Regulatory Manager, LP Gas
Focus:
Implement Department of Homeland Security registration, CSAT completion, and assure annual EPA Tier II reporting for all affected LP Gas locations, including affected customer locations. Work with the business to ensure that customer locations are reported only once.
Develop and maintain all state specific LP Gas site, operator and employee permits, licensing, registration and continuing education requirements in a database format including the development of a compliance calendar and alerts relative to expiring permits and licenses. Determine if a 3rd party firm can provide LP Gas permit and licensing tracking and alerts in states in which the business operates or develop a tracking option working with the designated LP Gas operations representative for each state.
Provide LP Gas permitting and reporting support to operations. Ensure local operators provide necessary information to submit reports or develop a process in which the local manager submits required external documentation and a copy is retained centrally.
Maintain NFPA knowledge to support LP Gas Board permitting leadership and Fire Safety analysis and coordination with local fire marshal as needed. Ensure Fire Safety analyses are complete and meet state requirements.
Develop improvements to NGL procedures and other compliance policies and procedures as needed.
Duties / Responsibilities:
Complete Department of Homeland Security registration and Top Screens as required for storage facilities exceeding regulatory thresholds. File CSATs in central electronic file for access as needed. As a part of an annual storage audit verification, delete obsolete registrations, update existing and file additional registrations for any facilities that were not properly registered during the prior calendar year.
Audit company and customer propane storage locations exceeding EPA Tier II reporting requirements and coordinate/submit annual Tier II filings for all affected locations.
Provide input to new hire role based training curriculum using online/self-training options to create efficiency and cost optimization through PERC or other LP Gas industry standards. Provide input to monthly safety meeting topics by role for business unit – edit/create additions to safety meeting materials to drive safety/compliance improvements. Provide LP Gas audit protocol input and integration of new/developing regulatory requirements.
Develop and implement LP Gas operating permit/licenses applications and renewals. Coordinate licensing and registration processes for LP Gas facilities and LP Gas operators with local management. Maintain matrix of facility and operator LP Gas permit, licensing and registration requirements by state and address local requirements as needed. Develop a compliance calendar by site which addresses renewals and expirations. Develop system such that an inventory of permits and licenses including issuing entity and financial/bond obligations are tracked.
Develop PHMSA gas systems compliance knowledge to provide input to Operator qualification and PHSMA manuals and operator training and qualification. Develop working knowledge of UST/AST regulatory requirements to support NGL Refined Fuels business.
Develop process and tracking system for identification, tracking and closure of agency notices of deficiency and notices of enforcement for LP Gas facilities.
Participate in agency auditing and reviews of LP Gas facilities.
Provide investigation and corrective action development for LP Gas incidents associated with customer facilities including information coordination with legal and outside attorneys as needed.
Qualifications
Competencies:
Demonstrates Leadership, Personal Initiative, Teamwork, Collaboration, Communication, Drive Measurable Results, Influence without Authority
Performance Measures:
NGL Permit and Licenses Database (may be 3rd party supported)
NGL agency reporting and agency investigation/inquiry interface
NOD/NOE tracking, closure, and periodic analysis of trends
AST/UST compliance: registration, permitting, reporting, closure as needed