Abnormal Operating Conditions
The Operator Qualification (OQ) Rule has been in place for nearly twenty years, and most pipeline operators have effective OQ programs. One area of OQ that can improve is training and evaluating individuals to recognize and react to Abnormal Operating Conditions, or AOCs.
Abnormal Operating Condition means a condition identified by the operator that may indicate a malfunction of a component or deviation from normal operations that may:
(a) Indicate a condition exceeding design limits; or
(b) Result in a hazard(s) to persons, property, or the environment.
The definition of an Abnormal Operating Condition, or AOC, is the same in both the Gas Code (Part 192) and the Liquids Code (Part 195). A common understanding of an AOC is something that can go wrong during the performance of a covered task.
General AOCs, Task-Specific AOCs, or Both?
There are varying schools of thought concerning setting up your list of AOCs. For example, is it best to use General AOCs, Task-Specific AOCs, or a combination?
A sound approach is to use both General and Task-Specific AOCs, ensuring you don’t miss any common AOCs (General) and AOCs related to the task being performed (Task-Specific.)
Establishing AOCs
How extensive should your list of AOCs be? Should you create a long list or keep it simple and concise?
The best plan is to only include AOCs that are likely to occur without going to extremes. AOCs should be realistic and the list concise. An airplane could crash into a gas facility while replacing damaged pipe coating. However, experience has shown that this situation is very unlikely to occur. Based on the rarity of this event, an airplane crash should not be included as an AOC for this task. It is possible to take AOCs to the extreme. What about a building collapse or a meteor striking the facility? Those are also possible but highly unlikely to occur. Regulatory inspectors often challenge an operator’s AOCs and ask the operator to justify their AOCs and explain why other AOCs are not included in the operator’s OQ Plan. Regulatory inspectors are free to voice their opinions. However, operators should tactfully push back on requests to add just one more AOC if the operator does not believe the additional AOC should be added.
Industry Associations and Vendors
Operators should familiarize themselves with helpful industry organizations such as the American Society of Mechanical Engineers (ASME) B31Q committee and the American Petroleum Institute’s (API) Operator Qualification Working Group (OQWG) and consider joining the organizations' committees. These associations update two of the industry’s most significant works on operator qualification and AOCs.
Operators who plan to incorporate an industry association’s or vendor-provided list of AOCs should first review each of the AOCs for applicability to the operator’s system. Operators often accept AOCs unchanged without creating documentation of their review and acceptance. This can prompt regulatory inspection questions that might not even be asked if the operator had performed due diligence by documenting their review and acceptance of the AOCs. We’ll go through each of the steps necessary to properly vet AOCs.
Step One: Review Proposed AOCs
Operators should gather subject matter experts (SMEs) from various operating areas and go through each AOC related to their area of expertise. Ask the SMEs if each AOC is appropriate, meaning (1) does each meet the regulatory and/or operator definition of an AOC, and (2) is the AOC something likely to occur? If both questions are answered affirmatively, the SMEs should be asked to define how the AOC will be recognized. A good process to establish the recognition of each AOC is to use the five senses: sight, smell, hearing, taste, and touch. Ask the SMEs what the AOC will look, smell, sound, taste, and feel like. Then, document the SME responses on how individuals performing covered tasks will recognize the AOC. The recognition should be the same for contractors and operator personnel.
For example, SMEs may determine the AOC of Ignition of Gas or Hazardous Liquid will:
Next, ask the SMEs how individuals should react to each AOC. The reaction may be different for contractors and operator personnel. In the example, operator personnel have an additional step in the reaction of shutting off the source of gas if it can be done safely, while contractors are not permitted to perform this step. The differences in reactions are highlighted in the tables below.
Once the recognitions and reactions are defined, modify the association or vendor-provided AOCs.
Step Two: Modify AOC Training, Testing, and Evaluation Materials
Supplemental training and testing content and evaluations can be created to be used in addition to current materials, or operators can create brand-new courses and exams to incorporate the work of the SMEs. The key consideration here is to ensure individuals who will perform covered tasks for the operator are trained, tested, and evaluated to the operator’s AOCs. In an ideal situation, the association or vendor-provided list of AOCs wouldn’t require significant modification other than incorporating operator-defined recognitions and reactions.
Step Three: Acceptance
Operators should get the SMEs involved in the AOC process and relevant company leaders to accept the AOCs. It’s important to note that even when operators begin with an association or vendor-provided list of AOCs, after the SME review, operator-specific recognitions and reactions and any necessary modifications to training, testing, and evaluation materials, the AOCs are no longer generic, industry materials. The AOCs are now the operator’s.
Step Four: Documentation
As with everything in the pipeline industry, documentation is necessary to prove these processes occurred. Documentation may include sign-up sheets of the participants attending the SME meetings. Document the updated recognitions and reactions. Document any modifications made to training, testing, and evaluation processes and documentation of the operator’s acceptance of the AOCs. This documentation should be maintained and made available, if necessary, during regulatory inspections.
EWN’s AOC Groups
Energy Worldnet has created twelve groups to organize fifty-six AOCs. These are:
1. Abnormal Pressure or Liquid Level
?2.????? Activation of a Safety Device
领英推荐
3.????? Cathodic Protection Malfunction
?4.????? Corrosion of System Component
?5.????? Damaged or Defective Component
?6.????? Electrical Hazard
?7.????? Environmental Hazard
?8.????? Equipment Malfunction
?9.????? Excavation Hazard
?10.?? Failure to Follow Procedures
?11.?? Hazardous Atmosphere
?12.?? Product Release
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AOC Training
Pipeline operators and contractors train individuals less frequently on AOCs than on regularly performed tasks, which is the opposite of where we should be. Individuals will be more proficient in tasks they perform regularly than in recognizing and reacting to AOCs since those are encountered less frequently.
The Aviation Industry doesn’t need a passenger plane pilot to perform routine takeoffs, flights, and landings. Automated systems can do those things. You need a pilot to handle unexpected problems that may occur. These unexpected situations are like AOCs in the pipeline industry.
Well-trained technicians are needed to handle unexpected situations that endanger life and/or property.
Evaluation of AOCs
Knowledge testing supplemented by performance testing is effective for evaluating recognition. Performance evaluation supplemented by knowledge testing is effective for evaluating reactions.
Simulations can be valuable in training and evaluating the recognition and reaction to AOCs. Many operators are using critical questions for AOC-related questions.
After the Evaluation
§192.805(b) and §195.505(b) require operators to ensure through evaluation that individuals performing covered tasks are qualified. §192.803 and §195.503 define qualified when an individual has been evaluated and can (a) perform assigned covered tasks and (b) recognize and react to Abnormal Operating Conditions. Note that these requirements aren’t limited to when an individual is qualified or requalified. While an individual is performing covered tasks, operators must ensure they can appropriately recognize and react to AOCs. This can be accomplished through ongoing site visits.
As always, document your observations as well as any corrective measures task.
Regulatory Inspections
What are regulatory inspectors looking for regarding AOCs?
Some regulatory inspectors may expect individuals to be able to recite all of the AOCs associated with a task they’re performing. However, PHMSA, in question twenty-nine of their recently updated Operator Qualification Frequently Asked Questions, states: Individuals are not expected to recite a complete listing of AOCs for the covered tasks without referencing manuals or guides provided by the operator.?
Summary
PHMSA Pipeline Consultant - Specializing in both CFR 192 & 195, Auditing for Compliance, CRM, OM&E, OQ, PSMS. OQ'ed in Gas leak testing for 192 Transmission and Regulated gathering lines
1 年The clients I am working with for many years has gone back and forth on this issue. Working with them we have narrowed down on the AOC”s they have and made it very useful tool for them in training.
General Manager | Managing Director | People Leadership | Strategic Management | Financial Performance | Employee Development | Relationship Management | Problem Solving | Process Improvement | Compliance | Energy
1 年This is great to see such a useful piece of insight and not mountains of “fluff” with no practical application. Thank you again.