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:
– 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.