“The Importance of Understand and Adhering to Gas ...
Transcript of “The Importance of Understand and Adhering to Gas ...
“The Importance of Understand and Adhering
to Gas Operators’ O&M Procedures”
Stanley T. Kastanas
Vice President and Chief
Safety, Compliance &
Government Affairs Officer
SUMMARY32 Years Industry Experience
• All Levels of Field Operations
• All Pipeline & Plant Facility
Engineering, Design,
Construction, Operations,
Maintenance, Emergency
Response; LNG, Mobile LNG,
LPG, LP/Air, SNG, CG, N2,
and Treatment Plants
13 Years Federal Gov. Experience
Experience-PHMSA
• Chief of Enforcement
• Director Substance Abatement
Why should we bother with procedures, policies and drawings?
Construction Procedures
Engineering Procedures
When procedures are misunderstood,
the action taken may have unintended consequences
LOLLaugh Out
Loud
…or
Call 911?
If you see someone
drowning..
When warnings are ignored, even in the face of eminent safety threats, disasters can occur
..If you can
read this
you’re not a
train
..The Tracks
They are only
for trains..
When good procedures, protocols, warnings, and practices are understood and followed,
everyone benefits!
Scope and
Purpose
Compliance Code
Responsibility
Contractor
Company or
Job Position (e.g.
Plastic Pipe Fitter)
Equipment and
Materials
Operator
Qualification (OQ)
What is contained
in a typical
procedure?
Instructions
Maintenance and
Operation of
Equipment
O&M Procedure
Title
Covered Task
Revision Date
Instructions
General
(i.e., Overview)
Instructions
Manual Steps
Hydraulic
Machine Steps
Procedure
Prepared and
Approved by
and Date
WHAT ARE THE THREE KEY MANDATES FOR FOLLOWING
PROCEDURES?
1. Consistency and Standardization
2. Quality Assurance and Quality Control
3. Regulatory Compliance and Contractual Agreements
WHAT ARE THE THREE KEY MANDATES FOR FOLLOWING
PROCEDURES?
1. Consistency and Standardization
a) Install pipeline facility or perform
maintenance as specified and without
deviation
b) Use only the materials issued
c) Utilize only procedure-trained and OQ
qualified covered employees
d) Use maintained equipment and
handle material to avoid damage
e) Maintain personnel safety; PPE
WHAT ARE THE THREE KEY MANDATES FOR FOLLOWING
PROCEDURES?
2. Quality Assurance and Quality Control
a) Inspect all installed pipe and
components for defects or
deficiencies; if found, remove and/or
replace
b) Test pipeline facilities for leaks and
ability to hold pressure
c) Document and sign for all materials
installed, inspections, testing, and
location of facility
WHAT ARE THE THREE KEY MANDATES FOR FOLLOWING
PROCEDURES?
3. Regulatory Compliance and Contractual Agreements
a) Upon agreement, contractual stipulations
mandating contractor to follow and comply
with all applicable local, state, and federal
regulations
b) Title 49, Code of Federal Regulations (CFR),
Parts 40,191,192, and 199
c) CT, NH, NJ, NY, MA, ME, PA, RI, and VT State
(more stringent) pipeline-safety code
regulations, including “ONE CALL 811,”
enforcement violation notifications, and
civil/criminal penalties
§192.13 (c) Each operator shall maintain,
modify as appropriate, and follow the
plans, procedures, and programs that it is
required to establish under this part.
IF THE OPERATOR IS SUBJECT TO DIRECT FEDERAL JURISTICTION
OR IS REFERED TO FEDERAL AUTHORITIES, WHAT ARE THE
POTENTIAL CIVIL AND CRIMINAL PENALTIES ?
IF THE OPERATOR IS SUBJECT TO DIRECT FEDERAL JURISTICTION
OR IS REFERED TO FEDERAL AUTHORITIES, WHAT ARE THE
POTENTIAL CIVIL AND CRIMINAL PENALTIES ?
§190.223 Maximum penalties.
(a) Any person who is determined to have violated a provision
of 49 U.S.C. 60101 et seq., or any regulation or order issued
thereunder is subject to an administrative civil penalty not to
exceed $200,000 for each violation for each day the violation
continues, except that the maximum administrative civil
penalty may not exceed $2,000,000 for any related series of
violations.
IF THE OPERATOR IS SUBJECT TO DIRECT FEDERAL JURISTICTION
OR IS REFERED TO FEDERAL AUTHORITIES, WHAT ARE THE
POTENTIAL CIVIL AND CRIMINAL PENALTIES ?
§190.291 Criminal penalties generally.
(a) Any person who willfully and knowingly violates a provision of 49
U.S.C. 60101 et seq. or any regulation or order issued thereunder will
upon conviction be subject to a fine under title 18, United States
Code, and imprisonment for not more than five years, or both, for
each offense.
IF THE OPERATOR IS SUBJECT TO DIRECT FEDERAL JURISTICTION
OR IS REFERED TO FEDERAL AUTHORITIES, WHAT ARE THE
POTENTIAL CIVIL AND CRIMINAL PENALTIES ?
§190.291 Criminal penalties generally.
(b) Any person who willfully and knowingly injures or destroys, or
attempts to injure or destroy, any interstate transmission facility, any
interstate pipeline facility, or any intrastate pipeline facility used in
interstate or foreign commerce or in any activity affecting interstate
or foreign commerce (as those terms are defined in 49 U.S.C. 60101
et seq.) will, upon conviction, be subject to a fine under title 18,
United States Code, imprisonment for a term not to exceed 20 years,
or both, for each offense.
IF THE OPERATOR IS SUBJECT TO DIRECT FEDERAL JURISTICTION
OR IS REFERED TO FEDERAL AUTHORITIES, WHAT ARE THE
POTENTIAL CIVIL AND CRIMINAL PENALTIES ?
§190.291 Criminal penalties generally.
(c) Any person who willfully and knowingly defaces, damages,
removes, or destroys any pipeline sign, right-of-way marker, or
marine buoy required by 49 U.S.C. 60101 et seq. or any regulation or
order issued thereunder will, upon conviction, be subject to a fine
under title 18, United States Code, imprisonment for a term not to
exceed 1 year, or both, for each offense.
IF THE OPERATOR IS SUBJECT TO DIRECT FEDERAL JURISTICTION
OR IS REFERED TO FEDERAL AUTHORITIES, WHAT ARE THE
POTENTIAL CIVIL AND CRIMINAL PENALTIES ?
§190.291 Criminal penalties generally.
(d) Any person who willfully and knowingly engages in excavation
activity without first using an available one-call notification system to
establish the location of underground facilities in the excavation
area; or without considering location information or markings
established by a pipeline facility operator; and
(1) Subsequently damages a pipeline facility resulting in death,
serious bodily harm, or property damage exceeding $50,000;
(2) Subsequently damages a pipeline facility and knows or has
reason to know of the damage but fails to promptly report the
damage to the operator and to the appropriate authorities; or
(3) Subsequently damages a hazardous liquid pipeline facility that
results in the release of more than 50 barrels of product;
will, upon conviction, be subject to a fine under title 18, United States
Code, imprisonment for a term not to exceed 5 years, or both, for
each offense.
WHAT ARE SOME OF THE ISSUES THAT CONTRACTORS AND
OPERATORS HAVE IDENTIFIED WITH PROCEDURES..AND EACH OTHER?
This is a perception
held by some from
both parties, but, in
fact, both do listen!
WHAT ARE SOME OF THE ISSUES THAT CONTRACTORS HAVE
IDENTIFIED WITH PROCEDURES?
1. Operators provide insufficient or no training at all to
either contractor covered employees or the
contractor’s trainer on company procedures
2. Contractor covered employees are forced to learn
and distinguish between multiple procedures for
performing the same covered task with, essentially,
the same or similar materials
3. Procedures are either too convoluted with endless
references to other standards and appendices; or are
so shallow in detail that it becomes a guessing game
4. Operators should develop and adopt consensus
procedures to perform NGA designated covered
tasks for any NGA member company
WHAT ARE SOME OF THE ISSUES THAT OPERATORS HAVE IDENTIFIED
WITH CONTRACTORS APPLICATION OF PROCEDURES?
1. State Pipeline Inspectors witnessing contractor covered
employees demonstrating lack of training or knowledge
of a company’s procedures
2. Contractors (inaccurately) claiming to either provide
trained covered employees or not following through with
the promise to train covered employees before putting
them on the job
3. Lack of consistency in following company procedures, or
following another company’s procedure
4. Partially using materials (e.g., PE pipe and fittings) on
another company’s pipeline installation that were either
left-overs or “borrowed” from another company’s job
and joined to dissimilar materials without an approved
procedure