Are you new to Gas Pipelines Requirements? They are somewhat different than Oil Pipeline Requirements.

Today’s article is focused on addressing the emergency planning requirements under the Pipeline and Hazardous Materials Safety Administration (PHMSA) gas pipeline regulations. Do you have a background in oil pipeline operations? If yes, you may have noticed that planning for gas pipelines is a little different than planning for oil pipelines. For example, one common concern with oil pipelines is containing the spread of oil over land and water. However, with gas, there is more concern about the evacuation of areas as gas ignites and goes up, not down.

Under PHMSA, oil response planning regulations are found under 49 CFR Part 194, while gas is found under 49 CFR Part §192.615.

------------------------

Missed our Compliance Workshop last November, email John Carroll at [email protected] to be added to our mailing list.

Our next workshop, PHMSA compliance (audit expectations, OSRPs, drills/training), is now scheduled for April 7th. Register Today

#wittobriens next two compliance workshops (SPCC/FRP) are now confirmed.

October 4 - SPCC Compliance

Presenters: Howard, Mark & Chris Perry

November 2 - FRP Compliance

Presenters: Chris Perry & Swackhammer, J-Troy

-----------------------

Before going too far, let’s see what the rule says.

§192.615 Emergency plans.

(a) Each operator shall establish written procedures to minimize the hazard resulting from a gas pipeline emergency. At a minimum, the procedures must provide for the following:

(1) Receiving, identifying, and classifying notices of events which require immediate response by the operator.

(2) Establishing and maintaining adequate means of communication with appropriate fire, police, and other public officials.

(3) Prompt and effective response to a notice of each type of emergency, including the following:

(i) Gas detected inside or near a building.

(ii) Fire located near or directly involving a pipeline facility.

(iii) Explosion occurring near or directly involving a pipeline facility.

(iv) Natural disaster.

(4) The availability of personnel, equipment, tools, and materials, as needed at the scene of an emergency.

(5) Actions directed toward protecting people first and then property.

(6) Emergency shutdown and pressure reduction in any section of the operator's pipeline system necessary to minimize hazards to life or property.

(7) Making safe any actual or potential hazard to life or property.

(8) Notifying appropriate fire, police, and other public officials of gas pipeline emergencies and coordinating with them both planned responses and actual responses during an emergency.

(9) Safely restoring any service outage.

(10) Beginning action under §192.617, if applicable, as soon after the end of the emergency as possible.

(11) Actions required to be taken by a controller during an emergency in accordance with §192.631.

(b) Each operator shall:

(1) Furnish its supervisors who are responsible for emergency action a copy of that portion of the latest edition of the emergency procedures established under paragraph (a) of this section as necessary for compliance with those procedures.

(2) Train the appropriate operating personnel to assure that they are knowledgeable of the emergency procedures and verify that the training is effective.

(3) Review employee activities to determine whether the procedures were effectively followed in each emergency.

(c) Each operator shall establish and maintain liaison with appropriate fire, police, and other public officials to:

(1) Learn the responsibility and resources of each government organization that may respond to a gas pipeline emergency;

(2) Acquaint the officials with the operator's ability in responding to a gas pipeline emergency;

(3) Identify the types of gas pipeline emergencies of which the operator notifies the officials; and

(4) Plan how the operator and officials can engage in mutual assistance to minimize hazards to life or property.

Did you notice something about this rule that was very different than the oil side? Gas emergency response plan requirements are considerably shorter than those for oil. If you are familiar with the Occupational Safety and Health Administration’s (OSHA) 29 CFR Part 1910.38 (emergency action plans) rule, you will notice a lot of similarities. You will also notice no worst-case discharge discussion requirements or Oil Spill Removal Organizations (OSRO) requirements as gas is quite different than oil.

For those new to this type of planning, the following are common areas where those not familiar with gas emergency planning tend to struggle during plan development:

·        Not identifying detailed procedures to deal with upsets/leaks: It is common to see vague statements or conversations in plans. Procedures should tell the untrained how to prevent/minimize issues, and more importantly, how to keep everyone safe. It is acceptable to refer to other procedures for these. However, make sure those guidelines are accessible, and clear on what is required.

• Failure to establish proper evacuation protocols for the entire pipeline: This requires mapping out agencies, resources, and other pertinent information along the pipeline. Too often plans will have contact tables that simply state, “call 911 in the event of an emergency.” Contact tables should have 24/hr. numbers as well as alternate numbers. Evacuation discussions are commonly vague and overly generic. You should make plans for the various areas along the pipeline as location and terrain can impact how these are managed.
• Identifying proper equipment: Gas pipelines require different strategies and equipment. These need to be clearly defined in the plan, locations, type of equipment, and quantities.
• Lack of coordination with local agencies: Positive working relationships with local agencies are vital during an incident. These relationships are best built in advance when one is developing the plan and during training and drills. Do not neglect to include your local agencies in your plans and exercises. You are going to need them.
• Generic emergency scenario discussions (i.e., responses to a natural disaster): These discussions should be relevant to the area and provide clear details on what personnel should do. A common practice, which is easy to follow, is checklist-style instructions.

Today’s conversation is meant to shine a light on how gas response plans differ from oil response plans. The key thing to remember about any response plan is it must be easy to read, have a sensible flow that outlines how events generally progress, include important details to initiate a response (events are unpredictable-- however, a response plan attempts to think potential events through in advance), and, most importantly, keep your most valuable asset, your employees, safe and out of harm’s way.

My best advice is to move away from a “check the box” mentality when completing your plans and spend the time developing pipeline-specific plans you need.

Additional Reading:

• Transporting gas by pipeline: PHMSA 192 emergency preparation
• How does your 194-OSRP fair in today’s regulatory space? PHMSA-OPA90 Discussion
• Transporting hazardous liquids by pipeline: PHMSA 195 emergency preparation

For a complete listing of archived articles and compliance insights, click here. Past blogs cover training requirements, clarification on additional confusing elements within the above rules, and much more.

We are here to help solve your compliance questions and challenges. Need some compliance assistance, or just have a question? Please email John K. Carroll III ([email protected]) Associate Managing Director – Compliance Services or call at +1 281-320-9796.

Witt O’Brien’s:

• To learn more about Witt O'Brien's and all that we do, please visit us on our website.
• To follow Witt O’Brien’s and stay informed on important updates, follow us on LinkedIn.