A letter sent in July 2020 by the Pipeline and Hazardous Materials Safety Administration (PHMSA) to the Tennessee Public Utility Commission has opened up a whole new range of more rigorous requirements for LNG facility monitoring, setting off a cascade of questions and uncertainty for the industry. The letter was a summary of an audit that highlighted three issues of concern:
A lack of training for the control room personnel who are assigned to remote monitoring.
Lack of clarity over monitoring requirements for LNG operations governed by PHMSA §193, versus separate pipeline regulations set out under PHMSA §192.
Lack of clarity over specific LNG technical competencies required for staff at remote centers.
Though some room remains for interpretation and clarification, this has been a wakeup call for the industry. LNG facilities controlled or monitored via remote operations centers — whether located one mile or hundreds of miles away — have a new set of compliance requirements.
What the Code Says
According to PHMSA (§193.2441), each LNG plant must have a remote monitoring center from which operations and warning devices are monitored and controlled. Further, the monitoring center must:
Be located far enough away from the LNG process operations so that it remains operational during a controllable emergency.
Have the ability to remotely activate an automatic shutdown control system.
Be staffed and operational 24/7 while any operations are ongoing at the LNG facility. However, for plants monitored and controlled by more than one control center, only one is required to be staffed 24/7.
Have more than one means of communication with any other control centers set up to monitor the plant facility.
Have a means of communicating a warning of hazardous conditions to other locations within the LNG plant that may be frequented by any personnel.
What Is Changing
Though, again, there are some areas of the PHMSA §193 sections that still need to be clarified, it is clear that the Tennessee audit will usher in an era of more stringent controls and monitoring of LNG plant operations.
Here are questions LNG plant operators will need to ask themselves in order to comply with specific LNG plant operations guidelines for their facilities.
Is the LNG plant manned 24/7 or are there times when the LNG plant is unattended?
If the LNG plant is unattended, you should next consider what process operations are running during those periods. These may include boil-off gas compression, liquefaction, vaporization, or others.
If the LNG plant is unattended, is there a remote monitoring center (for example, a gas control center) that is monitoring LNG plant operations such as pressure, temperature, equipment running and security?
If the remote monitoring center detects Abnormal Operating Conditions (AOC) and determines field operations personnel need to go to the plant, you may need to specify expected response times. These response times would need to comply with the acceptable norms for an AOC response, generally ranging from 30 minutes to no more than 60 minutes.
Are process operations under the control of the LNG plant distributed control system (DCS), or are there manual controls?
If manual operations can mitigate an AOC, operators may need to consider automating specific manual operations.
Does the remote monitoring center have the means to remotely actuate automatic shutdown systems? Does this remote actuation require management approval?
If the monitoring center does not have remote actuation, the operator should consider adding this capability. The actuation may be as simple as clicking on a screen control in the remote monitoring center, but in any case, plant operations would have to specify how shutdowns will occur.
Do remote monitoring center personnel have training in specific LNG operations being monitored to understand AOCs? Will remote monitoring center personnel be required to “adjust” operations or actuate automatic shutdown systems?
Many remote operations centers are set up in compliance with PHMSA §192 regulations governing pipeline and distribution systems, so remote monitoring personnel often are not familiar with LNG regulations set out in PHMSA §193. Some unique LNG operations may require training of control room monitoring staff to meet standards set out in Section §193 compliance requirements, including recognizing AOCs. This will likely be the most reasonable path forward as not many utilities will be interested in setting up separate control centers for pipeline and LNG operations.
Is the utility operating the LNG plant considering cybersecurity standards for bringing the LNG plant site DCS onto the utility network?
Cybersecurity regulations are coming for LNG and natural gas systems, much like the North American Electric Reliability Corp. Critical Infrastructure Protection (NERC-CIP) standards are now in place for electric utilities. As more LNG plants are configured for remote monitoring and controls, proactive design and implementation of cybersecurity protocols will likely be required to keep operators in compliance.
Has the LNG plant operator utility discussed the plans for remote monitoring of the LNG plant with the Authority Having Jurisdiction that regulates the LNG plant?
Proactive discussions with state or other regulatory authorities with jurisdiction over your plants can pay big dividends, saving operators from investing in systems and equipment that may not be needed.
The industry has a wide variety of operational setups, and this is really the heart of the issue that must be resolved. Some LNG plants only have staff on-site when they are vaporizing liquefied natural gas out of tanks and directing it into the pipeline network. There is a strong preference throughout the industry for trained personnel to be on-site during vaporization and other critical operations, as any pipe or pump failure could have serious potential consequences if systems are not shut down immediately.
However, the industry is justifiably concerned about potential requirements to have staff on-site at plants during low-risk periods when plants are in standby modes and can be safely monitored and controlled via remote centers.
A reasonable path forward can be defined, but the industry has an obligation to provide a clear and concise response to the basic questions it now faces.
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