One of the more confusing issues for small hazardous liquids operators is compliance with PHMSA required emergency plans. For oil liquids, emergency plans that comply with both below are required:
- Part 194 – Response Plans for Onshore Oil Pipelines
- Also known as:
- OPA Response Plans
- Facility Response Plans (FRPs)
- This part contains requirements for oil spill response plans to reduce the environmental impact of oil discharged from onshore oil pipelines.
- Oil means oil of any kind or in any form, including, but not limited to, petroleum, fuel oil, vegetable oil, animal oil, sludge, oil refuse, oil mixed with wastes other than dredged spoil.
- Also known as:
- Part 195
- 195.402(e) Procedures for Emergencies
- 195.403 Emergency Response Training
- Prompt and effective response to a notice of each type of emergency:
- including fire or explosion occurring near or directly involving a pipeline facility,
- accidental release of hazardous liquid or carbon dioxide from a pipeline facility,
- operational failure causing a hazardous condition,
- and natural disaster affecting pipeline facilities.
Some of the issues I have seen include:
- Only a Part 194 plan
- Does not cover the fire or explosion hazards required by Part 195 since it only covers oil spills
- Questions about whether a Part 194 plan is required for HVLs (Highly volatile liquid or HVL means a hazardous liquid which will form a vapor cloud when released to the atmosphere and which has a vapor pressure)exceeding 276 kPa (40 psia) at 37.8 °C (100 °F))
- HVL’s vaporize and generally do not contaminate soil or water so no Part 194 plan is required.
- Questions about whether one combined plan for Part 194 and Part 195 emergencies is allowable
- Many larger HL operators have combined plans that cover all requirements of both code sections
- Two separate plans are fine if the operator chooses – PHMSA focuses on whether all applicable code sections are addressed whether one combined plan or two.
- Combined plans that do not clearly articulate the training received that addresses 195.403 training noted below:
- (a) Each operator shall establish and conduct a continuing training program to instruct emergency response personnel to:
- (1) Carry out the emergency procedures established under 195.402 that relate to their assignments;
- (2) Know the characteristics and hazards of the hazardous liquids or carbon dioxide transported, including, in case of flammable HVL, flammability of mixtures with air, odorless vapors, and water reactions;
- (3) Recognize conditions that are likely to cause emergencies, predict the consequences of facility malfunctions or failures and hazardous liquids or carbon dioxide spills, and take appropriate corrective action;
- (4) Take steps necessary to control any accidental release of hazardous liquid or carbon dioxide and to minimize the potential for fire, explosion, toxicity, or environmental damage; and
- (5) Learn the potential causes, types, sizes, and consequences of fire and the appropriate use of portable fire extinguishers and other on-site fire control equipment, involving, where feasible, a simulated pipeline emergency condition.
- Sometime in combined plans this training is buried in training slides and not gathered by the operator to show compliance with the above training requirements
- (a) Each operator shall establish and conduct a continuing training program to instruct emergency response personnel to:
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