Regulatory Compliance Programs
Overview
RegSafe designs, develops, and based on the client’s needs assists with the implementation and management of the PHMSA (and state partner) requirements for natural gas and hazardous liquids pipeline systems, and liquefied natural gas facilities.
Our work includes, but is not limited to developing, implementing, supporting, and managing regulatory compliance programs, processes, procedures, relating to:
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Reporting: Annual/Accident/Incident/Other
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Class Location and HCA/MCA
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Design and Construction
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Corrosion Control
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Inspection and Testing
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Uprating
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Operations, Maintenance, and Emergencies
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Public Awareness / Damage Prevention
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Accident, Incident, and Failure Investigation
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Management of Change
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Qualification of Personnel
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Integrity Management
Gas and Hazardous Liquids Pipeline Systems
RegSafe develops Operations and Maintenance Programs for gas pipeline systems (§191, §192), hazardous liquids pipeline systems (§195), and Drug and Alcohol Programs (§199). We utilized our operating and regulatory knowledge, experience, and know-how to develop state and federally compliant programs that are not only compliant but are operationally implementable and sustainable.
Underground Natural Gas Storage
RegSafe has been working in the field of Underground Storage of Natural Gas in both reservoirs and salt formations since 1990. Our experience is from the hands-on operations and maintenance of these facilities. Our regulatory experience begins with the introduction of the Texas Railroad Commission Statewide Rule 96 for the Underground Storage of Gas in Productive or Depleted Reservoirs (effective 1/1/1994) and Statewide Rule 97 for the Underground Storage of Gas in Salt Formations (effective 1/1/1994).
We have consulted and assisted some 20 underground natural gas storage facilities across 8 states with:
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Staffing
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Gap analysis and program adequacy reviews
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Gas storage field reviews
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Historical records reviews and cataloging
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Training and qualification
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Construction
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Commissioning
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Operations
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Maintenance
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Risk management
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Risk analysis
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Risk assessments
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Safety management systems
Key aspects of underground natural gas storage work include development of §192.12, API RP 1171 and 1170 site-specific:
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Compliance programs and procedures
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Risk analysis
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Integrity assessments
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Compliance work plans
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Internal audit guidance
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Regulatory auditing
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Records management
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Notification and reporting
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Code applicability tests
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Emergency management and response
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Contractor management and qualification
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Subject matter expert consultation and executive management
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Operations support
Liquified Natural Gas
RegSafe has developed Liquified Natural Gas (LNG) regulatory programs that meets current PHMSA requirements (§193 including the Incorporated by Reference industry standards). We specialize in the clear delineation of the regulatory requirements associated with the operations, maintenance, inspection, testing, qualification of personnel and security. We have developed specialized LNG tools that allow us to analyze our client’s needs against the regulatory requirements to ensure our clients programs are operationally implementable and sustainable.
Safety Management Systems
RegSafe developed its first pipeline safety management system (PSMS) prior to the introduction of API RP 1173 1st edition. This work began in 2012 as a requirement of the California Public Utilities Code sections 961 and 963 [Decision No. 12-04-010]. The continued revisions and updates to the PSMS are based on API RP 1173, industry input and operator performance. We ensure the SMS is designed, developed, implemented, and continuously improved in accordance with the client goals and industry standards. Examples of our experience include:
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Operating, maintenance, and safety and health program reviews
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Stakeholder Engagement,
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SMS Assessments,
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Risk Management, and
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Operational Controls.
Emergency Management
Our experience in responding to and supporting emergency operations as well as conducting incident investigations and accident reconstructions gives us the practical real-world experience necessary to ensuring that these plans are regulatory compliant, implementable, and sustainable.
RegSafe has decades of experience developing:
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Emergency Response Programs (ERP),
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Emergency Action Plans (EAP),
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Integrated Contingency Plans (ICP)
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Crisis Communications Plans,
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Oil Pollution Act 1990 Plans (OPA 90), and
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Hazard Mitigation Plans.
Our clients rely on us to:
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Support and/or manage the development of their programs,
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Conduct annual reviews,
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Provide emergency response training,
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Liaison with emergency officials and responders, and
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Conduct exercises and drills.
Operator Qualification
RegSafe’s experience in the qualification of operators and the identification of “Covered Tasks” (§ 192 Subpart N and §195 Subpart G). We provide our clients with multiple O&M and compliance avenues to ensure their OQ program and procedures are practical, implementable, effective and within PHMSA compliance. We perform:
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O&M and regulatory compliance gap analysis
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Covered task list review and development
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Develop site-specific OQ programs and procedures for OQ Covered Tasks
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Training and evaluation of personnel
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Records management
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Contractor management
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Conduct independent 3rd party compliance audits
Regardless of your specific needs, RegSafe can develop training and qualification solutions for your specific operation.
Control Room Management
RegSafe has been developing and implementing control room management programs for gas and hazardous liquids pipeline systems (§192.631, §195446 [IBR API RP 1168]) since 2009. We are experienced in fatigue management, alarm management, shift change procedures, and controller responsibilities. Our CRM training has always included the team training concept as our clients often operate their facilities with cross-trained/multi-functional personnel who are qualified as controllers and field operations and/or maintenance personnel. RegSafe also provides compliance checklists, internal audit support as well as audit support for specialized Control Room Management Audits.
RegSafe can assess your operation and determine if CRM applies to you as well as develop procedures and perform work associated with fatigue mitigation, monthly alarm reviews, workload analysis, compliance deviations, point-to-point reviews, annual program reviews, records management and training.
Document and Records Management
RegSafe has developed client driven and regulatory driven document and records management plans. These plans can include:
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The document sources
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Document purpose
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Company and regulatory records retention requirements
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Document storage (hard copy and electronic) requirements
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Controlled and open access requirements
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Production of records resulting from regulatory and legal requests
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Protection status of certain records (HIPAA, confidentiality agreements, etc.)
UNGS Integrity Monitoring (API RP 1170)
RegSafe has developed and implemented Cavern Integrity Monitoring Programs in accordance with API RP 1170 Section 10 ("Cavern Integrity Monitoring”) as required by PHMSA for operators of salt cavern UNGS facilities. RegSafe manages and evaluates the effectiveness of Integrity Monitoring Programs and provides thorough documentation for all aspects of the program for the life of the facility.
Examples of other regulatory compliance programs
RegSafe has specialized in compliance management and operations support of transmission pipeline systems, underground natural gas storage, and liquified natural gas facilities. Examples of other compliance, operations and maintenance programs include:
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Pressure Testing
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Corrosion Control
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Public Awareness & Damage Prevention
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Design and Construction
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Pipeline Security
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Incident Investigation
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Uprating
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Conversion to Service
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Regulatory Notification & Reporting
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Management of Change
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Internal Regulatory and Operational Compliance Auditing
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Training