“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 not followed, public safety is at risk and costly

When procedures are misunderstood,

the action taken may have unintended consequences

LOLLaugh Out

Loud

…or

Call 911?

If you see someone

drowning..

When procedures are not revised as necessary, everyone looks foolish

When protocols are out-of-date, they should be retired

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

Warnings

Reporting/

Notification

Documentations

As Built

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


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


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


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 ?




§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.




§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.





(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.





(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.





(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

Contact Information:

Stanley T. Kastanas

Tel. #:781.996.8414

Email: [email protected]

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