PIPELINE SAFETY Darin Burk, Manager Pipeline Safety January 28, 2014
Congressional Delegation of Authority Pipeline Safety Act of 1968 Congress Delegated Inspection and Enforcement Authority to the Secretary of Transportation Secretary can delegate authority DOT Research & Special Programs Administration DOT Pipeline & Hazardous Materials Safety Administration ( PHMSA )
PHMSA May retain inspection authority or delegate PHMSA trains all inspection staff Delegation via Certification or Agent Agreement Certification delegates Inspection & Enforcement Authority Agent Agreement Agent must perform inspections as PHMSA instructs PHMSA retains Enforcement Authority
Categories of Pipelines Interstate Gas Transmission Intrastate Gas Transmission Intrastate Gas Distribution Interstate Hazardous Liquid Intrastate Hazardous Liquid Gas Gathering Hazardous Liquid Gathering Offshore Pipeline
Illinois Commerce Commission Certification - Intrastate Gas Transmission and Distribution Has authority to enact regulations more stringent than Federal Regulations Has full inspection and enforcement authority Must conduct program according to PHMSA guidelines Receives funding from PHMSA to implement program
Code of Federal Regulations ( CFR ) Parts 190-193 CFR Part 190 Prescribes procedures used to carry out duties regarding pipeline safety CFR Part 191 Pipeline operator reporting requirements of Incidents, Safety Related Conditions and Annual Pipeline Data CFR Part 192- Minimum safety requirements for gas pipelines and transportation CFR Part 193 Requirements for Liquefied Natural Gas ( LNG )
CFR Part 194-199 CFR Part 194 Contains requirements for Oil Spill Response Plans CFR Part 195 Safety standards and reporting requirements for hazardous liquid and carbon dioxide CFR Part 198 Regulations governing grant-in-aid for State pipeline safety compliance programs CFR Part 199 Requirements for Anti-drug and Alcohol Programs
CFR Part 191- Definitions and Reporting 191.3 Definitions 191.5 Immediate Notice for Certain Incidents 191.7 Report Submission Requirements 191.9 Distribution System: Incident Reports 191.11 Distribution System: Annual Reports 191.12 Mechanical Fitting Failure Reports 191.15 Transmission, Gathering & LNG Incident Reports 191.17 Transmission, Gathering & LNG Annual Reports
CFR Part 192 Subpart A: General Definitions Standards Incorporated by Reference Defines Requirements For Pipelines Rules for Regulatory Construction Customer Notification Requirements
CFR Part 192 - Subpart B: Materials General Requirements for Materials Steel Pipe Qualification Requirements Plastic Pipe Qualification Requirements Requirements for Making of Materials Requirements for Transportation of Materials
CFR Part 192 Subpart C: Pipe Design General Requirements Design Formula for Steel Pipe Design Factor for Steel Pipe Design of Plastic Pipe Design Limits for Plastic Pipe Design of Copper Pipe
CFR Part 192 Subpart D: Design of Pipeline Components Qualifying Metallic Components Valves, Flanges, Fittings, Fabricated Components Welding Fabrication and Branch Connections Compressor Station Design and Construction Design of Vaults Pressure Limiting and Overpressure Equipment Control and Sample Piping
CFR Part 192 Subpart E: Welding of Steel Welding Procedures Qualification of Welders Limitations on Welders Inspection of Welds Non-destructive Testing Repair and Removal of Defects
CFR Part 192 Subpart F: Joining of Materials - Other Joining of: Cast Iron Pipe Ductile Iron Pipe Copper Pipe Plastic Pipe Qualification Joining Procedures Qualification of Persons to make joints Inspection of Joints
CFR Part 192 Subpart G: General Construction Requirements Transmission Lines and Mains Specification Compliance Inspection of Materials Repair of Pipe Installation of Pipe Cover Underground Clearance
CFR Part 192 Subpart H: Customer Meter Sets Customer Meter & Regulator: Location & Protection Service Line: Installation, Valves, & Connections Excess Flow Valve Requirements Service Line Installation Requirements for: Steel Plastic Copper
CFR Part 192 Subpart I: Corrosion Control External Corrosion Control Protective Coatings Cathodic Protection: Installation Monitoring Testing Remedial Measures Isolation
CFR Part 192 Subpart J: Test Requirements Leak Test Requirements Strength Test Requirements Testing Plastic Pipe Recordkeeping
CFR Part 192 Subpart K: Uprating of Pipelines Uprating Written Procedures Limitations Leak Testing Records
CFR Part 192 Subpart L: Operations Maintenance and Emergency Response Procedures Damage Prevention Requirements Public Awareness of Pipeline Hazards Failure Investigation Odorization Control Room Management Continuing Surveillance
CFR Part 192 Subpart M: Maintenance Leak Detection & Leak Management Pipeline Patrolling Repair Requirements Pressure Regulation Equipment Inspection Valve Inspection Prevention of Accidental Ignition Compressor Station Inspection & Testing
CFR Part 192 - Subpart N Operator Qualification Covered Tasks Qualification Procedures Span of Control Recordkeeping
CFR Part 192 Subpart O: Transmission Integrity Management High Consequence Area Identification Potential Impact Radius External Corrosion Direct Assessment Internal Corrosion Direct Assessment Remedial Measures
CFR Part 192 Subpart P: Distribution System Integrity Management Knowledge of System Threat Identification Leak Management Measures to Reduce Threats Program Effectiveness Evaluation
Safety & Security Through SCADA Supervisory Control and Data Acquisition Systems Monitor Pressure in Pipeline Control Pressure in Pipeline Remote Valve Control Rupture Detection Flow Control
Optical Fiber Monitoring Fiber Optic material along pipeline Can detect seismic activity along pipeline Excavation Activity Tapping Sabotage Leakage
Local Authority Pro s and Con s Pro s Pride of ownership to ensure security and safety Regulator lives in community Local authorities are most familiar with potential threats to the pipeline Can result in more rapid response and enforcement Provides for flexible enforcement
Local Authority Pro s and Con s Political Pressure or Lack of Enforcement Complacency Too close to situation to recognize issues Favoritism May overlook indiscretions by acquaintances Contracts Corruption Direct or Indirect Bribery Kickbacks
Example of Local Authority Issues State Oversight of Pipeline Safety Budget constraints can limit resources and equipment Failure to enforce regulations Elected Official influence Reluctant to initiate self-imposed penalty Over Regulation or Inconsistent Regulations States have over 1000 additional Pipeline Safety related requirements Single event can cause excessive localized regulation
Local Authority Municipal Government Reluctant to set rates at appropriate levels Lack of knowledge regarding safety and security Outside financial influence Complacency
Penalties Regulation Compliance Failure Third Party Damages Intentional Damage to the Pipeline Theft
Summary Regulatory Requirements for all phases of pipeline must be Law of the Land Extensive, proven resource materials are available for: Design Construction Maintenance One Central Authority Consistent Rules and Regulations Consistent Training of Regulatory Staff Consistent Enforcement of Penalties
Summary - Continued Appropriate funding of inspection and enforcement activities Trained, Committed Inspection Staff Verification of Operator: Knowledge Skill Ability
Summary - Continued Technology should be used to enhance Safety and Security Remote Monitoring Remote Pressure and Flow Control Consistent Enforcement Must apply to all Stakeholder Authority must be used consistently Penalty levels should out weight benefits of non-compliance
Essential Elements of Safety and Security 1. Utilize proven regulations and best practices to develop comprehensive regulations 2. Establish central, neutral authority for oversight 3. Establish reliable funding mechanism for inspection 4. Hire and fairly compensate knowledgeable workforce 5. Implement technology to enhance security and safety monitoring
References Electronic Code of Federal Regulations http://www.ecfr.gov/cgi-bin/textidx?tpl=/ecfrbrowse/title49/49cfrv3_02.tpl Compendium of State Regulations http://www.napsr.org/siteassets/pages/comp2013/compen dium-napsr-second-edition-clean-gl-100313.pdf PHMSA web page http://phmsa.dot.gov/
References American Petroleum Institute Best Practices http://www.api.org/ American Society for Testing and Materials http://global.ihs.com/standards.cfm?publisher=astm&rid= Z56&MID=5280&gclid=CN7B3rGKl7wCFeYWMgoda3IALA American National Standards Institutue http://www.aga.org/membercenter/gotocommitteepages/gpt C/Pages/default.aspx
Questions?
Thank You! Darin Burk Illinois Commerce Commission Pipeline Safety Program Manager