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PHMSA Pipeline Safety Programs Update

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Title: Where Did That Crazy Rule Come From? Author: Jeff Wiese Last modified by: mcomsto Created Date: 4/24/2006 5:13:08 PM Document presentation format – PowerPoint PPT presentation

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Title: PHMSA Pipeline Safety Programs Update


1
PHMSA Pipeline Safety Programs Update
  • Office of Pipeline Safety

2007 Western Regional Gas Conference Tempe,
Arizona August 21, 2007
2
Presentation 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

3
Basic 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

4
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

5
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

6
Governments 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

7
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

8
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

9
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

10
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

11
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

12
Distribution 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

13
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

14
Pipeline 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
27
Source PHMSA Liquid Accidents and Gas Incidents
Reports Data as of 2/15/2007.
15
Major Issues in Rule Development
  • Excess Flow Valves (EFVs)
  • Development/Use of Industry Guidance
  • Leak Management
  • Performance Measures
  • Reportable at the national level
  • Operator specific

16
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

17
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

18
Guidance 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

19
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

20
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

21
Elements 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

22
Elements 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

23
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

24
The 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
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