What are the considerations when combining regulated and non-regulated pipe in a pipeline control room? Or possibly more to the point, what about combining non-regulated facilities such as compressor stations into a regulated pipeline control room?
If you have DOT regulated pipe then the control room must be in compliance with the control room management provisions of PHMSA 49 CFR 192 and/or 195, meaning a fully compliant plan that includes proper documentation, alarm management, adequate information, fatigue management and in the case of best practice, situational awareness including adoption of the high performance HMI. For those not familiar with these requirements it can be daunting and create concerns about cost.
While there is nothing to prevent adding a non-regulated facility such as a compressor station to the regulated control room – (in fact there are significant benefits to operating with the PHMSA CRM practices), many operators are unaware of the benefits and want to contain the impact of control room management to only those areas that require the additional diligence.
Midstream operators in particular are struggling with this issue. Midstream operations typically tie plant, facility and pipeline operations together. Resulting in control centers operating both pipe and facilities, and both regulated and non-regulated pipe.
If the issue is reducing the number of control rooms by combining into one, then the benefits would include; reduction in staff, fewer call outs, less miles driven, improved situation awareness, shared infrastructure, and the list goes one.
However, there are also costs associated with a regulated versus a non-regulated control room. In particular workload and management around compliance documentation, shift handover, and alarm management to name a few.
Further complicating the issue are that some midstream operators have only a few miles of DOT regulated pipe and the industry consensus is that the scope of regulatory oversight is likely to be increased to cover gathering systems. Which raises the question “where and how I draw the line?”.
So what to do?
One solution is to put everything in a PHMSA compliant control room, and standardize operations around best practices. Another is to implement an enterprise approach to operations management where facilities are clearly identified as covered or not, but where the tools and processes are the same across the enterprise.
What do you think?