This week’s Pipeliners Podcast episode features host Russel Treat providing an update from the joint GPAC and LPAC meetings in Washington, D.C. in November.
Listen for an update on what was discussed during the meetings, where things stand with the Gas Gathering Rule and other rules moving through the PHMSA rulemaking process, how gas and liquid operators will be affected moving forward, next steps for Pipeline SMS adoption, and more valuable information from the meeting.
GPAC & LPAC Update: Show Notes, Links, and Insider Terms
- GPAC and LPAC held a joint committee meeting on November 14, 2019, in Washington, D.C.
- PHMSA (Pipeline and Hazardous Materials Safety Administration) ensures the safe transportation of energy and hazardous materials.
- Howard “Skip” Elliott is the fifth Administrator of PHMSA. Elliott joined PHMSA after retiring from CSX Transportation in Jacksonville, Florida, where he served as Vice President of Public Safety, Health, Environment, and Security.
- Gas Pipeline Advisory Committee (GPAC) reviews PHMSA’s proposed regulatory initiatives to assure the technical feasibility, reasonableness, cost-effectiveness, and practicability of each proposal. The committee also evaluates the cost-benefit analysis and risk assessment information of the proposals.
- Liquid Pipeline Advisory Committee (LPAC) reviews PHMSA’s proposed regulatory initiatives to assure the technical feasibility, reasonableness, cost-effectiveness, and practicability of each proposal. The committee also evaluates the cost-benefit analysis and risk assessment information of the proposals.
- R&D Forum is the research and development forum put on by PHSMA every two years.
- Skip Elliot is the administrator of PHSMA and presidential appointee in charge of PHSMA. He gave the opening remarks at the GPAC and LPAC joint committee meeting.
- The Pipeline Safety Trust (PST) is a public charity promoting pipeline safety through education and advocacy by increasing access to information, and by building partnerships with residents, safety advocates, government, and industry.
- The Gas Gathering Rule (Safety of Gas Transmission and Gathering Pipelines) was initiated in 2016 when PHMSA issued a notice seeking comments on changes to the pipeline safety regulations for gas transmission and gathering pipelines. The proposed rule has advanced through various stages to expected issuance in late 2019 or early 2020.
- Sentho White is the director of engineering and operations for research and development at PHMSA. She gave a presentation at the GPAC and LPAC joint committee meeting on the various projects and research and development efforts PHSMA is underwriting and collaborating on.
- Rapid Aerial Small Methane Leak Survey is a type of emerging technology using air vehicles and drones to perform surveys of pipeline areas to support the detection of methane leaks.
- PRCI (Pipeline Research Council International) is a community of the world’s leading pipeline companies, vendors, service providers, equipment manufacturers, and other organizations supporting the oil and gas industry.
- API (American Petroleum Institute) is the only national trade association representing all facets of the oil and natural gas industry, which supports 10.3 million U.S. jobs and nearly 8 percent of the U.S. economy. API’s more than 625 members include large integrated companies, as well as exploration and production, refining, marketing, pipeline, and marine businesses, and service and supply firms.
- API 1170, published in July 2015, provides the functional recommendations for facilities that use natural gas storage service, including monitoring and maintenance practices.
- API 1173 established the framework for operators to implement Pipeline Safety Management Systems (SMS). A significant part of this recommended practice is a training and competency aspect.
- OMB (Office of Management and Budget) is the largest office within the Executive Office of the President of the United States (EOP). OMB’s most prominent function is to produce the President’s Budget, but OMB also measures the quality of agency programs, policies, and procedures to see if they comply with the president’s policies and coordinates inter-agency policy initiatives.
- The Rupture Detection and Valve Rule is a proposed amendment to CFR Parts 192 and 195 to require valve installation and minimum rupture detection standards. The rule is currently at the NPRM stage (notice of proposed rulemaking).
- Paul Roberti is PHSMA’s chief counsel and offered a presentation on the regulatory program. [Download the Presentation]
- Cary Coglianese is the director of the Penn Program on Regulation (PPR) at the University of Pennsylvania Law School. Coglianese gave a presentation on regulatory context, means versus ends, and micro versus macro. [Download the Presentation]
- Means is the direction to take or avoid and action.
- Ends means a mandate towards a particular outcome or an avoidance of a particular outcome.
- Micro means targeted to a specific contributor to the ultimate problem.
- Macro means a focus widened to the ultimate problem itself.
- U.S. Regulation of Oil and Gas Operations published by the American Geosciences Institute has several objectives: protecting the environment (including air and water quality), protecting cultural resources, protecting workers’ and the public’s health and safety, and reducing wasted resources.
- NTSB (National Transportation Safety Board) is an independent U.S. government investigative agency responsible for civil transportation accident investigation.
- Robert Hall is the Director of the Office of Railroad, Pipeline, and Hazardous Materials Investigations. He gave a presentation on the investigation and findings related to the Merrimack Valley incident. [Download the Presentation]
- The Merrimack Valley gas explosion in Massachusetts in September 2018 was the result of excessive pressure build-up in a natural gas pipeline owned by Columbia Gas that led to a series of explosions and fires. [Read the preliminary NTSB Accident Report]
- Columbia Gas of Massachusetts is the assumed name of Bay State Gas Company. They are a supplier of retail natural gas to over 300,000 customers in parts of Massachusetts surrounding Springfield, Brockton, and Lawrence.
- PE Seal is a professional engineer’s approval.
- Massachusetts Office of Public Safety and Security keeps the people of Massachusetts informed about public safety issues, and provides services to protect residents from natural and man-made threats.
- Robert Hall is the Director of the Office of Railroad, Pipeline, and Hazardous Materials Investigations. He gave a presentation on the investigation and findings related to the Merrimack Valley incident. [Download the Presentation]
- Pipeline SMS (Pipeline Safety Management Systems) is an industry-wide focus to improve pipeline safety, driving toward zero incidents.
- Angie Kolar is a chair on the Pipeline SMS Working Group and provided an update on Pipeline SMS. [Download the Presentation]
- OSHA (Occupational Safety and Health Administration) is an agency of the United States Department of Labor.
- Injury (Incident) Rate is calculated by multiplying the number of recordable cases by 200,000, and then dividing that number by the number of labor hours at the company.
GPAC & LPAC Update: Full Episode Transcript
Russel Treat: Welcome to the Pipeliners Podcast, episode 104, sponsored by EnerSys Corporation, providers of POEMS, the Pipeline Operations Excellence Management System, SCADA, compliance, and operations software for the pipeline control center. Find out more about POEMS at enersyscorp.com.
Announcer: The Pipeliners Podcast, where professionals, Bubba geeks, and industry insiders share their knowledge and experience about technology, projects, and pipeline operations. Now your host, Russel Treat.
Russel: Thanks for listening to the Pipeliners Podcast. I appreciate you taking the time. To show that appreciation, we give away a customized YETI tumbler to one listener each episode. This week, our winner is Stuart Saulters with the American Public Gas Association. Congratulations, Stuart, your YETI is on its way.
For the record, Stuart, who’s been a guest a couple of times, in order to win a YETI, he had to go to the website and submit a form. If you want to know how to do that, stick around until the end of the episode.
This week on the Pipeliners Podcast, I’m going to be talking about the recent PHMSA Gas Pipeline Advisory, Liquid Pipeline Advisory Committee meeting that occurred on November 14th in Washington, D.C. Many of the listeners probably have heard me talk about the LPAC and GPAC before.
These are committees that are a combination of industry, public, and other interested stakeholders that provide advice and guidance to PHMSA as PHMSA works through its rulemaking process. Their primary role is to make sure that the rulemaking makes commercial, technical, and operating sense. In other words, for the effort invested, the safety gain makes sense.
They do really good work. This was a joint meeting. It was a one-day meeting. What I want to do in this episode is cover the things that they talked about. There was a number of interesting topics here. I’m going to go through eight hours of conversation in about 30 minutes. We’ll see how this works.
The meeting started with Skip Elliot, the administrator of PHMSA. He is the presidential appointee in charge of the Pipeline Hazardous Material Safety Administration. He gave the opening remarks. He started talking about the Pipeline Safety Trust meeting that occurred the previous week in New Orleans.
He talked about how the meeting was opened by a video of Bellingham. He made the point, quoting Churchill, that those that fail to learn the lessons of history are condemned to repeat it. The point he was making is the pipeline industry needs to focus on safety management systems and culture.
Skip comes out of the railroad industry, and he had safety and high-level safety leadership roles in railroad. Part of his key initiative was to do R&D, to look at technology, and look for ways to improve safety. The point that he was making is that we, as an industry, need to get better.
One of the key aspects of this is going to be improvements in technology. Another key aspect of this is going to be a well designed, well implemented, voluntary information system, basically, a way for the pipeline operators to share information so that we get better as an industry. There’s some difficulties with that for many reasons. The whole point, as an industry, is that we must drive to zero incidents.
The next presentation was by Sentho White, the director of engineering and operations for research and development at PHMSA. She talked about the various projects and R&D efforts that PHMSA is underwriting and collaborating with, a very interesting presentation.
There’s a lot going on in that domain. PHMSA has sponsored 335 projects since 2002, and the rate of that is growing. That represents over $50 million in projects. Those projects span a number of different programs, some PHMSA programs, some small business innovative research programs, and others.
There was a lot of talk about the technology. There was some technology around encroachment, some things around natural gas leak rate measurement, and Rapid Aerial Small Methane Leak Survey. These are all things that have been commercialized. The goal of all of this R&D is to get new tools, new technology to the pipeline operators in order to improve safety.
They’ve done a lot of anomaly detection projects with PRCI. There’s some new projects in that domain, one with Arizona State, which is artificial intelligence for interactive threats and pipeline integrity. One with Iowa State for pipeline degradation. One with Brown University for non-destructive tests, and some others.
There’s also a lot of new emphasis and interest in unmanned aerial systems. There’s some interesting work going on in that domain.
Probably the most important thing to keep in mind, if you have an interest in this, is that every two years, PHMSA puts on an R&D forum. The next one’s going to be February 19th and 20th in Arlington, Virginia. This is where they solicit ideas for R&D.
Over the course of the day, many of the presentations that were made in this meeting, there wasn’t a lot of public comment. There’s a lot of public comment to this particular presentation. Some of the key points that were being made is that we need to do a better job of collaborating between operators — between operators and these projects.
One of the points that was made about all of this is that for the public representatives that are on the GPAC and LPAC, they need to be getting information sooner rather than later because they have a bigger learning curve around the details of these technologies than those of use that are engineers and work in the industry.
Another comment that was made is, when we’re looking at calls for proposals, we should be looking at the recent rulemaking and look for technologies that facilitate, streamline, and simplify implementing new rules.
There was some questions about tech transfer, intellectual property rights, and how this gets into use in the industry, a lot of conversation about satellites and what’s going on in that domain, some conversations about big data, particularly for utility operators, which have a lot of information about their pipelines.
One of the questions was asked about the activity that goes on in Silicon Valley around big data and how that’s being advanced. How does industry and PHMSA work together to create some kind of critical mass for that kind of work in the pipeline industry? A lot more coming in that domain.
I would say that with the rulemaking that’s occurring, with the advances in technologies, particularly around cameras, satellite, and image processing, and around big data and data analytics for monitoring right of ways and doing the pipeline integrity actions, there’s a lot that can be done to improve safety in those domains. That technology and the rate of that technology, it’s moving quickly, so a lot of opportunity there.
The next presentation was by John Gale. He presented the regulatory agenda for 2020. I’m not going to go through this in a great deal of detail because I’ve talked about it in other podcasts. The important thing to note is there’s a lot going on. There’s a lot they’re trying to get done.
They’ve got notices of proposed rulemaking around valves in LNG and classifications about standard updates, about regulatory reform, and hazardous liquid regulator reform. Regulatory reform is about getting things out of the standard that are no longer applicable given current technology.
Consider that a lot of these standards and rules date back to the ’70s, that’s a valid question. The standards update is about getting the most recent version of various API and other standards into the code versus earlier versions that are incorporated by reference.
Probably going to be five or six LPAC and GPAC meetings over the course of the next year to work these rules. Tentatively, be looking at meetings in March, July, and November. The expected final rules for 2020, first, there’s the recent final rule that came out in October. We did a podcast about that.
The Gas Transmission and Hazardous Liquid Rule is expected in July of 2020. The Emergency Order Rule’s expected, what I’m showing from my notes, December of this year. We’re looking at an interim final rule for underground storage and revisions in the standards for API 1171 and 1170. The final rule is at OMB at present. The Rupture Detection and Valve Rule is currently at the NPRM stage. It is also at OMB.
In regards to the standards update, this impacts about 60 standards that are incorporated by reference into the rule. This is one of those things that’s controversial, and it should move rather quickly. PHMSA’s looking at ways to streamline this so they can keep the rules that are incorporated by reference more current.
I’ve got a fair amount more notes on this, and I’ll get those to our copywriter. We’ll incorporate some additional notes onto the website about what was discussed in this area. The key takeaway here is there’s a lot of things happening. I do want to talk a little bit about the Gas Gathering Rule. That rule is in final stage. We have talked about that in the podcast on some previous episodes.
There was a lot of discussion, and I gather that there was a letter that went from API to PHMSA about the last GPAC meeting where this rule was discussed and voted on. I was originally thinking that rule would probably go final in 2020. I’m not sure at this point that it’ll happen that fast. It may not happen until 2021. There’s a lot going on behind the scenes as that rule’s going through the final rulemaking process.
There was a presentation from Paul Roberti, who is the PHMSA chief counsel. He was talking about the regulatory program. There was comment about settlement activity and such. We’ll link up that presentation. I’m not going to talk about that in detail. It’s outside of my expertise, and I don’t want to mislead the listeners about what was being talked about.
There was also an interesting presentation by Cary Coglianese, who is the director of the Penn University program on regulation at the University of Pennsylvania Law School.
Very interesting presentation about regulatory context, means versus ends, and micro versus macro. I’ll try to summarize this in terms of what is an appropriate framework. There was some interesting conversation about this.
Means, from a standpoint of the terminology, means take direction to take or avoid and action. Ends means a mandate towards a particular outcome or an avoidance of a particular outcome. Micro means targeted to a specific contributor to the ultimate problem. Macro means a focus widened to the ultimate problem itself.
For example, a “macro means” might be adopting a safety management system. A “macro ends” might be keeping the workplace free from hazards. Of course, micro would be much more specific and prescriptive than that. I’ll link the meeting up so that you have access to all the presentations.
It’s an interesting context. It provides more of a strategic view, if you will, towards regulatory frameworks, the use of terminology, and how frameworks need to be put together in order to support safety outcomes. It’s interesting. It would be helpful for those of you that work in the regulator domain to look at that and understand it. It helps you better understand the conversation going on at PHMSA.
The other thing in the meeting is there was a presentation by the NTSB. The presentation was by Robert Hall, who is the director of the Office of Railroad, Pipeline, and Hazardous Materials Investigations. The presentation was about the investigations and findings related to the Merrimack Valley incident in Massachusetts.
A couple things to understand about the NTSB. The NTSB investigates accidents, determines causes, and issues recommendations. They do not have any authority to enforce laws or regulations or to fine organizations. Their mission is to find out what was the root cause of the accident and what actions should be taken in the future to prevent those kinds of accidents.
The NTSB investigation of the Merrimack Valley incident focused on how and why the overpressure occurred, the emergency response to the event, and the recommendations to improve safety. They got out recommendations very quickly after the incident.
The root cause was very clear right off the bat. For those that aren’t aware, this is an oversimplification, but basically, there was a regulator set, and the regulator set had a sensing line. They were in the process of converting old cast iron pipe to new plastic pipe.
In the process of doing that work, somebody failed to take into account the sensing line. As they were doing the work, they basically put high-pressure gas into a low-pressure system. That’s what caused the incident. There’s actually, in the presentation, some pretty good diagrams that show you exactly what occurred. If you have an interest in understanding this, I’d recommend you go and take a look at it.
There were 14 findings, five new recommendations, and a determination of probable cause. Some selected findings that were presented was that, first off, NiSource’s engineering risk management processes were deficient, failed to identify the possibility of human error that led to the over-pressurization.
Columbia Gas of Massachusetts constructability review process was insufficient and did not detect the omission of a work order to relocate the sensing lines. Finally, the delay between the development of the initial project work order and its execution did not have any impact on the accident.
One of the things that was interesting to me, I’ve heard a lot of conversation about the sensing line, the overpressure, and the work order process that led to the incident.
The other thing that’s very interesting here is that when you look at the emergency response, because of the scale, geographically, of the issue and the way that it happened, the speed in which it happened, it pointed out some issues with emergency response.
The incident commander was challenged by facing a whole lot of priorities, communicating with the affected municipalities, updating emergency responders — there were emergency responders, if I recall correctly, in the order of 15 different entities shutting down the natural gas system. These competed priorities impacted the speed of response.
The specific recommendations that are coming from the NTSB related to the Merrimack Valley incident are to make sure that low-pressure natural gas distribution systems are protected against single operator error or equipment failure. That’s going to be a big deal for the utilities. It means that I’ve got to have redundant overpressure protection to the house, at least that’s my interpretation.
The other recommendation was to alert all operators to the possibility of the overpressure events and urge them to prevent such a failure. There was some commentary about this, but AGA has been very proactive and the members of AGA have been very proactive about responding to this.
A number of the participants on the committee made commentary about actions that they’re taking, proactively, and were appreciative of the early findings that came out from NTSB. It let them look at what their practices and procedures were earlier than if they had to wait for a final report.
The other recommendation is that to the 31 states that don’t require a PE seal, change your laws to require a professional engineer’s seal on public utility engineering drawings. That’s a really interesting finding.
One of the points that was made in the conversation is that a PE seal doesn’t necessarily indicate that they have the right experience to be placing the seal on the drawing. What you need is experienced utility engineers to do that kind of work and to certify it. I do think it does point out a need for a standard of care.
The other recommendation was the Massachusetts Office of Public Safety and Security. That was to develop guidance for effective first responder communications in a large scale emergency event, really a challenge when you start getting into a large event that impacts multiple municipalities and multiple first responders.
Again in the presentation, if you’re interested, it gives you some direction to go onto the NTSB site to the place where you can download the entire final report. It also directs you to where you can go to get all of the documentation that NTSB’s created related to this report.
The last thing that I want to talk about that was covered in the meeting is the Pipeline SMS presentation. This presentation was presented by Angie Kolar, who is currently chairing the Pipeline SMS Working Group. I had the opportunity to talk to her briefly after her presentation.
She’s been on quite the tour going to meetings, making presentations, and working to facilitate the industry’s ability to adopt, implement, and improve their implementation of Pipeline SMS. Pipeline SMS was first started in 2015/16 when API Recommended Practice 1173 was originally published.
In that time, they gave some implementation tools and some individual implementation efforts began. In 2017, liquids and gas joined forces and started forming some cross-industry teams to support the implementation. In 2018, they changed their focus to work in increasing participation in SMS and developing guidance.
In 2019, they’re maintaining the focus on strategy and then working on tactics to ensure implementation across the industry. Recently, AGA put out communications to its members with a strong recommendation that all pipeline operators implement SMS within three years.
The goal of SMS is zero incidents. The way that’s done is through three key pillars. One is conformance to the API Recommended Practice 1173. Another is focusing on culture. The last is focusing on key performance indicators (KPIs) that will give you some indication of how you’re doing.
In terms of measuring effectiveness, there’s a combination of two factors that SMS is recommending you look at. One is conformance. Conformance would be key metrics that are available across the industry such as right-of-way incidents per thousand miles and IPE per thousand miles. Both those come from PHMSA.
Then the OSHA injury rate, combining that with indications of infectiveness, which are internal KPIs developed. Put those two things together, and that gives you a maturity score. That’s kind of the key approach that is being recommended for implementation and tracking of the effectiveness of implementation of Pipeline SMS.
There’s a lot of information about the details and some numbers around how many people are participating, the level of participation, the nature of that participation, through 2019. What I want to focus on in this conversation is what the Pipeline SMS initiative is putting out as their strategic objectives for 2020.
The first strategic objective is to increase industry participation. That has to do with getting everyone to conduct an annual survey and to establish some industry awards related to SMS implementation. They also talk about barrier to entry determination, trying to figure out what are the barriers to entry and how do we help the operators overcome those barriers to implement this? There’s a lot of conversation there around smaller operators.
The second initiative is to ensure proactive external engagement. That’s working with PHMSA, putting together a newsletter, putting together an annual report, building and improving the website, all those kinds of things to help people stay engaged and be able to communicate effectively and make tools and resources available.
The next major objective is to provide ongoing support for the operator journeys. Key thing about Pipeline SMS is that it’s a journey. It’s not a destination. It’s something you implement as a culture and you continually do and improve. One of the initiatives to support that is to create a culture survey for operator use so I get some indication of what’s the state of my safety culture.
They talked about third party voluntary assessment, basically having others come in and assess how you’re doing so that your determination of where you’re at with your program is not solely built on your internal view. Then also talked about continuing to do education workshops and webinars around Pipeline SMS.
The fourth pillar or the fourth objective is to provide governance and oversight. Continue to have a clear industry team strategy, reaffirm API 1173, look at the Pipeline SMS, its team structure and membership, and then look at the overall industry metrics that’s being accomplished.
I think that Pipeline SMS is one of those things that’s going to transform our industry. I think we’re in the very early days of Pipeline SMS. I think people are at the place where the larger operators, for sure, are more mature in their programs, in general, but we’re getting to a point where most of the industry has said, “Yes, I wanna do this.”
In fact, there was some conversation from Angie about her experience going to some places like APGA where it represents the smaller operators. She was surprised by how many people were aware of Pipeline SMS and had something already going on.
I think we’re at a place where SMS is being adopted by the industry and embraced, but there’s a very wide range of maturity of those programs. Be interesting to see what the developments. I’m sure you’re going to see a lot happening in this domain.
I hope you found this week’s episode of the Pipeliners Podcast informative and beneficial. A reminder before you go, you should register to win our customized Pipeliners Podcast YETI tumbler. Simply visit pipelinerspodcast.com/win to enter yourself in the drawing.
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Russel: If you have ideas, questions, or topics you’d be interested in, please let me know on the Contact Us page at pipelinerspodcast.com, or you can reach out to me directly on LinkedIn. Thanks for listening. I’ll talk to you next week.
Transcription by CastingWords