Incident Mitigation Management (IMM):

Considerations Prior to an Incident

Daron Moore - August 20, 2013

Rulemaking Activity

• Pipeline Safety Act

• Within 2 years of the PSA “the Secretary, if appropriate, shall require by

regulation the use of automatic or remote-controlled shut-off valves, or

equivalent technology, where economically, technically, and

operationally feasible on transmission pipeline facilities constructed or

entirely replaced after the [PSA date].”

• A study within one (1) year by the Comptroller General on “the ability of

operators to respond to a…gas release from a pipeline…in…a high

consequence area.”

• Advanced Notice of Proposed Rulemaking

• Asked many questions and was in the spirit of adding ASV/RCVs

• Section H, questions H.5 through H.7 (Docket No. PHMSA-2011-0023)

• Oak Ridge National Laboratory Study

• ASVs/RCVs are feasible and reduce consequences

2

3

IMM Overview

•Focus is on consequence analysis and reduction – very different

from the last ten (10) years focus on likelihood

•What IMM can be:

• Scalable

• Ideally suited to continual improvement through Lessons Learned

and industry best practices

• A process, not a project – take off the likelihood engineering hat

•IMM INGAA Commitments:

• Sixty (60) minute response to incidents on pipelines greater than

12 inch nominal diameter, including crossovers, receipts,

deliveries

• Design considerations

4

IMM Element Review

•There are currently eight (8) Elements (commitments, best

practices, current requirements)

1. One (1) hour pipe section isolation in populated areas (PSA,

ANPRM)

2. Design philosophy for valves

3. Leak detection capability (PSA)

4. Risk model review/modification (ANPRM)

5. Lessons learned

6. Sample/visit impaired mobility sites

7. Emergency response plan

8. Gas Control responsibilities/authority

5

Element Review

1. One (1) Hour Pipe Section Isolation in Populated Areas

• Initial study of valves and HCAs/Class 3/4

• Analysis if section can be isolated in one (1) hour

• If not, prioritize methods to attain one (1) hour isolation

• NTSB pressure due to San Bruno, California, incident

• Rulemaking is probable, no timetable

6

Element Review

2. Design Philosophy for Valves

• Determine and document a design philosophy for valves and

operators

• New and existing, normal disposition, ancillary valves

• Initially on new valves/facilities

• Initially for lines larger than nominal 12 inches

• May be in any manual

• Example: Could be a site-by-site analysis with consistent logic

• GAO report states this is easiest route to quick isolation

7

Element Review

3. Leak Detection Capability

• All leak detection methodologies, including in-field and Control

Room-based, should be reviewed for capability to detect

significant leaks and ruptures

• Consideration should be given to field personnel training

• Operator qualification could be affected

• Understanding of research and best practices is necessary

• Lots of political pressure – Congressional hearing on topic in May

2013

• Rulemaking is likely

8

Element Review

4. Risk Model Review/Modification

• Consequence analysis inclusion and increased robustness in risk

model may be needed

• Currently risk models heavy on likelihood

• Considerations:

• Structures/areas outside PIR be included?

• Impaired mobility facilities be prioritized?

• Physical surroundings, such as wood buildings or grasses or

drought, be ranked higher?

• Risk model altered with these and other considerations

9

Element Review

5. Lessons Learned

• Recommend systematic review and implementation of identified

improvements

• Studies, research, programs, specific efforts, incident analysis

• Rigorous, scheduled, and systematic is goal

• Should extend across pipeline safety spectrum

10

Element Review

6. Sample/Visit Impaired Mobility Sites

• Impaired mobility sites probably have little pipeline knowledge

• Systematic program to sample or visit up to ten (10) sites each

year to assess knowledge and offer information should be

implemented; can expand if successful (note – executive

pressure to move this to 20% of sites per year)

• Is ripe for continuous improvement, best practices, Lessons

Learned

11

Element Review

7. Emergency Response Plan

• Existing plans focus on regulatory requirements and typically

little else

• Considerations examples:

• Ingress/egress to neighborhoods, schools, etc

• Particular land uses such as parks or outside gathering areas

• Company in-field emergency response, such as on-call

personnel and distance from sites

• Education of first responders and their capabilities (iterative)

12

Element Review

8. Gas Control Responsibilities/Authority

• All Gas Control personnel should be aware of their roles and

responsibilities, which should be delineated in the CRM Manual

• All personnel should know expectations and limitations and have

full management backing

• Explicit expectations such as call-outs and 911 should be

understood

• Training should be expected

• Very customizable

• Is largely in CRM rule now, but failed at Marshall

• Continued political pressure – Congressional hearing in May 2013

13

Further Considerations

• Meet the intent of the ANPRM, NTSB, and Congress

• Complete analyses on costs/benefits for future rulemaking

responses

• Begin work toward meeting commitments within operating

companies

• Begin analysis of Best Practices and determine “home” for

publication and use of Best Practices

So what’s our priority?

• A lot of work went into the IMM process

• IMM’s commitment scope was lessened following the

IVP/MAOP flowchart release

• Many good ideas were cast into the Best Practices bucket

• Will those ideas save lives and reduce property damage?

• We should be trying to do what’s right:

• “Transportation of Natural and Other Gas by Pipeline: Minimum

Federal Safety Standards”

• Let’s not lose sight of the end goal as citizens

• Do unto others….

• Do no evil….

14

Questions and Comments

15