mountain West, formerly Dominion Questar) procedures for Control Room\nManagement in Salt Lake City, Utah. As a result of the inspection, Mountain West was issued a Notice\nof Amendment on December 19, 2022, which proposed amendment of your procedures.\nMountain West submitted its amended procedures on January 11, 2023. 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 for your\ncooperation.\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Dunphy (#22-232643)","truncated":false,"body_characters":12872}