Control Room Management Control Room Management Amendments

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Control Room Management Control Room Management Amendments Powered By Docstoc
					Control Room Management

           Amendments 192-
           112 and 195-93
Proposed Rule

   Mandated by PIPES 2006
   NPRM September 2008
   Proposes specific regulations for control rooms
   Includes considerations of human factors
    –   Fatigue
    –   Training
    –   Qualification
Proposed Rule

   Proposed 15 changes to federal regulations
   Include human factors in O&M
   New definitions
   Alarm Management, communications
   Record keeping
   Initial SCADA verification
Control Room Studies

    –   PSIA 2002 pipeline program
    –   Controller Certification project
   NTSB study on liquid SCADA systems
    –   Display graphics and alarm management
    –   Controller training and fatigue data
    –   Leak detection systems
Key Changes from the NPRM

   LNG not included in the rulemaking
   Limited scope to control rooms with SCADA systems
   Limited applicability to local control panels and field
    control rooms
   Redefined controller
   Limited scope of the rule to persons and operating
    centers that directly affect pipeline safety
Key Changes from the NPRM

   Definition of SCADA system
   Allow operators to define roles and
   Removed baseline verification of SCADA
   Modified application of API RP 1165 to
    systems installed after rule implementation
   Removed shift overlap requirement
Key Changes from the NPRM

   Requires operators to establish maximum
    hours of service limit
   Removes prescriptive alarm management but
    requires management plan
   Near miss review not included
   Allows flexibility in change management
   Included training for controllers
   Removed required periodic qualification
The Final Rule

   Effective date of the rule is Feb. 3, 2010.
   Implement procedures by Feb. 1, 2013
   Applies to Part 192 and 195 regulated
    pipelines where controllers use SCADA

   Added to 192.3 and 195.2
   Alarm means an audible or visible means of
    indicating to the controller that equipment or
    processes are outside operator-defined, safety-
    related parameters.
   Control room means an operations center
    staffed by personnel charged with the
    responsibility for remotely monitoring and
    controlling a pipeline facility.

   Controller means a qualified individual who
    remotely monitors and controls the safety-
    related operations of a pipeline facility via a
    SCADA system from a control room, and who
    has operational authority and accountability for
    the remote operational functions of the pipeline

   Supervisory Control and Data Acquisition
    (SCADA) system means a computer-based
    system or systems used by a controller in a
    control room that collects and displays
    information about a pipeline facility and may
    have the ability to send commands back to the
    pipeline facility.
Incorporated by Reference

   192.7
   API Recommended Practice 1165
    "Recommended Practice for Pipeline SCADA
    Displays," (API RP 1165) First edition (January
   Only sections 1, 4, 8, 9, 11.1, and 11.3 apply
    unless operator demonstrates not practical.
Incorporated by Reference

   195.3
   API Recommended Practice 1165
    "Recommended Practice for Pipeline SCADA
    Displays," (API RP 1165) First Edition (January
    2007). Only sections 1, 4, 8, 9, 11.1, and 11.3,
    unless operate demonstrates not practical.
   API Recommended Practice 1168 "Pipeline
    Control Room Management," (API RP 1168)
    First Edition (September 2008). Only section 5.
Operations, Maintenance and
Emergency Manuals

   192 and 195, include procedures for:
   Implementing CRM procedures as required by
    the regulation. (O&M manual)
   Actions to be taken by a controller in an
    emergency. (Emergency plan)
Control Room Management
(The Regulation)

   192.631
   General applicability
    –   Operators with controllers who monitor and control
        with a SCADA system.
    –   Must have written procedures
    –   Exempts distribution systems < 250,000 services
    –   Exempts gas transmission w/o compression but
        they must follow paragraphs (d) fatigue, (i)
        validation and (j) compliance and deviations.
Control Room Management
(The Regulation)

   195.446
   Applies to pipelines with controller in control
    monitoring and controlling through SCADA.
Compliance Dates

   Both liquid and gas
   Procedures must be integrated into operation,
    maintenance and emergency plans
   Procedures developed by Aug. 1, 2011
   Procedures implemented by Feb. 1, 2013
   (Implementation dates changed by final rule
    correction on Feb. 3, 2010, Federal Register:
    February 3, 2010 (Volume 75, Number 22)
Roles and Responsibilities
   192.631(b) and 192.446(b) -Operator must define the following for
   (1) … authority and responsibility to make decisions and take actions
    during normal operations;
   (2) … role when an abnormal operating condition is detected, even if the
    controller is not the first to detect the condition, including the controller's
    responsibility to take specific actions and to communicate with others;
   (3) … role during an emergency, even if the controller is not the first to
    detect the emergency, including the controller's responsibility to take
    specific actions and to communicate with others; and
   (4) A method of recording controller shift-changes and any hand- over of
    responsibility between controllers.
Providing Adequate Information

   192.631 and 195.446, paragraphs (c)
   Provide information, tools, processes and
    procedures necessary to carry out the roles
    and responsibilities
   Gas – API RP 1165, sections 1, 4, 8, 9, 11.1,
    and 11.3
   Liquid – API RP 1165
   Unless operator demonstrates not practical
Providing Adequate Information

   Point to point verification between SCADA and field
    equipment when added, removed, changed
   Test, verify internal communication for manual
    operation once each calendar year, NTE 15 months
   Test backup SCADA once each calendar year, NTE 15
   Procedures when different controller assumes
    responsibilities (liquid API RP 1168, section 5)
Fatigue Mitigation

   Shift lengths, provide for 8 hours continuous
   Educate controllers/supervisors in fatigue
   Train controllers/supervisors to recognize
    effects of fatigue
   Maximum limit on hours-of-service, provide for
    emergency deviation if needed
Alarm Management

   Written alarm management plan
   Review SCADA safety related alarms
   Once each calendar month identify points off
    scan, alarms inhibited, false alarms, or alarms
    with forced/manual values
Alarm Management

   Once each calendar year NTE 15 months
    –   Verify correct safety related set points and
    –   Review alarm management plan
    –   Monitor content/volume of activity to assure
        controllers have sufficient time to analyze and react
        to alarms
   Address identified deficiencies in alarm
Change Management

   Assure changes that could affect control room
    operations are coordinated by
   Establish communications between control room,
    management, field
    –   Liquid – implement section 7 of AP RP 1168
   Require field to contact control room in emergency and
    when making changes
   Gas – Control room participation in planning hydraulic
    or configuration changes
Operating Experience

   Incorporate lessons learned into procedures
   Review incidents
    –   (i) Controller fatigue;
    –   (ii) Field equipment;
    –   (iii) The operation of any relief device;
    –   (iv) Procedures;
    –   (v) SCADA system configuration; and
    –   (vi) SCADA system performance.
   Include lessons learned in training programs

   Establish training program
   Review for potential improvement once each
    calendar year NTE 15 months

   Include the following elements
    –   Responding to abnormal operating conditions (AOC) likely to
        occur simultaneously or in sequence
    –   Computerized simulator
    –   Responsibilities for communications under emergency
        response procedures
    –   Provide working knowledge of pipeline system, AOC
    –   Opportunity to review relevant procedures for setup used
        periodically but infrequently, in advance of operation
Compliance Validation

   Upon request, operators must submit their
    procedures to PHMSA or, in the case of an
    intrastate pipeline facility regulated by a State,
    to the appropriate State agency.
Compliance and Deviations

   An operator must maintain for review during
    –   (1) Records that demonstrate compliance with the
        requirements of this section; and
    –   (2) Documentation to demonstrate that any
        deviation from the procedures required by this
        section was necessary for the safe operation of a
        pipeline facility.

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