u.s. dot pipeline and hazardous materials safety administration pipeline safety reauthorization...

U.S. DOTPipeline and Hazardous Materials

Safety Administration

Pipeline Safety Reauthorization

September 16, 2015

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Overview

• Reauthorization

• Mandates & Recommendations

• Regulatory Update

– Integrity Verification Program

• Safety Management Systems and Safety Culture

– API RP 1173

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Congressional Reauthorization

• Congress Reauthorizes the Federal Pipeline Safety Program Every 4 years. (Due in 2016)• State Pipeline Safety Program Certification Agreements are

reauthorized as part of larger package. (50 million grant program)

• Reauthorization is the Congressional “Performance Appraisal” of an Agency• Good job = “Clean” bill

• Poor job = New ways to improve (OUCH!)

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Why should you care about reauthorization?

Flashback to January 2010…• “Window” was open, and our performance had been

good

• Everyone was generally happy with PHMSA –

• Congress

• Inspector General (Exec Branch’s internal auditor),

• General Accounting Office (Congress’ auditor),

• National Transportation Safety Board

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April 20, 2010

Congress and the Public did not distinguish between an

offshore drilling incident and onshore pipelines.

They saw Big Oil and Gas hurting people and the

environment.

Salt Lake CityJune 11, 2010

Marshal, MIJuly 26, 2010

San Bruno, CASeptember 2010

Philadelphia, PAJanuary 19, 2011

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Allentown, PAFebruary 2011

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Chicago, ILNovember 13, 2011

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The Fallout• A spate of tragic and highly visible accidents in 2010 -2011.

• A polarized political environment, and a rabid media

• We appeared ineffective and too close to industry

• Congress reauthorized PHMSA in late 2011, with a ton of new mandates, little time, and no new resources.

We DON’T want this to happen in 2016.

• p.s. What is a mandate?

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2011 Act Mandates

• 42 mandates and 6 actions in Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011

• Completed 26 mandates and 2 actions

• Includes 9 required studies (Leak Detection, Cover over Buried Pipelines, R&D, Diluted Bitumen, Cast Iron, Damage Prevention, Expansion of IMP, Gathering Lines, etc.

• Other topics include: MAOP Records Verification, Rpting of Any Exceedance of MAOP, Tests to Confirm Material Strength of Previously Untested GT in HCAs, 1 hr Notification of Incidents, Automatic/Remote Shut-off Valves, EFVs, Biofuels, CO2, Updated Mapping, Cost Recovery for Design Reviews, Limitation on IBR, Tribal Consultation, Increased Civil Penalties, etc.

• http://phmsa.dot.gov/pipeline/psa/phmsa-progress-tracker-chart

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NTSB Recommendations

• 39 NTSB recommendations:

• Investigations – 17 open/9 Closed

– Excess flow valves

– ASV/RSVS

– Communication

– Removal of Grandfather clause, etc.

• 22 from the Gas IM Study 21 open/ 1 closed

– State Programs

– NPMS

– Threat identification and risk assessment

– Data

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GAO Audits & Recommendations

7 Recommendations/ 1 Closed

• Completed: Whether transmission should be redefined from 20% to 30% SMYS (No recs)

• Completed: Unregulated Gathering Lines

– 2 recommendations, 1 closed: related to collecting data and information sharing.

• Completed: Diversity in the Industry Workforce (No recs)

• Completed: Operator’s Response to Emergencies

– 2 recs related to improving incident response data and assisting operators in decisions about automated valves.

• Completed: 7- year reassessment interval

– 2 recommendations related to risk based inspection intervals

• Completed: Oil and Gas Transportation

– 1 recommendation related to gathering lines

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IG Audits & Recommendations

• Completed: Hazardous Liquid IMP

– 9 recommendations, 7 closed: Recs were related to various issues including IM measures, better identification/validation of operator risk assessments, improved data analysis

• Completed: State Program Oversight

– 7 recommendations, 7 closed: Recs were related to procedures and guidelines, training, and the formula

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State Regulated Entities• Growing Recognition of the State Role in Pipeline Safety

– DOT/IG Top 10 Management Challenge

– NTSB Integrity Management Audit

– Data: 75% of all human consequences at State level

– States Lead on Issue of Damage Prevention

– Drive for More Prescriptive Rulemaking

• Methane Emission Reduction – From All Sources– Keeping it in the Pipe

• Pressure on Infrastructure Modernization– High risk pipe replacement:

http://opsweb.phmsa.dot.gov/pipeline_replacement/

– Innovative rate recovery: https://www.aga.org/sites/default/files/agastatereplacementactivity.docx

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Rulemaking • Miscellaneous Rulemaking (Final Rule)

• Standards Update (Final Rule)

• Excavation Damage Prevention (Final Rule)

• Plastic Pipe (NPRM)

• Operator Qualification, Cost Recovery and Other Pipeline Safety Proposed Changes (NPRM)

• EFV Expansion beyond Single Family Residences (NPRM)

• Safety of Gas Transmission and Gathering Lines (NPRM)

• Safety of On-Shore Hazardous Liquid Pipelines (NPRM)

• Rupture Detection and Valve Rule (NPRM)

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Current Rulemakings in Process

Safety of On-Shore Hazardous Liquid Pipelines

(NPRM stage – not yet issued) NPRM moved past DOT 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• Piggability of lines • Reporting requirements for Gathering lines• Gravity Line exception

Current Rulemakings in Process

Safety of Gas Transmission and Gathering Lines

(NPRM stage – not yet issued) NPRM moved past DOT

ANPRM Published 8/25/2011

Major Topics under consideration:

• Expansion of IM requirements beyond HCA’s

• Repair criteria for both HCA and non-HCA areas

• Assessment methods

• Corrosion control

• Gas gathering

• Assessment methods for GT Lines (NACE petition)

• IVP – Grandfathered pipe/pipe records/legacy pipe/pipe tested below 1.1 MAOP - 29 -

Current Rulemakings in Process

Excavation Damage Prevention

(Final Rule stage)

Final Rule published 7/23/2015 Effective date 1/1/2016 Adv. Committee approval vote December 2012 NPRM published 4/2/2012 Major Topic

• Enforce damage protection laws in States that have inadequate enforcement to protect safety. Complies with PIPE’s Act 60114(f).

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Current Rulemakings in Process

Miscellaneous Rulemaking

(Final Rule stage) Final Rule published 3/11/2015

Effective date 10/1/2015 Immediate compliance authorizedReceived three petitions for reconsideration

NPRM published 11/29/2011 Major Topics

• performance of post-construction inspections• leak surveys of Type B onshore gas gathering lines• requirements for qualifying plastic pipe joiners• regulation of ethanol• transportation of pipe

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Current Rulemakings in Process

EFV Expansion beyond Single Family Residences

(NPRM stage)

NPRM published 7/15/2015; Comment period ended 9/14/2015 ANPRM published 11/25/2011

Major Topics

• Rule will propose to require EFVs for:

– branched service lines serving more than one single family residence

– multi-family residential dwellings

– commercial buildings

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Current Rulemakings in Process

Operator Qualification, Cost Recovery and Other Pipeline Safety Proposed Changes

(NPRM stage) NPRM published 7/10/15; comment period ended 9/8/2015

This rule will address reauthorization issues related to:

• Operator Qualification for new construction

• Incident Reporting

• Cost Recovery

• Assessment methods for HL lines (NACE petition)

• Renewal process for special permits

• API 1104 and in-service welding

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Current Rulemakings in ProcessPlastic Pipe

(NPRM stage) NPRM published May 21, 2015; Comment period ended 7/31/2015

Address the following plastic pipe topics:

• Authorized use of PA12

• AGA petition to raise D.F. from 0.32 to 0.40 for PE pipe

• Enhanced Tracking and traceability

• Miscellaneous revisions for PE and PA11 pipelines

• Additional provisions for fittings used on plastic pipe

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Current Rulemakings in Process

Rupture Detection and Valve Rule

(NPRM stage – not yet issued)

This rule would establish and define rupture detection and response time metrics including the integration of Automatic Shutoff Valves (ASV) and Remote Control Valve (RCV) placement as necessary, with the objective of improving overall incident response

Current Rulemakings in Process

Rupture Detection and Valve Rule

(NPRM stage – not yet issued)

This rule responds to:

Requirements of the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 (The Act):

• Section 4: ASV/RCV or equivalent technology be installed on newly constructed or entirely replaced natural gas and hazardous liquid transmission pipelines 2 years after the act was issued

• Section 8: Require operators of hazardous liquid pipeline facilities to use leak detection systems and establish standards for their use.

• The Act also mandated two studies of leak detection and response, one by the GAO, and one by PHMSA.

• Two NTSB Recommendations related to valves and leak detection

Current Rulemakings in Process

Future Actions

State Decertification rulemaking

Standards Update rulemaking

Integrity Verification Program

• Drivers: Incidents (San Bruno and Marshall, MI) directly led to NTSB recommendations and Congressional mandates.

• Basic premise – companies don’t know their pipe as well as they should and assumptions are not conservative enough.

• IVP is designed to:

– Verify records and MAOP;

– Confirm material strength of untested lines;

– Help with deletion of the grandfather clause;

– Verify seam stability via 1.25 x MAOP; and

– Move towards making all lines piggable.

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Pipeline Infrastructure (% by Decade in USA)

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< 1940 1940s 1950s 1960s 1970s 1980s 1990s 2000s0%

5%

10%

15%

20%

25%

Gas Transmission Pipeline Vintage59% installed prior to 1970

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Basic Principles of IVP Approach

• IVP is based on 4 principles1. Apply to higher risk locations

– High Consequence Areas (HCAs) and Moderate Consequence Areas (MCAs)

2. Screen segments for categories of concern (e.g., “Grandfathered” segments)

3. Assure adequate material and documentation

4. Perform assessments to establish MAOP

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Why Implement a Safety Management System (API

1173)

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(It’s not about Compliance)

It’s About Getting to Zero and Improving Performance

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We believe SMS concepts will improve safety through organizational and cultural

change.

We are implementing SMS concepts within PHMSA.

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We embrace SMS and all of the other safety

improvements not because they are easy or save

money.

We do it because it is the right thing to do.

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Thank you!

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Bonus Slides

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Description of Regulated Industry

Pipeline Facilities by System Type – data as-of 2/2/2015

System Type Miles % Miles # Operators

Hazardous Liquid 192,3886,970 Tanks

7% 442

Gas Transmission 302,811 11% 993

Gas Gathering 17,437 1% 357

Gas Distribution (Mains & Services ) 2,149,291 81% 1,371

Total 2,661,927 100% Some Operators have multiple System Types

Liquefied Natural Gas 133 Plants 203 Tanks 83

Safety Trends and Leading Causes

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All Reported – everything operators report

Serious – fatality or injury requiring in-patient hospitalization, but Fire First excluded. Fire First are gas distribution incidents with a cause of “Other Outside Force Damage” and sub-cause of “Nearby Industrial, Man-made, or Other Fire/Explosion”

Significant include any of the following, but Fire First excluded: 1. Fatality or injury requiring in-patient hospitalization 2. $50,000 or more in total costs, measured in 1984 dollars 3. Highly volatile liquid (HVL) releases of 5 barrels or more 4. Non-HVL liquid releases of 50 barrels or more 5. Liquid releases resulting in an unintentional fire or explosion

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Serious Incidents

All System Type rises slightly in 2014

29 each in CY 201490% Gas Distribution

7% Gas Transmission

3% LNGdata as-of 2/2/2015

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Significant Incidents

All System Types rises slightly in 2014

310 in CY 2014 21% Gas Dist 3% Gas Gather

25% Gas Trans 50% Haz Liq

1% LNGdata as-of 5/18/2015

Gas Distribution Significant Incidents

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CY 2014 Leading Causes:Excavation DamageOther Outside Force DamageOther

data as-of 2/2/2015

Gas Gathering Significant Incidents

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CY 2014 Leading Causes:CorrosionMaterial/Weld/Equipment FailureOther

data as-of 2/2/2015

Interstate Gas TransmissionSignificant Incidents

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Top 3 Causes: Equipment, Corrosion, Pipe/Weld Failure

data as-of 2/27/2015

Intrastate Gas TransmissionSignificant Incidents

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Top 3 Causes: Equipment, Corrosion, Excavation Damage

data as-of 2/27/2015

Hazardous Liquid and Carbon Dioxide Significant Incidents

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Top 2 Causes: Equipment Failure and Corrosion

data as-of 2/27/2015