1 / 16

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

garrett-heaph
Download Presentation

An Industry Response to the Expected Control Room Management Rule

An Image/Link below is provided (as is) to download presentation Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript

  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

More Related