§195.402(d) Abnormal Operation, Enforcement Guidance

Operators are required to include procedures in their O&M Manual for actions to provide for safety of their system when an abnormal operation occurs.  The regulation lists several examples and expected actions.

The following is from the PHMSA Enforcement Guidance and lists items an operator should consider for complying with this regulation, and examples of possible violations.

195.402(d)

Enforcement Guidance O&M Part 195
Revision Date 11-24-2014
Code Section §195.402(d)
Section Title Procedural Manual for Operations, Maintenance, and Emergencies
Existing Code Language (d) Abnormal operation. The manual required by paragraph (a) of this section must include procedures for the following to provide safety when operating design limits have been exceeded;

(1) Responding to, investigating, and correcting the cause of;

(i) Unintended closure of valves or shutdowns;

(ii) Increase or decrease in pressure or flow rate outside normal operating limits;

(iii) Loss of communications;

(iv) Operation of any safety device;

(v) Any other malfunction of a component, deviation from normal operation, or personnel error which could cause a hazard to persons or property.

(2) Checking variations from normal operation after abnormal operation has ended at sufficient critical locations in the system to determine continued integrity and safe operation.

(3) Correcting variations from normal operation of pressure and flow equipment and controls.

(4) Notifying responsible operator personnel when notice of an abnormal operation is received.

(5) Periodically reviewing the response of operator personnel to determine the effectiveness of the procedures controlling abnormal operation and taking corrective action where deficiencies are found.

Origin of Code Original Code Document, 34 FR 15473, 10-04-1969
Last Amendment Amdt. 195-22, 46 FR 38357, 07-27-1981
Interpretation Summaries
Advisory Bulletin/ Alert Notice Summaries
Other Reference Material & Source
Guidance Information 1.  Checking for variations from normal operation after abnormal operation may be a review of pressure records or it may entail a hydraulic analysis along the pipelines alignment to account for elevation variations.

2.  Abnormal operations do not pose an immediate threat to life or property as do emergency conditions.

3.  Abnormal operations are generally less severe, but could escalate to emergency conditions if not promptly corrected.

4.  Any pipeline operator that chooses to treat abnormal operations as emergency conditions still must comply with §195.402(d) and have separate procedures for abnormal operations.

5.  The operator’s O&M procedures may be a comprehensive set of cross-referenced volumes set up according to functional subjects or a single manual.

6.  Procedures are required for all facilities in the system.

7.  The procedures are not just for the field personnel.

8.  Procedures are also required for tasks normally performed at the operations control center, engineering and other headquarters-type functions as applicable to O&M tasks.

9.  The procedures should be clear, straight forward, and applicable to the company’s system.

10. All these procedures must be reviewed and updated by the operator at intervals not exceeding 15 months, but at least once each calendar year.

11. §195.402(d)(5) is directed to procedures refinement, not employee evaluation.

12. Operators may apply various techniques to determine the effectiveness of its abnormal O&M procedures, some examples are:

a.  Root cause analysis

b.  Post event reports

c.  Tailgate meeting agenda item

d.  Near-miss and accident investigation analysis

e.  Simulation or event re-construction reviews

f.  Abnormal operations drills and mock exercises

g.  Ongoing management of change process

13. Refinement and efficiency of procedures must not compromise safety.

14. Abnormal operations should be trended and reviewed.  Consistently occurring abnormal operations are an indication that pipeline operations need to be modified to prevent possible failure.

15. Abnormal operations should be documented – typically by a form or work management system, etc. to facilitate review and trending by operations personnel to make corrections to prevent system from exceeding design limits.

16. Abnormal operations for particular lines or systems need to be defined.

17. For loss of communications the operator should define how long this is allowed before personnel are sent to the facility to monitor pipeline.  There should be direction in use of back-up communications, or the local facility’s PLC programming can “drive” the station to lower setpoints when PLC loses communication with SCADA.

18. MOP does not have to be exceeded for an event to be considered an abnormal operation.

19. Final Order Guidance:

a.  Potomac Electric Power Company and Support Terminal Services [1-2000-6003] (Jun. 2, 2004):  For purposes of 49 C.F.R. § 195.402(d), an abnormal operation is not limited solely to instances where the internal design or maximum operating pressure (MOP) of a hazardous liquid pipeline is exceeded.  Any increase or decrease in pressure or flow rate outside of normal operating limits, as well as any other malfunction of a component, deviation from normal operation, or personnel error which could cause a hazard to persons or property, is an abnormal operation under § 195.402(d). CO/CP

Examples of a Probable Violation or Inadequate Procedures 1.  There is no written procedure or the operator did not follow the procedure.

Depending on the circumstances, some of the examples listed in this section may be inadequate plans and procedures, and not probable violations.  Thus, the enforcement tool to address these issues would be a Notice of Amendment and not a Notice of Probable Violation or a Warning Letter.  Section 3 of the Enforcement Procedures provides guidance on selecting the appropriate enforcement action.

Examples of Evidence 1.  Copy of O&M plan or applicable procedure that shows omission or deficiency in the plan.

2.  The only procedure for addressing vapors in excavated trenches is OSHA’s confined space procedures.

3.  Copy of O&M plan or applicable portion that shows omission or deficiency in the plan.

4.  Documented conversations with operator personnel who are charged with establishing the plan.

Other Special Notations

 All this and more, including all PHMSA Enforcement Guidance in WinDOT, The Pipeline Safety Encyclopedia, now a web based application.

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