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Western Region Facts

Pipeline and Hazardous Material Safety Administration ( PHMSA) Office of Pipeline Safety Dave Mulligan Community Assistance & Technical Services (CATS) Western Region . Western Region Facts. Western Region encompasses 12 states 26 Inspectors and 3 Contractors

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Western Region Facts

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  1. Pipeline and Hazardous Material Safety Administration(PHMSA) Office of Pipeline SafetyDave MulliganCommunity Assistance & Technical Services (CATS)Western Region

  2. 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

  3. 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)

  4. 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.

  5. 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

  6. 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

  7. 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)

  8. 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)

  9. 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

  10. What We Regulate

  11. Regulatory UpdateThis PHMSA website link http://www.phmsa.dot.gov/pipeline/regs/rulemakinghas the status of federal rulemaking Not much new in 2013-2014

  12. 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)

  13. 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

  14. 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

  15. 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

  16. 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

  17. 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

  18. Western Region CATS Contact Information • Tom Finch: • thomas.finch@dot.gov • Phone: (720) 963-3175 • Dave Mulligan: • david.mulligan@dot.gov • Phone: (720) 963-3193

  19. Pipeline and Hazardous Materials Safety Administration Hazardous Liquid IM Program Huy Nguyen 12300 West Dakota Avenue, Suite 110 Lakewood, CO 80228 huy.v.nguyen@dot.gov

  20. General Topics • Overview • Observations • Western Region Focus Areas

  21. 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.

  22. 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

  23. 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

  24. 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

  25. 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

  26. 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

  27. 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

  28. 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

  29. Overview • Preventive and Mitigative Measures: • Risk Analysis Criteria • Leak Detection Capability Evaluation • Emergency Flow Restricting Devices (EFRD) Evaluation

  30. Overview • Continual Evaluation: • Periodic Evaluation • Reassessment Interval • Assessment Methods • Assessment Interval Variance • External Corrosion Direct Assessment (ECDA)

  31. 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

  32. 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.

  33. 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

  34. 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 • – ADB 2012-10 & Office of the Inspector General (OIG) • - ADB 2012-06

  35. Questions ?

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