This week’s Pipeliners Podcast episode features first-time guest Carin Meyer of Atmos International discussing the importance of pipeline operators aligning with API 1130 to create a compliant Leak Detection System.
In this episode, you will learn about the importance of advancing beyond just having a computational pipeline monitoring (CPM) system to support leak detection, how to use API 1130 to build a more robust leak detection program that is audit-ready, how to answer the four key questions that API 1130 says that operators need to be able to answer, how external changes are affecting leak detection audits, and more important information for pipeline operators.
Auditable Leak Detection System: Show Notes, Links, and Insider Terms
- Carin Meyer is a Regulation Compliance Program Specialist at Atmos International. Connect with Carin on LinkedIn.
- Atmos International provides pipeline leak detection, theft detection, and simulation technology to oil and gas companies.
- Leak Detection Systems (LDS) include external and internal methods of leak detection. External methods are based on observing external factors within the pipeline to see if any product is released outside the line. Internal methods are based on measuring parameters of the hydraulics of the pipeline such as flow rate, pressure, density, or temperature. The information is placed in a computational algorithm to determine whether there is a leak.
- API (American Petroleum Institute) has developed more than 700 standards to enhance industry operations. Today, it is the global leader in convening subject matter experts to establish, maintain, and distribute consensus standards for the oil and natural gas industry.
- API 1130 defines the requirements for leak detection in pipeline operations. API 1130 is incorporated by reference into the U.S. pipeline regulations in 49 CFR 195.134 and 49 CFR 195.444 for how pipeline operators should design, operate, and maintain their computational pipeline monitoring (CPM) systems.
- API 1175 establishes a framework for Leak Detection Program Management for hazardous liquid pipelines within the jurisdiction of the U.S. DOT (specifically, 49 CFR Part 195). API RP 1175 is specifically designed to provide pipeline operators with a description of industry practices in risk-based pipeline LDP management and to provide the framework to develop sound program management practices within a pipeline operator’s individual companies.
- PHMSA (Pipeline and Hazardous Materials Safety Administration) ensures the safe transportation of energy and hazardous materials.
- The CRM Rule (Control Room Management Rule as defined by 49 CFR Parts 192 and 195) introduced by PHMSA provides regulations and guidelines for control room managers to safely operate a pipeline. PHMSA’s pipeline safety regulations prescribe safety requirements for controllers, control rooms, and SCADA systems used to remotely monitor and control pipeline operations.
- AOC (Abnormal Operating Condition) is defined by the 49 CFR Subpart 195.503 as a condition identified by a pipeline operator that may indicate a malfunction of a component or deviation from normal operations that may indicate a condition exceeding design limits or result in a hazard(s) to persons, property, or the environment.
- API 1168 is the Recommended Practice for Pipeline Control Room Management. RP 1168 provides pipeline operators and pipeline controllers with guidance on industry best practices on Control Room Management to consider when developing or enhancing processes, procedures, and training. RP 1168 addresses pipeline safety elements in pipeline control rooms for hazardous liquid and natural gas pipelines in both the transportation and distribution sectors.
- SCADA (Supervisory Control and Data Acquisition) is a system of software and technology that allows pipeliners to control processes locally or at remote location. SCADA breaks down into two key functions: supervisory control and data acquisition. Included is managing the field, communication, and control room technology components that send and receive valuable data, allowing users to respond to the data.
- API 1164 (Pipeline SCADA Security) outlines SCADA cybersecurity processes for pipeline operators. RP 1164 provides guidance to the operators of oil and gas liquids pipeline systems for managing SCADA system integrity and security. The RP is specifically designed to provide the operators with a description of industry practices in SCADA security, to provide the framework needed to develop sound security practices within the operator’s individual companies, and to drive toward possible system improvements.
- API 1165 is the Recommended Practice for Pipeline SCADA Displays. This standard outlines the best practices for designing and implementing displays that are used by controllers to evaluate information available in all operating conditions.
- Alarm Management is the process of managing the alarming system in a pipeline operation by documenting the alarm rationalization process, assisting controller alarm response, and generating alarm reports that comply with the CRM Rule for control room management.
- API 1167 provides operators with recommended industry practices in the development, implementation, and maintenance of an Alarm Management program. The implementation of API 1167 is required by reference in the CRM Rule.
- Alarm Rationalization is a component of the Alarm Management process of analyzing configured alarms to determine causes and consequences so that alarm priorities can be determined to adhere to API 1167. Additionally, this information is documented and made available to the controller to improve responses to uncommon alarm conditions.
- Operator Qualification Training (OQ Training) refers to a process of training control room decision-makers who have the authority to act in normal, abnormal, and emergency situations. Read the Operator Qualification Overview published by PHMSA.
- The Marshall Incident refers to the Enbridge Incorporated Hazardous Liquid Rupture and Release, which occurred on July 25, 2010, in Marshall, Michigan. Read the full NTSB Accident Report.
Auditable Leak Detection System: Full Episode Transcript
Russel Treat: Welcome to the Pipeliners Podcast, episode 189, sponsored by ROSEN, the global leader in cutting-edge solutions across all areas of the integrity process chain, providing operators the data they need to make the best integrity management decisions. Find out more about ROSEN at ROSEN-Group.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 that you’re taking the time, and to show the appreciation, we give away a customized YETI tumbler to one listener every episode. This week, our winner is Jon Lester with Marathon Pipe Line. Congrats, John. Your YETI is on its way. To learn how you can win this signature prize, stick around until the end of the episode.
This week, Carin Meyer of Atmos International joins us to talk about the use of API 1130 to create an auditable Leak Detection System. Carin, welcome to your first episode of the Pipeliners Podcast.
Carin Meyer: Thank you so much. I’m happy to be here.
Russel: If you would, would you do a little introduction for the listeners and tell them a little bit about your background and how you got into leak detection?
Carin: It’s actually interesting, because when I started my career and my education, I was an accountant for public education for school districts in California and Colorado, and fell into the oil and gas business. It’s just a crazy phenomenon.
I started with BP Pipelines in Tulsa. I started as a SCADA engineer and became the SCADA team lead. Right then is obviously when we started working with leak detection. I worked with Atmos leak detection at that time, and then moved to MarkWest in Denver and became the senior SCADA manager over seven regulated control rooms about the time that CRM was rolling out.
Obviously — it’s a midstream company — we started getting into liquids and had to add leak detection onto that. I’ve really been digging into it since the beginning of my oil and gas career.
Russel: You’re with Atmos now, right?
Carin: I am. I’m currently with Atmos. Actually, on the 15th, it’ll be a year.
Russel: For the benefit of the listeners, Carin and I have been knowing each other for some time, probably over 10 years now. We did some work on one of those control rooms she had at MarkWest. If you ever meet her at a conference, you need to ask her about a wedding at a bowling alley in West Virginia.
Carin: Oh, my gosh.
Russel: How’s that?
Carin: That was icing on top of the cake for the day we had. [laughter] We had a rough day that day working with OPC. You’re right. I’ve known you over 10 years now, and that was a rough day. We decided to burn some steam off and go bowling. There literally was that wedding proposal. They had Journey playing in the background. It was a night to remember.
Russel: That’s what I think of every time I see or talk to you. [laughs] That always comes back to mind. What can I tell you? That has nothing to do with what I asked you to come on and talk about, however. I asked you to come and talk about API 1130, and specifically, what does an operator need to do so that their leak detection program would pass an audit?
Maybe the best way to start is I’ll just ask, what is API 1130?
Carin: API 1130 came into play for liquid pipelines specifically. It’s actually, if you have a CPM, a computerized program for your leak detection, that’s why including in liquids because there is not necessarily that requirement or the same type of technology for all of the gas. You can do flyovers and a few other things, but for liquids, they want a form of detection. If you have a CPM, then you must follow API 1130.
Russel: What is in API 1130 that an operator needs to follow?
Carin: There’s multiple sections in API 1130. They want to know, obviously, they talk about the robustness, the reliability, and the sensitivity with that type of information. To break it down, I’ll tell you more in detail what they’re looking for.
What they’re looking for is they want to make sure that you’ve done an analysis, or a risk analysis, on your pipelines to determine which is the best process, or which is the best leak detection application that you can put on pipeline.
Then, once you do that, they want to ensure that you have thought everything through, that you’ve actually done everything, as well as you can test it. It’s following all the performance indicators that you want, and all the different pieces.
There’s multiple different sections to it. Once you select one, and you put in a CPM, they want you to detail and think about, “How are we going to test this? When are we going to test this? What are we going to do to test this?”
There’s a big testing program in there, which incorporates potentially maintenance documents and different other things that can affect your Leak Detection System. As you remember from September about two years ago, they added that group training regulation, which is incorporated with this, because a lot of times if someone went to the field to a meter or a valve and did calibrations or did different things, they didn’t understand the impact that it had — potentially in the control room or on the SCADA — and/or the robustness of the Leak Detection System.
There’s a lot of aspects to it. There’s different pieces in there regarding what kind of training are you going to do? How often are you going to train? It’s definitely incorporated with your OQ and different pieces of that.
Then, of course, you have your SCADA side, which my background is I worked more SCADA and fell into leak detection, but I actually started on the SCADA side directly. You’ve got to think about the different things that incorporate with Control Room Management, the API 1168, or even SCADA screens, API 1165, or even Alarm Management, API 1167.
It really encompasses a bigger piece than just, “We have leak detection. This is how often we test it, and these are our results of what we’ve tested.”
Russel: Carin, you’ve just said a mouthful there, right?
Carin: I know, I know. [laughs]
Russel: Any operator that’s sitting listening to this and says, “Well, I have leak detection,” is probably quaking a little bit after listening to all that. I don’t disagree with anything you’ve said. I think every bit of that’s right on point. It raises the question as an operator, “Well, what do I need to do to have a leak detection approach that’s going to stand up to the audit,” right?
Russel: I think what I would break it down that — and I’ll for your feedback — is, “I need to have some kind of deliberate process that I use to select my approach. I need, based on that process I used to select and the risk I think I have, I need a way to test and assure performance.”
Russel: Then I need a pretty rigorous O&M program to make sure that it continues to operate. Then what I do when I lose leak detection?
Carin: Exactly. Like I said, I know I said a mouthful, and I threw out a lot of APIs and a lot of different programs and stuff that are out there that we have to comply with for pipelines. One thing that I can tell you from experience is going through an audit.
We got away with saying, “We have this form of leak detection, and here’s the documentation of how that leak detection works and here’s our testing records.” At that time, it worked. Now, this was a few years ago. Things are changing now, and the audits are changing, especially being virtual audits, or documentation audits, and not face-to-face audits.
You can’t just talk your way through it so much anymore. You just have to send them all the information. Now, they’re realizing, and I’m hearing from a lot of different operators, that PHMSA or whomever that’s auditing them, if it’s a state audit or a federal audit, are coming back saying, “We want more documentation. This is not sufficient.”
We’re finding that there’s a lot more focus on leak detection than there has been in the last, well, since I have been involved in the last 16 years.
Russel: I think it warrants asking the question, “Why is that true?” Do you have an opinion about that?
Carin: I do have an opinion.
Russel: You always have an opinion.
Carin: I always have an opinion.
Russel: As do I do.
Carin: [laughs] That’s why we get along so well. I would say, in the last maybe four years, we’ve had…Especially since the pandemic, and I’m going to use that as my marker date, so let’s go back a year and a half.
Even in a year and a half ago, on leak detection specifically, we have had more leaks, and it’s breaks my heart, but it’s happened. We’ve had more leaks in the last year and a half than we’ve had in the last 10 years. I think that they’re looking at it different.
It’s like the same idea as some of the other regulations. Like even I was a call this morning about API 1164, cybersecurity’s now a big thing. I think that put a push on leak detection.
Russel: I believe that to be true. I think there’s another factor at play. The other thing that’s happening is that there’s a lot more attention on pipelines. When I started in the pipeline business 20 years ago, nobody ever talked about pipelines.
They’re in the news all the time now. Anything that happens gets a lot of airplay. That creates two things. It creates operating risk for operators, but it also creates regulatory compliance risks for many others, other stakeholders than just the operators.
I think that’s pushing us. Then, with the new administration and their focus on minimizing releases of all types, that’s also putting some focus on leak detection. That focus is really outside of liquid pipeline leak detection through a CPM, but it does…
What I would also say, too, just as I’m thinking through and unpacking this, is that we’ve been under this idea of, “Well, if I have a piece of leak detection software, it’s running, well, then I’m covered.”
Russel: That’s not actually true.
Carin: That’s a true statement. I didn’t want to get too political, so that’s why I didn’t go down that [laughs] rabbit hole, but since you brought it up…
Russel: I don’t want this to be a political podcast, but it is a reality, right?
Carin: Agreed, and I totally, 100 percent agree with you. I think that’s a big push on it, too, especially with all the new emissions and things coming out, but that’s more on the gas side. The new regulations coming down for that, the leak detection industry as a whole is going to have to adjust and modify to be able to accommodate for that.
I do agree with you that, you made a statement that, “We are definitely in the limelight.” Like you said, 20 years ago, you didn’t hear about pipelines. Now, you hear about them consistently, for multiple different reasons.
Russel: I think where I would go with this is that you were talking about the pandemic. The other thing that’s the reality is PHMSA’s continued to pretty much sustain its targeted audit pace. They’re a little behind, but not a lot.
Carin: That’s true.
Russel: They’ve been doing these audits remotely, which means there’s been a lot more focus on, “Give me the document. Let me analyze the document,” versus, “I’m going to come, and we’re going to sit down for a week and have a conversation.”
Carin: Exactly. That’s where the document needs to be…You need to ensure that your policies, procedures, document, program — whatever it may be — is solid. Very solid, because you’re right. Before, you could sit in a room, and — even it’s maybe not hyperlinked or however you have your documentation designed — you can pull up a document on the screen and say, “Yeah, but we have this. This covers that requirements.” Now, you have to send them everything, so you can’t just say, “Oh, we do have that.” They’re going to ding you, and then you can go back.
Russel: They’re going deeper.
Carin: Thank you. That’s the word.
Russel: They’re going deeper. They’re saying, “Okay, that’s what you say you’re doing. Show me the policies and procedures that demonstrate how you do it. Show me the records that demonstrate you’re doing it. Show me the analysis that demonstrates doing all of those things creates the safety benefit we’re looking for.”
Carin: Exactly, exactly. I do agree with you. I remember what the comment was that you made, was about you put in a CPM system, and you think you’re done. That was the comment I wanted to piggyback off of a few minutes ago, and that’s not a true statement. Some customers do that. Some operators do that. I’ve been in the industry 16 years now, and I’ve seen it. They’re just like, “But we have one in there.” Like you stated, that’s not necessarily the case.
That’s what API 1130 is trying to get people to understand, document, and recognize that there’s certain testing requirements, there’s certain pieces that go above and beyond your O&M, and even not necessarily above and beyond Control Room Management, but they coincide together. How things are related to each other, and that you really need to keep an eye on it.
Definitely, especially your documentation, and your program, your leak detection program. What do you do if you calibrate a meter? Do you go back and do retesting? Do you just say, “I no longer have a false alarm?”
Whatever different things for the robustness and the accuracy of your leak detection system they want you to think about that and continually improve it to make it better and catch the leak quicker and sooner.
Russel: Right. I want to catch a smaller leak. I want to catch it faster, and I want to know where it occurred.
Carin: Exactly, and location, yes. That’s definitely a big one, too.
Russel: Let’s unpack that a little bit, because I think if people understood a little bit more about 1130 and the details…Whenever I’m looking at a leak detection program around CPM, I’m looking to try and answer how does the operator answer the four key questions that API 1130 says you need to look at — sensitivity, reliability, accuracy, and robustness? What is sensitivity?
Carin: Sensitivity, how I see that is: how far down can you get your percentage span to be able to determine a leak. As you know, probably, depending on the pipeline, depending on the terrain, depending on the size, depending on the metering, all that information can depend on the reliability of your data.
Basically, for a CPM, you really want repeatable — to keep the reliability, not get the false alarms — and that type of thing. Communications is in there also. That’s a big one. How far can you tune it down to? Can I say, “I can get a five percent leak without tuning it too much to get too many false alarms?” Or, can I go down to a 1 percent leak, or a .05? Whatever it may be. That would be the accuracy looking at your data.
One thing that you’ll find — or I’ve seen in the past — is when implementing a CPM system, we found a lot of issues in the field that needed to be corrected, and/or equipment updated, or communications modified, or something to be able to get this data or this accuracy data that’s repeatable.
Russel: Carin, that’s such an important thing for people to understand, is that the sensitivity you can drive out of a Leak Detection System is constrained primarily by the equality of your metering and the rapidity, how quickly you can get poll and get the data in.
Russel: Those two things are the primary drivers. If I’ve got metering that’s in and out and meters are going offline — they’ve got bad meter factors or whatever; I’m having problems with density consistency — any of that kind of stuff is going to impact sensitivity. The software can only do as good a job as the data it’s fed.
Carin: Because you’ve got your field operations, leak detection is more typically out of the control room or potentially an engineering group, depending on how your organization is set up. Those two sometimes don’t always understand what the other one does or the importance. That’s where that team training regulation comes in, which is a totally different podcast. They need to work together. These actually go hand-in-hand. We’re not pointing fingers.
Russel: It’s a team effort, and we need to understand that when I’m out calibrating a meter or servicing a meter, what impact did that have on the operations and the safety of the overall pipeline?
Russel: Let’s transition. What’s reliability?
Carin: Reliability falls a little bit under the same thing. As far as how I see it — I’m going to rephrase that — is the reliability of the data, false alarms, that type of thing. Can you actually trust the CPM system that you chose?
There’s a big thing about eliminating false alarms and finding a CPM that doesn’t give a lot of false alarms. You may get a few, for whatever reason, but you want to be able to tune it down as much as you can. It’s obviously just that reliable, and it gets the information that it needs, and it’s keeping it…
Russel: Exactly. Reliably, simply stated, is it’s false alarms, but the thing that a lot of operators don’t understand is there’s two kinds of false alarms. There’s false alarms related to instrumentation problems, or maybe problems with the software or the servers. Something it gets corrupted or it’s not running quick enough, or whatever. That’s one thing.
There’s also false alarms that are related to normal operating conditions that occur rarely, like slackline or whatever else, that can generate false alarms. Really, reliability is what are you doing to manage and deal with false alarms, and what are you doing to make sure — to the best of your ability — every alarm is valid?
Carin: Exactly. That actually, like I said, there’s different pieces to this. I brought up the Alarm Management / Control Room Management. This goes hand-in-hand with that.
You also, from experience, have found where we had a bunch, as you call, “operational false alarms,” let’s say. That was because other field operations were running the line and doing all these different things, and they didn’t realize the impact it had. Then you got together and decided or worked together to come up with a better work process that stopped surges and stopped slacking the line or different things and smoothed out operations.
Russel: Right. You’d tighten up your operations in order to get…
Carin: Tighten up operations, yep, exactly.
Russel: I think, too, that I’ve had some really interesting conversations with some of the operators I work with about false alarm versus valid alarm, meaning yes, the system should have generated an alarm, but it’s not a leak, versus a leak alarm.
How do they manage the distinctions between those things, and how does that relate to procedures in the control room and in the field?
Carin: That’s interesting that you say that, because a lot of these, like that one, that operational issue, that was a valid alarm. It was not a false alarm, but when you talk to a lot of people in oil and gas, they only have those two attributions, false alarm or leak alarm.
But, a valid alarm that’s not a leak should be in conversation more because it builds confidence.
Russel: That’s where your Alarm Management program and your alarm response should be focused. What do I do about these valid alarms that are not leaks or that might not be leaks? How do I get some really strong fencing around that definition?
Carin: Exactly. That is part of the section of the API 1130 where they talk about the alarms, and what do you do? Do you have meetings? To circle the loop, basically. If you have a valid alarm that’s not a leak, what do you do to mitigate that, and how are you handling those? That’s also part of the 1130 process.
Russel: For people that are interested, the Marshall Incident — Marshall, Michigan Incident on the Kalamazoo River — if you look at that one, that’s very much tied to what we’re talking about right now. They had valid alarms that were actually leak alarms, but they didn’t interpret them as leak alarms. They’d interpret them as operational alarms. If you read the timelines, and you read the analysis that the NTSB did in its report around Marshall, it puts a box around this problem or this challenge.
Carin: Exactly, exactly.
Russel: Let’s shift again. We’ll talk about accuracy. What is accuracy, as it relates to API 1130?
Carin: You’re only as good as your data. In the big picture, you’re only as good as your data. Accuracy would be just that, and from personal experience, we had a couple of meters that were calibrated off just a little bit, but it was on a long pipeline. It affected the readings from the meter before and the meter after. Obviously, accuracy, we had to do a work order and get that corrected, but it took us a while to figure out what was happening. We kept asking for the program and this, that, and the other. It’s another one of those ideas of working together, the team training idea. You’re only as good as your data.
Russel: It’s interesting. I focus on accuracy…This is a different way to say what you’re saying, probably, but I focus on accuracy as when you get an alarm, can it tell you a leak rate, and can it tell you a leak location? Can it tell you that with some level of accuracy?
Carin: Yes, and that would depend on the CPM system you have. Some of them offer location. Some don’t. Some offer an area. It really depends on what CPM system you have on that. A lot of them do sizes, but the location seems to be one of the bigger challenges for a lot of the CPM systems out there.
If you look and do your research, and that’s part of — actually, it’s more API RP 1175 — but to go through the analysis to determine why you picked the system that you picked, but that one falls a little bit more under RP 1175.
Russel: Interesting. It’s interesting to me because there are a number of systems out there that do not really give you any indication of location, other than it’s between these two metering points, right?
Russel: The other thing you mentioned is…You made the point about metering, and I think you’re absolutely right. Part of accuracy is being very clear about what is the performance standard for my metering and for my instrumentation?
Russel: How do I maintain that performance standard for metering and instrumentation, and then how does that relate to my CPM performance?
Carin: Like I said, as part of API 1130, if you read through it, there is a section on this. That’s where it can incorporate your maintenance records, or maybe something from I&E, or your measurement — how ever your organization is designed and set up.
It all comes back to its more than just saying, “I have a leak detection system.” What are you doing to be able to make sure that your leak detection system is doing what it’s supposed to be doing?
Russel: Exactly. Then lastly, what about robustness? What is robustness? Well, I’ll tell you how I read 1130. Robustness is how well does your Leak Detection System work when you have communications problems, server problems, metering problems, etc.? How well is it able to operate through a range of operating conditions, and through a range of abnormal operating conditions? Again, how do you get a fence around that?
Carin: There’s different processes in there and procedures, and different things that they want to see, in order to handle those conditions. The AOC program or the AOC matrix and different things along those lines and training.
When do we call the field out? When we close or shut a pipeline in? When do we do certain things when different abnormal operating conditions to occur? Are you addressing the ones that affect your leak detection equipment?
In the control room, you may have an AOC matrix that is for all metering, or whatever you have on your pipeline, but then only maybe one-third of that is actually somehow related to your Leak Detection System. I’m just pulling numbers out of the air, so I’m not trying to say only one-third…
Russel: No, I think you’re right on it, Carin. It’s understanding your AOCs, the specific AOCs that affect leak detection, and understanding what your policy is about addressing those.
Carin: Exactly. When we talk about the API 1130 program, and even with the Alarm Management, I’ll use that one as my example. You have your safety-related points that you have identified along your pipeline. All of those may not be part of your Leak Detection System. They could be. They could not be. It depends on how you’re set up.
They want to see, for the API 1130, have you earmarked the ones that do affect the Leak Detection System, and are you doing things to ensure that those points are handled appropriately for the leak detection application that you have?
Russel: Right. It’s interesting, 1130 pretty much — the first time you read it — you think it’s about the CPM software. Then about the fourth or fifth time you read it, you start realizing it’s not really about the CPM software as much as you thought.
Carin: Exactly, yeah.
Russel: It’s more about all the other things that have to be in place for the CPM software to do its job.
Carin: That’s exactly it. That’s why, like I had stated earlier, that the audits are getting harder. Before, you could talk your way through it and just say, “We have a CPM system. Here’s the documentation on how they do their algorithms, statistics,” whatever it is that that application does.
Then, “Here’s our test records. Here’s our training records.” It’s more than that. It’s so much more than that. I think that’s a lot of people are discovering, especially now, that everything is done more virtual. You just send them all the documentation, thinking that you have all the pieces.
Then you find out you may have them, but they’re not all together in the same place or earmarked in the fashion that they want to see them. Everybody, we do it all. 9 times out of 10, we’re already doing it, but we just may not have it organized and put together appropriately.
Russel: I think that’s absolutely right. I do think, though, that this is one of those areas, particularly for the smaller operators, where they might have risks they don’t know they have.
Russel: I’m talking about regulatory risk more than operating risk.
Carin: Agreed. I definitely agree with you, because we all have the same goal as far as operations go. Safety, safety, safety, safety. You’re right, regulatory, you just may not have it put together, documented, or even thought about some of this stuff to realize the impact of everything, until you bring it all together for, like a program for API 1130.
We are in the process right now. The APIs get reviewed every five years. API 1130 is on the marker, too, it has been rewritten, and it’s going to vote in Congress sometime this year. I don’t know when.
The regulation is going to be changed and/or added to, which is going to cause another potential gap for clients or customers or companies out there, because it’s going to be a little bit different. I don’t have a date of when any of that’s going to happen.
Russel: I think the API has been shifting its priorities around — both the changed priorities from the new administration and related to the Colonial incident — shifting their priorities about what standards are getting primary focus.
Russel: For justifiable reasons, right?
Carin: I totally agree. [laughs]
Russel: What would you say the key takeaways are for an operator in this whole conversation?
Carin: I would say get familiar with API 1130. There’s companies out there that can help you pull it together and do this different kind of making sure you have everything, but it is bigger than just saying, “I have a CPM system.”
There are so many different aspects to it, and understanding that there’s other components that are involved, and potentially could impact your CPM system. It’s just more than just saying, “I have a CPM system,” or a leak detection.
Russel: I think, again, very well said. The other thing I would just illustrate is that an operator could — with a simple point-to-point pipeline — could do a simple mass balance in their SCADA system. As long as they did all the API 1130 around it, they could be compliant.
Carin: The mass balance, if I did it with a spreadsheet or that type of thing…It depends on how they do it. If they do it computerized, it would be 1130. If they did it on paper, visually, or a different type of way, it would fall more under API or RP 1175. It depends.
Russel: I agree. I’m referring to somebody that had a SCADA system, could build something of their own that’s pretty simple.
Carin: They could.
Russel: As long as they had 1130 wrapped around it, that could be compliant.
Carin: That is a true statement.
Russel: Whether or not that’s best practice is a different question, right?
Carin: Good point. That’s exactly a true statement, yeah.
Russel: [laughs] You and I both know enough to know what the operational reality of that is and how actually effective it is. I’m just making a point that the key thing is 1130 is not really what software you pick. It’s all the things that you’re doing to operate and maintain that software.
Carin: That is a true statement, like I said because it’s so much bigger.
Russel: Then on the flip side of that, even if you’ve picked a well-known, highly-used software, if you’re not doing 1130, it’s the flipside. Even if I have good software, I still have to do the 1130.
Carin: That is a true statement also, so yes. Agreed, agreed.
Russel: That would be the key takeaway I would want people to take, is it really doesn’t matter what the software you have is. You’ve still got to do all this other stuff.
Carin: Exactly. API is agnostic. You could have five different leak detection software’s running in your company. It doesn’t matter.
Russel: That’s not uncommon.
Carin: No, not at all.
Russel: Some of the bigger operators, they’re running multiple tools as a way to mitigate risk.
Carin: The same thing with SCADA. There are multiple tools for everything, and they can run multiple ones, but your API 1130 should encompass the program for your CPM, not the technology.
Russel: Listen, this has been great, and I will tell the listeners that we plan on having you back. We’ve got some other things we want to talk about specific to what you’ve mentioned several times, API 1175. I think it would be great to do a conversation on 1175.
I think another thing it would be good to do is talk about all of the regulations incorporated by reference that are impacted by leak detection.
Carin: That would be wonderful. I would love to do that.
Russel: We’ll definitely have you back. Listen, thanks for coming on. It’s been fun.
Carin: Thank you so much. I appreciate it.
Russel: I hope you enjoyed this week’s episode of the Pipeliners Podcast and our conversation with Carin. Just 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.
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 reach out to me on LinkedIn. Thanks for listening. I’ll talk to you next week.
Transcription by CastingWords