May 20, 2011 By Tom Miesner Pipeline Knowledge And Development

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Control Room Regulations PresentationIntroduction to Control Room Management –What it Means and RequiresMay 20, 2011ByTom MiesnerPipeline Knowledge and Development 2011 Pipeline Knowledge & DevelopmentTom Miesner Principal Pipeline Knowledge & Development––––– Pipeline Education and TrainingStrategy and Project DevelopmentExpert Testimony and ArbitrationAppraisals and Independent OpinionsManagement and Improvement ConsultingExtensive pipeline background and experiencePresident Conoco Pipe Line CompanyNumerous JV Boards and CommitteesAuthor Oil and Gas Pipelines in NonTechnical Language, TheRole of Pipelines and Research in the U. S., PipelineEngineering for McGraw Hill, and numerous other articles andreportsTeaches a two day Oil and Gas Pipeline fundamentals classand other training modules. 2011 Pipeline Knowledge & DevelopmentPipeline Knowledge & Development21

Control Room Regulations PresentationCopyright and DisclaimerThe materials contained in this presentation are copyright PipelineKnowledge & Development 2011. All rights are reserved. No part of thispresentation may be reproduced, distributed, or stored in any form or by anmeans without prior written permission from Pipeline Knowledge &Development.Some of the images have been supplied by others . Other information hasbeen taken from literature or the internet in which case any copyrightremains with those organizations or individuals.The information contained in these materials was secured from sourcesbelieved to be reliable. However, Tom Miesner, Miesner, LLC, and PipelineKnowledge & Development;1.2.3.Make no warranty or representation, expressed or implied regarding the accuracy,completeness, reliability, or usefulness of the information contained in this presentationAssume no liability with respect to the use of the materials contained in these presentationsAre not responsible for damages resulting from use of the information in these presentations.For information or to receive permission to copy or reproduce, contact TomMiesner, tom@pipelineknowledge.com or 1-281-579-8877 2011 Pipeline Knowledge & Development3Outline Evolution of Pipeline Safety RegulationsControl Room Management BackgroundRequirements and TimingAreas CoveredIndustry InitiativesAgencies and AcronymsDetails of Gas and Oil RegulationsSummarySelected ReferencesDiscussion 2011 Pipeline Knowledge & DevelopmentPipeline Knowledge & Development42

Control Room Regulations PresentationU. S. Safety Regulations Enabling Legislation– The Natural Gas Pipeline Safety Act of 1968 asamended (NGPSA)– Hazardous Liquid Pipeline Safety Act of 1979 asamended (HLPSA) U. S. Regulation – CFR Title 49: Transportation– Part 192—Transportation Of Natural And Other GasBy Pipeline: Minimum Federal Safety Standards– Part 195—Transportation Of Hazardous Liquids ByPipeline Must be periodically reauthorized (2006) Inclusion of Homeland Security (TSA) 2011 Pipeline Knowledge & Development5Security Regulations and Enforcement Department of Home Land Security– Transportation Safety Administration Office of Transportation Sector NetworkManagement (TSNM)– Pipeline Security Division Department of Transportation (PHMSA) (OPS) State officials Local officials 2011 Pipeline Knowledge & DevelopmentPipeline Knowledge & Development63

Control Room Regulations PresentationPipeline Security Division Office of Transportation Sector Network Management– Develop security programs– Conduct analysis to maintain pipeline and domainawareness– Particular focus on critical systems and infrastructure;– Identifying industry best practices and lessons learned;– Maintain a dynamic modal network through effectivecommunications with the pipeline industry andgovernment stakeholders.– Distribute compact disc-based training titled "PipelineSecurity Awareness for the Pipeline Industry Employeehttp://www.tsa.gov/what we do/tsnm/pipelines/training.shtm 2011 Pipeline Knowledge & Development7Pipeline Inspection, Protection, Enforcementand Safety Act of 2006 Sec. 1. Short title.Sec. 2. Pipeline safety and damage prevention.Sec. 3. Public education and awareness.Sec. 4. Low-stress pipelines.Sec. 5. Technical assistance grants.Sec. 6. Enforcement transparency.Sec. 7. Direct line sales.Sec. 8. Petroleum transportation capacity and regulatory adequacystudy.Sec. 9. Distribution integrity management program rulemaking deadline.Sec. 10. Emergency waivers.Sec. 11. Restoration of operations.Sec. 12. Pipeline control room management. 2011 Pipeline Knowledge & DevelopmentPipeline Knowledge & Development84

Control Room Regulations PresentationPipeline Inspection, Protection, Enforcementand Safety Act of 2006 (continued) Sec. 13. Safety orders.Sec. 14. Integrity program enforcement.Sec. 15. Incident reporting.Sec. 16. Senior executive signature of integrity program performance.Sec. 17. Cost recovery for design reviews.Sec. 18. Authorization of appropriations.Sec. 19. Standards to implement NTSB recommendations.Sec. 20. Accident reporting form.Sec. 21. Leak detection technology study.Sec. 22. Corrosion control regulations.Sec. 23. Inspector General report.Sec. 24. Technical assistance program.Sec. 25. Natural gas pipelines.Sec. 26. Corrosion technology. 2011 Pipeline Knowledge & Development9Section 12 of the PIPES Act (codified at 49 U.S.C. 60137)requires PHMSA to issue regulations requiring each operatorof a gas or hazardous liquid pipeline to develop, implement,and submit a human factors management plan designed toreduce risks associated with human factors, including fatigue,in each control room for the pipeline. The plan must include,among other things, a maximum limit on the hours of servicefor controllers working in a control room. PHMSA, or a stateauthorized to exercise safety oversight, is required to reviewand approve operators' human factors plans, and operatorsare required to notify PHMSA (or the appropriate state) ofany deviations from the plan.Section 19 of the PIPES Act requires PHMSA to issuestandards to implement the three recommendations of theNTSB SCADA safety study described above. 2011 Pipeline Knowledge & DevelopmentPipeline Knowledge & Development105

Control Room Regulations PresentationSelected Safety Studies Supervisory Control andData Acquisition(SCADA) in LiquidPipelines NTSB/SS-05/02 Liquid Pipeline OperatorsControl Room HumanFactors Risk Assessmentand Management Guide,November 26, 2008 2011 Pipeline Knowledge & Development11Recommendations from the NTSB Study Require operators of hazardous liquids pipelines tofollow API RP 1165 for graphics Require pipeline companies to have a policy for thereview/audit of alarms Require controller training to include simulator ornon-computerized simulations for controllerrecognition of abnormal operating conditions, inparticular leak events Change the liquid accident reporting form to requiredata related to controller fatigue Require operators to install computer-based leakdetection systems unless not needed. 2011 Pipeline Knowledge & DevelopmentPipeline Knowledge & Development126

Control Room Regulations PresentationNTSB Study Extract Examined 13 accidents April 1992 to March 2004 In 10 of these “some aspect” of SCADA systemscontributed to the severity of the accident Principle issue was the delay between controllerrecognizing a leak and beginning response SCADA factors included; alarms, display formats,accuracy of screens, controller’s ability to evaluateSCADA data during abnormal operating conditions,appropriateness of controller’s actions, ability tomake appropriate decisions, effectiveness of trainingin preparing controllers to interpret the SCADAsystem and react to abnormal operating conditions. 2011 Pipeline Knowledge & Development13Abnormal Operating Conditions § 192.803 Definitions and§ 195.503 Definitions Abnormal operating condition means a conditionidentified by the operator that may indicate amalfunction of a component or deviation fromnormal operations that may: (a) Indicate a condition exceeding design limits; or (b) Result in a hazard(s) to persons, property, orthe environment.The definitions for gas and oil are the same 2011 Pipeline Knowledge & DevelopmentPipeline Knowledge & Development147

Control Room Regulations PresentationWhatcom Creek Arial View Post FireSource: National Transportation Safety Board 2011 Pipeline Knowledge & Development15General Requirements “Each operator must have and follow written control room management procedures that implement the requirements of thissection.” In the CRM plan, operators must:Define a controller’s roles, responsibilities and authorities duringnormal operations, abnormal operations and emergencies, evenwhen the controller in not the first to detect the situation,Provide adequate information and training to the controllers toperform those duties,Establish a method to record shift changes,Establish shift lengths, schedule rotations and establish maximumhours-of-service to ensure controllers can achieve eight hours ofsleep (emergency deviations are allowed in some circumstances)andEducate and train applicable staff on fatigue and fatigue mitigation. 2011 Pipeline Knowledge & DevelopmentPipeline Knowledge & Development168

Control Room Regulations PresentationRule Timing and Applicability Effective February 1, 2010.Programs must be written by August 1, 2011Programs must be implemented by August 1, 2012.Grows out of the Pipeline Inspection, Protection,Enforcement, and Safety Act of 2006 (PIPES) Actwhich required PHMSA to set standards for a newhuman factors management plan. Applies to those persons who monitor SCADA datafrom a control room and have “operational authorityand accountability for the remote operationalfunctions of the pipeline facility as defined by thepipeline operator”. 2011 Pipeline Knowledge & Development17Control Room Cross pload/Post NPRM 101408e.pdf 2011 Pipeline Knowledge & DevelopmentPipeline Knowledge & Development189

Control Room Regulations PresentationSelected Industry Initiatives API RP 1165 Recommended Practice for PipelineScada Displays API RP1167 Alarm Management API RP 1168 Pipeline Control Room Management AGA Alarm Management for Control RoomOperations in the Natural Gas Industry API RP 1113: Developing a Pipeline SupervisoryControl Center EEMUA Publication 191: “Alarm Systems - A Guideto Design, Management and Procurement GPTC Guide for Gas Transmission and DistributionPiping Systems 2011 Pipeline Knowledge & Development19ISA Committee 18 ANSI/ISA-18.1-1979 (R2004), “AnnunciatorSequences and Specifications”––––––WG1 – Alarm PhilosophyWG2 – Alarm Identification and RationalizationWG3 - Basic Alarm DesignWG4 – Enhanced and Advanced Alarm MethodsWG5 – Alarm Monitoring, Assessment and AuditWG6 - Alarm Design for Batch and DiscreteProcesses. 2011 Pipeline Knowledge & DevelopmentPipeline Knowledge & Development2010

Control Room Regulations PresentationAgencies and Acronyms DOT – Department of Transportation PHMSA – Pipeline and Hazardous Materials SafetyAdministration NTSB – National Transportation Safety Board AGA – American Gas Association API – American Petroleum Institute INGAA – Interstate Natural Gas Association of America AOPL – Association of Oil Pipelines CCERT – Controller Certification PSIA – Pipeline Safety Improvement Act of 2002 PIPES – Pipeline Inspection, Protection, Enforcement,and Safety Act of 2006 2011 Pipeline Knowledge & DevelopmentPage 21192.631 & 195.446 Control Room Management a) Generalb) Roles and Responsibilitiesc) Provide Adequate Informationd) Fatigue Mitigatione) Alarm Managementf) Change Managementg) Operating Experienceh) Trainingi) Compliance Validationj) Compliance and Deviations 2011 Pipeline Knowledge & DevelopmentPage 22Pipeline Knowledge & Development11

Control Room Regulations Presentationa – General Gas and Oil Applies to each operator of a pipeline facility with acontroller working in a control room who monitorsand controls all or part of a pipeline facility through aSCADA system. Each operator must have andfollow written control room management proceduresthat implement the requirements of this section. An operator must develop the procedures no laterthan August 1, 2011 and implement the proceduresno later than February 1, 2013 (August 1, 2012) 2011 Pipeline Knowledge & Development23a – General Gas Only except that for each control room where anoperator's activities are limited to either or both of:––(i) Distribution with less than 250,000 services, or(ii) Transmission without a compressor station, the operator must have and follow writtenprocedures that implement only paragraphs– (d) (regarding fatigue),– (i) (regarding compliance validation), and– (j) (regarding compliance and deviations) of thissection. 2011 Pipeline Knowledge & DevelopmentPipeline Knowledge & Development2412

Control Room Regulations Presentationa – General Gas Vs Oil Gas – The procedures required by this section mustbe integrated, as appropriate, with operating andemergency procedures required by Sec. Sec.192.605 and 192.615. Oil – The procedures required by this section mustbe integrated, as appropriate, with the operator'swritten procedures required by Sec. 195.402. 2011 Pipeline Knowledge & Development25b - Roles and Responsibilities Gas and Oil Each operator must define the roles andresponsibilities of a controller during normal,abnormal, and emergency operating conditions. Toprovide for a controller's prompt and appropriateresponse to operating conditions, an operator mustdefine each of the following:– (1) A controller's authority and responsibility to makedecisions and take actions during normal operations;– (2) A controller's role when an abnormal operatingcondition is detected, even if the controller is not thefirst to detect the condition, including the controller'sresponsibility to take specific actions and tocommunicate with others; 2011 Pipeline Knowledge & DevelopmentPipeline Knowledge & Development2613

Control Room Regulations Presentationb - Roles and Responsibilities Gas and Oil(continued)– (3) A controller's role during an emergency, even ifthe controller is not the first to detect the emergency,including the controller's responsibility to take specificactions and to communicate with others; and– (4) A method of recording controller shift-changes andany hand-over of responsibility between controllers. 2011 Pipeline Knowledge & Development27c - Provide Adequate Information Gas and Oil Each operator must provide its controllers with theinformation, tools, processes and proceduresnecessary for the controllers to carry out the rolesand responsibilities the operator has defined byperforming each of the following:– (2) Conduct a point-to-point verification betweenSCADA displays and related field equipment whenfield equipment is added or moved and when otherchanges that affect pipeline safety are made to fieldequipment or SCADA displays; 2011 Pipeline Knowledge & DevelopmentPipeline Knowledge & Development2814

Control Room Regulations Presentationc - Provide Adequate Information Gas and Oil(continued)– (3) Test and verify an internal communication plan toprovide adequate means for manual operation of thepipeline safely, at least once each calendar year, butat intervals not to exceed 15 months;– (4) Test any backup SCADA systems at least onceeach calendar year, but at intervals not to exceed 15months; and 2011 Pipeline Knowledge & Development29c - Provide Adequate Information Gas vs Oil(continued Oil – (1) Implement API RP 1165 (incorporated byreference, see §195.3) whenever a SCADA systemis added, expanded or replaced, unless the operatordemonstrates that certain provisions of API RP 1165are not practical for the SCADA system used; Gas – (1) Implement sections 1, 4, 8, 9, 11.1, and11.3 of API RP 1165 (incorporated by reference,see Sec. 192.7) whenever a SCADA system isadded, expanded or replaced, unless the operatordemonstrates that certain provisions of sections 1,4, 8, 9, 11.1, and 11.3 of API RP 1165 are notpractical for the SCADA system used; 2011 Pipeline Knowledge & DevelopmentPipeline Knowledge & Development3015

Control Room Regulations Presentationc - Provide Adequate Information Gas vs Oil(Continued) Oil – (5) Implement section 5 of API RP 1168(incorporated by reference, see Sec. 195.3) toestablish procedures for when a different controllerassumes responsibility, including the content ofinformation to be exchanged. Gas – (5) Establish and implement procedures forwhen a different controller assumes responsibility,including the content of information to beexchanged. 2011 Pipeline Knowledge & Development31d - Fatigue Mitigation Gas and Oil Each operator must implement the followingmethods to reduce the risk associated with controllerfatigue that could inhibit a controller's ability to carryout the roles and responsibilities the operator hasdefined:– (1) Establish shift lengths and schedule rotations thatprovide controllers off-duty time sufficient to achieveeight hours of continuous sleep;– (2) Educate controllers and supervisors in fatiguemitigation strategies and how off-duty activitiescontribute to fatigue; 2011 Pipeline Knowledge & DevelopmentPipeline Knowledge & Development3216

Control Room Regulations Presentationd - Fatigue Mitigation Gas and Oil (continued)– (3) Train controllers and supervisors to recognize theeffects of fatigue; and– (4) Establish a maximum limit on controller hours-ofservice, which may provide for an emergencydeviation from the maximum limit if necessary for thesafe operation of a pipeline facility. 2011 Pipeline Knowledge & Development33e - Alarm Management Gas and Oil Each operator using a SCADA system must have awritten alarm management plan to provide foreffective controller response to alarms. Anoperator's plan must include provisions to:– (1) Review SCADA safety-related alarm operationsusing a process that ensures alarms are accurate andsupport safe pipeline operations;– (2) Identify at least once each calendar month pointsaffecting safety that have been taken off scan in theSCADA host, have had alarms inhibited, generatedfalse alarms, or that have had forced or manualvalues for periods of time exceeding that required forassociated maintenance or operating activities; 2011 Pipeline Knowledge & DevelopmentPipeline Knowledge & Development3417

Control Room Regulations Presentatione - Alarm Management Gas and Oil (Continued)– (4) Review the alarm management plan required bythis paragraph at least once each calendar year, butat intervals not exceeding 15 months, to determinethe effectiveness of the plan;– (5) Monitor the content and volume of general activitybeing directed to and required of each controller atleast once each calendar year, but at intervals not toexceed 15 months, that will assure controllers havesufficient time to analyze and react to incomingalarms; and– (6) Address deficiencies identified through theimplementation of paragraphs (e)(1) through (e)(5) ofthis section. 2011 Pipeline Knowledge & Development35e - Alarm Management Gas Vs Oil Oil – (3) Verify the correct safety-related alarm setpoint values and alarm descriptions whenassociated field instruments are calibrated orchanged and at least once each calendar year, butat intervals not to exceed 15 months; Gas – (3) Verify the correct safety-related alarm setpoint values and alarm descriptions at least onceeach calendar year, but at intervals not to exceed 15months; 2011 Pipeline Knowledge & DevelopmentPipeline Knowledge & Development3618

Control Room Regulations Presentationf - Change Management Gas and Oil Each operator must assure that changes that couldaffect control room operations are coordinated withthe control room personnel by performing each ofthe following:– (2) Require its field personnel to contact the contro

Pipeline Knowledge & Development 1 Control Room Regulations Presentation 2011 Pipeline Knowledge & Development May 20, 2011 By Tom Miesner Pipeline Knowledge and .

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