Transcript PHMSA Office of Pipeline Safety

U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Pipeline and Hazardous Material Safety Administration
(PHMSA) Office of Pipeline Safety
Dave Mulligan
Community Assistance & Technical Services (CATS)
Western Region
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Western Region Facts
• Western Region encompasses 12 states
• 26 Inspectors and 3 Contractors
• Regional office Based in Lakewood, CO
• Major Satellite offices in Anchorage, AK
and Ontario, CA
• One man field offices in Billings, MT,
Cheyenne, WY, and Reno, NV
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
CATS Western Region Focus
• Public Complaints/Whistleblowers
• Technical Support Re: Pipeline Safety Regulations
• Emergency Response – Information dissemination
including incident causes and PHMSA safety actions
• Permits – Foster relationships with other
Federal/State/Local agencies and pipeline operators
• Pipeline Safety Education - public and gov’t officials
• Operators’ Public Awareness Program Effectiveness
Evaluations (PAPEE)
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Western Region (WR) CATS Example 1
• Products pipeline – Willard Bay,
UT (March 2013)
– Low frequency seam failure
– Focus on communication
(federal, state, local public
officials) to cause and
mandated remedial actions
– Ongoing communication
through startup and ongoing
repairs and tests.
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
WR CATS Example 2
•
Products pipeline – Lodge Grass, MT (July
2013)
– Failure due to land movement
– Facilitated Interaction
between Crow Nation leaders
and pipeline operator due to
cause and follow PHMSA
actions
– Communication with public
officials due to remoteness
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
WR Safety Challenges
• Low stress and rural gathering lines applicability – Finding those
operators who do not think they are regulated by PHMSA
• AC Interference/Lightning
• Landslide Areas
• Seasonal flash flooding events
• Encroachment of urban areas and parallel utility/pipeline
construction
• Aging Infrastructure Being Overly Amortized - Bandaids
• Impact of Shale Oil/Gas: New, Reversed, Converted Pipelines
• Challenges to Recruit, Train and Retain Qualified Workforce
• The World is Watching – Bloggers and the Internet
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Integrity Management (IM)
• IM Program Working:
– ILI tools advancement in technology (MFL,
geometry, crack, seam, stress/strain) continue to
identify integrity threats before they can fail
– Systems being reassessed and compared to
previous ILI results thereby finding changes in pipe
condition
– Fewer incidents caused by:
• Corrosion
• Outside Force Damage (dents/gouges)
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Who Regulates Pipelines
• Individual state
• U.S. DOT , PHMSA
In California:
• Hazardous Liquid Pipelines
 CSFM Regulates Intrastate pipelines
 PHMSA Regulates Interstate pipelines
• Natural Gas Pipelines:
 CA PUC Regulates Public Utilities systems within CA
 PHMSA Regulates all other systems (municipal
distribution, master meter, non-public utility
transmission)
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Jurisdictional Vs. Regulated?
• Jurisdictional: Transportation of hazardous liquid by
pipeline under Part 195
• Regulated: Pipeline facilities and the transportation of gas
that are not exempted under Part 195.1(b)
– In plant
– Gravity
– Other modes of transportation
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
What We Regulate
Pipeline Miles by System Types – as-of 3/14/2013
System Type
Miles
%Total
# Operators
Hazardous Liquid
182,563
7%
379
Gas Transmission
304,873
12%
923
Gas Gathering
19,872
1%
320
2,114,659
80%
1308
Gas Distribution
(Mains & Services )
Total
2,621,966
Liquefied Natural Gas
97 Plants
Some Operators
have multiple
System Types
138 Tanks
57 Operators
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Regulatory Update
This PHMSA website link
http://www.phmsa.dot.gov/pipeline/regs/rulemaking
has the status of federal rulemaking
Not much new in 2013-2014
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Rulemakings in Process
• Safety of On-Shore Hazardous Liquid Pipelines (NPRM stage)
• Excavation Damage Prevention (Final Rule stage)
• Miscellaneous Rulemaking (Final Rule stage)
• EFV Expansion beyond Single Family Residences (NPRM stage)
• Safety of Gas Transmission and Gathering Lines (NPRM stage)
• Operator Qualification, Cost Recovery and Other Pipeline Safety
Proposed Changes (NPRM stage)
• Plastic Pipe (NPRM stage)
• Standards Update (Final Rule stage)
• Rupture Detection and Valve Rule (NPRM stage)
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Current Rulemakings in Process
Safety of On-Shore Hazardous Liquid Pipelines
(NPRM stage)
 NPRM moved past PHMSA
 ANPRM published 10/18/2010
 Major topics under consideration:
• Assessments beyond High Consequence Areas (HCAs)
• Leak detection beyond HCAs
• Repair criteria in HCA and non-HCA areas
• Stress Corrosion Cracking (SCC)
• Piggability of lines
• Reporting requirements for Gathering lines
• Gravity Line exception
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
The Pipeline Inspector
• Regular People, believe it or not? (like Operations people)
• Hired to protect the public and environment from pipeline
inherent risks (Enforce Pipeline Safety Regulations)
• 80+ days away from home
• Plenty of windshield time
• Typically no Hilton where Interstate Pipelines are
• Not out to “get-em” philosophy
• We do not get graded on finding something wrong
• Another information resource for operators
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Inspector’s Role
• #1 tool to enforce regulations is phone call and showing up
• Ask plenty of questions – and listen
• Be considerate and cooperate with the operator
– Meeting time/place
– Understand operators file keeping process
• Different set of outside eyes on safety
• Should learn something new each inspection
• Inform operator of deficiencies/concerns upon leaving
• Why I do it:
– Great people and industry
– Would rather be on the ROW than in office
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
It’s Inspection Time
• Don’t panic
• Should be prepared every day
– Records in order
– Business as usual
• Typically scheduled
• Your time to show off your pipeline safety program
• Ask questions and be cooperative
• Don’t be afraid to voice your opinion
• Seems tougher on the inspector than operator
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
New PHMSA Inspection Tool
• IA – Inspection Assistant
• A tool for Inspector’s to capture results from questions
• A software application installed on a laptop (client/server
solution)
• Replaces standard MSWord inspection forms and questions
• Electronically records inspection results in database for
historical trending
• Provides considerations/guidance to Inspector to determine
compliance to regulations
– Considerations are for inspector guidance only. They are
memory joggers. They are not meant to replace the code
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Western Region CATS Contact
Information
• Tom Finch:
• [email protected]
• Phone: (720) 963-3175
• Dave Mulligan:
• [email protected]
• Phone: (720) 963-3193
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Pipeline and Hazardous Materials
Safety Administration
Hazardous Liquid IM Program
Huy Nguyen
12300 West Dakota Avenue, Suite 110
Lakewood, CO 80228
[email protected]
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
General Topics
• Overview
• Observations
• Western Region Focus Areas
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Objectives for the HL IM Program
• Accelerate and improve the quality of integrity
assessments conducted on pipelines in areas with
the highest potential for adverse consequences,
• Promote a more rigorous, integrated, and systemic
management of pipeline integrity and risk by
operators,
• Strengthen government’s role in the oversight of
pipeline operator integrity plans and programs, and
• Increase the public’s confidence in the safe
operation of the nation’s pipeline network.
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Overview of HL IM Program
• Hazardous Liquid Pipelines - ~186,000(1) miles.
• Over 79,000(1) miles or 43% of all hazardous liquid
pipelines designated as potentially affecting a high
consequence area.
• 8100(1) immediate repair conditions have been
remediated
• 32,000(1) 60 and 180-day conditions have been
remediated
(1) – 2012
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Program Elements for the HL IM
Program
• Segment Identification
• Risk Analysis
• Baseline Assessment Plan
• Assessment Results Review
• Remediation
• Preventive and Mitigative Measures
• Continual Assessment
• Performance Evaluation
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Overview
• Segment Identification:
– Direct Intersect Method
– Release Locations and Spill Volumes
– Overland Spread of Liquid Pool
– Water Transport Analysis
– Air Dispersion Analysis
– Identification of Segments that Could Indirectly
Affect an HCA
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Overview
• Risk Analysis:
– Comprehensiveness of Approach
– Integration of Risk Information
– Process for Input of Data and Information
– Risk Analysis of Segments that Could Affect HCAs
– Results
– Facilities
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Overview
• Baseline Assessment Plan:
– Assessment Methods
– Prioritized Assessment Schedule
• Category 3 – Date of pipeline begins operation
• Low-stress pipeline:
– Category 1 – July 3, 2015
– Category 2 – October 1, 2016
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Overview
• Assessment Results Review:
– Qualifications of Individuals that Review and Evaluate
Assessment Results
– ILI Vendor Specifications
– Validation of Assessment Results
– Integration of Other Information with Assessment Results
– Identifying and Categorizing Defects
– Hydrostatic Pressure Testing
– Results from the Application of Other Assessment
Technologies
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Overview
• Remediation:
– Discovery of Condition
– Schedule of evaluation and remediation
– Special requirements for scheduling remediation
• Immediate Repair Conditions
• 60-day Conditions
• 180-day Conditions
– Pressure Reduction:
• Temporary Pressure Reduction
• Long-term Pressure Reduction
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Overview
• Preventive and Mitigative Measures:
– Risk Analysis Criteria
– Leak Detection Capability Evaluation
– Emergency Flow Restricting Devices (EFRD)
Evaluation
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Overview
• Continual Evaluation:
– Periodic Evaluation
– Reassessment Interval
– Assessment Methods
– Assessment Interval Variance
– External Corrosion Direct Assessment (ECDA)
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Overview
• Performance Evaluation:
– Process for Measuring IM Program Effectiveness
– Records Demonstrate IM Program Effectiveness
– Process for Defining Performance Metrics
– Records Demonstrate Effective Use of Performance
Metrics
– Communication of Evaluation Results
– Root Cause Analysis Process
– Revision and Document Control
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Observations
• Operators generally understand the Rule and are
implementing the assessment provisions of the Rule.
• Operator interactions have been generally cooperative
with open communication.
• Operators of small systems may be more likely to
contract out significant portions of IM program
development.
• Operators now have an improved understanding of the
condition of pipelines in the safety-sensitive areas.
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Observations
• Operators are generally making progress toward
developing the mature, proactive IM Program.
• Progress is needed in development and implementation
of several IMP elements
 Preventive & Mitigative Measures
 Continual Evaluation
 Performance Evaluation
 Remediation
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Western Region Focus Areas
• Assessment Results
• Results of ILI Tool Data Evaluation
• Repair Records
• Preventive and Mitigative Measures
• Performance Metrics(1)
• Verification of Records(2)
• Other IMP Activities
(1) – ADB 2012-10 & Office of the Inspector General (OIG)
(2) - ADB 2012-06
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Questions ?
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