Operation & Maintenance - Oklahoma Corporation …M Highlights_Normal...Subpart F – Operations and...

87
Tulsa, Oklahoma 2014 Seminar

Transcript of Operation & Maintenance - Oklahoma Corporation …M Highlights_Normal...Subpart F – Operations and...

Tulsa, Oklahoma

2014 Seminar

§195.402

Procedural Manual for

Operations,

Maintenance, and

Emergencies

Subpart F – Operation

and Maintenance

§195.400 – Scope

This subpart (Subpart F) prescribes the

minimum requirements for operating and

maintaining pipeline systems

constructed with steel pipe.

Subpart F – Operations

and Maintenance

§195.401 – General Requirements

No operator may operate or maintain its

pipeline systems at a level of safety

lower than that required by this subpart

and the procedures it is required to

establish under §195.402(a)……..

Operator shall prepare and follow for each

system a manual of written procedures for:

Conducting normal operations

Handling abnormal operations

and emergencies

§195.402(a) Procedural manual for

operations, maintenance, and

emergencies.

Manual shall be reviewed at

intervals not exceeding 15

months, but at least once each

calendar year.

Changes to insure

manual is effective

§ 195.402(a) Procedural manual for

operations, maintenance, and

emergencies.

Manual shall be prepared before

initial operation of pipeline

system and appropriate parts

kept at locations where O&M

activities are conducted.

§195.402(a) Procedural manual for

operations, maintenance, and

emergencies.

Manual Considerations

• Is it in writing?

• How detailed and is it adequate?

• Is it being followed?

• Does it apply to each pipeline

system?

• Did it exist before startup?

• Is it reviewed as required?

Manual Considerations

• How are changes communicated?

• How is it kept?

• All copies same version?

• Employees trained and qualified on it?

• How do employees access it?

• Documentation and records retention?

Notice of Amendment

§195.402 (b)

• OPS or Certified State Agency

• Opportunity for Hearing

(§190.237)/Relevant State Procedures

• May Require Operators to

Amend Procedures

• Provide Reasonable Level

• of Safety

(c) Maintenance and normal operations.

The manual required by (a) must include

procedures for the following to provide safety

during maintenance and normal operations.

(1) making construction

records, maps and operating

history available

§195.402 (c)

Maintenance and Normal Operations

§195.402(c)(1) Construction

Records & Maps

• Construction Records

– §§195.266 & 195.310

– Welding Records, Pipe Specs, Depth of

Cover, Pressure Test and MOP Records

• Maps

– Location of P/L Crossings, Utility

Crossings, Overhead Crossings, Valve &

CP Test Stations

• Operating History

– Pressure Test Records/

Historical Pressures

Records

• Life of Facility – Include construction, materials, repairs,

MOP information, and most corrosion

records

–Retained for active life of facility

• Other Records – Include tests, inspections, patrols, surveys

and procedure reviews which prove

compliance with 49 CFR 195

–Retain for intervals as required §195.404

(2) gathering of data for reporting

accidents under Subpart B in a timely

and effective manner

§195.402(c)(2) Data Gathering

§195.402(c)(2) Data Gathering

Who is responsible for making immediate

notification / written report

Criteria for completing each report

Time limit on reporting

Data to be reported (§§195.50 , .52 & .54)

Telephone number

Electronic reporting requirements

(3) operating, maintaining,

& repairing the pipeline

system in accordance with

this subpart and Subpart H

§195.402(c)(3) Operations,

Maintenance and Repairs

§195.402(c)(3) Operations,

Maintenance and Repairs

• Training

• Maps & Records

• Floating Roofs

• MOPs

• Communications

• Line Markers

• ROW Inspections

• Valve Maintenance

• Corrosion Control Records

• Pipeline Repairs

• Pipe Movement

• Scraper & Sphere Facilities

• Overpressure Safety Devices

• Fire Fighting Equipment

• Breakout Tanks

• Signs

• Security of Facilities

• Smoking or Open Flames

• Public Education

• Damage Prevention

• CPM Leak Detection

(4) determine which pipelines are located in areas

requiring immediate response to prevent hazards to

the public if the facilities failed or malfunctioned

§195.402(c)(4) Areas of Immediate

Response

§195.402(c)(4) Areas of

Immediate Response

• Define Areas Requiring Immediate Response ?

– Check HCA’s / Pipeline Facility Response Plan

(49 CFR Part 194)

• Where are They?

– Proximity to: Residential, Commercial, Industrial

– HVLs must consider Topography

• Does an Operator have to claim some?

(5) analyzing pipeline accidents to determine cause

§195.402(c)(5) Analyzing Accidents

§195.402(c)(5) Analyzing Accidents

• Consideration should be given to:

– Data examination

– Responsible personnel

– Metallurgical examination

– Material analysis

– Procedures

– OQ

(6) minimizing potential for hazards identified under

(c)(4) and possibility of recurrence of accidents

analyzed under (c)(5)

§195.402(c)(6) Minimizing Hazards

(7) starting up & shutting down pipeline in a manner

to assure operation within limits of §195.406,

considering system parameters

§195.402(c)(7) Start up and Shut down of

Pipelines

(8) for pipelines not equipped to fail safe, monitoring from

an attended location, pressure during startup until steady

state and during shut-in to assure operation within

§195.406

(9) for facilities not equipped to fail safe that are identified

under (c)(4) or that control receipt and delivery, detecting

abnormal conditions and transmitting the same to an

attended location

§195.402(c)(8)(9) Start up, Shut down and

Monitoring of Pipelines

§195.402(c)(8)(9) Start up, Shut down and

Monitoring of Pipelines

Monitoring Pressure During Start up, Delivery or Shut-Ins

– Fail-safe - A design feature which will maintain or

result in a safe condition in the event of malfunction

or failure of a power supply, component, or control

device. Fail-safe may occur by three methods: fail

open, fail close, or fail at last position (§193.2007)

– Shut-down or Other Action To Prevent Exceeding

the Operational Limits

§195.402(c)(8) Start up and

Shut down of Pipelines

Monitoring P/L Data From Facilities in:

– Areas Requiring Immediate Response

– Receipt and Delivery Points

– If Not Equipped to Fail Safe – Emergency Flow Restricting Valves (EFRVs)

such as check valves or remote control valves (RCV)

(10) abandoning pipeline facilities, including --

• Safe disconnection from operating pipeline

system

• purging of combustibles

• Sealing abandoned facilities left in place

• Filing reports on applicable facilities

§195.402 (c)(10) Abandonment

Each abandoned offshore pipeline facility or

each abandoned onshore pipeline facility that

crosses over, under or through commercially

navigable waterways

Last operator of that facility must file a report

upon abandonment of that facility in accordance

with §195.59 of this part.

Abandonment - Reporting

(11) minimizing the likelihood of accidental ignition

of vapors in areas identified under (c)(4)

(immediate response locations) where potential

exists for presence of flammable liquids or gases

§195.402 (c)(11) Accidental

Ignition

(12) Establish & maintain liaison with -- fire

police

other appropriate public officials

to learn the responsibility

& resources of agencies

that may respond to an

emergency ...

§195.402 (c)(12) Liaison

What is liaison?

Coordination: the exchange of information

or the planning of joint efforts by two or

more people or groups, often of military

personnel

A communication for establishing and

maintaining mutual understanding and

cooperation

... and acquaint

them with the

operator's ability in

responding to

pipeline

emergencies and

means of

communications

(13) periodic reviewing the work done by operator

personnel to determine the effectiveness of the

procedures in normal operation and maintenance

and take corrective

action where

deficiencies

are found

§195.402 (c)(13) Periodic Review

(14) take adequate precautions in excavated

trenches from unsafe accumulations of vapor or

gas, and make available WHEN NEEDED ...

emergency rescue equipment

breathing apparatus

rescue harness & line

§195.402 (c)(14) Excavation

(15) Implementing the

applicable control room

management procedures

required by § 195.446

§195.402 (c)(15) Control Room

Abnormal

Operations

§195. 402 (d) Abnormal Operations

Purpose:

– Provide Safety When Operating Design Limits

Have Been Exceeded

– Near misses, to which there is no response,

may escalate into accidents or other

reportable items

§195.402(d) Abnormal Operation

The manual required by (a) must include

procedures for the following when

operating design limits have been

exceeded

Operating Design Limits

• “ ...those limits or ranges of pressure, flow, or

temperature etc., that a carrier imposes on it’s pipeline

system to define normal operations”

• “Operations outside these limits indicate an abnormal

condition which should be corrected to avoid

approaching the strength limit of the system and the

potential for failure” Amnd. 195 -16

• Now defined in §195.446 – Control Room

Management

§195.402 (d)(1)Causes of Abnormal

Operations

Responding to, investigating, correcting

– Unintended Closure of Valves or Shutdowns

§195.402 (d)(1)Causes of

Abnormal Operations

Responding to, investigating, correcting

– Increase or decrease in pressure or flow

outside of normal operating limits

§195.402 (d)(1)Causes of

Abnormal Operations

Responding to, investigating, correcting

– Loss of Communications

§195.402 (d)(1)Causes of

Abnormal Operations

Responding to, investigating, correcting

– Operation of Any Safety Device

– Any other

Malfunction of Component

Deviation from Normal Operation

Personnel Error

– Cause hazard to Persons or Property

Check variations from normal operations after

abnormal operation has ended at critical locations to

ensure system integrity and safe operation;

§195.402 (d)(2) Abnormal

Operations

Correcting variations from normal

operation of pressure and flow and

control;

§195.402 (d)(3) Abnormal

Operations

Notify responsible operator

personnel when notice of

abnormal operation is received;

§195.402 (d)(4) Abnormal

Operations

Periodic review of the response of

personnel to determine effectiveness of

procedures controlling abnormal

operations and make corrections of

deficiencies.

§195.402 (d)(5) Abnormal

Operations

Manual required by paragraph (a) must

include procedures for the following to

provide safety when an emergency

condition occurs

§195.402 (e) Emergencies

• Procedures for

receiving, identifying,

and classifying notices

of events which require

an immediate response

by the operator or

§195.402 (e)(1) Emergencies

• Notice to fire, police,

other public officials

and communicating

information to operator

personnel for corrective

action

• ADB 2010-08

§195.402 (e)(1) Emergencies

Receiving Notices:

24 hour telephone number Toll free or collect call

Number changed

Company during the day,

or police or answering

service at night?

How is it answered?

§195.402 (e)(1) Emergencies

Identifying Notices:

List of questions to help identify the type

of emergency event

Contact information

Location of event

Training to determine the type of event,

is it an emergency event, are people in

danger, is it on your system?

§195.402 (e)(1) Emergencies

Instructions for Callers:

Safety instructions for someone

reporting a HL pipeline event

Do the instructions provide information

for the safety of people first

Person receiving trained to

understand and make decisions

§195.402 (e)(1) Emergencies

Prompt and effective response to notice of

each type of emergency, including...

fire/explosion near or directly involving a

pipeline facility

§195.402 (e)(2) Emergencies

Prompt and effective response to notice of

each type of emergency, including...

Accidental release of hazardous liquid or

carbon dioxide from pipeline facility

§195.402 (e)(2) Emergencies

Prompt and effective response to notice of

each type of emergency, including...

Operational failure causing hazardous

conditions

§195.402 (e)(2) Emergencies

Prompt and effective response to notice of

each type of emergency, including...

Natural disaster affecting pipeline facilities

§195.402 (e)(2) Emergencies

• The availability of personnel, equipment, tools, and

materials, as needed at the scene of an emergency

• Current personnel contact lists, numbers, and

responsibilities

• Current lists of equipment, tools, and materials,

needed to respond to possible types of

emergencies

• Current contractor contact list, capabilities, and

equipment, available to respond to an

emergency

§195.402 (e)(3) Emergencies

The availability of personnel, equipment,

tools, and materials, as needed at the

scene of an emergency

§195.402 (e)(3) Emergencies

• Responsibility for overall

coordination of personnel

and execution of the

emergency response plan

• Incident command system

(ICS)

THE SYSTEM CONSISTS OF

PROCEDURES FOR: Controlling facilities

Controlling personnel

Coordinating response agencies

Providing for common terminology

Effectively managing communications

Responding to nearly any kind of disaster

Managing equipment and “hard” resources

ICS

Provides for:

- Single jurisdiction/single agency involvement

- Single jurisdiction with multi-agency involvement

- Multi-jurisdiction/multi-agency involvement

Readily adaptable to new technology

Common terminology, procedures and standards

Applicability and acceptability throughout country

Expandable in a logical manner from a single point

Adaptability to wide range of response requirements

ICS Structure

Taking necessary action, such as

emergency shutdown

pressure reduction

To minimize the volume that is released

§195.402 (e)(4) Emergencies

Control of release product at accident

scene to minimize hazards, including

possible intentional ignition in cases of

HVLs

§195.402 (e)(5) Emergencies

Minimize public exposure to injury or

probability of accidental ignition by

assisting with evacuation, halting

traffic on roads or railroads, or

taking other appropriate action

§195.402 (e)(6) Emergencies

Notify fire, police,

other appropriate

public officials of

pipeline

emergencies

§195.402 (e)(7) Emergencies

Coordinate with them preplanned and

actual responses during an emergency

§195.402 (e)(7) Emergencies

Including additional

precautions

necessary for HVL

pipelines

§195.402 (e)(7) Emergencies

ADB - 2012 – 09

October 11, 2012

Communication during emergency

situations NTSB recommendation that operators ensure

control room operators immediately and

directly notify the appropriate public safety

access point (PSAP) when a possible rupture

or other pipeline problem is indicated

ADB - 2012 – 09

October 11, 2012

Communication during emergency situations

Reminder to maintain informed relationship

Call all appropriate PSAP’s with indications

of a pipeline emergency

Immediate contact and conversation will

facilitate timely, effected, and coordinated

response.

In case of HVL pipeline

failure, use appropriate

instruments to assess

extent and coverage of

vapor cloud and

determine hazardous

areas.

§195.402 (e)(8) Emergencies

Providing for post accident review

of employee activities to determine

whether procedures were effective

and take corrective action if

deficiencies are found

195.402(c)(4&5)

§195.402 (e)(9) Emergencies

Actions required to be taken by a

controller during an emergency in

accordance with §195.446

§195.402 (e)(10) Emergencies

(a) Each operator shall establish and

conduct a continuing training program to

instruct emergency response personnel to:

§195.403 Emergency Response

Training

Carry out emergency procedures

established under §195.402 that relate to

their assignments

§195.403 (a)(1) Emergency

Response Training

§195.403 (a)(2) Emergency

Response Training

Know the characteristics and hazards

of products transported, including

for HVLs, flammability mixtures in

air, odorless vapors, and water

reactions

§195.403 (a)(3) Emergency

Response Training

Recognize conditions likely to cause

emergencies, predict consequences

of malfunctions or failures and

spills, and take appropriate

corrective action

§195.403 (a)(4) Emergency

Response Training

Take steps necessary to control an

accidental release, and minimize the

potential for fire, explosion, toxicity,

or environmental damage

H Hazard

E Extent

L Life

P Property

S Safe

§195.403 (a)(5) Emergency

Response Training

Learn potential

causes, types,

sizes, and

consequences

of fires

§195.403 (a)(5) Emergency

Response Training

Learn potential

causes, types,

sizes, and

consequences

of fires……..

§195.403 (a)(5) Emergency

Response Training

…….the appropriate use

of portable fire

extinguishers and

other on-site fire

control equipment,

involving………

§195.403 (a)(5) Emergency

Response Training

…….where feasible, a

simulated pipeline

emergency

§195.403 (b) Emergency

Response Training

At intervals not exceeding 15 months, but

at least once each calendar year, each

operator shall:

(1) review with personnel their

performance in meeting objectives of

emergency response training as found in

(a)

§195.403 (b) Emergency

Response Training

At intervals not exceeding 15 months, but

at least once each calendar year, each

operator shall:

(2) make appropriate changes to training

program as necessary to ensure it is

effective

§195.403 (b) Emergency

Response Training

At intervals not exceeding 15 months, but

at least once each calendar year, each

operator shall:

(3) Operator shall require and verify that

supervisors maintain a thorough

knowledge of the emergency plans for

which they are responsible for

compliance

§195.402 (f) Safety

Related Conditions

The manual required by (a) must include

instructions enabling personnel who

perform O&M activities to recognize

conditions that potentially may be safety-

related conditions that are subject to

reporting under §195.55

§195.402 (f) Safety Related

Conditions