API Pipeline Conference San Antonio, Texas

Transcription

1 Page 1 of 15 API Pipeline Conference San Antonio, Texas The Best Regulations Don t Happen By Accident April 8, 2014 Alan Mayberry -1-

2 Page 2 of 15 External Drivers Current PHMSA major rulemaking activity is being driven by recent incidents, external mandates and oversight Major accidents Congressional Mandates NTSB recommendations

3 Page 3 of 15 Recent Major Accidents San Bruno, CA Marshall, MI Yellowstone River Sissonville, WV

4 Page 4 of 15 Previous Missed Opportunities 1990 s Texas Eastern and Colonial 2000 s Olympic Pipeline In both cases: Congress responded with calls for more prescriptive regulations PHMSA responded with flexible performance-based regulations Industry responded with a mixed level of quality programs -4-

5 Page 5 of 15 New Opportunity: 2010 s Incidents: San Bruno, Marshall, Yellowstone, Sissonville Congress again calls for PHMSA to evaluate the need for more prescriptive regulations PHMSA is evaluating the right balance between more prescriptive regulations and stronger requirements for risk management programs How will industry respond this time? Another lost opportunity may mean far more prescriptive regulations in the future will be unavoidable -5-

6 Page 6 of 15 Breaking the Cycle Accident occurs Public, media, and Congressional reaction Mandates for expanded and more prescriptive regulation Focus remains on minimal compliance Performance does not appreciably change Accident occurs Repeat cycle -6-

7 Page 7 of 15 Moving Beyond Compliance Robust Risk Management Programs Performance Goals, Monitoring, and Response Safety Management Systems -7-

8 Page 8 of 15 Robust Risk Management Based on an accurate understanding of your system Investigative (searching for hidden vulnerabilities, not just structuring what you already think you know) Used to drive improvement, not to justify the status quo -8-

9 Page 9 of 15 Proposed Process for Performance Goals Setting and Follow-up Action Perform Annual Operator Performance Measurement and Goal Setting Define Performance Measures Based on Objectives Assemble Data to Evaluate Measures for Each Operator Define Operator Performance Goal for Each Performance Measure and Thresholds for Follow on Action Which Operators Exceed Threshold for Follow up Action? Implement Follow up Actions with Operators

10 Page 10 of 15 Safety Management Systems PHMSA is actively monitoring progress on API-1173 PHMSA is holding workshops and considering various options for promoting safety management systems Our actions will be based on the seriousness that industry demonstrates in developing and implementing robust safety management systems -10-

11 Page 11 of 15 Key Activities in 2014 Regulatory agenda (9 active rules) Mandates (42) Advisory Bulletins Recommendations: NTSB, OIG, GAO Safety Management Systems Inspection program Data analysis improvements -11-

12 Page 12 of 15 Rulemakings in Process Safety of On-Shore Hazardous Liquid Pipelines (NPRM stage) Excavation Damage Prevention (Final Rule stage) Miscellaneous Rulemaking (Final Rule stage) EFV Expansion beyond Single Family Residences (NPRM stage) Safety of Gas Transmission and Gathering Lines (NPRM stage) Operator Qualification, Cost Recovery and Other Pipeline Safety Proposed Changes (NPRM stage) Plastic Pipe (NPRM stage) Standards Update (Final Rule stage) Rupture Detection and Valve Rule (NPRM stage) -12-

13 Page 13 of 15 Current Rulemakings in Process Safety of On-Shore Hazardous Liquid Pipelines (NPRM stage) NPRM moved past PHMSA 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 Stress Corrosion Cracking (SCC) Piggability of lines Reporting requirements for Gathering lines Gravity Line exception -13-

14 Page 14 of 15 Current Rulemakings in Process Safety of Gas Transmission and Gathering Lines (NPRM stage) NPRM under development within PHMSA 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 Valve Spacing Corrosion control Gas gathering -14-

15 Page 15 of 15 Current Rulemakings in Process Integrity Verification Process Issues and alternatives under development Topics raised in Gas Transmission ANPRM Recommendations from NTSB Areas for consideration: Data from revised Gas Transmission Annual Report Grandfather clause Miles of GT pipe for which operators have incomplete records to verify their MAOP Piggability of Gas Transmission lines -15-