Title: PHMSA Pipeline Safety Programs Update
1PHMSA Pipeline Safety Programs Update
- Office of Pipeline Safety
2007 Western Regional Gas Conference Tempe,
Arizona August 21, 2007
2Presentation Overview
- Basic Message
- Things We Worry About, Not Covered Today
- Pipeline Soapbox
- Governments Challenging Context
- Regulatory Philosophy
- Performance Equation
- Regulatory Approach Menu
- PHMSA Programs Update
- Heavy Focus on DIMP
3Basic Message
- Your Work is Vital to The Country
- Your performance is watched closely and thats
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
4Things 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
5Pipeline 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
6Governments 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
7Regulatory 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
8Performance 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
9Regulatory 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
10Inspection 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
11PHMSA 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
12Distribution Integrity The Rule
- Enterprise Approach to Rule Development
- In Rulemaking Now
- NPRM publication Nov-Dec 2007
- GPTC Guidelines pending NPRM publication
- DIMP Final Rule Summer 2008
- EFV Requirement Effective 6/1/2008
- DIMP Effective Date Early 2010
13Why 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
14Pipeline Accident Frequency 1999 - 2006
13 by operators of unknown service size
5 by operators with less than 12000 services
81 by operators with equal or more than 12000
services
36
36
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Source PHMSA Liquid Accidents and Gas Incidents
Reports Data as of 2/15/2007.
15Major Issues in Rule Development
- Excess Flow Valves (EFVs)
- Development/Use of Industry Guidance
- Leak Management
- Performance Measures
- Reportable at the national level
- Operator specific
16Excess 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
17Guidance 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
18Guidance SHRIMP
- APGAs SIF To Develop More Detailed Guidance For
Smallest Operators - Simple, Handy, Risk-based, Integrity Management
Plan (SHRIMP) - Turbo Tax-like Approach
- Flexibility Traded Off For Simplicity
- Development Planned For 2007-2008
19Leak 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
20Performance 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
21Elements of an Operators Distribution Integrity
Management Program
- Operators Should Have
- Written Plan
- Understanding of their infrastructure
- Process to identify the threats
- Process to assessing the risks
- Program/plans to address the threats and risks
- Process to monitor performance and adjust
approach as needed - Plan for reporting results
22Elements of Effective Statewide Excavation Damage
Prevention Programs
- Enhanced Communications between operators and
excavators - Fostering support partnership of all
stakeholders - Operators 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
23Regulatory 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
24The End
- Closing Thought
- Leadership Matters You are leaders
- Make 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