An Industry Response to the Expected Control Room Management Rule Western Regional Gas Conference Daron Moore – El Paso Pipeline Group August 25, 2009

Rule Development NPRM issued in September 2008 NPRM issued in September 2008 Difficult to comply with Difficult to comply with Extremely costly in implementation Extremely costly in implementation No incident history or justification for rule No incident history or justification for rule Trades proposed following Congressional guidance only Trades proposed following Congressional guidance only Some issues for liquids industry due to incidents Some issues for liquids industry due to incidents

Rule Development Trade Associations commented heavily on Proposed Rule Trade Associations commented heavily on Proposed Rule Trade Associations negotiated with PHMSA extensively prior to meeting Trade Associations negotiated with PHMSA extensively prior to meeting Result was greatly slimmed-down rule that is perceived to be able to be implemented Result was greatly slimmed-down rule that is perceived to be able to be implemented Final Rule is expected in September to December 2009 timeframe Final Rule is expected in September to December 2009 timeframe

One Industry Response SGA established group to address creating a “common framework” for all operators to comply with. Anticipated benefits include: SGA established group to address creating a “common framework” for all operators to comply with. Anticipated benefits include: –Increased probability of compliance with rule –Lower cost of compliance (manual development, information exchange, learned processes, etc) –Shorter inspection times –Common model for both state and federal inspectors when visiting –Strength in numbers –Flexible for individual operations –Model for other “programs” (O&M, OQ, IMP, NDE/Joining, etc)

Probable Rule Summary Definitions effectively limited scope to what we know as Gas Control Definitions effectively limited scope to what we know as Gas Control Written plan is required (see SGA effort)( (b)) Written plan is required (see SGA effort)( (b)) Roles and Responsibilities ( (c)) Roles and Responsibilities ( (c))

Probable Rule Summary Provide Adequate Information ( (d)) Provide Adequate Information ( (d)) –Use API RP-1165 if changes –Point-to-point verification if changes –Annually test communications plan –Annually test back-up SCADA plan –Establish shift change procedures

Probable Rule Summary Fatigue Management ( (e)) Fatigue Management ( (e)) –Establish shift length and rotations –Educate and train controllers and supervisors (could be joint training effort, common platform) –Establish service hours limit

Probable Rule Summary Alarm Management ( (f)) Alarm Management ( (f)) –Must review SCADA alarms to: Monthly identify safety points off scan or with forced values Monthly identify safety points off scan or with forced values Annually verify setpoint values Annually verify setpoint values –Annually review Alarm Management plan and change if necessary –Monitor content and volume of activity to each controller

Probable Rule Summary Change Management ( (g)) Change Management ( (g)) –If significant software or physical changes, control room must be consulted with Operating Experience ( (h)) Operating Experience ( (h)) –All incidents must be analyzed for control room involvement –All lessons learned from incidents shall be incorporated into training program

Probable Rule Summary Training ( (i)) Training ( (i)) –Program must be established and annually reviewed –Focus areas: Responding to AOCs Responding to AOCs Use of established area of training Use of established area of training Controller responsibilities during emergencies Controller responsibilities during emergencies Pipeline system working knowledge training Pipeline system working knowledge training Opportunity to review procedures for infrequent setups Opportunity to review procedures for infrequent setups

Probable Rule Summary Validation ( (j)) Validation ( (j)) –Submit program to respective agencies when requested Compliance and deviations ( (k)) Compliance and deviations ( (k)) –Required for review during inspections: Compliance records Compliance records Documentation of decisions deviating from this section Documentation of decisions deviating from this section Deviations must be submitted on request Deviations must be submitted on request

Draft Common Manual Table of Contents Section Introduction – Applicable Companies/Facilities1 102 – Applicable Scope ( (a))2 103 – Change Procedures – Deviation Procedures ( (k)(2))2 105 – Approval2 106 – Effective/Implementation Dates2 107 – Validation ( (j))3 108 – Records ( (k)(1))3

Draft Common Manual Table of Contents Section 200 – Definitions4 201 – Alarm4 202 – Control Room4 203 – Controller4 204 – Supervisory Control and Data Acquisition System (SCADA)4

Draft Common Manual Table of Contents Section 300 – Roles and Responsibilities5 Section 400 – Controller Information6 401 – Controller Tools ( (d))6 402 – API RP ( (d)(1))7 403 – Point-to-Point Verification ( (d)(2))7 404 – Internal Communication Plan ( (d)(3))7 405 – Backup SCADA System ( (d)(4))7 406 – Shift Changes ( (d)(5))8

Draft Common Manual Table of Contents Section 500 – Fatigue Management9 501 – Shift Lengths and Rotations ( (d)(1) and (d)(4))9 502 – Fatigue Education ( (d)(2-3))9 Section 600 – Alarm Management Plan – Alarm Management Plan Review ( (f)(2)) – SCADA Point Review ( (f)(1)) – Activity Review ( (f)(3))11

Draft Common Manual Table of Contents Section 700 – Change Management – Communications ( (g)) – Significant Hydraulic or Configuration Changes ( (g)(1-2))12 Section 800 – Operating Experience – Incident Review ( (h)(1)) – Lessons Learned ( (h)(2))13 Section 900 – Training – Training Program Review ( (i)) – Training Program Elements ( (i)(1-5))14