National Academy of Science

Transcription

1 National Academy of Science Transportation Research Board Study of Performance-Based vs Prescriptive Safety Regulation State Pipeline Safety Representatives Perspectives on Inspection and Enforcement Steve Allen Director of Pipeline Safety, IURC Chairman, Natl. Assoc. of Pipeline Safety Representatives

2 National Association of Pipeline Safety Representatives (NAPSR) A Not-For-Profit corporation comprised of members from State Pipeline Safety Programs from the 48 contiguous states plus the District of Columbia and Puerto Rico. Provides for a collective voice of its members and works in partnership with PHMSA toward improvements in pipeline safety. NAPSR members through certification agreements with PHMSA have been granted enforcement authority over all intrastate distribution and transmission pipelines in the country.

3 National Association of Pipeline Safety Representatives (NAPSR) NAPSR States are responsible for enforcement oversight of: 12,000 miles of jurisdictional gas gathering lines (69% of U.S. total) 106,000 miles of gas transmission pipelines (35% of U.S. total) 2,200,000 miles of gas distribution mains and service pipelines (>99% of U.S. total), and 122 liquefied natural gas (LNG) plants (82% of U.S. total) and 166 LNG tanks (73% of U.S. total)

4 State of Indiana Overview 94 Total Operators in Indiana (only three with over 30K customers) 38 Master Meter Operators 15 Intrastate Transmission Operators 189 Individual Inspection Units One Intrastate Hazardous Liquid Operator Approximately 2 Million Services (93% Million with Big Three) Over 40,000 Miles of Main Over 1,900 Miles of Transmission Lines Pipeline Safety Program Staff of 12

5 Areas of Pipeline Safety Regulation Minimum Pipeline Safety Standards today address virtually every aspect of NG and HL pipelines including: Materials, Design and Construction Training & Operator Qualification Operations & Maintenance (Procedures and Records) Control Room Management Emergency Response Reporting (Incident, Safety Related Conditions, Annual Reports, etc.) Integrity Management (TIMP, DIMP and LIMP) Damage Prevention (including One-Call Enforcement) Public Awareness Drug and Alcohol

6 NAPSR Perspectives on Performance versus Performance-Based Regulations More Subjective (grey) More difficult to inspect (Inspectors do not have the requisite knowledge or expertise to adequately evaluate) More difficult to enforce (harder to legally prove non-compliance) Abstract/conceptual for operators as well as inspectors More Objective (black and white) Easier to inspect (check the box) very straightforward Easier to enforce non-compliance (burden of proof less difficult) Easier to understand by inspectors and most operators

7 NAPSR Perspectives on Performance versus Performance-Based Regulations Larger operators tend to desire this approach - more flexibility and latitude One-size does not fit all (regulation requires consideration of circumstances, environment and size) Driven by circumstances and risk - dynamic Favors larger, more sophisticated operators Smaller operators desire direction ( Just tell us what you want us to do! ) One-size STILL doesn t fit-all (form over substance is often found) Not necessarily driven by circumstances or risk The Minimum - static

8 NAPSR Perspectives on Performance versus Observations: State Pipeline Safety Inspectors are not adequately trained to effectively audit performance-based or management-system based regulations. State Pipeline Safety Programs have historically been driven by check-the-box compliance inspections Many operators (large and small) still operate at the minimum level of compliance which is contrary to the intent of performance-based regulations Many operators (particularly smaller operators) do not have sufficient resources to effectively manage risk under performance-based regulations

9 NAPSR Perspectives on Performance versus Observations: Many small operators simply struggle and require more attention by state inspectors to educate and train Employee turnover is a very large problem with master meter operators who generally are in a constant state of re-training to ensure qualified employees are in place Regulatory compliance with this group of operators is general very difficult

10 My Opinion Both types of regulation are required Operators must take a holistic approach to managing risk Intentional and systematic actions by operators is required to address risk Safety culture is of paramount importance Diligence and continuous improvement efforts by operators is essential Open, honest and ongoing communications at all levels is critical Regulators must recognize difficulties in transforming industry culture and provide appropriate levels of assistance and enforcement

11 Questions?