LNG & Natural Gas Terminals

The Challenge

The first 30 minutes of a declared emergency at an LNG terminal involve five separate federal notification obligations — with different windows, different agencies, and no margin for error.

PHMSA, FERC, the NRC hotline, USCG COTP, and EPA EPCRA each have their own clock. Miss a window and you have a compliance violation layered on top of whatever caused the incident. The organization that looks up the NRC number during an active event is the organization that gets cited — not for the incident, but for the notification.

FERC certificate conditions are not derivable from any regulation. They are facility-specific, written into the actual certificate order at the time of approval. If they are not encoded at onboarding, they are not in the system — and the Living Model is incomplete where it matters most.

Construction-phase operations add a separate layer: contractor personnel accountability across 50 or more firms, mass casualty coordination protocols, and OSHA fatality notification within 8 hours. This is not an EHS problem. It is a governance problem — and most facilities handle it with a binder.

How CROS Helps

The Living Model knows what your organization is obligated to do — and whether it is doing it.

Five-agency notification sequence pre-loaded at onboarding — NRC, FERC, USCG COTP, EPA SERC/LEPC, PHMSA — each with the correct contact, the correct window, and a pre-drafted communication
FERC certificate conditions encoded from the actual certificate order, not derived from CFR — every condition traced to source, every notification trigger defined
USCG COTP authority encoded in the Living Model — transfer operation suspension protocols activated automatically when COTP order is received
Construction-phase contractor accountability — tier structure, site safety officers, daily headcount, authorized zones — maintained as live data, not a static roster
ESD activation classification gate — distinguishes actual emergency from commissioning test before the PHMSA clock starts
Doctrine Delta monitoring — Phronesis surfaces gaps between documented procedure and operational behavior before a regulator does

When PHMSA shows up, you don't reconstruct. You produce. The incident thread is append-only from creation to all-clear. Every decision, every notification, every action — attributed, timestamped, and available on demand.

Regulatory Framework

Obligations CROS encodes at onboarding.

PHMSA 49 CFR 193

LNG facilities — siting, design, installation, operation, and maintenance. Incident notification to NRC within 1 hour; written report within 30 days.

FERC Certificate of Public Convenience

Facility-specific conditions written into the certificate order. Not derivable from CFR. Must be pulled and encoded at onboarding.

USCG 33 CFR Part 127

Waterfront transfer operations. COTP authority to suspend transfers. Waterway Suitability Assessment required. Intersects MTSA overlay.

EPA EPCRA Section 304

Extremely hazardous substance releases — notification to SERC and LEPC within the legislated window. Separate from PHMSA obligation.

OSHA 29 CFR 1910.119

Process Safety Management — for facilities handling covered chemicals above threshold quantities. Fatality notification within 8 hours.

PHMSA 49 CFR 191

Gas transmission and gathering — operational reporting, incident reporting, annual reporting. Overlaps with 49 CFR 193 at some facilities.

See how CROS handles the LNG terminal regulatory stack.

We load your facility type, encode your FERC certificate conditions, and run a scenario against your notification sequence. You see exactly what CROS surfaces in the first 30 minutes of a declared event.

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