Interpretation Response #PI-20-0012
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Tennessee Public Utility Commission
Individual Name: Mr. Bryce Keener
Location State: TN Country: US
View the Interpretation Document
Response text:
Mr. Bryce Keener
Director, Gas Pipeline Safety Division
Tennessee Public Utility Commission
Andrew Jackson State Office Building
502 Deaderick Street, 4th Floor
Nashville, TN 37243
Dear Mr. Keener:
In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), dated May 21, 2020, you requested an interpretation of 49 Code of Federal Regulations (CFR) Part 193. Specifically, the Tennessee Public Utilities Commission (TPUC) asked for an interpretation on whether 49 CFR § 193.2441(c) "is fulfilled when an LNG operator leaves the control center to perform assigned duties when an offsite SCADA control room is assigned and equipped only to monitor LNG alarms and is without an LNG trained operator." TPUC requests this interpretation to resolve a disagreement with a liquefied natural gas (LNG) operator as to the correct application of § 193.2441(c) to the operator's proposed one-man operator procedure.
The letter indicates that on May 17, 2020, an LNG operator implemented a one-man operation procedure that includes the requirement that when the control center is manned by only a single qualified operator, the operator is to contact an off-site Supervisory Control and Data Acquisition (SCADA) control room to monitor the alarms of the vacant LNG control center. This off-site SCADA control room has no ability to control any of the functions or operating components of the LNG facility; it can only monitor the alarm system. The off-site SCADA control room also only has Part 192 qualified gas operation personnel, with no Part 193 qualified LNG operators in attendance.
If the operator's procedure is followed, you stated that TPUC believes that as soon as the LNG operator leaves the LNG control center, a violation of § 193.2441(c) will have occurred. You stated the operator disagrees because its LNG facility is equipped with automatic shutdown capability, and the off-site SCADA control room monitoring the LNG facility's alarm systems will contact the LNG operator if an alarm goes off while the LNG control center is vacant. Based on these operational factors, the operator contends that its procedure meets the requirement of the regulation.
Section 193.2441(c) requires that "[e]ach control center must have personnel in continuous attendance while any of the components under its control are in operation, unless the control is being performed from another control center which has personnel in continuous attendance."
The regulation requires that an LNG facility has at least one person in the control center at all times (i.e. uninterrupted) while any of the components under the control center's control are in operation. This does not necessarily preclude the LNG control center operator from taking short breaks in the area of the control center to attend to physiological needs. Furthermore, § 193.2441(c) states that the "continuous attendance" requirement at the LNG control center does not apply if the control of any components in operation is being performed from another control center which has personnel in continuous attendance. However, § 193.2441(c) specifically requires that this "[other] control center" be capable of controlling any of the components at the LNG facility while in operation. Therefore, a control center operator may perform duties outside the control center during his/her shift as long as another control center's operator has control of any operating components with uninterrupted attendance of the control center.
In this case, the operator would not meet these regulatory requirements by relying on a SCADA system to monitor alarms without controlling the facility. Therefore, to respond to your question, the requirement in § 193.2441(c) is not fulfilled any time the operator's offsite SCADA control room is assigned and equipped to monitor LNG alarms without being able to control any of the operating components at the LNG facility whenever the LNG operator leaves the LNG control center vacant to perform other assigned duties.
If we can be of further assistance, please contact Tewabe Asebe at 202-366-5523.
Sincerely,
John A. Gale
Director, Office of Standards
and Rulemaking
Regulation Sections
Section | Subject |
---|---|
193.2441 | Control center |