Oil and Gas Production Facility Regulatory Compliance or Am I Aware of What I Need to Be Aware of

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Oil and Gas Production Facility Regulatory
Compliance orAm I Aware of What I Need to Be
Aware of?

• Mark L. Garner
• Chevron Buckeye CO2 Plant
• Operations Supervisor

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Safety Moment!

• Exits are located where?
• In case of emergency meet where?
• Restrooms are located in hotel lobby.
• Please turn communication devices to vibrate or
  silent!
• Thank You for attending this presentation!

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Introduction

• As Health, Safety and Environmental
  Professionals do we really know what rules and
  regulations apply to the plants and production
  facilities we support?
• or
• Do we sometimes accept the things we find in
  our facilities without really being aware of the
  regulations or recommended practices that cover
  those particular operations?

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Introduction

• In this presentation I will attempt to address
  some of the rules and regulations that may cover
  your operations and give you some ideas on how to
  check to see if your production operations are in
  compliance with federal, state and local
  regulations.

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Disclaimer!

• But, please be aware that due to the diversity of
  our operations I will not be able to cover ALL
  the rules, regulations and practices that may
  apply to you and your specific operations!

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Agenda

• Cover the major regulatory agencies and rules
  that apply to oil and gas surface production
  facilities.
• Ideas for ways to ensure we are in compliance.
• Sources for rules and regulations.

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Major Regulatory Agencies and Rules

• There is not just one set of rules that apply
  to oil and gas production operations.
• There are several rule making groups and
  regulatory agencies that apply to oil and gas
  production operations.

API
OSHA
EPA
DOT
ASME
NIOSH
NFPA
NACE
NEC
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Regulatory Agencies

• These agencies and groups include governmental
  agencies that make regulations and can enforce
  those regulations by force of law. (OSHA, EPA,
  etc.)

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Industry Groups

• Other agencies are industry specific related.
  They provide rules, guidance and generally
  accepted practices for different aspects of oil
  and gas operations. These rules are not laws as
  such, but they can and will be referenced by
  government agencies when determining if an
  operator has disregarded safe working practices.
• Also, when deciding on new legislation these
  industry groups will give input and advice to the
  government on the proposed legislation. (API,
  NFPA, ASME, ANSI, NIOSH, etc.)

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Vocabulary Review

• All professions have their own language. As
  HES Professionals we talk our own language that
  includes a lot of references to letter and
  acronym agencies that put forth and enforce the
  rules we are trying to comply with. Before we get
  in to some of the specific agencies, rules and
  regulations lets review what some of these
  abbreviations and acronyms mean!

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Some Acronyms and Abbreviations

• ACGHI American Conference of Governmental
  Industrial Hygienists
• ANSI American National Standards Institute
• API American Petroleum Institute
• ASME American Society of Mechanical Engineers
• ASTM American Society for Testing and Materials
• CERCLA Comprehensive Environmental Response,
  Compensation and Liability Act
• CFR Code of Federal Regulations
• DOT U. S. Department of Transportation
• EPA Environmental Protection Agency
• HAZWOPER Hazardous Waste Operations and
  Emergency Response
• IDLH Immediately Dangerous to Life and Health
• NACE National Association of Corrosion
  Engineers
• NEC National Electric Code
• NFPA National Fire Protection association
• NIOSH National Institute for Occupational
  Safety and Health
• OSHA Occupational Safety and Health
  Administration
• PEL Permissible Exposure Limit
• PSM Process Safety Management
• RCRA Resource Conservation and Recovery Act

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Major Regulatory Agencies and Rules

• What rules and regulations may apply to my
  operations?
• For the purposes of this presentation we
  will split oil and gas production facilities in
  to two separate groups.
• 1. Surface Production Facilities These include
  Pumping Units, Tank Batteries, Salt Water
  Disposals (SWD), Injection Stations, Field
  Offices etc.
• 2. Gas Plants
• The reason for this is even though they
  have many rules in common, typically, gas plants
  will have some additional rules and regulations
  associated with them.

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Some rules and regulations that may apply to your
operations

• Surface Production Facilities
• OSHA Rules
• 29 CFR 1904
• 1904.0 to 1904.46 Recording and reporting
  occupational injuries and illness
• 29 CFR 1910 Occupational Safety and Health
  Standards
• Subpart D - 1910.21 Walking Working Surfaces
• Subpart E - 1910.33 Exit Routes, Emergency Action
  Plans and Fire Prevention Plans
• Subpart F 1910.66 Powered Platforms, Manlifts,
  Vehicle Mounted Work Platforms
• Subpart G 1910.95 Occupational Noise Exposure
• Subpart H 1910.101 Compressed Gases
• 1910.101, 102, 104 Hazardous
  Materials
• 1910.106 Flammable and
  Combustible Liquids
• 1910.120 Hazardous Materials,
  HAZWOPER
• Subpart I 1910. 132, 133, 134, 135, 136, 137,
  138, PPE

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OSHA Rules Continued

• Subpart J 1910.141 General Environmental
  Controls Sanitation
• 1910.144 Safety Color Code
  For Marking Physical Hazards
• 1910.146 Permit Required
  Confined Spaces
• 1910/147 Control of Hazardous
  Energy (LOTO)
• Subpart K - 1910.151-152 Medical Services and
  First Aid
• Subpart L - 1910.157 Portable Fire Extinguishers
• 1910.165 Employee Alarm
  Systems
• Subpart M -1910.169 Compressed Air Equipment
• Subpart N - 1910.176 Materials Handling and
  Storage, General
• 1910.178 Powered Industrial
  Trucks (Forklifts)
• 1910.179 Overhead and Gantry
  Cranes
• 1910.180 Crawler, Locomotive
  and Truck Cranes
• 1910.184 Slings
• Subpart O -1910.212 Machinery and Machine
  Guarding, General

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More OSHA Rules

• Subpart P -1910.241 -.244 Hand and Portable
  Powered Tools
• Subpart Q -1910.251-.255 Welding, Cutting and
  Brazing
• Subpart S - 1910.303 -.307 Electrical General
  Requirements
• 1910.332 Training
• 1910.333 Selection and Use of
  Work Practices
• 1910.334 Use of Equipment
• 1910.335 Safeguards for
  Personal Protection
• Subpart Z - 1910.1000 Toxic and Hazardous
  Substances, Air Contaminants
• 1910.1001 Toxic and Hazardous
  Substances, Asbestos
• 1910.1020 Toxic and Hazardous
  Substances, Access to Employee
  Exposure and Medical Records
• 1910.1028 Toxic and Hazardous
  Substances, Benzene
• 1910.1030 Toxic and Hazardous
  Substances, Bloodborne Pathogens
• 1910.1200 Toxic and Hazardous
  Substances, Hazard Communication

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Still More OSHA Rules!

• OSHA Rules
• 29 CFR 1929 Safety and Health Regulations for
  Construction
• Subpart E Personal Protective and Life Saving
  Equipment
• Subpart L Scaffolds
• Subpart M Fall Protection
• Subpart P Excavations

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Gas Plant Regulatory Compliance

• Gas Plant Operations
• Gas processing facilities fall under all the
  OSHA Rules that are applicable to field
  operations. In addition to this, HES
  professionals need to be aware if their gas plant
  operations fall under OSHA Process Safety
  Management (PSM) Rules and EPA Risk Management
  Plans (RMP).

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Gas Plant Regulatory Compliance

• OSHA Rules
• 29 CFR 1910
• 1910.119 Process Safety Management of Highly
  Hazardous Chemicals
• This rule will apply to your operations if
  under OSHA Rule 1910.119(a)(1)(ii) you have a
  process which involves a flammable liquid or gas
  (as defined in 1910.1200(c)) on site in one
  location, in a quantity of 10,000 pounds.

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Gas Plant Regulatory Compliance

• 10,000 Pounds!!
• This amount equals approximately 2000 gallons
  of natural gas liquids. This is not that much
  when considering process surge tank volumes or if
  your process involves refrigerant propane.

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Gas Plant Regulatory Compliance

• Plus!!
• EPA Rules
• 40 CFR Part 68
• 40 CFR Part 68 Chemical Accident Provisions
• This regulation addresses a facilities
  exposure to off site receptors in case of a
  catastrophic release.
• If your facility falls under PSM, this rule
  will apply to your operations in one form or
  another.

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Speaking of Other Government Agencies!

• Oil and gas production facilities are also
  under the guidance of the U.S. Environmental
  Agency (EPA) and the U.S. Department of
  Transportation (DOT)
• Depending on the circumstance of your
  operations some of these rules may not apply and
  some rules not mentioned may apply.
• What follows is a list of EPA and DOT rules
  that could be applicable.

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Environmental Regulations

• U.S. Environmental Protection Agency Regulations
  
• 40 CFR
• Part 63, Subpart A, Sec 63.1 - 63.15 National
  Emission Standards for Hazardous Air Pollutants
  for Source Categories, General Provisions
• Part 63, Subpart HH, Sec 63.760 63.777 National
  Emission Standards for Hazardous Air Pollutants
  From Oil and Natural Gas Production Facilities
• Part 68 Chemical Accident Prevention Provisions
• Part 71 Federal Operating Permit Programs
• Part 110 Discharge of Oil
• Part 112 Oil Pollution Prevention (SPCC and
  Facility Response Plans)
• Part 122 EPA Administered Permit Programs
  National Pollution Discharge Elimination System
• Part 144 Underground Injection Control Program
• Part 260 Hazardous Waste Management System,
  General
• Part 261 Identification and Listing of Hazardous
  Waste
• Part 262 Standards Applicable to Generators of
  Hazardous Waste
• Part 273 Standards for Universal Waste Management
• Part 279 Standards for the Management of Used Oil
• Part 355 Emergency Planning and Notification
• Part 370 Hazardous Chemical Reporting Community
  Right to Know

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DOT Rules

• U.S. Dept. of Transportation Regulations
• 49 CFR
• Part 107 Hazardous Materials Program Rule Making
  Procedures
• Part 171 General Information, Regulations and
  Definitions
• Part 172 Haz Mat Table, Special Provisions, Haz
  Mat Communications, Emergency Response
  Information and Training Requirements
• Part 173 Shippers, General Requirements for
  Shipments and Packaging
• Part 177 Carriage by Public Highway
• Part 191 -195 Transportation of Natural and Other
  Gas by Pipeline
• Part 199 Drug and Alcohol Testing
• Part 382 Controlled Substances and Alcohol Use
  and Testing
• Part 383 Commercial Drivers License Standards
• Part 391 Qualifications of Drivers
• Part 395 Hours of Service of Drivers
• Part 396 Inspection, Repair and Maintenance

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State Regulations!

• Every state has its own set of rules and
  regulations that apply to oil and gas operations.
• They are too numerous to mention here in
  detail, but as HES Professionals we need to be
  knowledgeable about the state and local rules
  that apply to the various aspects of our
  operations.

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Examples of Some State Agencies and Regulations
That Apply to Oil and Gas Operations

• Colorado
• Colorado Department of Public Health and
  Environment
• Air Quality Control Commission (AQCC)
• Materials and Waste Management Division (CMWD)
• Colorado Dept. of Natural Resources
• Colorado Oil and Gas Conservation Commission
• New Mexico
• New Mexico Environmental Dept. Air Quality Bureau
  (AQB)
• New Mexico Water Quality Control Commission (QCC)
• New Mexico Oil Conservation Division (OCD)
• Texas
• Railroad Commission of Texas (RRC)
• Texas commission on Environmental Quality (TCEQ)

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Industry Organizations

• As stated before they provide rules, guidance
  and generally accepted practices for different
  aspects of oil and gas operations. These rules
  are not laws as such, but they can be referenced
  by government agencies when determining if an
  operator has disregarded safe working practices.
• As a HES Professional you need to be aware of
  these standards. They are a source of valuable
  information and guidance in your daily
  operations.
• I have listed some of the more important rules
  and recommended practices. I encourage all to
  review these rules and standards when you return
  to your operations.

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Industry Organizations

• ANSI
• B31.3 Chemical Plant and Petroleum Refining
  Piping
• B31.4 Liquid Petroleum Transportation Piping
  Systems
• B31.8 Gas Transmission and Distribution Piping
  Systems
• API
• RP 11ER Guarding of Pumping Units
• RP 12R1 Setting and Maintenance, Inspection,
  Operation and Repair of Tanks in Production
  Service
• RP 65 Oil and Gas Producing and Gas Processing
  Plant Operations Involving Hydrogen Sulfide
• RP 500 Classification of Locations for Electrical
  Installations at Petroleum Facilities
• RP 576 Inspection of Pressure Relieving Devices
• RP 750 Management of Process Hazards
• 510 Pressure Vessel Inspection Code Maintenance
  Inspection, Rating, Repair and Alteration
• 570 Piping Systems
• Bulletin E2 Management of Naturally Occurring
  Radioactive Materials (NORM) in Oil and Gas
  Production
• Publication 2015 Safe Entry and Cleaning of
  Petroleum Storage Tanks
• STD 1104 Welding of Pipelines and Related
  Facilities
• ASME

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Ways to ensure your production operations are
compliant

• Facility Compliance Audits should include
• Facility Site Inspections
• Check lists are handy for this
• Be sure to include office areas in your
  audit
• Your own PPE
• Employee (Field) Interviews
• Try to interview the field personnel in
  their comfort zone. Dont summon them to the
  office if can be avoided.
• Record Reviews
• If it not written down it has not been done!
• These compliance audits can be done by
  properly trained and qualified company personnel
  or to remove any question of bias an outside
  consulting firm can be brought in.

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Checklists

• An example of a facility audit

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Compliance Audits

• What if you have questions if a rule applies?
• Use your HES network
• Outside consultants
• Contact your local governmental agency
  representative!

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Audit Follow Up

• Very Important!
• Once the audit has been completed it is very
  critical to document the findings of the audit.
  These findings need to be communicated to the
  management of the organization and action plans
  developed to address the areas of regulatory non
  compliance.

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Information Sources

• Part of the duties of a HES Professional is
  to stay up with the latest rules and regulations.
  This can be difficult in today's oil and gas
  production operations because new rules and
  regulations are constantly being changed or
  adopted. Ways to help keep up are
• Become an active member in a local HES Group.
• Subscribe to industry publications.
• Make the internet your friend!
• When you look up the rules on the agency web
  site you have a lot better chance of getting the
  most current regulations. Also you dont clutter
  up your limited office space with a lot of books!
• On the following slide I have listed links to
  some of the regulatory and industry web sites.

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• API - Exploration Production Onshore Safety
  Standards
• ASME - ASME.ORG - Codes Standards
• NIOSH - http//www.cdc.gov/niosh/npg/pdfs/2005-149
  .pdf
• NFPA - NFPA Codes and Standards
• OSHA - Occupational Safety and Health
  Administration - OSHA HOME PAGE
• EPA RMP - Electronic Code of Federal Regulations
• EPA - Laws and Regulations US EPA
• ASSE - American Society of Safety Engineers

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Conclusion

• Compliance may seem very overwhelming, but it can
  be managed by being aware of the resources
  available to you.
• I hope this presentation has been helpful to you!
• This presentation is available on the Permian
  Basin ASSE web site.
• Thank You to Pure Resources and Chevron Mid
  Continent /Alaska Business Unit for some of the
  material used in this presentation!
• Questions or comments!