How do you know if you have a control room?

According to PHMSA (unofficially), an operator with personnel who respond to alarms and make decisions concerning the operation of valves and pressure regulators, are considered controllers and the CRM regulations apply.

There is some gray area in regard to dispatchers, supervisors etc. who report an alarm to someone else who then makes the decisions as it pertains to documentation and training.

What is the difference between ‘accident’ and an ‘incident’?

Incident (this covers distribution systems, transmission pipelines and gathering lines)

As defined in §191.3, Incident means any of the following events:

(1) An event that involves a release of gas from a pipeline, or of liquefied natural gas, liquefied petroleum gas, refrigerant gas, or gas from an LNG facility, and that results in one or more of the following consequences:

(i) A death, or personal injury necessitating in-patient hospitalization;

(ii) Estimated property damage of $50,000 or more, including loss to the operator and others, or both, but excluding cost of gas lost;

(iii) Unintentional estimated gas loss of three million cubic feet or more;

(2) An event that results in an emergency shutdown of an LNG facility. Activation of an emergency shutdown system for reasons other than an actual emergency does not constitute an incident.

(3) An event that is significant in the judgment of the operator, even though it did not meet the criteria of paragraphs (1) or (2) of this definition.

 

Accident

As defined in §195.50, an Accident is a failure in a pipeline system subject to this part in which there is a release of the hazardous liquid or carbon dioxide transported resulting in any of the following:

(a) Explosion or fire not intentionally set by the operator.

(b) Release of 5 gallons (19 liters) or more of hazardous liquid or carbon dioxide, except that no report is required for a release of less than 5 barrels (0.8 cubic meters) resulting from a pipeline maintenance activity if the release is:

(1) Not otherwise reportable under this section;

(2) Not one described in §195.52(a)(4);

(3) Confined to company property or pipeline right-of-way; and

(4) Cleaned up promptly;

(c) Death of any person;

(d) Personal injury necessitating hospitalization;

(e) Estimated property damage, including cost of clean-up and recovery, value of lost product, and damage to the property of the operator or others, or both, exceeding $50,000.

 

In 49 CFR 199 (Drug & Alcohol), “Accident” has a composite definition:

Accident means an incident reportable under part 191 of this chapter involving gas pipeline facilities or LNG facilities, or an accident reportable under part 195 of this chapter involving hazardous liquid pipeline facilities.

What is a Special Permit?

Special Permits

A special permit (previously called a waiver) is an order that waives or modifies compliance with a regulatory requirement if the pipeline operator requesting it demonstrates the need and PHMSA determines that granting a special permit would be consistent with pipeline safety. Special permits are authorized by statute in 49 USC § 60118(c) and the application process is set forth in 49 CFR 190.341. PHMSA performs extensive technical analysis on special permit applications and typically conditions a grant of a special permit on the performance of alternative measures that will provide an equal or greater level of safety. PHMSA is committed to public involvement and transparency in special permit proceedings and publishes notice of every special permit application received in the Federal Register for comment.

State Waivers

A state waiver is similar to a special permit, except that it waives or modifies compliance with a regulation adopted by the state pursuant to its participation in the pipeline safety program under a certification authorized by 49 USC § 60105 or an agreement authorized by 49 USC § 60106. Prior to issuing a state waiver, the state is required to provide PHMSA with a 60-day review period.