Mercer clarifies PHMSA and PSM boundaries with 2018 AIChE Whitepaper

DEC 2020 UPDATE
PHMSA Publishes FAQs
Midstream processing facilities under PHMSA jurisdiction should pay close attention to the proposed guidance document issued November 4, 2020. View our article on the PHMSA FAQs.

Jurisdictional Boundaries in Midstream

Where is the Line?

Account Director Lauren Mercer presented her whitepaper “Jurisdictional Boundaries in Midstream: Where is the Line?” at the 2018 AIChE Spring Meeting in Orlando, Florida. Mercer has a skill for taking complex and nuanced topics and making them manageable and consumable for the audience. The AIChE committee chose to record her presentation, and it will be made available in the archived AIChE meeting database, available to AIChE members and conference attendees.

Author: Lauren Mercer
Account Director

Paper Abstract

Where is the Line?

This paper discusses the gray area between OSHA and DOT jurisdiction, including coverage of terminal operations, railcars/trucks, and underground storage applicability. The nuances of PSM applicability, including interconnectivity and colocation, hydrocarbon used as a fuel, atmospheric tanks, and safety systems will be presented.

Furthermore, this paper will provide a history of jurisdictional boundary and PSM applicability cases/interpretations and will present examples of determining PSM jurisdiction and applicability. The intent is to pull all aspects of each regulations together in a single location to be used as a reference when evaluating the jurisdictional boundaries at a midstream facility.

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Presentation Slides

Download the PowerPoint Show of Mercer's presentation at the 2018 AIChE Spring Meeting

Presentation Handout

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