COLONIAL PIPELINE COMPANY OPERATOR QUALIFICATION PROGRAM

Transcription

1 COLONIAL PIPELINE COMPANY OPERATOR QUALIFICATION PROGRAM

2 Table Contents 1. PURPOSE SCOPE COVERED TASKS VALIDATION OF COVERED TASK LIST OF ACTIVITIES PERFORMED AT CPC INITIAL QUALIFICATION RE-QUALIFICATION OF COVERED TASKS FREQUENCY OF PERFORMANCE OF THE COVERED TASK COVERED TASK COMPLEXITY CONSEQUENCE OF PERFORMANCE OF THE COVERED TASK DETERMINATION OF RE-QUALIFICATION FREQUENCY WELDING TASK RE-QUALIFICATION IDENTIFY ELEMENTS AND STANDARDS FOR COVERED TASKS ABNORMAL OPERATING CONDITIONS IDENTIFY SKILL AND KNOWLEDGE REQUIREMENTS FOR COVERED TASKS EVALUATION METHODS FORMS OF EVALUATION Written Examinations Electronic Examination Oral Examination Verification Simulation Oral Other Forms Administration s Unsatisfactory Completion an TRAINING POST ACCIDENT INVESTIGATIONS SUSPENSION AND/OR DISQUALIFICATION NON-QUALIFIED INDIVIDUALS MANAGEMENT OF CHANGE CONTRACTOR PERSONNEL MUTUAL ASSISTANCE DETERMINING WHETHER AN ACTIVITY CONSTITUTES A COVERED TASK REMOVAL OF EQUIPMENT FROM A PIPELINE FACILITY NEW CONSTRUCTION RECORD KEEPING PROGRAM EVALUATION PRIVATE/PROPRIETARY. 2 67

3 20.1 PROGRAM REVIEW AUDITS NOTIFICATION TO PHSMA OF SIGNIFICANT MODIFICATIONS TO PROGRAM IDENTIFY ORGANIZATIONAL REQUIREMENTS OQ COORDINATOR AND A TECHNICAL TRAINING DESIGNEE EVALUATOR TRAINERS MANAGERS WORK SITE SUPERVISORS APPENDIX A QUALIFICATION REQUIREMENTS PURPOSE INTERNAL CPC QUALIFICATION METHODS INDUSTRY AND PROFESSIONAL CERTIFICATIONS API API API Section IX ASME ASNT AWS Clock Spring Repair (Composite wrap) NACE CP1 CP Tester NACE CP 2 CP Technician NACE CIP Level TDW CT50 Qualified Technician TDW LineMaster T50 (Transmission) Other Third Party Certifications (as authorized) EXTERNAL QUALIFICATION METHODS NCCER National Center for Contractor Education and Research OQ Module Written Assessment Verifications Curriculum module OQSG CT - Operator Qualification Solutions Group Computer-based Training (CBT) Verification Veriforce CCT Common Covered Task ABNORMAL OPERATING CONDITIONS QUALIFICATION PROCESSES CPC-WA-AOC - CPC Written Assessment for Abnormal Operating Conditions Specific Abnormal Operating Conditions Other External Abnormal Operating Conditions Qualification TASKS-TO-QUALIFICATION REQUIREMENTS MATRIX APPENDIX B - RESERVED APPENDIX C OQ VERIFICATION REPORT APPENDIX D DISQUALIFICATION AND SUSPENSION APPENDIX E DEFINITIONS APPENDIX F ANNUAL REVIEW DOCUMENTATION PRIVATE/PROPRIETARY. 3 67

4 1. PURPOSE The Operator Qualification (OQ) Program includes provisions designed to satisfy obligations imposed under 49 CFR 195 Subpart G and ensures, through evaluation, that individuals who perform Covered Tasks (as defined in 49 CFR (b)), are qualified to perform the Covered Task as well as recognize and react to abnormal operating conditions. This program applies to Colonial personnel and the personnel contractors Colonial. 2. SCOPE The Program is designed both to ensure that individuals performing a Covered Task on hazardous liquid pipeline facilities operated by are qualified to perform specific Covered Tasks, and to reduce the probability and consequences incidents. All employees and contractors performing Covered Tasks on pipeline facilities operated by Colonial Pipeline will be qualified under this Program, or be directed and observed by an individual that is qualified. 3. COVERED TASKS A list Covered Tasks included in this Program is set forth in Appendix A. The Covered Tasks were identified by application the following four part test set forth in 49 CFR (b)(1)-(4). A Covered Task is one that: 1. Is performed on a pipeline facility 2. Is an operations or maintenance task 3. Is performed as a requirement 49 CFR Part 195 for liquid pipelines 4. Affects the operation or integrity the pipeline When a task is proposed for consideration as a Covered Task during reviews Lessons Learned, Incident Analysis, discussions with industry representatives, or by an employee or contractor, that task will be reviewed by the OQ Committee to make sure it meets the four part test. If approved, the task is to be added to the task list by OQ Coordinator at the next update, or as soon as practicable when recommended by the OQ Committee. 4. VALIDATION OF COVERED TASK LIST OF ACTIVITIES PERFORMED AT CPC CPC has worked with industry and Subject Matter Experts (SME) to identify and analyze tasks performed on DOT covered pipeline facilities. The list Covered Tasks was derived, in part with reference to the API (American Petroleum Institute) Recommended Practice 1161 Recommended Practice for Pipeline Operator Qualification. A complete listing tasks identified by Colonial is identified in Appendix A. PRIVATE/PROPRIETARY. 4 67

5 5. INITIAL QUALIFICATION Any employee or contractor must be qualified under this program to perform a Covered Task unless they meet the requirements Section 15 Non-Qualified Individuals. qualification requires training on skill and knowledge requirements, abnormal operating conditions and completion a performance evaluation. Upon satisfactory completion required training and a demonstration competency through evaluation as identified in Section 10, an individual can be deemed qualified to perform the Covered Task. qualification typically requires training through a company or external instructor-led course, self-study, on-the-job training or computer based training. Following training, initial qualification requires an evaluation through s such as written, electronic or oral examination, or a 3 rd party certification, and task performance verification. Any individual working as a Controller on Colonial s pipeline system must be trained and qualified on a specific desk, console, or system(s) procedures. These individuals will only operate the specific desk, console, or system(s) he / she has been trained and qualified to operate. Each control room desk, console, or system is configured to provide monitoring and control capability for defined segments the pipeline system. qualification pertains to new employees, job transfers, or change in job duties. Covered tasks common to job roles will be assigned to employees by means Colonial s Learning Management System. Covered Tasks assigned to Colonial employees outside core tasks for their job title will be assigned by a functional area leader. 6. RE-QUALIFICATION OF COVERED TASKS Re-qualification (re-evaluation for continued qualification) a covered task after initial qualification requires a performance verification or written/electronic evaluation. The Colonial OQ Committee has developed maximum re-qualification intervals between 36 months and 60 months based on input from task subject matter experts. If the OQ Committee determines that the frequency should be changed, justification for the interval must be established. Qualification frequencies for Covered Tasks can be found in Appendix A and are determined by utilizing the following factors: performance the Covered Task Covered Task Complexity Consequence performance the Covered Task The factors are used as a means to determine the frequency re-qualification Covered Tasks. The values assigned to each factor are combined to determine the total score. The total score is used for the final re-qualification interval determination. PRIVATE/PROPRIETARY. 5 67

6 6.1. the Covered Task The frequency that an individual performs a given Covered Task influences the probability that incorrect performance will affect the operations or integrity the pipeline. Many factors determine the frequency the performance Covered Task including operations schedules, maintenance schedules and some reactive work. Values shall be assigned for frequencies based on typical job performance in Colonial. Values are scored as: Daily = 2 Weekly = 1.5 Monthly = 1 Semi-annually = 2 Annually = Covered Task Complexity The complexity a Covered Task influences the probability that it could be performed incorrectly and affect the operations or integrity the pipeline. The complexity a given task is to be determined assessing five areas complexity as follows: Information Access (How difficult is it to get information to perform task?) Mental Loading (How great is the mental workload to complete the task?) Physical Loading (How complex are the physical actions required?) Communication Loading (How complex and demanding are communication requirements?) Stress (How great is the psychological stress due to time demands, abnormal conditions, or exposure to hazardous conditions?) Each area is scored between 1 and 5 for a given task with 5 being the highest complexity. These scores are averaged for a total task score for complexity. 6.3 Consequence performance the Covered Task The consequence(s) incorrectly performing the task is risk rated using the following scores. Minimal (Minimal affect to safety or pipeline integrity) =1 Minor (Some potential impact to health or quality operations) =2 Moderate (Personal injury or minor environmental damage possible) =4 Major (Possible lost time injury or pipeline integrity threatened) =6 Extreme (Significant health and/or environmental damage possible) =8 6.4 Determination Re-Qualification To determine the re-qualification frequency, the above parameters (frequency performance, complexity, and consequence) are scored individually. These scores are then added together for a total score. This total number then determines the frequency qualification: Score : 3 to 7 Five-year qualification frequency. Score : 7.5 to 10 Four-year qualification frequency. Score : 10.5 to 16 Three-year qualification frequency. PRIVATE/PROPRIETARY. 6 67

7 6.5 Welding task re-qualification Qualifications for pipeline welding tasks require an increased frequency re-qualification based on Colonial s procedures for pipeline welding qualification. The welder s qualification is verified by the successful completion a performance welding test (Reference Appendix A.) Re-qualification is verified by successful completion a weld within the preceding six calendar month period for pipeline welding. Weld acceptability is in accordance with API Qualifications for tank welding and repair are required to comply with Section IX ASME (American Society Mechanical Engineers) Boiler and Pressure Vessel Code (Reference Appendix A). 7. IDENTIFY ELEMENTS AND STANDARDS FOR COVERED TASKS A complete listing tasks identified by Colonial is identified in Appendix A. 8. ABNORMAL OPERATING CONDITIONS An abnormal operating condition (AOC) is a condition identified that may indicate a malfunction a component or is a deviation from normal operations that: Indicates a condition exceeding design limits, and /or Could result in a hazard(s) to persons, property, or the environment Note: A deviation from normal operation does not necessarily mean an abnormal operating condition exists. Through the OQ evaluation process, a determination is made if an individual is able to recognize and react appropriately to abnormal operating conditions specific to each Covered Task. At no time will an individual be allowed to perform work that is considered as covered under this program that has not been properly evaluated on their ability to react and respond to abnormal conditions. The AOCs possibly encountered while performing Covered Tasks at CPC are listed below. This list may not be comprehensive and may change as new conditions are identified. Hazardous liquids leak Operational situations caused by a fire or explosion Component failure or component malfunction Physical damage in pipeline system Abnormal facility condition Communications, control system or power interruption or failure Activation a safety device Unexplained pressure and/or flow rate deviation PRIVATE/PROPRIETARY. 7 67

8 Colonial employees who qualify on pipeline operations tasks will be required to be assessed on abnormal operating conditions that are specific to the operation the pipeline. Appropriate response to abnormal operating conditions is task specific and situationally dependent, and typically includes steps to minimize the situation and notify appropriate personnel. Colonial corporate protocol dictates the following priorities and actions: 1. Protect the health and safety personnel, then 2. Protect the community and environment, then 3. Protect the assets CPC and its affiliates. Once a situation becomes an Emergency, the appropriate action will be taken in accordance with Colonial s Emergency Procedures. 9. IDENTIFY SKILL AND KNOWLEDGE REQUIREMENTS FOR COVERED TASKS CPC conducted an analysis training programs and selected s evaluation in Section 6 that meet its requirement for the Knowledge, Skills and Abilities for each Covered Task. 10. EVALUATION METHODS CPC has developed a qualification program that accepts multiple evaluation s. The evaluation and qualification requirements may vary between Covered Tasks. s may change over time to allow for other s verifying an individual s ability to perform a Covered Task. The OQ Coordinator will add all evaluation s approved to Appendix A. PRIVATE/PROPRIETARY. 8 67

9 10.1. FORMS OF EVALUATION Acceptable means evaluation include one or more the following s: Written Examination Electronic Examination Oral Examination Verification: o on the Job o On the Job Training o Simulations Other Forms Assessment as approved and documented by the OQ Coordinator Primary forms qualification include online training modules with associated assessments (Electronic Examination) and performance evaluations. Any form cheating on an evaluation will be seen as a major infraction and disciplinary action, up to termination, will be taken. Any form cheating is strictly prohibited by Colonial s Code Business Conduct and Conduct Training Manual. Colonial s Human Resources Department must be contacted by the Supervisor should an infraction occur. Review work performance history is not used as a sole evaluation and was not utilized previously as a sole evaluation. This may be considered for use in combination with other s. Evaluators must have attended a training class for Evaluators based on the evaluation used. When observing an individual s performance, the Evaluator will be evaluating skills, knowledge and the ability to recognize, react and respond to Abnormal Operating Conditions. The evaluation knowledge, specifically abnormal operating conditions, during performance verification will be completed orally as part the evaluation and documented on the performance verification documentation Written Examinations Written examinations are used as evaluations for certain Covered Tasks. Unless otherwise specified, all internal written assessments will have a minimum passing requirement 80% correct Electronic Examination Unless otherwise specified in Appendix A, electronic testing will be performed using Colonial s Learning Management System or an approved vendor web based systems. PRIVATE/PROPRIETARY. 9 67

10 Oral Examination It may be necessary that a written exam or parts a performance verification be administered orally. Evaluator s administering an oral exam are not required to be qualified to perform that Covered Task but should be knowledgeable in the subject area, or have someone present who is knowledgeable in the subject area, so that they may know if the individual is responding correctly to a question Verification When observation performance is utilized as an evaluation, the qualifying individual will be required to demonstrate or simulate the task for an Evaluator. The Evaluator will observe the qualifying candidate perform the task and document his/her performance. The Evaluator is not required to be qualified in the specific Covered Task but should be knowledgeable in the subject area or have someone present who is knowledgeable in the subject area. Observation on-the-job performance without interaction between the Evaluator and the qualifying individual during performance will not be used as an evaluation. Observation on-the job performance will not be used as the sole qualification. By definition, performance evaluations must include observation performance through actual task performance or task simulation. Based s can be performed by utilizing any the following s: Simulation Oral An individual may be evaluated or re-evaluated during actual performance a Covered Task using live equipment. Special attention must be given to safety if the evaluation is performed as a part actual work. At no time should an unqualified individual be allowed to operate the equipment without the direct supervision a qualified person. based evaluations will be graded as satisfactory or unsatisfactory. The following must be met to receive a satisfactory score during a performance-based evaluation: Performed all steps identified as critical with 100% accuracy. Obtained 100% accuracy on all safety practices. PRIVATE/PROPRIETARY

11 If an individual fails a step or task during an evaluation, the Evaluator has the option stopping the evaluation or performing immediate remediation. Evaluators should document on the performance verification () form that the individual unsuccessfully completed a specific step or task. If the evaluation process was stopped, the performance verification form must be completed and indicate that the individual did not successfully complete the. If remediation is performed, the Evaluator must then have the individual reschedule the evaluation. Evaluators must complete the appropriate form and forward an employee to the Technical Training Department designee. The Technical Training Department is responsible for recording the results the evaluation into the CPC Learning Management System Simulation Simulation requires an individual to act out the step(s) associated with the performance a Covered Task. The evaluation will be graded and recorded as described above for actual performance Oral Some parts performance verification may be oral if performance or simulation is impractical. Oral responses during performance evaluations are integral to the evaluation process to verify knowledge components such as abnormal operating conditions Other Forms Other forms evaluation may include but are not limited to, the use trade schools, Universities, Junior Colleges, and Pressional Certifications. Utilizing these types assessments will require a review and documentation by the OQ Coordinator. Other forms evaluation that have been approved can be found in Appendix A. Other evaluation s may be available but not specifically identified within Appendix A. In the event a proposed evaluation is not authorized in Appendix A the OQ Coordinator should be contacted. Approved s will be added to Appendix A Administration s The Evaluator or Proctor is responsible for completing the documentation required to document the results the evaluation. All employee documents should be forwarded to the Technical Training Department for record retention. The Technical Training Department is responsible for assuring that the individual s qualifications are documented properly and available upon request. Contractors are responsible for documenting evaluation results for their personnel. PRIVATE/PROPRIETARY

12 Unsatisfactory Completion an An individual not successfully completing an initial evaluation or an evaluation for continuing qualification (re-qualification) must wait at least 24 hours before the next attempt in order to retrain, study and develop the skills required to perform a task. The waiting period does not apply when evaluations are interrupted/stopped due to temporary site conditions or technical problems. An individual who has not successfully completed a Covered Task evaluation may not perform that task without a qualified individual directing and observing him/her while performing the task. A second failure an evaluation requires that the Evaluator or Proctor contact the individual s Supervisor in order to determine if the failure was due to inadequate training, an issue with the evaluation, or other cause. The Supervisor will be required to make the determination if continued training, study or skills development is necessary. If necessary, the Disqualification and Suspension form provided in Appendix D this Program will be completed by the Supervisor to suspend the qualification an individual attempting to re-qualify for a covered task. The Disqualification and Suspension form for a CPC employee should be sent to the OQ Coordinator who will notify the Technical TrainingDepartment designee responsible for updating Covered Task qualification records in the Learning Management System. If additional training, study or skills development is necessary following a second failure an evaluation, the Supervisor will document the development or remedial activities and notify the OQ Coordinator before additional evaluations are allowed. 11. TRAINING Training is considered an integral part CPC s Operator Qualification Program. CPC and CPC contractors will provide training, as appropriate, to ensure that individuals performing covered tasks have the necessary knowledge and skills to perform the tasks in a manner that ensures the safe operation pipeline facilities. To accomplish this, training may be performed in a number different ways: On the job Classroom Computer/Web based Self-study Simulation activities 12. POST ACCIDENT INVESTIGATIONS In the event a pipeline accident a post-accident review will commence per Corporate Procedure 16 Incident Analysis and Near Miss Process. The review is performed using the Learning from Experience and Analysis Process (LEAP.) PRIVATE/PROPRIETARY

13 During this process it will be determined whether any Covered Tasks were being performed at the time the accident or leading up to the accident and if so, if the individual s performance a covered task was a contributing factor to the accident. If no Covered Tasks were involved, then no further action is required as a part the Operator Qualification Program. If it is determined that a Covered Task was being performed prior to the accident and that it may have contributed to the accident, then further investigation will be required. Upon further investigation all personnel who were performing the Covered Tasks will have their qualifications immediately suspended until it can be determined whether his/her action contributed to the accident. The Disqualification and Suspension documentation, located in Appendix D, should be completed by the individual s supervisor or manager. If during the accident investigation an individual s performance a Covered Task was found to have contributed to an accident, a determination will be made the level remediation that must be completed. Depending on the circumstances, an individual may be required to complete remedial training and/or re-qualification before being allowed to perform the Covered Task. Remedial measures to be taken must be noted in the Disqualification and Suspension documentation that is found in Appendix D. In the event that an individual s qualifications for one or more Covered Task are suspended or revoked, the Disqualification and Suspension documentation found in Appendix D must be completed and forwarded to the OQ Coordinator who will notify the Technical Training Department designee responsible for updating Covered Task qualification records in the Learning Management System. Upon re-qualification, all qualification forms and assessment material must be forwarded to the Technical Training Department designee for filing. 13. SUSPENSION AND/OR DISQUALIFICATION If there is reason to believe an individual is no longer qualified to perform a Covered Task, he or she will not be allowed to perform that Covered Task until successfully completing requalification on the Covered Task. Disqualification and Suspension documentation is provided in Appendix D. Circumstances that might justify a belief that an individual is no longer qualified to perform a Covered Task may include but is not limited to: Failure to properly perform a Covered Task Excessive absenteeism Loss motor skills, vision, impairment, etc. Statement from the individual Prolonged period non-performance the Covered Tasks Complaints regarding the individual s capabilities If it is found that the suspension/disqualification was not justified, the qualification will be reinstated and the Suspension/Disqualification paperwork properly discarded. PRIVATE/PROPRIETARY

14 14. NON-QUALIFIED INDIVIDUALS Individuals not qualified to perform a Covered Task may perform the task when either: the non-qualified individual is directed and observed by a qualified individual as the work is being performed and is able to respond and react to an abnormal operating condition; the component is physically removed from the pipeline facility; or the task is being performed as a part new construction. The number non-qualified individuals that may be supervised by a qualified individual through the directed and observed may vary significantly from job to job as well as from Covered Task to Covered Task. The following must be taken into consideration prior to allowing a qualified individual to direct and observe non-qualified individuals: Can all the non-qualified individuals performing the job be directed and observed by the qualified individual Can the qualified individual recognize and react immediately to an event that would be considered an abnormal operating condition Appendix A provides a typical span control ratio for directing and observing individuals where the first number is the qualified individual and the second number is the number unqualified persons being directed and observed. (Example: 1:5 means that one qualified person can direct five non-qualified people.) Certain conditions should be taken into account when determining the number persons to be directed and observed by one individual. Some these conditions to be taken into consideration are: The individual directing and observing the task can only be observing the performance one covered task at a time (although several individuals could be performing that task) Is there a clear means communications: verbal, visual, work noise Is there available lighting: sun in the eyes, daytime vs. night time, shadows What are the weather and ground conditions: rain, mud, ice, fog etc. Are there obstructions that impact vision or a person s ability to react to any abnormal operating condition What is the task complexity Due to the critical nature some tasks (i.e. welding and hot tapping) the number individuals that a person will be allowed to direct and observe may be limited. For limitations refer to Appendix A. In some situations, may provide the qualified person to directly observe the non-qualified contract employees. The qualified individual directing and observing Covered Task work being performed by non-qualified individual(s) is ultimately responsible for the correct and safe performance the Covered Task(s). The qualified individual will be accountable for the actions that the PRIVATE/PROPRIETARY

15 non-qualified individual takes. 15. MANAGEMENT OF CHANGE The purpose the Management Change policy is to ensure that changes to equipment, stware, or processes are not released for operations use without proper review impacts, communication, training and documentation. This policy applies to all operations and support personnel. (Reference CPC Conduct Operations) These changes may include but are not limited to: Modifications to policies or procedures Changes in state or federal regulations Use new equipment and/or technology that affects Covered Tasks New information from equipment or product manufacturers that affects a Covered Task Mergers and acquisitions Communication changes that affect a Covered Task will be made to individuals performing that task using the Required Reading process defined in Colonial s Conduct Operations. Alternative s communication, such as reading certification in PolicyTech for document revisions, can be used if approved by the OQ Coordinator and all communications are documented. If changes are deemed significant to task performance training and/or re-qualification will be necessary. In the event that the change should also affect contract employees, the contract company should be notified immediately the change. It will be the responsibility the contract company to update their employees on the changes and update the reports that are sent to Colonial. In the event that a change requires re-qualification Contract personnel, the Contractor will be responsible for requalification all individuals affected. No Contract person will be allowed to perform the Covered Task work until qualified and the appropriate reports have been updated indicating that re-qualification has been completed. 16. CONTRACTOR PERSONNEL All companies that are contracted to perform Covered Task work for CPC must be able to supply documentation that verifies that personnel performing the task or personnel that are directing non-qualified individuals are qualified and meet the CPC Operator Qualification program. Each contractor must have the capability to immediately produce upon request acceptable records an individual s qualifications. These qualifications must meet the requirements this program and maybe written or electronic. Records must include at a minimum the following: The individuals name PRIVATE/PROPRIETARY

16 The individual s unique identification number used to track the individuals qualifications The Covered Tasks qualified to be performed Dates current qualifications The qualification. Acceptable on site records may be in hardcopy or electronic form as long as they are current (less than thirty days old). If the contractor or CPC has capability to utilize other technology such as wireless internet access, then this will be considered an acceptable means obtaining the information and should be utilized. All prior qualifications must be also be available and accessible for a minimum five years. The contract company will be responsible for providing to CPC a list individuals qualified to perform Covered Tasks. Contractor personnel may perform Covered Tasks at CPC provided that: The individual is qualified to perform the Covered Task under CPC s qualification program The individual has been qualified to perform the Covered Task by a that has been approved by CPC and found under OQ-Appendix A If the individual is not qualified to perform the Covered Task, the individual may perform the Covered Task provided that the conditions Section 14.0 Non-qualified Individuals are met. The individual either supervising or performing the Covered Task must be on the contractors most recent version the qualification report supplied to Colonial by the contractor. Any employee not on the list will not be allowed to perform a Covered Task unless directed and observed by a qualified individual. In the event that an infraction this program is found all Covered Task work will cease until the program requirements are met. Procurement will be notified any infraction to this program. Periodic field verifications will be performed to verify that qualified individuals are performing Covered Task work. 17. MUTUAL ASSISTANCE In the event that a third party performs a Covered Task on a CPC pipeline, that third party shall be qualified in accordance with a program which meets or exceeds Colonial s own Operator Qualification Program. It will be the responsibility the procurement department to ensure that all operator qualification information is addressed within any agreements developed between the two parties. 18. DETERMINING WHETHER AN ACTIVITY CONSTITUTES A COVERED TASK Any task performed on equipment removed from the pipeline facility or performed, as an activity considered to be a part new construction will not be considered covered under this program. PRIVATE/PROPRIETARY

17 18.1 Removal Equipment from a Pipeline Facility Work performed on equipment that is physically removed from a pipeline facility is not considered a Covered Task and will not require a person qualified under this program to complete the work. Equipment remaining in the same location, as when in operation will not be considered as removed from the pipeline system and will require qualified individuals to perform the task. As defined in 49 CFR 195.2, a pipeline facility means new and existing pipe, rights--way and any equipment, facility, or building used in the transportation hazardous liquids 18.2 New Construction Activities performed as a part new construction are not considered part this program. The following are considered to be new construction activities: Activities on pipelines that have never been in service and not physically attached to an operating pipeline Fabrication new installations Expansion activities that expand the pipeline capacity Any task carried out on a new segment pipeline at the point the tie in will be considered as a Covered Task. Ordinary repairs to the pipeline, including replacement one or more pipe joints that have been severely damaged by threats such as corrosion or third party damage will be considered as maintenance. 19. RECORD KEEPING CPC has an internal record keeping system or Learning Management System that at a minimum fulfills the most basic record keeping requirements the Rule and allows for handling management change (MOC) issues. Verification an individual s qualification records can be conducted either by accessing the Learning Management System through the CPC intranet system or contacting the Technical Training Department designee. The Technical Training Department shall maintain documentation the individual s current qualification while the individual is performing the Covered Task. Documentation prior qualification and records individuals no longer performing Covered Tasks shall be retained by the Technical Training Department for a minimum five years. At a minimum both Colonial and Contractor qualification records must be maintained that give the following information: Identification qualified individuals Identification the Covered Tasks the individual is qualified to perform Date(s) current qualification and The qualification 20. PROGRAM EVALUATION CPC has defined the following components to ensure proper administration the program and to effectively implement and maintain the OQ program. PRIVATE/PROPRIETARY

18 20.1 Program Review The Operator Qualification Committee is a group individuals primarily responsible for monitoring and evaluating the effectiveness the OQ program and overseeing necessary adjustments. The committee should include individuals with the authority to approve modifications to the program. At a minimum the committee should include representation from the following departments: Technical Training Department Operations and Maintenance Technical Services Procurement Compliance The CPC Operator Qualification Committee is responsible for review CPC s OQ program at intervals not exceeding 15 months, but at least once each calendar year. The object the review is to verify its content and effectiveness and gauge when program modifications should be considered. The Chairman, the OQ Coordinator or other Committee designee is responsible for facilitation the meeting and may modify the discussion topics as needed. The review may include the following items as discussion items. Incidence a Covered Task(s) being performed by a non-qualified individual(s) while not being directly observed by a qualified individual Incidents a Covered Task(s) contributing to an accident or an incident re-evaluations Contractor audit results Additions or deletions Covered Tasks Clarification program content Reviewing process for possible changes Review PHMSA inspection results regarding operator qualification Regulatory changes Training Review for matching procedures for each task 20.2 Audits Periodically audits may be performed by the Internal Audit Team to determine the effectiveness the Operator Qualification program. Audits may be performed on both contractors and/or internal employees. The results these audits will be reviewed during the annual review conducted by the CPC Operator Qualification Committee. If during the course an audit an issue is found that is not in compliance with the OQ program, the individual performing the audit shall immediately notify the contractor and/or the Colonial on-site representative the findings. If the audit is being performed at a job site and an issue is discovered on a task that is in the process being conducted, the individual performing the audit should notify both PRIVATE/PROPRIETARY

19 the contractor and/or CPC person in charge the job immediately and determine whether the work should be stopped. In the event that an audit uncovers an issue with work that has already been performed the individual performing the audit shall notify the contractor and/or the CPC person responsible for the job immediately. Substantive issues found should be reviewed by a qualified CPC person in order to determine if there is a potential impact to pipeline safety. Remedial action may be needed to correct work that is performed by an improperly qualified individual. All audit reports will be forwarded to the Internal Audit Team for review and filing. 21. NOTIFICATION TO PHSMA OF SIGNIFICANT MODIFICATIONS TO PROGRAM After December 16, 2004, Colonial must notify PHMSA if Colonial significantly modifies the OQ Program after PHSMA has verified that it complies with 49 CFR As applicable to OQ program modifications, PHMSA has defined significant to include, but not be limited to: increasing evaluation intervals, increasing span control ratios, eliminating covered tasks, mergers and/or acquisition changes, evaluation changes such as written vs. observation, and wholesale changes made to OQ plan. In the event Colonial significantly modifies this Program, Colonial will notify PHMSA accordingly. A memorandum to file will be prepared to document Colonial s determination as to whether or not the OQ Program modifications constitute significant modifications that require notification to PHMSA. Colonial will send any notifications significant modifications the OQ Program to PHMSA. Each notification to PHMSA should include: 1. OPID(s), operator name(s), HQ address. Name individual submitting notification, data/ /phone number, Commodity (gas/liquid/both), PHMSA Region(s) where pipeline(s) operate, and names respective facilities or pipeline systems where changes apply. 2. Complete OQ Program accompanied by revision/change log and effective date change(s). The plan should be notated such that changed areas the plan can be readily identified. Employee-specific information (i.e., social security numbers) and testing material are not needed. 22. IDENTIFY ORGANIZATIONAL REQUIREMENTS CPC has identified the following individuals as responsible for the proper administration and implementation the OQ program. PRIVATE/PROPRIETARY

20 22.1 OQ Coordinator and a Technical Training Department Designee The OQ Coordinator and the Technical Training Department are responsible for many aspects the OQ program. The OQ Coordinator and the Technical Training Department is responsible for defining the following: The time limit for taking a re-test for a failed evaluation The process used to review evaluation failures Training resources used for study The process used to verify past qualifications for individuals previously qualified Updating the Learning Management System Filing all qualification documentation Reviewing qualification s Track and report employee qualification status 22.2 Evaluator Only individuals trained and qualified as an evaluator may be utilized to perform a qualification evaluation. Evaluators may be identified as either internal or external (3 rd Party). Internal Colonial evaluators must be nominated by their supervisor and approved by the OQ Coordinator. These evaluators must complete a evaluator training course as well as the Colonial Ethics and Code Conduct CBT or instructor-led training. The Evaluator is not required to be qualified to perform a Covered Task for which he or she is qualifying individuals to perform. However, the evaluator should have the required knowledge, or have someone present who is knowledgeable in the subject area, to determine an individual s ability to perform a Covered Task by evaluating whether they: Possess the knowledge, skills and abilities to safely and competently perform the Covered Task Can recognize and react appropriately to abnormal operating conditions that might occur while performing the Covered Task Evaluators may be asked to perform different forms evaluations. s are found in OQ-Appendix A Section 6 Task-to-Qualification Requirements Matrix. Technical Training Department should be contacted for additional information about conducting evaluations. Evaluators are expected to provide clear documentation task performance. Reciprocating evaluations (whereby two evaluators evaluate each other on the same task) are not the preferred but are allowed so long as measures are taken to eliminate any perceived conflict interest in the evaluation process. PRIVATE/PROPRIETARY

21 22.3 Trainers The responsibilities associated with this role are: Conduct On-the-Job training activities for assigned Covered Tasks using approved materials Conduct remedial training and initiate notification for trainees who fail to meet task standards Ensure the trainee possesses a sufficient level knowledge to perform the required Covered Tasks 22.4 Managers Managers are responsible to verify the qualifications employees that are direct reports and performing Covered Tasks. The Colonial Learning Management University (CLMU) is used to help track qualifications and send expiration notices prior to expiration qualifications Work site supervisors Employees or contractors Colonial Pipeline that supervise work sites on Colonial facilities are responsible for verification qualifications related to the Covered Tasks performed on the job, which may be by Colonial employees or Colonial contractors. These supervisors are also responsible for ensuring proper span control when a qualified person is directing and observing a non-qualified person while performing a Covered Task. PRIVATE/PROPRIETARY

22 APPENDIX A QUALIFICATION REQUIREMENTS 1. PURPOSE The following tables outline the evaluation s that have been identified as approved for qualification individuals to perform covered tasks under the (CPC) Operator Qualification Program. Any individual having successfully completed training and evaluation by these s will be considered qualified to perform the corresponding covered task and to recognize and react to abnormal operating conditions. 2. INTERNAL CPC QUALIFICATION METHODS The following internal qualification abbreviations are used in the matrix as follows: CPC-WA- Task Number - CPC Written Assessment CPC-WA-AOC - CPC Written Assessment for Abnormal Operating Conditions CPC-JPM-Task Number - CPC Job--Measure CPC Gold Card a Maintenance and Repair Welding Certification Card issued to a welder who has successfully completed the Colonial Welding Test. 3. INDUSTRY AND PROFESSIONAL CERTIFICATIONS The following pressional certification and qualification abbreviations are used in the matrix and the certification requirements are defined as follows: 3.1 API 510 American Petroleum Institute Standard 510 Pressure Vessel Inspection Code: In-Service Inspection, Rating, Repair, and Alteration (reference Appendix B Inspector Certification) qualified inspector in good standing having certified and re-certified within the most recent three year period. Individuals who have successfully completed an API 510 Certification for qualification to perform a covered task may fulfill the Abnormal Operating Conditions requirement by successfully completing a written evaluation listed in the tables such as the CPC Written for Abnormal Operating Condition. 3.2 API 653 American Petroleum Institute Standard 653 Tank Inspection, Repair, Alteration, and Reconstruction (reference Appendix D Authorized Inspector Certification) qualified inspector in good standing having certified and re-certified within the most recent three year certification period. Individuals who have successfully completed an API 653 Certification for qualification to perform a covered task may fulfill the Abnormal Operating Conditions requirement by successfully completing a written evaluation listed in the tables such as the CPC Written for Abnormal Operating Conditions. PRIVATE/PROPRIETARY

23 3.3 API 1104 American Petroleum Institute Standard 1104 Welding Pipelines and Related Facilities is one the standards referenced in 49 CFR 195 for qualification welders for pipeline welding. The API 1104 standard is used to develop performance evaluation test for pipeline welders including the Colonial Welding Test. API does not have a program to qualify welders. 3.4 Section IX ASME Section IX the American Society Mechanical Engineers (ASME) Boiler and Pressure Vessel Code is one the standards referenced in 49 CFR 195 for qualification welders for pipeline welding. The ASME Code Section IX standard is used to develop performance evaluation test for pipeline welders including those that perform welding on Colonial breakout tanks and certain other components. ASME does not have a program to qualify welders. 3.5 ASNT American Society Non-destructive Testing (ASNT) non-destructive testing (NDT) certification programs have three levels NDT qualification and are based on ASNT Recommended Practice SNT-TC-1A. Level II NDT certification is the minimum required for qualification to perform covered tasks or to direct nonqualified individuals. Individuals with higher levels qualification such as ASNT NDT Level III certification are also qualified under this program but all higher levels qualification are not listed in the following tables. An individual in good standing must be re-certified per the ASNT requirements (typically within the most recent five years) in the type inspection being performed as a Covered Task. Individuals who have successfully completed an ASNT Certification for qualification to perform a covered task may fulfill the Abnormal Operating Conditions requirement by successfully completing a written evaluation listed in the tables such as the CPC Written for Abnormal Operating Conditions. 3.6 AWS American Welding Society (AWS) certification programs may be used for qualification for weld inspection. Certified Welding Inspector (CWI) is the minimum required for qualification to perform covered tasks or to direct non-qualified individuals. Individuals with higher levels qualification such as Senior Certified Welding Inspector (SCWI) are also qualified under this program but all higher levels qualification are not listed in the following tables. An individual in good standing must be re-certified per the AWS requirements (typically every three years.) Individuals who have successfully completed an AWS Certification for qualification to perform a covered task may fulfill the Abnormal Operating Conditions requirement by successfully completing a written evaluation listed in the tables such as the CPC Written Assessment for Abnormal Operating Conditions. PRIVATE/PROPRIETARY

24 3.7 Clock Spring Repair (Composite wrap) Clock Spring Repair certified installer in good standing having re-certified every three years. Individuals who have successfully completed a Clock Spring Repair Installer Certification for qualification to perform a covered task may fulfill the Abnormal Operating Conditions requirement by successfully completing a written evaluation listed in the tables such as the CPC Written Assessment for Abnormal Operating Conditions. 3.8 NACE CP1 CP Tester NACE CP1 Cathodic Protection (CP) Tester certification in good standing having recertified at intervals required by NACE are qualified to perform certain covered tasks as specified in the following tables. Individuals with higher levels NACE qualification such as NACE CP2 CP Technician are also qualified under this program for CP1 tasks but all higher levels qualification are not listed in the following tables. Individuals who have successfully completed a NACE CP Certification for qualification to perform a covered task may fulfill the Abnormal Operating Conditions requirement by successfully completing a written evaluation listed in the tables such as the CPC Written Assessment for Abnormal Operating Conditions. 3.9 NACE CP 2 CP Technician NACE CP 2 Cathodic Protection (CP) Technician certification in good standing having recertified at intervals required by NACE are qualified to perform certain covered tasks as specified in the following tables. Individuals with higher levels NACE qualification such as NACE CP3 CP Technologist are also qualified under this program for CP2 tasks but all higher levels qualification are not listed in the following tables. Individuals who have successfully completed a NACE CP2 certification for qualification to perform a covered task may fulfill the Abnormal Operating Conditions requirement by successfully completing a written evaluation listed in the tables such as the CPC Written Assessment for Abnormal Operating Conditions NACE CIP Level 1 Individuals who have successfully completed a NACE Coating Inspector Program (CIP) Level 1 certification for qualification to perform a covered task may fulfill the Abnormal Operating Conditions requirement by successfully completing a written evaluation listed in the tables such as the CPC Written Assessment for Abnormal Operating Conditions. PRIVATE/PROPRIETARY