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Mercer clarifies PHMSA and PSM boundaries with 2018 AIChE Whitepaper

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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Webinar

Relief Devices, DOT, and OSHA: Insight for Pressure Relief Systems Engineers [Webinar]

Is your facility under the OSHA PSM Standard or the DOT PHMSA regulations? Are you confused by fuzzy jurisdictional boundaries? Take this webinar.

In this 60-minute sponsored webinar, hear Provenance Consulting tackle an issue that causes confusion for many oil and gas industry professionals: The OSHA PSM Standard and the DOT PHMSA regulations and which apply to their relief devices. Join in to examine the unclear boundary between one jurisdiction and the other and how this is a source of consternation for pressure relief systems engineers.

What is the impact on your pressure relief systems design? Which requirements are the same across both agencies? Which are different? Tune in to gain insight and guidance.

Take a look at your agenda:

  • An overview of the DOT PHMSA and its regulations
  • What you need to know about OSHA and the PSM standard
  • Understanding jurisdictional boundaries and the contentious nature between OSHA and DOT
  • What’s similar and what’s different and the impact on your pressure relief systems design and related process engineering activities

Learn more about our Relief Systems Services

Presenter

Justin Phillips, P.E.

Justin Phillips has over eight years of onshore and offshore oil & gas process engineering and project execution experience. His technical experience includes process design with specialty in flare and relief systems.

Justin is the Relief Systems Line of Service Manager at Provenance Consulting, LLC. He holds a B.S. in Chemical Engineering from Texas A&M University in College Station, Texas and is a Licensed Professional Engineer in the State of Texas.