In the first of a series of episodes, Pipeliners Podcast host Russel Treat welcomes Dan Sensel, Jason Dalton, and Kyle Miller from Marathon Pipe Line to discuss API 1175 and Leak Detection Program Management.
In this episode, you will understand the distinction of API 1175 as a management system practice versus a regulatory requirement, the importance of performing Gap Analysis before implementing API 1175, and the critical step of establishing the right leak detection culture before investing in technology
Leak Detection Program Management: Show Notes, Links, and Insider Terms
- Marathon Pipe Line (MPL) is a subsidiary of Marathon Petroleum Corporation that owns, operates, and develops midstream energy infrastructure assets. MPL operates pipelines, storage tanks, and barge dock facilities.
- Dan Sensel is the Leak Detection Project Lead at Marathon. Find and connect with Dan on LinkedIn.
- Jason Dalton is the leak detection and hydraulics supervisor at Marathon. Find and connect with Jason on LinkedIn.
- Kyle Miller is the pressure control process lead at Marathon. Find and connect with Kyle on LinkedIn.
- API Recommended Practice 1175 (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.
- The Real-Time Transient Model (RTTM) for leak detection simulates the behavior of a pipeline using computational algorithms. The model, which is driven by the field instrumentation, monitors discrepancy between the measured and calculated values potential caused by a leak. RTTM uses flow, pressure, temperature, and density among many other variables.
- API 1130 defines the requirements for leak detection in pipeline operations.
- API 1130 Figure C-1 (page 31) shows how a CPM (computational pipeline monitoring) system should use instrument data.
- 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.
- ILI (Inline Inspection) is a method to assess the integrity and condition of a pipe by determining the existence of cracks, deformities, or other structural issues that could cause a leak. Pigging is used to detect the presence of problematic areas and take measurements of the areas.
- PDCA (Plan-Do-Check-Act) is a management method to enhance control, help controllers achieve situational awareness, and build continuous improvement into processes.
- PipelineSMS.org is a useful resource with various safety tools that was developed by pipeline operators to help other operators enhance safety in their operation. Read the website resources or email firstname.lastname@example.org with inquiries.
Leak Detection Program Management: Full Episode Transcript
Russel Treat: Welcome to the Pipeliners Podcast, episode 53.
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, and to show that appreciation, we’re giving away a customized YETI tumbler to one listener each episode.
This week, our winner is Dan Sensel with Marathon Pipe Line. Interestingly enough, Dan is also one of our guests this week. To learn how you can win this signature prize pack, stick around to the end of the episode.
This week, we’re very fortunate. We have three engineers from Marathon Pipe Line that are going to join us and talk about API 1175 and pipeline leak detection program management. Jason Dalton, Dan Sensel, and Kyle Miller, welcome to the Pipeliners Podcast.
Gentlemen, welcome to the Pipeliners Podcast. It’s such a pleasure to have you. We’ve got a whole team today. I’m going to start a little differently. I’m going to ask you guys maybe to take a second and each introduce yourselves.
Dan Sensel: Hi, this is Dan Sensel with Marathon Pipe Line. I am the leak detection process leader here.
Jason Dalton: Hi, Russel. This is Jason Dalton. I’m the leak detection and hydraulics supervisor for Marathon Pipe Line.
Kyle Miller: This is Kyle Miller. I’m the pressure control process leader up here at Marathon Pipe Line.
Russel: We are glad to have you guys. Welcome again to the podcast. We’re here to talk about API 1175. Maybe a good place to start is why don’t you tell us what is API 1175? How is it different than other leak detection standards?
Jason: Sure. API RP 1175 is an outline of a management system for leak detection for pipeline operators. One of the differences of it is that most other API documents are lists of “go-dos” and things you should comply with.
API RP 1175 is a little bit different in that it’s very close to a management system. It is a management system, but it outlines various forms of leak detection systems that you cannot use together to create an overall leak detection strategy that fits an individual operator’s capabilities, culture, and what their real risk tolerance is.
Instead of prescribing that you should “go do something,” it lists all the possible things that you could do and how to generate a robust leak detection culture and strategy for your company.
Russel: To me, that’s interesting because it gives the operator a lot of flexibility to discern what’s appropriate. I think that probably leads to some complexity if people are trying to figure out how to apply this. You think that’s a fair comment?
Jason: Absolutely. As it’s been rolled out, a lot of smaller operators have asked, what exactly do I do? How do I make sure that I’m in compliance with this? The answer is there’s no real way to be in compliance with this document since it’s more of an outline on the things that you can do.
It was written in a way to go at it from a perspective of how to meet it with what you’ve got. Dan’s really been involved in trying to make sure that we comply with it for Marathon. I’ll hand it over to him on where he thinks a good starting point would be.
Dan: I’ve spent the last year with one of my major goals as getting Marathon Pipe Line compliant with API RP 1175. I think there’s a couple of key points you have to look at when you’re starting out. The first thing is to really get into the weeds and understand what are you currently doing for leak detection.
What we found is that many of the different elements within 1175, we were actually doing those, we just didn’t have robust documentation of them. We really didn’t have a way to tie them all together, all the different leak detection processes.
Russel: That’s really an interesting comment to me, Dan. As I think a little bit about my experience, if you don’t address leak detection as a program, I think it’s fairly easy for the various things that you do to end up in different silos, or different departments within the company.
There’s a tendency or a propensity, if you will, to lose overall oversight of leak detection as a program. You think that’s a fair commentary?
Dan: Yeah, that hits the nail right on the head here. We have aerial patrol, which is a great leak detection method we use. We have our RTTM software that we’re involved with daily.
We also have our landowners and the interactions with landowners that are a big part of a leak detection strategy. Not necessarily the people we want to find the leak first, but they are our eyes on the ground.
Jason: Russel, the other thing that we’ve considered is the fact that API 1130 handles the CPM system; 1149 handles your sensitivity around CPM. RP 1175 is the first thing that starts around culture into the fold. Leak detection is the synergy of the culture you’ve got, the technology you’ve got, and the processes you’ve got.
For example, you can get an absolute state-of-the-art leak detection system with all of the bells and whistles and the right technology. If the operators aren’t being listened to correctly, or you don’t have the kind of culture that’s going to listen to what the system is telling you, that investment in technology is really not benefiting you.
Russel: Boy, I think you just said a mouthful there. That certainly tracks with my experience. We tend to work more with smaller operators where resources are at a premium and where people are wearing multiple hats.
In particular, in those situations, I’m looking for something I can turn it on and forget about it versus it requires a level of care and feeding. I think that’s what you’re getting at with the conversation about culture.
Dan: Right. I think one of the first things that you should do when you are looking to implement is API has provided a Gap Assessment Tool.
It’s a simple spreadsheet that you walk through, and it has a bunch of questions related to each element. You score yourself on it, and at the end, it tells you where you’re weak and where you’re strong.
That really helped us to identify the areas that we needed to focus on to get ourselves in compliance. Not just to get in compliance, but to improve our leak detection strategy here and help get that culture further along.
Russel: Ultimately, this is not a compliance conversation. This is a fiduciary responsibility conversation.
Dan: That’s correct.
Jason: What doing the Gap Assessment for RP 1175 did was Dan and I sat down and we looked through all of the requirements that were in there. We could look at each other and say, yeah, we do do that.
Because you’re now filling out this Gap Assessment, we’ve come to the realization we don’t have that written down anywhere that Dan and I do that during the course of our day-to-day business, or that the OC does that.
If something were to happen to one of us, we were to go into a new position, that thing that we’re doing or that some other department is doing is really raising the bar on our leak detection system.
If that’s not written down and documented, it’s not sustainable. RP 1175 really pushed us to document that and to make sure that everybody understood that that was going on.
Russel: Again, I think you’re making an excellent point. The idea of whatever we’re doing to run our leak detection program, it needs to be sustainable, and it needs to be the kind of thing we can incrementally improve.
Russel: Was there anything else that came out of the Gap Assessment for you guys that was kind of an “aha?”
Dan: As we’ve said, the biggest thing was that we didn’t have something that tied everything together. API 1175 talks about a strategy document and we didn’t have that. We didn’t have an overall strategy document that outlined this is what we do for leak detection here at Marathon Pipe Line.
Everybody understood their role, and everybody was out doing their tasks, but there wasn’t that high-level document that said this is how we do it. That’s one thing we completed last year to help move us along the improvement continuum.
Jason: The other thing that it did for us was when you first look at this, it’s another guiding document. You’re looking through it thinking we’re going to have to slow up lots of new processes to partners. As we read it and studied it, it really marries up nicely with the SM, safety management system, API 1173.
A lot of the things that we’ve put in place for that just naturally dovetailed into 1175, in terms of our management change system, our reliability centered maintenance, how we handle issues in the company. It was eye-opening to see how the two management systems worked together to increase our overall level of responsiveness.
Russel: I’ve been doing several episodes recently on API 1173 and pipeline safety management. These are certainly first cousins, if not brother/sister. Both of these are the first forays of API of management system standards. It’s a little different than what we classically think of API doing, which is more of the “this is how you do it” kind of thing.
Russel: If you were talking to an operator that’s getting started with 1173, what might you advise them to be cautious about in terms of, “Here’s the things you might miss or the things you might want to pay close attention to?”
Jason: If I was talking to an operator starting up 1175, the first thing I would say is, “Don’t think that this is going to lead you to do an investment in a lot of technology. You need to fully consider the things you’re already doing in the course of your day-to-day business that are forms of leak detection that you don’t normally think of as leak detection.
If you’ve got, right away, aerial patrol going on. That’s a form of leak protection. If you’ve got a system where your risk tolerance says all you need to do is aerial patrol, you don’t need to really be scared of this stuff. You need to use it to your advantage and document that as you are following your risk tolerance to make sure that you are operating in a safe manner.”
Russel: One of the conversations that’s come up around 1173, I suspect it’s also true with 1175 — I’ll put the question out to you guys — is that it seems like one of the benefits is once you’ve done this assessment, you now have a better idea of where to apply resources. Does that fit with one of the things that came out of y’all doing the gap assessment?
Dan: Yes, definitely. That really is what told us where to “go-do” for the next year. When we combine this with our internal operating system of plan, do, check, adjust, this fits right together to where we have that continuous improvement. By establishing where we are, now, we can identify the things we need to improve.
We use that gap assessment every year. We re-score it and look at, where have we improved? Is there anywhere that we’ve actually taken a step back with policy changes or with changes within the company that we need to go and look at again? To us, that gap assessment is really the metric by which we’re scoring our leak detection program — with the other KPIs under that — as are identified in 1175.
Russel: Exactly. That makes a lot of sense to me. Where I’d like to go in the conversation from here is, the nature of this is it’s a program. It’s a management system. It’s designed so that each operator can uniquely apply it. To me, that comes with some challenges, the fact that it gives you that flexibility. How broad is the spectrum? I want to ask about the ability to uniquely apply.
Jason: As far as I’m concerned, it’s very broad on this particular guiding document. Like I said, for smaller operators that do not have a lot of resources to put into this and have very low-risk tolerances, an aerial patrol or even a right-away survey is adequate.
For larger operators that have the existing technology and are gathering all the field polarimetry, it outlines how a CPM system can be used effectively. It really comes down to what your individual exposure is. Even more than that, it ties down to what kind of existing assets you’ve got.
There are some companies that, if you’ve got to really robust ILI program, that can be considered a form of leak detection because you’re routinely patrolling your lines through integrity assessments. As long as you make a concerted effort to go through and study what you’re doing and how it applies to leak detection, this is a very wide-open document.
Kyle: I’d add in there that there is no pass/fail in this document. It is, “Here are guidelines on how to lay out your program.” The most important thing is to identify where you are, do the gap assessment, be open in it, be honest.
You may have some really high scores with high gaps. The real key takeaway from the whole system is you know what you’re doing. You’re documenting what you’re doing. You’re looking to improve it year-over-year.
Russel: If somebody’s brand-new, what would you tell them? Once they’ve done the gap analysis, what do you think’s next?
Kyle: I’d say, taking your results from the gap analysis and looking at your high scores and identifying what are the things we can do right away to improve these? If you look at the questions that are part of that gap assessment, it’ll point you in the right direction of what is the key piece you’re missing.
In our case, it was the overall strategy document. We went off, straight away, from the gap assessment and worked to put that strategy document together and bring together all the different processes within our company that are doing leak protection.
Russel: Why did the strategy document rise to the top? What value, from a leak detection standpoint, did the strategy document create for you guys?
Jason: The strategy document allowed us to identify everybody that was involved in our leak detection process, make sure that we were keeping them on-board with changes. In the past, as a leak detection team, I would say, it went as far as the technology went. We would make changes to our real-time transient models and our SCADA systems, kind of in a vacuum.
There were times that the integrity groups could have really used that information. Identifying it all through a strategy document gave us the who, what, when, why, and where. Who to notify that we were making changes. Who to ask for input on potential changes that we could be making.
It, also, really helped as we on-board new assets to make sure that we’re talking to the right people about what the needs are going to be of the company from a leak detection perspective, as we bring that asset into the fold.
Russel: I’m wondering how far you actually moved the needle just by doing the work to write the strategy document. Obviously, you had to do a lot of investigation, and conversation, and discovery around things that you may have not been intimate with before you started the process. How far do you think you moved the needle?
Dan: I’d say it was a step change for us.
Russel: Really? Just by doing strategy?
Dan: Because it opened up those avenues of talking to all the other groups and looking at our leak detection as a holistic approach to understanding the interactions between line patrol and ILI data and our RTTM models.
Also, it identified that we have a lot more stakeholders involved in our leak detection system than just those people that were actually doing the leak detection, and identified that our lead personnel are a big part of how our leak detection systems perform. That actually identified that we needed to go out and do some training.
We’ve now trained all of our field technicians on what our leak detection system is and how they can impact it in their day-to-day operation.
Russel: Wow. To me, that’s a huge takeaway. It’s not surprising when you say it, but it wouldn’t have come top-of-mind if we weren’t having this conversation. I think when people talk about leak detection, they tend to be thrown to a conversation about technology.
What you’re saying is, yes, that’s part of it, but probably as important if not more important, it’s about corporate culture.
Jason: Absolutely. If you had to weigh it, the vast majority of a good leak detection program is a good culture. You need operators on the systems that understand that they need to think leak-first. They need to be able to understand what’s going on.
You need technicians in the field to understand that when they’re removing transmitters from service, they’re degrading more than just the ability to see a pressure. They could be stopping a leak detection system.
The ILI group needs to understand that they need to tailor their tools sometimes to the condition the line is in. If we’ve got really good leak detection, that means different things to how the system is operated.
The technology I would say is probably the absolute smallest part of it. As an industry, as technology is slowing up, everybody’s first pass at any problem is we just need to computer it up. That’s not necessarily the best answer.
The more complex information coming in needs more complex training for people to understand it. If you don’t pick that up, it’s just a nice-looking toy.
Russel: Yeah. This sounds very familiar to a safety conversation. Safety is a cultural thing. It requires leadership, it requires management, and it requires process. If you’re going to really be good at it as a company, everybody in the company has to be leaning into that.
You can’t give it lip service. It has to be real. It has to mean something operationally, which is what I hear you all saying in your examples about how you went out and you’ve done training, who you’re training, and what you’re training on. To me, that’s a big deal.
Jason: If I was going to talk to a small operator, the first thing I would say is you don’t need to invest in the latest and greatest technology. Your investment needs to be in training the people out on-site and training your operators. Start there.
In terms of the most efficient use of your budget training and making sure that you’ve got a good culture will far outweigh any infrastructure or technology upgrades.
Russel: Yes, absolutely. I would absolutely agree with that. This is not really a trick question, but I think it’s an appropriate question. What is the appropriate performance standard for leak detection?
Dan: That’s a really good question. What we look for here is the right balance between false alarms and sensitivity. That is something that changes over time. We haven’t actually established a firm, pass/fail for that yet. Right now, we’re just looking at improving it year over year.
That can change based on how a system operates, or what the pipe integrity is like on a certain system. You may be willing to have more false alarms on a pipe that you’re worried about from an integrity standpoint in order to get your sensitivity down.
These are things that we go over here as part of our internal process where we review our thresholds and go through evaluations on whether or not they should be lowered further, tuned further based on leak alarm rates.
Russel: What you’re saying is that it’s a risk evaluation and an effort evaluation. That’s how I’m going to translate what I heard you say.
Dan: I’d say that’s fair.
Jason: It also goes back to the communication that we were talking about. We can stay on our side of the room and look at our CPM displays and see what alarms we’re seeing. We’re not seeing everything that’s going on out on an operational console on a day-to-day basis.
One alarm on a console that’s got tons of other business going on — that’s a big impediment to that operator doing his or her job correctly. Whereas, another console with not a lot going on, they could probably handle a lot more nuisance alarms.
Getting feedback from the end user is really what we’re trying to say. “Okay, operation center, what do you need from this system, so that you can perform at the right level?”
Russel: I think ultimately the answer to my question, the standard is zero releases, just like the standard in a safety program is zero injuries.
Now, I might not achieve that standard. From a safety perspective, I might not be able to achieve with that perfection forever, but I can do it for a day. I might be able to do it for a week.
I think it’s the same kind of thing except that the other part and what you guys are getting at is when and if I do have a leak, I want to find it and take appropriate mitigation activity as quickly as I possibly can, even for a small leak.
I think your answer is right. I think it’s also fair to say that we need a set of standards in this domain, things that may not be absolutely achievable, but they’re the only standard that makes sense to work towards.
Jason: I absolutely agree. I don’t think there’s any point where we as an industry will get to a situation where you say, “Well, we’re good here. We probably don’t need to push the envelope any further.”
Russel: Absolutely. You could take the same analogy to the aircraft industry or other industries that are dealing with critical infrastructure. The standards need to be what the standards are. We got to get better. That’s our job.
Russel: Gentlemen, this has been really interesting. I’m going to try and wrap this up with what I think are the key takeaways. The first key takeaway is that 1175 is not a regulatory requirement. It’s a management system practice.
I think the second key takeaway is you have to do the Gap Analysis to determine what’s the appropriate way for you, as an operator, to implement 1175. It’s probably going to be a little bit different for every operator.
Lastly, this is not about technology, this is about culture. It’s about how an operator equips its people to do leak detection as part of their overall job. That sound reasonable to you guys? I do a good enough job of summarizing that out?
Jason: I think you nailed it, Russel.
Russel: What would you like to add that I missed?
Jason: I think I’d like to add that everybody is doing what they can to ensure the safety of the general public with these pipelines. Leak detection is a risk mitigation. It needs to work with the existing integrity programs that are out there.
Risk is consequence, not likelihood. What we’re trying to do with leak detection is reduce the consequences by minimizing the amount of fluid out of the pipe.
We have really good integrity guidelines that the industry is following, and the integrity guidelines should match up well with leak detection to lower the overall risk across the industry.
Russel: Yeah, that’s extremely well said. Leak detection is a consequence-mitigation effort. It’s the inline inspection, the integrity management that is a “don’t have the outcome” effort. Those two things have to work in conjunction with one another — I think that’s an excellent point.
Look, gentlemen, thank you so much coming onboard. I’ll just tell the listeners that we are planning to bring this group back to talk about some other subjects around leak detection and pipeline hydrology, so stick around and we’ll have these three guys from Marathon come back and join us again. Thank you, guys, for joining us.
Jason: Thank you, Russel.
Dan: Thanks, Russel.
Russel: I hope you enjoyed this week’s episode of the Pipeliners Podcast and our conversation with Dan, Jason, and Kyle. 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 us know on the Contact Us page at PipelinersPodcast.com, or reach out to me on LinkedIn. Thanks again for listening. I’ll talk to you next week.
Transcription by CastingWords