Control Room Management - Implementation of the Rule

1. Western Regional Gas Conference Daron K. Moore El Paso Pipeline Group August 25, 2010 Control Room Management - Implementation of the Rule

2. 2003 – C-CERT initiative focusing on controller certification begins 2006 – PIPES Act required PHMSA action September 2008 – NPRM released December 2008 – Advisory committees voted on draft rule language December 2009 – Final Rule released February 2010 – Effective date of Final Rule August 2011 – Operator plans must be final February 2013 – Operator plans must be implemented Control Room Rule History

3. Operator-by-operator development of plans • Historical approach (O&M, OQ, IMP, design and construction, welding, etc) • APGA small operator development of plan • Plans tailored for small operators such as OQ and IMP • Regional association development of plan • MEA and NGA plans for OQ • An industry-wide approach to a common plan • Never done before • Needed industry/geographic breadth • Needed grass-roots buy-in • Needed belief that a common manual framework had value Many Possible Compliance Approaches

4. SGA sponsored group (LDCs and transmission) to address rule by creating a “common framework” for all operators to use. Characteristics include: • Drafted by volunteers and is entirely voluntary • Approximately 70 operators involved in process • Addressed all major aspects of Final Rule • Is completely cross-referenced to Final Rule • Reviews and results • Reviewed by OPS with comments incorporated • Reviewed by NTSB (hours of service issue) and pipeline’s fatigue management issue removed from Most Wanted list Industry-Wide Response

5. Common framework benefits (translatable?) • Increased probability of compliance • Lower cost of compliance (manual development, information exchange, learned processes, training, etc) • Shorter inspection times • Strength in numbers • Common model for inspectors when visiting • Flexible for individual operations • Ancillary pieces • Circadian Technologies white paper providing technical justification for hours of service criteria • Common training addressing fatigue management being prepared by SGA’s Training Committee for all operators (consistent approach and shared experiences) Benefits of Approach

6. Hours of service is crux issue of Final Rule • Final Rule is completely performance-based on hours of service with the exception of the 8 hour continuous sleep requirement • Hours of service requirements in framework: • No more than 63 hours of service in 5 day period • If 5 consecutive days worked at 12 hours, must have 34 hour rest period • No more than 14 hours on for 12 hour shift • No more than 17 hours on for 8 hour shift • Compares favorably with FMCSA, NRC, FAA, and API RP-755 requirements Crux Issue and Response

7. 12 hour and 8 hour shift lengths are equally safe and acceptable • For 12 hour shifts, 60 hours in 5 days, not to exceed 63 hours, is acceptable • 36 hour rest period to follow, which then re-starts the clock • On 8 hour shifts, a maximum of 17 hours of consecutive duty, although limited in scope • On 12 hour shifts, a maximum of 14 hours of consecutive duty, although limited in scope • Limited use of 7 on, 7 off schedule under specific situations Circadian White Paper Conclusions