There are many safety programs involved in pipeline operations. Because pipeline control rooms are only one aspect of running a safe and efficient pipeline operation, it is easy to overlook the need to verify whether control room management regulations apply to your operation.
Performing this review is especially critical following the recent introduction of the final Gas Gathering Rule for gathering lines. The rule impacts which of your facilities might now be deemed a regulated control room. Not performing this review could cause your operation to be in non-compliance with the PHMSA Control Room Management Rule (CRM Rule).
The CRM Rule (192.631 for transport of natural gas and 195.446 for the transport of hazardous liquids) provides the minimum safety standards for Control Room Management. What we recently found is that some operators are not complying with these fundamental requirements.
In the continuation of our series on the 2021 PHMSA Enforcement Actions pertaining to the control room, we will review recent issues of non-compliance with Section A of the CRM Rule (General Requirements). By sharing learned lessons and our solutions, we hope to provide operators with valuable insight into how to naturally comply with regulations.
Section A – General Requirements for Pipeline Control Rooms
At its most basic level, Section A of the CRM Rule applies to each operator of a pipeline facility with at least one controller working in a control room who monitors and controls all or a portion of a pipeline facility through a SCADA system. Exceptions may apply for operations that are limited to a particular number of services (delivery points) and/or to operations that lack compression.
Additionally, based on the expanded definition for regulated lines in the new Gas Gathering Rule, certain operations with gathering lines that are monitored and controlled by a controller in a control room with a SCADA system may now find themselves having to implement CRM compliance.
For these reasons, operators need to discern whether their lines are regulated and whether they meet the definition of having a control room. In doing so, you can determine whether each asset is subject to the CRM Rule, only certain aspects of the CRM requirements, or not regulated at all.
For assets that are subject to regulations, PHMSA has identified certain actions that an operator must take to support the Section A General Requirements section of the CRM Rule:
- Each operator must have a written Control Room Management Plan (CRMP).
- The CRMP must have procedures that align with the CRM Rule.
- The operator must follow the policy and procedures that were set forth in the CRMP.
- Operators need to formalize and control all documents, which should be made readily available to controllers at their console.
- Training should be provided to control room personnel to facilitate understanding of how to follow the procedures in the CRMP.
- Operators must review the CRMP program annually, not to exceed 15 months.
Then, as operators dive deeper into the Section A requirements, there are specific aspects that operators need to be mindful of to ensure compliance. Let’s review where operators fell short in 2021 so that you can learn from these examples to support your operation.
PHMSA 2021 Enforcement Actions: General Requirements
In total, we identified 25 individual findings in 2021 where PHMSA cited an operator for failure to comply with Section A of the CRM Rule. The enforcement actions ranged from a basic lack of effort to identify whether an operator had a control room to very specific issues related to SCADA systems, team training, fatigue, and other issues. Our list below captures some of the most prominent items that we discovered.
Basic Violations of Section A of the CRM Rule
1. Did not review whether they have a control room. We identified three specific instances where an operator did not perform an adequate review of whether they had a control room.
– One operator was subject to a Notice of Amendment because their CRMP was inadequate. Specifically, the CRMP did not provide a process to determine if a facility is a control room.
The operator stated that they review all facilities on an annual basis to determine if a facility is a control room by applying a matrix of questions to each facility. The operator said they complete this process each year, but PHMSA cited them for non-compliance because the operator did not have a process in their CRMP to perform this review.
– PHMSA determined that another operator’s CRMP was inadequate because it did not provide guidance or structure to determine which of its facilities are control rooms. Specifically, PHMSA found during their inspection that the operator held internal discussions to review which facilities qualified as control rooms, but the results were not made available during the inspection. In addition to lacking documentation, PHMSA noted that the criteria the operator used in their discussions could not be found in the CRMP.
– Another operator was cited by PHMSA for a similar violation. PHMSA said the operator had an inadequate CRMP procedure for two reasons:
- The operator lacked criteria or a process to determine which facilities are control rooms.
- After a determination was made, the operator did not have guidelines for which facilities are required to have a CRMP and implement the CRM Rule requirements.
2. Failure to follow CRMP. One operator was subject to a Proposed Civil Penalty of $19,600 because they failed to follow their CRMP for the transport of hazardous liquids to satisfy the requirements of 195.446.
The specific issue was that the operator had a procedure to retain documents and records related to the review of their CRMP. However, during the audit, the operator was unable to provide documentation related to the review of their control room training program, as required by their own procedure.
3. CRMP is inadequate. One operator was cited for 8 individual violations of Section A. For all 8 findings, PHMSA cited that the operator’s control room management procedures were inadequate to assure safe operation of a pipeline facility. Consider this sample of the reasons:
- Failed to have and follow procedures that define a controller’s role during abnormal operating conditions (AOCs) or emergency situations.
- Lacked procedures that adequately define roles, responsibilities, and qualifications of others who have the authority to direct or supersede the actions of a controller.
- Absent of procedures that adequately provide controllers with information, tools, and resources necessary to carry out actions for point-to-point (P2P) verifications.
- Deficient in procedures that outline how to test their internal communication plan to support the safe manual operation of a pipeline.
- Insufficient procedures to establish a maximum limit on each controller’s Hours of Service (HOS) in the event of an emergency deviation.
Specific Violations of Section A of the CRM Rule
Some of the General A findings in the PHMSA Enforcement Actions were very specific in nature. As we continue our list of findings, consider this additional sample of violations that captures PHMSA going deeper into policy, procedure, and implementation to ensure compliance with the CRM Rule.
4. Not capturing changes to SCADA system. PHMSA determined that one operator’s CRMP was inadequate because it failed to provide information that defines what constitutes additions, expansions, or replacements to the SCADA system used in the control room.
5. Lack of SCADA back-up testing. The same operator was cited by PHMSA for failing to have a clear process to test the SCADA backup system in coordination with a back-up test.
6. What if not using SCADA? PHMSA noted that one operator’s document, “Controller Roles and Responsibilities,” defined a control room. However, PHMSA determined that the definition did not indicate instances where a controller is controlling part of a pipeline facility through a non-SCADA means of control.
7. Lack of integration of lessons learned. PHMSA cited an operator for failing to have and follow CRMP procedures that adequately explain how the operator should include lessons learned in their Control Room Management training program.
8. Training delays. One operator was found to be several months late in establishing team training and exercises. Another operator was cited by PHMSA for failing to implement the controller training procedures as required in Section A.
9. Inadequate fatigue mitigation. Another Section A violation centered on fatigue management. Specifically, an operator’s CRMP was inadequate because it relied heavily on self-reporting fatigue.
A different operator experienced a similar issue. PHMSA said their CRMP was inadequate because it did not include a process for implementing fatigue mitigation and evaluating the effectiveness of that criteria.
10. Unsatisfactory recordkeeping. PHMSA determined that one operator’s procedures were inadequate because they did not provide information to controllers on what they needed to record and document in their log that demonstrates compliance with the CRM Rule.
11. Vague roles and responsibilities. One operator provided PHMSA with a copy of their control room management manual with procedures that were relevant to the operation of their regulated pipeline facilities. However, the procedures were inadequate because the roles and responsibilities of the controllers identified in the CRM procedures were not specific to the operator.
Solutions to Align with Section A Requirements of the CRM Rule
The 2021 CRM PHMSA Enforcement Actions pertaining to Section A covered a wide variety of challenges for pipeline operators.
Whether your operation needs support with the basics of validating that you have pipeline control rooms or you need support for more specific issues in your CRMP, we have a control room solution for your operation.
– We can perform an applicability assessment. This assessment will determine whether you have a control room and whether your control room is subject to federal oversight. This will likely be an issue in 2022 following the announcement of the final Gas Gathering Rule that brought thousands of miles of pipeline assets under federal oversight.
If you operate gas gathering lines that were previously not subject to federal jurisdiction, then we can help bring your control rooms into compliance with the CRM Rule.
– We can provide you with annual program reviews. If you satisfy the applicability requirement of the CRM Rule, then we can help your operation through an annual program review that is completed through our EnerSys software tools.
We will discuss the current state of your control rooms, review your policy, procedure, and implementation, perform gap analysis, and support continuous improvement on the path to Natural Compliance with the CRM Rule.
– Let’s get started with a consultation about your pipeline control rooms. Call us at 281-598-7100 to speak with EnerSys General Manager Ross Adams or VP Business Development Dale Schafer. You can also contact us via email at email@example.com or complete our website contact form to get started.
We look forward to supporting your control room as you incorporate the lessons learned from the 2021 PHMSA CRM Enforcement Actions pertaining to General Requirements.