I Wish We had Met You 12 Months Ago — PHMSA Compliance in the LNG Value Chain

Alex Taimuri, P.Eng., MBA, Co-Founder and President of Capstone ITS 

 

The information and views expressed in this article are provided solely for informational purposes. It focuses on highlighting details concerning federal regulations for onshore Liquified Natural Gas facilities and reflects the viewpoint of Capstone ITS. Please note that it does not aim to offer a comprehensive assessment of the mentioned regulations. 

 

At a recent U.S. LNG trade show, while discussing Capstone ITS’ competency management and training solutions, one audience member shouted out, “I wish we had met you 12 months ago.” Why? Well, it related to federal oversight of the Liquefied Natural Gas (LNG) value chain, specifically the enforcement program under the U.S. Department of Transportation’s Pipeline & Hazardous Materials Safety Administration (PHMSA). 

 

To ensure the safe, reliable, and environmentally sound operation of pipelines and facilities within the U.S., PHMSA is one of several federal agencies, along with state agencies, that regulate LNG facilities in the U.S., depending on their use and location. 

 

For onshore LNG facilities, PHMSA has the authority to establish safety standards and inspect LNG facilities and operators to enforce compliance with Title 49 of the Code of Federal Regulations, specifically Part 193—Liquefied Natural Gas Facilities: Federal Safety Standards. 

 

 

As per PHMSA: 

The purpose of 49 CFR-Part 193 (Part 193) is to establish comprehensive safety standards and regulations for the design, construction, operation, and maintenance of LNG facilities. These regulations aim to ensure the safe and secure operation of LNG facilities, including storage, handling, and transportation, to protect public safety, property, and the environment. 

PHMSA periodically inspect LNG facilities under its jurisdiction for compliance with Part 193 by way of compliance audits, incident investigations and numerous inspections. During these audits, investigations, and inspection efforts, PHMSA verify LNG facilities are operating in compliance with Part 193, determine the cause of an incident and whether any regulatory violations occurred, and/or respond to specific permit concerns, safety or environmental alerts or emerging safety, environmental or security issues by way of inspections. 

PHMSA has several enforcement mechanisms to ensure compliance with Part 193. Beyond audits, investigations and inspections, PHMSA has the authority to issue corrective action Orders, impose Civil Penalties or pursue Legal Action to ensure compliance, and to protect public safety and to prevent incidents. 

With the recognized intent of protecting public safety, property and the environment, PHSMA’s role in ensuring LNG operator adherence to Part 193 is critical. 

 

Workforce training records and operator facility maintenance records are fundamental components of compliance with Part 193. With these records in place, LNG operators can provide a clear record of up-to-date personnel training, qualifications, and demonstration of compliance as well as show proof of equipment and systems being properly maintained, with preventative measures and procedures in place to reduce risks and to ensure the continued safe operation of the facility. 

 

For LNG operators, remaining compliant with Part 193 brings significant advantages in terms of safety, environmental responsibility, legal obligations, operational efficiency, and reputation. LNG operators that prioritize compliance to Part 193, can not only mitigate risks but also position their organization for safe and sustainable growth and success in the long term. 

 

A sample of Part 193 Subparts General, Operations, Maintenance and Personnel Qualifications & Training are listed below: 

  • As per Subpart General 193.2017 Plans and Procedures – each LNG operator shall maintain the plans and procedures required for each of its LNG plants, such as operating procedures, emergency response procedures, maintenance procedures, transfer procedures, purging procedures, security procedures, health and safety plans, and personnel qualification and training plans, etc. These plans and procedures must be available for review and inspection. In addition, each change to the plans or procedures must be available at the LNG plant for review and inspection within 20 days after the change. As well, each LNG operator must review and update its plans and procedures whenever a component is changed significantly or a new component is installed, and at intervals no more than 27 months, but at least once every 2 calendar years. To provide a reasonable level of safety, the LNG operator may be required to amend its plans and procedures as necessary.
 
  • As per Subpart Operations 193.2501 to 193.2519 Procedures – each LNG operator shall follow one or more manuals or written procedures to provide safety in normal operation and in responding to abnormal operation that would affect safety. Manuals or written procedures shall focus on operating procedures, cooldown, monitoring operations, emergency procedures, personnel safety, transfer procedures, investigation of failures, purging, and communication systems.   
 
  • As per Subpart Operations 193.2521 Operating Records – each LNG operator must maintain a record of the results of each inspection, test and investigation. This includes records required by NFPA–59A–2001 for facilities designed and constructed after March 31, 2000. Records must be kept for a period of not less than 5 years.
 
  • As per Subpart Maintenance 193.2601 to 193.2637 Procedures, System and Controls – each LNG operator shall maintain each component in service at the LNG plant, including its support system, in a condition that is compatible with its operational or safety purpose by repair, replacement or other means. Each operator shall follow one or more manuals of written procedures for the maintenance of each component. 
 
  • As per Subpart Maintenance 193.2639 Maintenance Records – each LNG operator must keep a record of the date and type of maintenance activity at the plant. For facilities designed and constructed after March 31, 2000, related periodic inspection and testing records must be maintained as required by NFPA–59A–2001. Records must be kept for a period of not less than 5 years. In addition, for as long as the facility remains in service, maintenance records or maps must be maintained to show the location of cathodically-protected components, neighboring bonded structures, and corrosion protection equipment. As well, for as long as the facility remains in service, records must be maintained of each test, survey or inspection required to demonstrate the adequacy of corrosion control measures.
 
  • As per Subpart Personnel Qualifications and Training 193.2707 Operations and Maintenance – each LNG operator shall only utilize operation or maintenance personnel who have demonstrated their capability to perform their assigned functions by successful completion of the training required by Part 3, verified experience related to the assigned operation or maintenance function and who can show acceptable performance on a proficiency test relevant to the assigned function. Any personnel who do not meet these requirements may operate or maintain components when accompanied and directed by an individual who meet the requirements. 
 
  • As per Subpart Personnel Qualification and Training 193.2711 Personnel Health – each LNG operator shall follow a written plan to verify that personnel assigned operating, maintenance, security or fire protection duties at the LNG plant do not have any physical condition that would impair performance of their assigned duties. The plan must be designed to detect both readily observable disorders, such as physical handicaps or injury, and conditions requiring professional examination for discovery.
 
  • As per Subpart Personnel Qualifications and Training 193.2713 Operations and Maintenance – each LNG operator shall provide and implement a written plan of initial training to instruct all permanent maintenance, operating and supervisory personnel. Training shall cover characteristics and hazards of LNG, and other flammable fluids, with an emphasis on safety. All personnel shall be trained on the potential hazards in operating and maintenance activities, as well as emergency procedures and first aid, and shall be capable of carrying out operating and maintenance procedures assigned to them. All operating personnel and supervisors shall be trained on detailed instruction of facility operations, controls, functions, and procedures, including LNG transfer procedures. Lastly, a written plan for continued instruction shall be in place, at intervals not more than every two years to keep all personnel current on their gained knowledge and skills. 
 
  • As per Subpart Personnel Qualification and Training 193.2719 Training Records

    each LNG operator shall maintain a system of records which provide evidence that training programs have been implemented, and that personnel have undergone and satisfactorily completed the required training. Training records must be maintained for one year after personnel are no longer assigned duties at the plant. 

 

From the sample overview of Part 193 Subparts above, it is obvious that an LNG operator must develop, manage, and maintain a significant catalog of LNG plant specific plans and procedures, as well as personnel training materials and qualification tools and records, at specific intervals and periods, to ensure ongoing competency and adherence to Part 193.

 

This is where Capstone ITS can step in. 

 

The Capstone ITS Training Competency Assurance Program (TCAP) is a structured competency management framework that aligns employee career planning with training requirements and competency assurance measures. The implementation and deployment of TCAP empowers an LNG operator to clearly demonstrate its commitment to workforce safety, training and career advancement, as well as to protecting public safety, property and the environment and to assuring PHMSA regulatory compliance. Suited to the requirements of each LNG operator, the effective implementation of TCAP is rightsized, scalable and repeatable to ensure audit-ready operational performance. 

 

Complementing the implementation and deployment of TCAP, Capstone ITS offers LNG operators Technical Writing, Custom Training, and Managed Training Services. As your extended training department, we’ll work with you to ensure that all foundational elements and tools that are critical to TCAP success and PHMSA regulatory compliance are in place. Whether developing net new training solutions or amending existing documents and training materials, these complementary services can range from procedure and operating manual development, to instructor-led through interactive, online training course development, with our managed training services team assisting you with training asset and records management along the way. This equips both technical and non-technical staff with the

knowledge to safely operate a facility within regulations and resolve operation and maintenance issues. 

 

Capstone ITS offers Qualified Assessors, Internal Verifiers, Trainers and Pipeline & LNG Facility Safety Regulation Advisors & PHMSA subject matter experts, plus online access to our Training on Demand library, for courses such as our LNG101 – LNG Process Fundamentals Certification course that delivers operations and maintenance training as required by PHMSA.

 

Whether you are planning a new LNG facility or operating an existing plant, the Capstone ITS team are here to assist you on the pathway to PHMSA compliance and peak operational performance. 

 

Don’t wait 12 months. Reach out today.  

 

Contact – Capstone Industrial Training Solutions (capstoneits.com)