Operations & Maintenance Enforcement Guidance Part 192 Subparts L and M



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Enforcement Guidance

O&M Part 192




Revision Date

09-28-2011




Code Section



§192.605(c)



Section Title

Procedural Manual for Operations, Maintenance, and Emergencies – Abnormal Operation




Existing Code

Language

(c) Abnormal operation. For transmission lines, 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; and,

(v) Any other foreseeable malfunction of a component, deviation from normal operation, or personnel error which may result in 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) Notifying responsible operator personnel when notice of an abnormal operation is received.

(4) 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.

(5) The requirements of this paragraph (c) do not apply to natural gas distribution operators that are operating transmission lines in connections with their distribution system.




Origin of Code

Original Code Document, 35 FR 13248, 08-19-1970




Last Amendment

Amdt. 192-71A, 60 FR 14381, 03-17-1995 (Affecting 192.605(c))




Interpretation Summaries





Advisory Bulletin/Alert Notice Summaries


Advisory Bulletin ADB-99-03, Potential Service Interruptions in Supervisory Control and Data Acquisition Systems.
Inform pipeline system owners and operators of potential operational limitations associated with Supervisory Control and Data Acquisition (SCADA) systems and the possibility of those problems leading to or aggravating pipeline releases.
Each pipeline operator should review the capacity of its SCADA system to ensure that the system has resources to accommodate normal and abnormal operations on its pipeline system. In addition, SCADA configuration and operating parameters should be periodically reviewed, and adjusted if necessary, to assure that the SCADA computers are functioning as intended. Further, operators should assure system modifications do not adversely affect overall performance of the SCADA system. We recommend that the operator consult with the original system designer.



Other Reference Material & Source

GPTC Guide Material is available





Guidance Information






  1. The operator’s operations and maintenance procedures must address abnormal operations as defined by §192.605(c). Abnormal operations and emergency response are not the same, and the operator must have separate procedures to address each type. However, failure by the operator to make an appropriate, timely response to an abnormal operation could result in an emergency situation.

  2. The structure of the operations and maintenance procedures manual is not prescribed and may consist of a single comprehensive manual or multiple cross-reference volumes with referenced documents. The manuals can be made available to operations personnel as hard-copy or computer based documents but must be accessible at locations where operations and maintenance activities are conducted. If the operations and procedures manual(s) are computer based, the operator must provide a means to access the procedures in the event of computer failure.

  3. The operator’s operations and maintenance procedures must adequately address each type of abnormal operation defined by §192.605(c) and clearly provide the appropriate response based on the situation and facilities involved.

  4. Procedures that are unique to a particular facility must be accessible at that facility.

  5. In addition to operations and maintenance functions performed by field personnel, tasks performed by operations control, engineering, integrity management and other functions associated with an office facility require written procedures for abnormal operations that must be included in the operations and maintenance manual.

  6. The operator’s procedures must specify the documentation requirements for abnormal operations events. Recording only those abnormal operations that result in a Part 191 reportable incident is not adequate. Abnormal operations must be documented

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

    1. Root cause analysis

    2. Post event reports

    3. Tailgate meeting agenda item

    4. Near-miss and accident investigation analysis

    5. Simulation or event re-construction reviews

    6. Abnormal operations drills and mock exercises

    7. Ongoing management of change process

  8. Procedures revisions made to increase efficiency must not compromise safety.




  1. The operations and maintenance procedures must be specific to address the facilities and equipment being used by the operator. The regulations define the minimum requirements but an operator’s procedures may need to exceed these basic requirements to ensure safe operation of the pipeline system. The operator’s written operations and maintenance procedures are enforced as a regulation.

  2. The operator must review and update, if necessary, the operations and maintenance procedures at least once each calendar year not to exceed 15 months. The operator must show that normal operations, abnormal operations, incidents, and emergency conditions were reviewed to determine if procedure modifications are needed. The individual procedures documents should include management approvals, origin date, and the effective date of the last revision.

  3. The operator’s operations and maintenance procedures must specify how checking for variations after returning to normal operations after an abnormal operations event has occurred will be performed. This checking must be performed in a manner to ensure continued integrity and safe operation.

  4. The operator’s operations and maintenance procedures for abnormal operations must include a process to evaluate the effectiveness and include defined actions where the procedures are found to have deficiencies. The operator must be able to show documentation that this review is being performed and the results of the review. The procedures modifications must reflect revisions to correct any deficiencies determined in the review process. The operator can use a variety of methods to determine the effectiveness of the procedures, including root cause analysis, post-event reports, discussions in safety meetings, evaluation of close-call reports, and table-top or live drills. Refinement of the procedures to improve efficiency must not compromise safety.




Examples of Probable Violation




  1. The operator failed to prepare and follow procedures for abnormal operations.

  2. The operator failed to document occurrences of abnormal operations.

  3. The operator failed to review the abnormal operations procedures and correct any deficiencies.

  4. The operator has not prepared and followed procedures for monitoring conditions after an abnormal operation event to ensure continued integrity and safe operation.





Examples of Evidence





  1. Copies of the written procedures in question.

  2. Copies of the operators required records indicating that the procedures were not followed.

  3. A written record of the observed actions that violated the procedures.

  4. Written documentation of conversations or interviews with the operator’s personnel.

  5. Incident investigation reports that document failure to follow procedures or problems with the procedures.

  6. The operations control log book that for the time period surrounding the abnormal operating event that does not clearly show a response according to the defined procedures.



  1. Data from the SCADA system or the operations control log book that fails to detail monitoring after an abnormal operating event to ensure continued integrity and safe operation.

  2. Data from the SCADA system that shows system operating parameters during the period of the abnormal operation.





Other Special Notations




  1. If inadequacies are found with the written procedures the inspector should prepare a Notice of Amendment.





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