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An Industry Response to the Expected Control Room Management Rule

An Industry Response to the Expected Control Room Management Rule. Western Regional Gas Conference Daron Moore – El Paso Pipeline Group August 25, 2009. Rule Development. NPRM issued in September 2008 Difficult to comply with Extremely costly in implementation

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An Industry Response to the Expected Control Room Management Rule

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  1. An Industry Response to the Expected Control Room Management Rule Western Regional Gas Conference Daron Moore – El Paso Pipeline Group August 25, 2009

  2. Rule Development • NPRM issued in September 2008 • Difficult to comply with • Extremely costly in implementation • No incident history or justification for rule • Trades proposed following Congressional guidance only • Some issues for liquids industry due to incidents

  3. Rule Development • Trade Associations commented heavily on Proposed Rule • Trade Associations negotiated with PHMSA extensively prior to meeting • Result was greatly slimmed-down rule that is perceived to be able to be implemented • Final Rule is expected in September to December 2009 timeframe

  4. One Industry Response • SGA established group to address creating a “common framework” for all operators to comply with. Anticipated benefits include: • Increased probability of compliance with rule • Lower cost of compliance (manual development, information exchange, learned processes, etc) • Shorter inspection times • Common model for both state and federal inspectors when visiting • Strength in numbers • Flexible for individual operations • Model for other “programs” (O&M, OQ, IMP, NDE/Joining, etc)

  5. Probable Rule Summary • Definitions effectively limited scope to what we know as Gas Control • Written plan is required (see SGA effort)(192.631(b)) • Roles and Responsibilities (192.631(c))

  6. Probable Rule Summary • Provide Adequate Information (192.631(d)) • Use API RP-1165 if changes • Point-to-point verification if changes • Annually test communications plan • Annually test back-up SCADA plan • Establish shift change procedures

  7. Probable Rule Summary • Fatigue Management (192.631(e)) • Establish shift length and rotations • Educate and train controllers and supervisors (could be joint training effort, common platform) • Establish service hours limit

  8. Probable Rule Summary • Alarm Management (192.631(f)) • Must review SCADA alarms to: • Monthly identify safety points off scan or with forced values • Annually verify setpoint values • Annually review Alarm Management plan and change if necessary • Monitor content and volume of activity to each controller

  9. Probable Rule Summary • Change Management (192.631(g)) • If significant software or physical changes, control room must be consulted with • Operating Experience (192.631(h)) • All incidents must be analyzed for control room involvement • All lessons learned from incidents shall be incorporated into training program

  10. Probable Rule Summary • Training (192.631(i)) • Program must be established and annually reviewed • Focus areas: • Responding to AOCs • Use of established area of training • Controller responsibilities during emergencies • Pipeline system working knowledge training • Opportunity to review procedures for infrequent setups

  11. Probable Rule Summary • Validation (192.631(j)) • Submit program to respective agencies when requested • Compliance and deviations (192.631(k)) • Required for review during inspections: • Compliance records • Documentation of decisions deviating from this section • Deviations must be submitted on request

  12. Draft Common Manual Table of Contents • Section 100 - Introduction 1 • 101 – Applicable Companies/Facilities 1 • 102 – Applicable Scope (192.631(a)) 2 • 103 – Change Procedures 2 • 104 – Deviation Procedures (192.631(k)(2)) 2 • 105 – Approval 2 • 106 – Effective/Implementation Dates 2 • 107 – Validation (192.631(j)) 3 • 108 – Records (192.631(k)(1)) 3

  13. Draft Common Manual Table of Contents • Section 200 – Definitions 4 • 201 – Alarm 4 • 202 – Control Room 4 • 203 – Controller 4 • 204 – Supervisory Control and Data Acquisition System (SCADA) 4

  14. Draft Common Manual Table of Contents • Section 300 – Roles and Responsibilities 5 • Section 400 – Controller Information 6 • 401 – Controller Tools (192.631(d)) 6 • 402 – API RP -1165 (192.631(d)(1)) 7 • 403 – Point-to-Point Verification (192.631(d)(2)) 7 • 404 – Internal Communication Plan (192.631(d)(3)) 7 • 405 – Backup SCADA System (192.631(d)(4)) 7 • 406 – Shift Changes (192.631(d)(5)) 8

  15. Draft Common Manual Table of Contents • Section 500 – Fatigue Management 9 • 501 – Shift Lengths and Rotations (192.631(d)(1) and 192.631(d)(4)) 9 • 502 – Fatigue Education (192.631(d)(2-3)) 9 • Section 600 – Alarm Management Plan 11 • 601 – Alarm Management Plan Review (192.631(f)(2)) 11 • 602 – SCADA Point Review (192.631(f)(1)) 11 • 603 – Activity Review (192.631(f)(3)) 11

  16. Draft Common Manual Table of Contents • Section 700 – Change Management 12 • 701 – Communications (192.631(g)) 12 • 702 – Significant Hydraulic or Configuration Changes (192.631(g)(1-2)) 12 • Section 800 – Operating Experience 13 • 801 – Incident Review (192.631(h)(1)) 13 • 802 – Lessons Learned (192.631(h)(2)) 13 • Section 900 – Training 14 • 901 – Training Program Review (192.631(i)) 14 • 902 – Training Program Elements (192.631(i)(1-5)) 14

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