{"operation":"document","citation":"PI-15-0001","title":"EnVen Energy Ventures — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2015-04-02","effective_on":null,"summary":"PI-15-0001 response to EnVen Energy Ventures concerning 195.446.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-15-0001.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-15-0001.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-15-0001","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2015/15-0001.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation\nPipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Ave, S.E.\nWashington, D.C. 20590\nAPR 0 2 2015\nMr. Robert Ellis\nVice President Operations\nEn V en Energy Ventures, LLC\n3850 N. Causeway Boulevard\nSuite 1770\nMetairie, LA 70002\nDear Mr. Ellis:\nIn a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated\nDecember 19,2014, you requested an interpretation ofthe applicability ofthe control room\nmanagement regulations in 49 CFR 195.446 to your crude oil pipeline.\nYou stated that En Ven Energy Ventures, LLC (En Ven) recently acquired Shell Oil's Cognac\nplatform located in the Mississippi Canyon Block 194A on the Outer Continental Shelf~\nincluding the Cognac 12-inch Crude Oil pipeline, which is approximately 28 miles long and\ncarries crude oil from the platform to the South West Pass Block 24 terminal operated by Hilcorp\n(Harvest Pipeline).\nYou stated that En V en plans to have continuous monitoring of the pipeline operations from the\nCognac platform via a local Supervisory Control and Data Acquisition (SCADA) system. The\npipeline will normally be controlled via SCADA supplied automated programmable logic which\nincludes automated safety devices that will shut down the pumps delivering crude oil to the\npipeline in case of high or low pressure, or low flow. There are local start/stop controls at the\nindividual components, such as the pumps and valves, should there be a need to bypass the\nautomated logic control. The platform operators are not using the SCADA to remotely control\noperations of the pipeline facilities; they are only monitoring the operational status of the\npipeline via the SCADA system. At the land based facility, there are three locally controlled\nvalves used for normal flow and pig receiving. The platform SCADA only monitors the status of\nthese valves and does not have the ability to control their operation. These valves are locally\ncontrolled for pigging the pipeline and in the event the platform is shut-in.\nYou stated that En V en does not believe it has personnel that meet the definition of a controller\nfound in 49 CFR 195.2. The platform operators only monitor operations of the pipeline facility\nfrom the SCAD A. they do not control from the SC ADA. The platform operator does not direct\nother personnel to take specific actions based upon monitoring of the SCADA. The pipeline\ncomponents (pumps, valves, etc.) are only operated locally and the SCADA is not capable of\noperating these components. All control actions are either performed by the automated logic\nprogrammed into the SCAD A or locally operated with manual on/off switches at the pipeline\nThe Pipeline and Hazardous Materials Safety Administration. Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to\nhelp the public understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\n2\ncomponents. In addition, En V en does not believe it has an operational center that meets the\ndefinition of a control room found in 49 CFR 195.2. The platform operators have not been\ncharged with the responsibility of remotely controlling the pipeline. Because En V en does not\nhave personnel that meet the definition of controller and does not have an operation center that\nmeets the definition of a control room, En Ven believes the control room management\nrequirements found under§ 195.446 do not apply. Therefore, you request PHMSA 's\ninterpretation as to the applicability of the control room management regulations in§ 195.446 to\nyour crude oil pipeline.\nOn February 3, 2015, my staff requested additional information and you responded to the request\non February 4, 2015. PHMSA's questions and your responses are as follows\nPHMSA Question: After monitoring the SCADA system, what actions would be\nundertaken when the personnel on the platform become aware of an abnormal or emergency\ncondition on the pipeline?\nEnVen Energy Response: The pipeline and platform are set up with programmable logic\nand safety devices that would automatically shut the pipeline pumps down immediately and keep\nthe pumps offline until qualified platform personnel could then investigate and act appropriately.\nPHMSA Question: Would the personnel analyze the SCADA displays to determine a\ncourse of action or who to call to intervene or personally correct the situation?\nEnVen Energy Response: No, the course of action is already set with the platform and\npipeline safety system. The pipeline pumps would be shut in or not allowed to come on line\nuntil the qualified personnel determine the issue at hand and act accordingly with respect to\nestablished protocol and existing procedures.\nPHMSA Question: If automatic switches, independent of the SCAD A system. are used\nto shut off the pipeline system, then why is the SCADA system needed?\nEnVen Energy Response: SCADA is not required; however, EnVen typically uses\nSCADA to monitor current conditions and document historical data on its important platforms\nand or flow lines.\nPHMSA Question: Do the job descriptions of the platform personnel include direction\nabout what to do when a pipeline upset condition occurs?\nEn Ven Energy Response: Yes, the job descriptions and required training do provide\nappropriate direction.\nPHMSA Question: Who monitors the traveling of the pig?\nEnVen Energy Response: The Platform does and documents this daily on our\nmorning rep01is.\nPHMSA Question: How are other elements of safety systems such as hydrogen sulfide or\nFire or Gas handled- does it automatically shut in the pipeline?\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations\n(49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the\nspecific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and\nare provided to help the public understand how to comply with the regulations.\n\n<<<PAGE 3>>>\n\n3\nEn Ven Energy Response: Our platform safety systems continually monitor our operating\nconditions and will shut in the entire platform including the pipeline pumps should there be an\nupset.\nPHMSA Question: Do the platform personnel override these abnormal conditions?\nEnVen Energy Response: No. As per EnVen standards and Government regulations, we\nnever override any safety system during abnormal conditions.\nPHMSA Question: What is the purpose of the SCAD A monitoring or the outcome of the\nresponse to the information?\nEnVen Energy Response: En Yen does trend analysis with the historic data and likes the\nability to get real time data if needed.\nPHMSA Question: What are the abnormal operating conditions or abnormal operations\nidentified and who responds to those?\nEnVen Energy Response: As this pertains to the DOT pipeline: Our qualified operators\nwill respond to all of the items listed below:\n• High Pressure, Pressure Safety 1-ligh Sensor that shuts in the pipeline pumps.\n• Low Pressure, Pressure Safety Low Sensor that shuts in the pipeline pumps.\n• Back flow, Installed flow safety valves.\n• Product loss, we communicate with the receiving station to double check volumes\npumped and received. As mentioned above, we will have SCADA to look for condition\ntrends and or irregularities in pressure and volume.\n• Other emergency situations. such as Fire. Explosions ... , TSE System (Temperature\nSafety Element) actuates a platform and pump shut in automatically.\n• Communication loss, we have backup generators for power loss, and battery powered\nsatellite phones to insure that we have communication.\n• Operator Error, our automatic safety devices will shut in the pipeline pumps.\nPHMSA Question: You mentioned that. at the end of your downstream pipeline, crude\noil is stored. Is the storage a breakout tank? If not please explain how the crude oil is introduced\ninto the downstream operator's pipeline.\nEnVen Energy Response: The oil, pumped from the platform is pipeline quality oil and\nis pumped through our pipeline into the onshore facility header and then into the facility storage\ntank.\nOn February 12, 2015, a PHMSA engineering staff called you and discussed your platform setup\nas follows:\nThe pipeline is a 12-inch. 28-mile long oil pipeline connecting the Cognac Production\nPlatform (located in 1 ,025 feet of water and operated under Bureau of Safety and\nEnvironmental Enforcement (BSEE) jurisdiction), to South West Pass 24/25 Harvest\nProcessing Facility; the operators on the offshore platform have the lease automatic\ncustody transfer (LACT) pumps set up per BSEE safety regulations with pressure safety\nhigh (1 06 psi) and low ( 49 psi) settings during pumping operations; these pumps\nThe Pipeline and Hazardous Materiais Safety Administration: Office ofPipeline Safety provides written clarifications of the Regulations\n(49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the\nspecific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and\nare provided to help the public understand how to comply with the regulations.\n\n<<<PAGE 4>>>\n\n4\ngenerally operate at 60 psi; when the pipeline pumps are shut down, the pipeline pressure\nis less than 5 psi; on the platform, the wells flow into oil storage tanks that have level\ncontrols that turn on and off the LACT pumps; these pipeline pumps will kick on and off\nwhen a certain level is reached.\nAlso, you stated that the pumps are shut off automatically and/or not allowed to pump if there are\nmajor upsets on the platfonn. This is done because the pipeline pumps are activated\nautomatically by level controls in the oil tanks. In addition, there are times that the ·pumps will\nbe turned on and off manually (testing, meter proving, pigging maintenance, etc). This operation\nis not directed by a land based controller/operator. When receiving a pig, the land operator will\nbe communicating with your platform operator as described in your pigging procedure. Your\noperators man the platform 24 hours a day; your operators can respond to an alarm immediately;\nthe pumps are run for approximately 2.5-2.8 hours a day. The pumps will turn on and off as\ndictated by the tank level controls and will run for 5-7 minutes during one of its 24 daily cycles.\nand your platform operators are in daily contact with the land based receiving station to double\ncheck daily volumes pumped and received.\nIn addition, whenever you fly from your Rotorcraft Leasing Company Venice Air Base to the\nCognac platform and back, your pilot and operators do a visual inspection of the pipeline route,\nand this is done a minimum of once a week. You have a sonic meter at the South West Pass\n24/25 Facility, and it is externally attached to your pipeline and is calibrated monthly or as\nneeded to double check the throughput volumes received. The SCADA is used to only monitor\nthe activities on the pipeline and there are no controls. Also, your offshore operators are\nregulated by your DOT procedures and are not given direction by your land based personnel.\nSection 195.446 applies to each operator of a pipeline facility with a controller working in a\ncontrol room who monitors and controls all or part of a pipeline facility through a SCAD A\nsystem. A person that has responsibility to monitor a SCADA system and contacts others to\ninitiate corrective actions is considered a controller. Also, a person that has responsibility to\nmonitor a SCADA system and personally initiates corrective action via the SCADA system is a\nc.ontroller. The person that receives the pipeline SCADA data and contacts operational personnel\nto operate or shut-in the pipeline would also be a controller. Controllers are subject to the\nControl Room Management (CRM) rule published on June 16, 2011 ;76 FR 35130, independent\nof the particular automated capabilities ofthe SCADA System. However, you stated that the off.\nshore platform operators have not been charged with the responsibility of remotely controlling\nthe pipeline. Also, all control actions are either performed by the automated logic programmed\ninto the SCAD A or locally operated with manual on/off switches at the pipeline components. In\naddition, at the land-based facility, there are three locally controlled valves used for normal flow\nand pig receiving. Therefore, for the off-shore application, as long as the persons on the\nplatform exclusively operate equipment on the platform (which may include pipeline pumps.\nvalves, and pressure control equipment located on the platform), and do not control the pipeline\ndownstream, they are not considered to be controllers subject to the CRM rule.\nThe Pipeline and Hazardous Materials Safety Administration. Office of Pipeline Safety provides written clarifications of the Regulations\n(49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the\nspecific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and\nare provided to help the public understand how to comply with the regulations.\n\n<<<PAGE 5>>>\n\n5\nPlease note that this response to your December 19, 2014, request and the additional information\nyou provided, reflects PHMSA' s preliminary views of the applicability of Part 195 regulations\nbased on the limited information in your description of the facilities in your letter. PHMSA may\nneed to collect additional information and possibly conduct a site visit to make a final\ndetermination.\nIf we can be of further assistance, please contact Tewabe Asebe of my staff at 202-366-5523.\nDirector, Office of Standards\nand Rulemaking\nThe Pipeline and Hazardous Materials Safety Administration, Onice of Pipeline Safety provides written claritications of the Regulations\n(49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the\nspecific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and\nare provided to help the public understand how to comply with the regulations.\n\n<<<PAGE 6>>>\n\nr:c 2: 2014\nenven\nE NERGY V ENTURES\nwww.enven.com\n3850 N. Causeway Blvd. Suite 1770\nLakeway Two\nMetairie. Louisiana 70002\nPhone: (504) 831-9008\nF o x: Lond/G&G/Exe (5041 830-7645\nFox: Accounting/Marketing (504) 831- 1528\nFox: Operotions/SEMS (504) 830-7629\nDecember 19, 2014\nBv Federal Express\nPipeline and Hazardous Materials Safety Administration\n1200 New Jersey Avenue SE\nWashington, DC 20590\nAttn: Alan Mayberry, Deputy Associate Administrator, Policies and Programs\nRE: Letter of Interpretation Request- Control Room Management\nDear Mr. Mayberry\nEnVen Energy Ventures, LLC (\"EnVen\") is an independent Oil Company with assets in the Federal Waters\nof the Gulf of Mexico. We recently acquired Shell Oil's Cognac platform located in the Mississippi Canyon\nBlock 194A on the Outer Continental Shelf, including the Cognac 12\" Crude Oil pipeline, which is\napproximately 28 miles long and carries crude oil from the platform to the South West Pass Block 24\nterminal operated by Hilcorp (Harvest Pipeline). E nVen has recently received our operator identification\nnumber (39214) to take over as the operator of record from Shell Pipeline Company.\nEnVen plans to have continuous monitoring of the pipeline operations from the Cognac platform via a\nlocal SCADA system. The pipeline will normally be controlled via SCADA supplied automated\nprogrammable logic which includes automated safety devices that will shut down the pumps delivering\ncrude oil to the pipeline in case of high or low pressure, or low flow. There are local start/ stop controls\nat the individual component s, such as the pumps and valves, should there be a need to bypass the\nautomated logic control. The platform operators are not using the SCADA to remotely control operations\nof the pipeline facilities; they are only monitoring the operational status of the pipeline via the SCADA\nsystem. At the land-based facility, there are three locally controlled valves used for normal flow and pig\nreceiving. The platform SCADA only monitors the status of these valves and does not have the ability to\ncontrol their operation. These valves are locally controlled for pigging the pipeline and in the event, the\nplatform is shut-in.\nBased upon how this pipeline operation is configured, it is EnVen's belief that 49 CFR 195.446 Control\nRoom Management would not be applicable in this case.\nEnVen does not have personnel that meet the definition of a \"controller\" found in 49 CFR 195.2.\n\n<<<PAGE 7>>>\n\nPipeline and Hazardous Materials Safety Administration\nLetter of Interpretation Request- Control Room Management\nDecember 19, 2014\nPage 2\nController means a qualified individual who remotely monitors and controls the safety-related\noperations of a pipeline facility via a SCADA system from a control room, and who has operational\nauthority and accountability for the remote operational functions of the pipeline facility.\nThe platform operators only monitor operations of the pipeline facility from the SCADA, they do not\ncontrol from the SCADA. The platform operator does not direct other personnel to take specific actions\nbased upon monitoring of the SCADA. The pipeline components (pumps, valves, etc.) are only operated\nlocally and the SCADA is not capable of operating these components. All control actions are either\nperformed by the automated logic programmed into the SCADA or locally operated with manual on/off\nswitches at the pipeline components.\nEnVen does not have an operational center that meets the definition of a \"control room\" found in 49 CFR\n195.2.\nControl room means an operations center staffed by personnel charged with the responsibility for\nremotely monitoring and controlling a pipeline facility.\nThe platform operators have not been charged with the responsibility of remotely controlling the pipeline.\nBecause EnVen does not have personnel that meet the definition of ~~co ntroller\" and does not have an\noperation center that meets the definition of a \"Control Room\", EnVen believes the Control Room\nManagement requirements found under 49 CFR 195.446 do not apply. Given the information provided\nherein, EnVen is requesting a written opinion as to whether PHMSA is in agreement with EnVen's\ndetermination. Should more information or additional discussion be needed, please contact Robert Ellis\n(contact information attached below).\nSincerely,\nRobert Ellis\nVice-President Operations\nEnVen Energy Ventures, LLC\n3850 N. Causeway Blvd.\nSuite 1770\nMetairie, LA 70002\nbellis@enven.com\n{504) 620-8998\n\n<<<PAGE 8>>>\n\n(LOOP LLC)\nStorage\nclovelly\nDelta Forms\nLOOP\nCentral\nLatitte\nStation\nAtiak\nJE\nCrude\nBarataria\nGRAND ISLE\nBLK.33\nHUBCAP\n-0-\nCamiine\n31.78\nBARATARIA\nPLAQUEMINES\nDELTA\nMARLIN\n12\" PELICAN-NAIR\nWEST\nST.\nABI. 1040\nNairn\nDELTA\nGAS\nMIŞS.CANYON\nBERNARD\nIsland\nPelican\nOstrica\nVENE ANT\nTETCO LAFERALS\n*SOUTH PASS\nTerminal\n16\" Mothbotted\nPilottown\nEnergy Part\nS.W.PASS 24\nMAN PASS 69\nMAIN PASS 69\nBRETON SOUND =\nSOUND\nCHANDELEUR\nODYSSEY\nDELTA 20\"\nBik. 70\nthe platform to the Hilarp\nNA KIKA\nApache\nPOMPANG\nthat carries crude oil from\nlong, (ruge Oil pipeline\nMAIN PASS\nСодрас /Linch, 28 mils\nCHANDELEUR 7\n• 8.500\nBik She®\nBi S06\nMENSA FLOW LINES\n• 8ík. 989\n20°\nVI:\n\n<<<PAGE 9>>>\n\nSL 1009 A\nSHELL\nCONOCO\nSL 979\nSL 978\n4405)\nSP24\nUNOCAL\nSL 1008\nSHELL\nSHEET|7\nWD53\nBOODRICH\nSP25\nSHELL PIPELINE\nWD54!\nCONOCO\nAO 0160\nAO 0161\nCONOCO\n> UNOCAL\nSL 2227\nSL 1010\nSHELL,\nTOTAL LENGTO\nMUS SEGMENT NO\nSP27\nSL 2593\nUNOCAL\nSL. 2227\nWD83\nSHEET 5\nSL 1922\nSL 17203\nEPL\nDATA BY\nSL 1011\nSHELI\nSP26\nFLORES & RUCKS\nSL 15016\nCEC GATA\n2,000\nShell Pipeline Company LP\nAS-BUILT 12\" OIL / HS PIPELINE\nBlock 194, Mississippi Canyon Ared\nRevised\nJOB NO: 062118\nBlock 27, South Pass Ama\nFILENAME: 092118_511093 DMG\nSHEET 6 of ?\nDATE: APR 27,2007\n\n<<<PAGE 10>>>\n\n80\nZ\nGET HAVE\nA FROM MC-194\nPRESUME SNOT ALM\n80.\n1001\nPSN 15999\nLOV SNUT\n02/20/1315-0/1\nPISER ISCUATION VALVE\nMASSAC SAITT IDE\nSTATION UMITS\n12/12/13 asUC FOR REVIE\nSULATING CASTE\nOCCATON OF NOVSON\nFLOW CONTROL WALVE PRESSURE NOICATOR/\nLOCK A KID VICE\nSOUTHWEST PASS PUMP STATION AND TERMINAL\nTANSMITTOR\nSAI\nO*:\nSoN. MANSI\nSOUTHWEST PASS\nCOGNAC OFFSHORE CRUDE\n→ TO TANKS\nSOUT NEST PASS INCOMING 12-OL PIPELINE\nDATE: -\n12/20/13\nAS-BUILT\nSD - 403\n\n<<<PAGE 11>>>\n\n/\n8/ROM ERL LACT SHE.L\nMATCHLINE\nTO LOUIRE\nSORC PA-\n10\" FROM CHEVRON\nE. RELEE FROM CHEVRON\n.ME TO BARCE LOADING (IDLE) -\nSEE D-TANTO\nMATCHLNE\nLEGEND\nTHIRD PARTY\nSPLC\nSEPCO\n(COGNAC)\nFLOW\nAE , REAS ONE DK OMRI WIK ONAT\nHEDEANCE ORAN MER\nGOUTHWEST PASS STATION\nDELTA CRUDE\nLAUNCHENE ORGE AREA\n(oran D- 16111\n\n<<<PAGE 12>>>\n\n1\nOHE VRVE\nPROISUE SAZTT VANE\n80\nNEUMANC OPERAOR\n0 (1\nARGE PUMP SKIC\nREDUCER (CONCONTRIC\nO 00»\nPLATFORM: SIMTEL\nSUR BOLTON HAM\nO JATNO DASAL\nSO PRO\n3°\n308\nALV FRISS ROCA'OTONTA\n1)-8-\n1,03\nMISSISSIPPI CANYON 194 PLATFORM \"A\" (COGNAC)\nDATE:\n12/20/13\nAS-BUILT\nMC 194A FACILITY\nCOGNAC OFFSHORE CRUDE\nP/L\nP/L\nP/L\nP/L\n85\n0 320\n3.822\n4 186\n1.123\n3 034\n12.530\n0 253\n0.253\n-E8=\nPSN 15999\n- La H PaC\n12.75\n12 75\n12 75\n1275\n1275\n12.75\n12 75\n12.75\n1440 730\n0.250\n0 250\n0 562\n0 562\n0.625\n0.562\n0 625\nSEGMENT (LENCTH (MI)| OD (IN)| W.T (IN) PIPE SPEC (GRADE) MAOP (PSIC)]\nPIPEUNE SEGMENT DESCRIPTION\nMC 194A OUTGOING - 12ª OIL PIPELINE\nFLOW DIAGRAM - SAFETY SCHEMATIC\n23 i%r MCS\nTO SW PASS\n5LX-X65\n5LX-X65\nSLX-X46\n5LX-X46\n5LX-X46\nSLX-X46\n5LX-X46\nSLX-X42\nSD - 402\n1440\n1440\n1440\n\n<<<PAGE 13>>>\n\n\n\n<<<PAGE 14>>>\n\n\n\n<<<PAGE 15>>>\n\n103,","truncated":false,"body_characters":22024}