PHMSA Pipeline Safety Program Update

Transcription

1 PHMSA Pipeline Safety Program Update NACE Central Area Conference August 28, 2013 William Lowry, PE Community Assistance and Technical Services Mgr, Southwest Region USDOT/PHMSA 1

2 Today s Agenda Underlying Principles Data Enforcement Statistics Incident/Accident Response Look Ahead 2

3 What PHMSA Regulates Pipeline Miles by System Types as-of 4/11/2013 System Type Miles % Total # Operators Hazardous Liquid 182,613 7% 381 Gas Transmission 304,873 12% 923 Gas Gathering 19,872 1% 320 Gas Distribution 2,114,990 80% 1318 Mains -- 1,233,249 46% Services ,741 34% Total 2,622,348 Liquefied Natural Gas 129 Plants 200 Tanks 80 Operators HL Breakout Tanks 6448 Tanks 93 Operators 3

4 Gas Transmission : 304,558 miles Hazardous Liquids : 182,524 miles - 4-4

5 Underlying Principles It is the responsibility of pipeline operators to understand and manage the risks associated with their pipelines PHMSA s primary role is to establish minimum safety standards (defined in the regulations by required risk control practices) and to verify that the operators perform to these standards PHMSA also strives to impact operator performance beyond mere compliance with the regulations 5

6 Categories of Incident Reports 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 6

7 Serious Incidents Downward Trend Continues in 2012 Serious Incident fatality or injury requiring in-patient hospitalization 7

8 Significant Incidents Downward Turn in 2012 Significant incidents include any of the following: 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; and 5. Liquid releases resulting in an unintentional fire or explosion 8

9 2012 Hazardous Liquid Incidents Top Causes for All Reported & Significant Categories Material/ Weld/Equip Failure Corrosion Incorrect Operation 9 9

10 2012 Gas Transmission Incidents Top Causes for All Reported & Significant categories Material/Weld/ Equip Failure Corrosion 10 10

11 2012 Gas Distribution Incidents Top Causes for all incident categories: Other Outside Force Damage Excavation Damage Other 11 11

12 Significant Accident Breakdown Total by Type (Fatalities) Total for All Types 1 Hazardous Liquid Gas Transmission Gas Distribution (19) 121 (1) 79 (10) 54 (8) (12) 139 (1) 83 (0) 60(11) (10) 129 (3) 62 (0) 49 (7) 3 Year Average ( ) 262 (14) 130 (2) 75 (3) 54 (9) 5 Year Average ( ) 10 Year Average ( ) 268 (12) 124 (2) 74 (2) 62 (8) 281 (15) 122 (2) 77 (2) 73 (11) 1 includes gas gathering (zero fatality) - excludes fire first incidents; data as of 03/29/

13 Index (1988 = 1) Context Measures Pipeline Safety with Context Measures ( ) Nat. Gas Consumption Petroleum Product Consumption Pipeline Mileage U.S. population Calendar Year Spills with environmental consequences Incidents w/death or major injury Data Sources: Energy Information Administration, Census Bureau, PHMSA Annual Report Data, PHMSA Incident Data - as of April 1,

14 Enforcement Statistics 14

15 Average Days for Enforcement Cases That Include Proposed Civil Penalties or Proposed Compliance Orders (from Notice Letter to Case Closure)

16 PHMSA Enforcement Actions Year Enforcement Orders Issued

17 Civil Penalties Proposed $10 $9 $8 Civil Penalties in Millions $7 $6 $5 $4 $3 $2 $1 $

18 Most Cited Corrosion Regulations Both Gas and Hazardous Liquid Pipelines (2002 Present) Parts 192 and 195 Citation Total Number of Individual Items Notices of Probable Violation Notices of Amendment Warning Items Adequacy of Cathodic Protection (c) Maintain Records (e) External Corrosion Corrective Action (d) External Corrosion Remedial Action (a) External Corrosion Annual Testing (a) Cathodic Protection (c) Corrosion Control Test Records (c) External Corrosion Rectifiers (a)(1) Required Testing for Cathodic Protection (a) Internal Corrosion

19 Corrosion Related Major Enforcement Actions in 2012 $1,000,000 penalty assessed for an individual violation linked an accident involving a release of crude oil. The violation resulted from operators failure to properly consider corrosion and cracking assessments it had performed, and its failure to integrate the information from these assessments to properly ensure pipeline integrity 19

20 Corrosion Related Major Enforcement Actions in 2012 $92,300 penalty assessed against operator for four corrosion related violations that were discovered during a multi-state inspection: atmospheric corrosion monitoring, rectifier inspections, pipe to soil potentials, and timely remediation of identified deficiencies $40,000 penalty assessed against operator for a violation for its failure to monitor separately protected short sections; specifically steel drips ( for low pressure system water collection) 20

21 Incident/Accident Response 21

22 Incident/Accident Response National Response Center reporting Information Loop (timely, accurate information critical) Reports and briefings for government leadership Congressional, media Action Loop Incident response and investigation Enforcement action Interagency coordination: NTSB, EPA, USCG, IG, DOJ 22

23 Pipeline Accidents Marshall, Michigan (Federally Regulated) Major Crude Oil Spill Dramatically Impacted Several Communities in Michigan San Bruno, California (State Regulated) Major tragedy Unimaginable Proportions Allentown, Pennsylvania (State Regulated) Cast Iron, low pressure Excavation Damage Fatalities (State Regulated) Texas, North Dakota, Georgia to name a few Yellowstone River (Federally Regulated) Significant Oil Spill near Billings, MT Bison Pipeline (Federally Regulated) Newly constructed natural gas pipeline 23

24 Recent High Profile Incidents Chevron; Salt Lake City, Utah (Interstate) Crude oil and refined products Multiple accidents: 6/10, 12/10, 3/13 Sissonville, West Virginia (Interstate) Impact to major interstate highway; questions on HCA determination Led to Congressional oversight hearing NTSB investigation Mayflower, Arkansas (Interstate) Canadian heavy crude Investigation underway 24

25 Chevron; Salt Lake City, Utah 8-inch diesel fuel Corrosion along pipe seam with overall general corrosion ERW pipe seam had low toughness 25

26 Sissonville, WV Pipeline Incident Dec 11, 2012: Rupture of a 20, X-60 gas transmission pipeline (1967 vintage)

27 Sissonville Pipeline Incident No injuries or fatalities (thankfully) 3 homes destroyed, others damaged Interstate 77 damaged and temporarily closed 3 pipelines in vicinity 20, 26 and 30 PHMSA issued Corrective Action Order NTSB investigated cause 27

28 Mayflower, AR Pipeline Accident March 29, 2012: 20 crude oil pipeline ruptured in Mayflower, Arkansas ~ 5,000 bbls of crude spilled Pipeline carrying Canadian crude oil (Wabusca) from Patoka, Illinois to Nederland, Texas Pipeline installed /

29 Mayflower Pipeline Incident Pipeline flow reversal project was completed in 2006 Line from Patoka, IL to Nederland, TX has been shut in pending the results of the investigation Considerable media attention 29

30 Incidents like these and others in past years helped to form the focus of PHMSA s 2013 Agenda 30

31 PSA of Mandates 42 Mandates in Pipeline Safety, Regulatory Certainty, and Job Creation Act (PSA) of 2011 Includes 9 required studies (Leak Detection, Cover over Buried Pipelines, R&D, Diluted Bitumen, Cast Iron, Damage Prevention, Expansion of IMP, Gathering Lines, ) Other topics include: MAOP Records Verification, Tests to Confirm Material Strength of Previously Untested GT in HCAs 1 hour Notification of Incidents, Automatic/Remote Shut-off Valves 31

32 NTSB Recommendations 27 NTSB recommendations: ERW Pipe Seam Study/Implementation Emergency Response Information Sharing Operator Sharing Plan Information 911 Notification (Operator and 911 info exchange) ASVs/RCVs Removal of Grandfather Clause for Gas Transmission ILI Piggable Gas Transmission Pipelines Pressure testing of Gas Transmission (w/ spike test) 32

33 Nominal Pipe Size data as of from Part H 33

34 Specified Minimum Yield Strength data as of from Part K 34 34

35 Decade Installed data as of from Part J 35

36 PSA of 2011, 23 MAOP Mandate Verify records for Class Locations 3 & 4 and HCAs Reconfirm MAOP for pipe with incomplete records 5,401 miles with Incomplete Records in Class 3 & 4 and HCAs Strength test all untested pipe in HCAs operating at > 30% SMYS 3,220 HCA miles with Pressure Test < 1.1 MAOP Gas Transmission 2012 Annual Report data as-of

37 37 U.S. Department of Transportation Specified Minimum Yield Strength data as of from Part K

38 NTSB Recommendation P Eliminate Grandfather clause and require hydrotest with a spike test for all pre-1970 pipe 55,120 miles Grandfathered miles reported (c) (22,717) and (a)(3) (32,403) 93,817 miles with Pressure Test < 1.1 times MAOP 20,272 miles with Stress Level > 72% SMYS or Unknown. Except for Special Permit/Alt MAOP pipelines, PHMSA expects this mileage is Grandfathered. PHMSA expects that Grandfather miles and Pressure Test < 1.1 MAOP are actually close to same # Somewhere between 55 and 94 thousand miles Gas Transmission 2012 Annual Report data as-of

39 Pressure Test Range Pressure Test Range Total Miles % Total PT 1.1 MAOP or no PT 93,817 31% 1.25 MAOP > PT 1.1 MAOP 19,131 6% PT 1.25 MAOP 187,628 62% Gas Transmission 2012 Annual Report data, Part R, as-of

40 Pressure Test < 1.1 MAOP data as of from Part R 40

41 Operating Stress Levels over 72% SMYS & Unknown % SMYS Interstate Intrastate Total > 72 to 80 11, ,895 > ,299 Unknown 973 6,074 7,038 Miles operating between 72 and 80% SMYS are either Grandfathered, Special Permit, or Alternative MAOP under 619(d) Miles with Unknown SMYS are Grandfathered Gas Transmission 2012 Annual Report data, Part K, as-of

42 Data Summary by HCA and Class Location data as of from Part Q Location Total GT Miles % in HCA GT HCA Miles Non-HCA Miles Class 1 237, , ,096 Class 2 30, ,412 28,798 Class 3 32, ,854 16,759 Class Total 301,540 19, ,862 42

43 NTSB Recommendation P Manufacturing & Construction Defects Considered Stable Only for Pipe with Pressure Test 1.25 times MAOP 3,220 GT HCA Miles with Pressure Test < 1.25 MAOP 1,483 miles ILI Able 1,737 miles ILI Not Able Gas Transmission 2012 Annual Report data as-of

44 Pressure Test < 1.25 MAOP data as of from Part R

45 NTSB Recommendation P Configure all lines to accommodate smart pigs, with priority given to older lines ILI Piggable 60% of Total 118,947 miles ILI Not Able 40% of Total 69,579 miles Diameter 8-inch 23% of Total 44,600 miles Diameter 6-inch 15% of Total???? miles ILI Not Able due to system configuration Gas Transmission 2012 Annual Report data as-of

46 ILI Able vs Not Able Part R Total Miles ILI Able ILI Not Able Class 1 - HCA 1,658 1, non-hca 234, ,035 88,816 Class 2 - HCA 1,409 1, non-hca 28,978 15,073 13,905 Class 3- HCA 15,850 10,469 5,381 - non-hca 16,751 6,924 9,827 Class 4 - HCA non-hca TOTAL 300, , ,947 Gas Transmission 2012 Annual Report data as-of

47 Integrity Verification Process 47

48 Integrity Verification Process GOAL: Establish a comprehensive program to effectively address Congressional Mandates and NTSB Recommendations. 48

49 Overview Held IVP Workshop on August 7 Link to Workshop and Presentations g=91 Speakers NTSB Vice Chairman Chris Hart PHMSA Pipeline Safety Trust NAPSR Operators Gas and Liquids Intrastate (2) PG&E and Northwest Natural Gas Interstate INGAA Liquids API/AOPL Explorer Pipeline

50 Integrity Verification Process (IVP) Chart Based upon Congressional Mandates and NTSB Recommendations 50

51 Basic Principles of IVP Approach IVP is based on 4 principles 1. 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 51

52 Principle #1 Apply to Higher Risk Locations High Consequence Areas (HCAs) Moderate Consequence Area (MCA): Non-HCA pipe in Class 2, 3, and 4 locations Non-HCA pipe Class 1 locations that are populated in PIR (proposed 1 house or occupied site) to align with INGAA commitment House count and occupied site definition same as HCA, except for 1 house or 1 person at a site (instead of 20) PHMSA Estimates 91,000 miles HCA/MCA (out of 300,000 miles) 52

53 HCAs and Est. MCA Mileage Scope of Proposed IVP Process Estimated to Apply to: Total Estimated HCA + MCA Mileage = 91,000 miles Total HCA Non-HCA MCA Class 1 237,756 1, ,096 (est.) 25,394 Class 2 30,210 1,412 28,798 28,798 Class 3 32,613 15,854 16,759 16,759 Class Total 301,540 19, ,862 (est.) 71,160 PHMSA estimates approximately 33,000 miles of GT pipe (approximately 11% of total GT mileage) would meet screening criteria & require IVP assessment to establish MAOP IVP Process Steps 1 12 based upon 2012 Annual Report Data. 53

54 Principle #2 Screen for Categories of Concern Apply process to pipeline segments with: Grandfathered Pipe Based upon 5-year highest actual operating pressure of segment prior to July 1, 1970 Operating pressures over 72% SMYS pre-code Grandfathered Pipe Lack of Records to Substantiate MAOP Lack of Adequate Pressure Test History of Failures Attributable to M&C Defects 54

55 Principle #3 Know & Document Pipe Material If Missing or Inadequate Validated Traceable Material Documentation, then Establish Material Properties by an approved process: Cut out and Test Pipe Samples (Code approved process) In Situ Non-Destructive Testing (if validated and Code approved) Field verification of code stamp for components such as valves, flanges, and fabrications Other verifications 55

56 Principle #4 Assessments to Establish MAOP Allow Operator to Select Best Option to Establish MAOP Candidate IVP Options for Establishing MAOP Subpart J Test with Spike Test Derate pressure Engineering Critical Assessment Replace Other options PHMSA should consider? 56

57 Draft - Process Steps 21 Step Process Grandfather Clause and MAOP Review Process Steps 1 4 Integrity Review Process Steps 5 8 Low Stress Review Process Steps 9 12 Material Documentation Review Process Steps Assessment and Analysis Review Process Steps Implementation Process Step 21 Deadlines for Implementation 57

58 Specific Guidelines & Criteria IVP Chart is high level concept Details and specifications under development Will use knowledge from workshop and comments on web site to develop details Details to Develop: Spike pressure test specs (pressure, hold time, etc.) De-rate criteria (amount of MAOP reduction) ILI program requirements and specifications Material verification specs (# of cutouts, etc.) 58

59 Target Completion Timeframes Implementation Timeframe Multi-Year Effort Graduated timeframes with priority to: Legacy (LF-ERW /Seam Issue) pipe segments HCAs High Stress segments Proposed deadlines under development 59

60 A Look Ahead - Inspections Inspections: Data driven, risk informed inspection process Review integrity management implementation Review records confirming MAOP/MOP Construction quality Oil spill response program drill participation 60

61 A Look Ahead - Programs Setting Our Own Course IMP 1.0 good progress, but plenty of work undone Records and data gaps, incomplete knowledge of environment around pipe, interacting threats, etc. IMP 2.0 warm up to multi-day workshops Fall 2013 Leak detection, valves, metrics, missing Safety Management Systems elements: employee involvement; near miss/voluntary reporting; audits; contractor alignment, flow down, and oversight, etc. Stronger State Programs including enforcement Advocating Innovative Rate Recovery in States Continued focus on construction issues 61

62 A Look Ahead - Challenges Unrealistic Expectations and Inadequate Resources The Congress Gives Work, But Not Much Help Potential Backlash Against Performance Based Regulation Workforce Development Finding/Creating a Diverse and Qualified Workforce in a Competitive Labor Market Slow pace of Technology Innovation Needed for More Efficient/Effective Detection, Characterization, and Mitigation Inability to Be All Things to All Parties While Maintaining a Steady and Progressive Course Forward 62

63 Resources PHMSA web sites: Includes damage prevention initiatives, info on grants, incident information and more resource links based on audience Includes PHMSA-wide, HazMat and Pipeline information, forms, regulatory actions, etc. Sites are linked 63

64 Thank you! 64

65 NACE Central Area Conference August 28, 2013 William Lowry, PE Community Assistance and Technical Services (CATS) Office of Pipeline Safety USDOT/PHMSA Southwest Region