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Tag: Lauren Mercer

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PHMSA FAQs Shed Light on Regulations for Midstream Processing Facilities

Midstream processing facilities under Pipeline and Hazardous Materials Safety Administration (PHMSA) jurisdiction should pay close attention to the proposed guidance document issued November 4, 2020.

Per the document summary, “PHMSA is making available for comment a set of draft frequently asked questions (FAQs) regarding federal oversight of midstream processing facilities. Specifically, this guidance will delineate where PHMSA and the Occupational Safety and Health Administration (OSHA) will each perform inspection and enforcement activities for midstream processing facilities where there is overlapping authority.”

Background on the PHMSA FAQs

In 2014, the PHMSA Gas and Liquids Technical Advisory Committee presented on the need to create a workgroup of stakeholders to discuss the issues related to regulatory oversight of midstream processing facilities. PHMSA and OSHA are seeking understanding of the concerns of the midstream companies because the agencies are in agreement on jurisdictional lines: OSHA covers gas processing units and PHMSA does not have an interest in regulating processing units.[1]

The subcommittee for Midstream Safety was formed with a goal to provide understanding of the boundaries between PHMSA and OSHA and ensure there are no gaps or overlaps in the regulation.[2]

The PHMSA subcommittee, consisting of representatives of federal agencies and industry, met on several occasions in 2014 and 2015. They presented their proposed guidance in August 2015, which was intended to provide clarity and is not considered to be a legally enforceable regulation. The proposed guidance was presented in the form of a set of frequently asked questions (FAQs).

In April 2018, Provenance Consulting Account Director Lauren Mercer presented the topic of jurisdictional boundaries in midstream at the 2018 AIChE Spring Meeting and Global Congress on Process Safety. The associated white paper contained discussion on the 2015 FAQs.

On November 4, 2020, PHMSA made available for comment the set of FAQs. This article serves as a comparison of the FAQs from 2015 to the 2020 set, contains comments related to the FAQs, and indicates remaining gray areas. Persons interested in submitting comments on the draft FAQs must do so by January 4, 2021…

…Read the rest of the article on trinityconsultants.com.

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We provide on demand process safety webinars covering all PSM topics including PHAs,
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Data Management, Mechanical Integrity, Process Safety Management, Webinar

What are “Good Faith Efforts”? PSM/RMP Compliance Discretion and COVID-19 [Webinar]

In response to the health and safety concern presented by the coronavirus in essential industries, OSHA and the EPA have both published enforcement discretion notices that are meant to add some breathing room for facilities juggling regulatory compliance with personal safety. However, the stipulations put in place for facilities to lean on these temporary enforcement policies, especially with regard to the OSHA PSM and EPA RMP standards, are vague as to what facilities must do to qualify for leniency in compliance.

Facilities must demonstrate “good faith efforts”, but what does that really mean with regard to PSM/RPM program elements?Read more

Blog

Things We Loved in 2019: ProvPSM Team Out & About

The Provenance team is not only dedicated to providing exceptional client services, we also strive to share our expertise. This past year, our team has participated in educational programming, industry conferences and presentations, and achieved some impressive professional milestones. Check out a brief list of what Provenance team members have participated in.


Industry Presentations/Events

In my experience, many industry professionals avoid asking “dumb” technical questions openly for reasons of fear or pride. What engineers need are answers to the technical pressure relief systems questions they just can’t find a way to ask. This presentation shared questions submitted from dozens of anonymous engineers when asked, “What do you want to know about pressure relief systems but were too afraid to ask?” It then answers them using the latest RAGAGEP and industry direction.

This presentation discussed the gray area between PSM and DOT jurisdiction, including coverage of Terminal operations (e.g. drying), break-out tanks, railcars/trucks, and cavern 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.

“It is likely that your problem is with the process and not so much maintenance wash procedures. I recommend looking into the stream components, particularly chloride concentrations. You may have a very-well-known damage mechanism, called ammonium chloride corrosion, at work in your main fractionator tower…” [read more]

“When it comes to distillation towers, you always want to be certain that you put the right pressure relief device (PRD) in the right spot. Due to the complexities of distillation towers, many relief cases can exceed the normal relief rates you see from your typical vessel overpressure scenarios. In events such as these, it’s always good to get an experienced evaluator or a second opinion of the evaluation of your column PRDs…” [read more]



Professional Achievements

To become licensed, engineers must complete a four-year college degree, work under a Professional Engineer for at least four years, pass two intensive competency exams and earn a license from their state’s licensure board. Then, to retain their licenses, PEs must continually maintain and improve their skills throughout their careers.

  • Lauren Hendrickson – Lauren has been promoted to Project Lead. She has worked for Provenance since 2014 and has a bachelor’s degree in chemical engineering from the University of Texas.
  • Edward Guillen – Edward has been promoted to Project Lead. He started working with Provenance in 2014 and has worked across numerous projects within the Mechanical Integrity Line of Service.

In addition, in 2019 Edward Guillen completed his API 653 Inspector certification, making him a rare triple-certified inspector (API 510, 570, 653).



Educational & Community Programming

  • UT Girl Day (University of Texas at Austin)

    • Our team of The University of Texas Chemical Engineering alumni loved helping over 800 students make their own Galaxy in a Bottle at #UTGirlDay 2019! Such an awesome event put on by the UT Women in Engineering Program at Austin. Check out the demonstration video to see our activity and more photos.
  • UT ChemE 102 – Presentation on Process Safety Opportunities

    • Our team gave an overview of process safety for first-year students.
  • UT ASME & AIChE Student Chapter Meetings and Tailgate

    • We hosted our annual tailgate with UT’s student chapters of ASME (The American Society of Mechanical Engineers) and AIChE – American Institute of Chemical Engineers on October 19th for the UT-Kansas game in Austin. Student members joined us for some awesome BBQ, beverages, and a few friendly games of washers!
  • Heat-Up Hutchinson County Cook-Off

View Recent Process Safety Webinars

Learn best practices from our team of knowledgeable experts

We provide on demand process safety webinars covering all PSM topics including PHAs,
mechanical integrity, relief systems and more.

Blog

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.

Download Whitepaper

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Presentation Slides

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

Presentation Handout

Download the a Quick View Handout

News

2018 #AIChESpring Meeting & Global Congress on Process Safety

Find Provenance Consulting

at the #AIChESpring Meeting & #GCPS

We are thrilled to be again participating in AIChE’s 14th Global Congress on Process Safety in Orlando, Florida April 23-25th, 2018. The event features a three-day program of technical papers and workshops on topics such as: Management Systems, Big Data Analytics, Industry 4.0, changes to Industry standards, HAZOP best practices, Improving Safety Culture, and Technology.Read more