PHMSA Pipeline Safety Programs Update Office of Pipeline Safety 2007 Western Regional Gas Conference Tempe, Arizona August 21, 2007.
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PHMSA Pipeline Safety Programs Update
Office of Pipeline SafetyOffice of Pipeline Safety2007 Western Regional Gas
Conference
Tempe, Arizona
August 21, 2007
Office of Pipeline Safety
Presentation Overview
Basic Message Things We Worry About, Not Covered Today Pipeline Soapbox Government’s Challenging Context Regulatory Philosophy Performance Equation Regulatory Approach Menu PHMSA Programs Update
Heavy Focus on DIMP
Office of Pipeline Safety
Basic Message
Your Work is Vital to The Country Your performance is watched closely and that’s
growing in relation to your criticality Good people are helping on many fronts
Times Have Changed – For the Better Incrementalism is out and performance is in
You Have Strong Representation Both at State and industry level
Your Voice Has Been Heard and Heeded Recognize there are constraints
Office of Pipeline Safety
Things We Worry About
Transportation Fuels and Products Supply Capacity, constraints to growth, new fuels, and
the market influence on prudent planning Natural Force Events Made-Made Threats Community Engagement and Education ROW Encroachment Enforcement Transparency
Office of Pipeline Safety
Pipeline Soapbox
Energy is our Lifeblood and a Birthright Our Economic Mobility is Fueled by Energy Energy Demand is Growing but Changing Growing Criticality of Pipelines in a Rate Constrained
Day Pipelines and the Environments They Cross Are Unique Regional Constraints in Capacity
Supply and Consumption Centers Are Shifting Demographics Are Changing Pipelines Are Increasingly Interdependent with Other Utilities Potential Consequences of Long-Term Disruptions Are Growing
BANANA Cake – Confidence is Improving but Strained
Office of Pipeline Safety
Government’s Challenging Context Change Averse (i.e. – slow) Requirements Partisan Environment with Myopic Interests Growing Competition for Resources
Both within government and within industry Aging Workforce – Little Time for Training Rapidly Evolving Technology and Knowledge Performance Based Budgeting and Evaluation
Age of metrics v. Inability to gather sufficient data Continually Changing Face of Pipeline
Industry
Office of Pipeline Safety
Regulatory Philosophy at PHMSA Goals:
Safe, clean & reliable energy transportation Objective:
Improve the performance of this critical infrastructure Overall Strategy:
Positively impact the performance of individual operators and industry direction
One size does not fit all and can misallocated resources Reliance on systematic management for performance Deliberative, risk-based, data driven decisions Commitment to continuous improvement
Office of Pipeline Safety
Performance = R / S + C.O. + B.C.
P = Performance Quantitative and qualitative Must factor contributions from people, processes, and technology
All are critical and are heavily intertwined All are important layers of defense in risk reduction and loss control
R / S = Regulations and Consensus Standards Regulations as minimum floor fleshed out/improved by standards Includes waivers and interpretations Development must be transparent, inclusive, and communicative
C.O. = Compliance Oversight Inspections, audits, accident investigations, use of enforcement
toolkit Credibility is important to both government and industry
B.C. = Beyond Compliance Excavation damage prevention, emergency preparedness, research
& Development, Partnerships, Communications, ROW Management
Office of Pipeline Safety
Regulatory Approach Menu
Command and Control (aka, Prescriptive) Performance Management Composite – A Blend of All of the Above
Pros and Cons to Each Approach For both the industry and the regulator A blend of all approaches is working for PHMSA Requires data, documentation, and active
assessment
Office of Pipeline Safety
Inspection Approach
PHMSA Uses a Mix of Inspection Approaches Ensure compliance with fundamentals
Standard inspections Operations and maintenance manual reviews
Drive performance through systematic approaches based in continuous improvement
Integrity Management Operator Qualification
Defensible risk ID, assessment, and mitigation are not only important but essential to inspection success
Documentation is a necessary evil/ingredient
Office of Pipeline Safety
PHMSA Programs Update
Process Distribution Integrity Management – Only Rule Discussed in Depth Transmission Integrity Management LNG Community Preparedness and Siting Standards Adequacy
People Operator Qualification Drug and Alcohol Programs Control Room Management / Fatigue Management Public Awareness Emergency Responder Training and Outreach – NASFM Damage Prevention: CGA, State Efforts, and PHMSA Support
Technology Maximum Allowable Operating Pressure Research and Technology Development/Demonstration
Office of Pipeline Safety
Distribution Integrity – The Rule Enterprise Approach to Rule
Development In Rulemaking Now
NPRM publication ~ Nov-Dec 2007GPTC Guidelines pending NPRM publicationDIMP Final Rule ~ Summer 2008
EFV Requirement Effective 6/1/2008 DIMP Effective Date ~Early 2010
Office of Pipeline Safety
Why DIMP?
Distribution Incidents Continue to Occur – Recently Trending Upward, Resulting in Significant Share of Consequences
Effecting a Significant Reduction in Pipeline Accidents, Deaths, and Injuries Cannot be Done Without Addressing Distribution
Integrity Management Principles Can Help Operators Focus on/Control System Risks
U.S. Congress Required It – PIPES Act of 2006
Office of Pipeline Safety
Pipeline Accident Frequency – 1999 - 2006
0
200
400
600
800
1000
1200
Liquid Transmission Distribution
Nu
mb
er
of
Rep
ort
ed
Sig
nif
ica
nt
Liq
uid
Ac
cid
ents
an
d G
as
Inc
ide
nts
36% 36% 27% 81% by operators with equal or more than 12000 services
5% by operators with less than 12000 services
13% by operators of unknown service size
Source: PHMSA Liquid Accidents and Gas Incidents Reports
Data as of 2/15/2007.
Office of Pipeline Safety
Major Issues in Rule Development Excess Flow Valves (EFVs) Development/Use of Industry
Guidance Leak Management Performance Measures
Reportable at the national levelOperator specific
Office of Pipeline Safety
Excess Flow Valves (EFVs)
EFVs Are One Mitigation Option When Properly Specified & Installed, EFVs
Function As Designed Fire Fighters Strongly Supported Mandatory
Installation Of EFVs On New Services Pipes Act 2006 Requires EFV Installation NARUC Resolution GA-4 Emphasizes Caution
In Promulgating New Requirements
Office of Pipeline Safety
Guidance – Overview Larger Operators Want Choices; Smaller Operators
Require Clarity - Not Choices GPTC Asked To Develop Guidance Describing
Candidate Approaches To Implement Such A Regulation
GPTC Divisions Approved The Draft Guidance In November ’06. Guide Will Publish For Public Comment After The NPRM
APGA, With PHMSA Funding, Is Developing A Model DIMP Plan (SHRIMP) For The Small Operators
PHMSA Proposed Rule Will Include Even Simpler Guidance (Baby SHRIMP) For MM And LPG Operators
Office of Pipeline Safety
Guidance – “SHRIMP”
APGA’s SIF To Develop More Detailed Guidance For Smallest Operators
Simple, Handy, Risk-based, Integrity Management Plan (SHRIMP)Turbo Tax-like ApproachFlexibility Traded Off For SimplicityDevelopment Planned For 2007-2008
Office of Pipeline Safety
Leak Management
Require Process For Managing Leaks Locate the leak Evaluate its severity Act appropriately to mitigate the leak, Keep records Self-Assess to determine if additional actions
are necessary to keep the system safe Require Better National Data Reporting &
Expansive Analysis By Operator National reporting changed to focus on
hazardous leaks removed & pipe materials Guidance to be developed on operator-
specific measures and analysis
Office of Pipeline Safety
Performance Measures Both Reportable, National Measures &
Operator-specific Measures National-Level
Incidents & normalized incidents Excavation damages per 1000 tickets Hazardous leaks removed and normalized EFVs installed
Operator-Specific Tailored to operator circumstances Measures to clarify management effectiveness in
addressing and reducing key identified threats GPTC Guidance will provide choices
Office of Pipeline Safety
Elements of an Operator’s Distribution Integrity Management Program Operators Should Have:
Written PlanUnderstanding of their infrastructureProcess to identify the threatsProcess to assessing the risksProgram/plans to address the threats and
risksProcess to monitor performance and adjust
approach as neededPlan for reporting results
Office of Pipeline Safety
Elements of Effective Statewide Excavation Damage Prevention Programs Enhanced Communications between operators and
excavators Fostering support & partnership of all stakeholders Operator’s use of performance Measures Partnership in employee training Partnership in public education Dispute resolution process Fair and consistent enforcement of the law Use of technology to improve process Analysis of data to continually evaluate/improve
program effectiveness
Office of Pipeline Safety
Regulatory Outreach
PHMSA Advisory Bulletin Industry/Public Meeting(s) During The Rule
Comment Period – Maybe Web-Based Overview APGA Working To Assist Small Operators
Planning 12 Regional Workshops States Will Need To Reach Out To Master Meter
And LPG Operators PHMSA Will Support State Operator Meetings Community Assistance And Technical Services
(CATS) PHMSA Website PHMSA Training &Qualifications Program Will
Provide Training To States and Outreach to Operators
Office of Pipeline Safety
The End
Closing ThoughtLeadership Matters – You are leadersMake a difference with your system,
your people, and your customers and it will pay, as well as feel good
Thanks for Your Time More Importantly – Thanks for Taking
Time to Do It Well
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