U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration

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Pipeline Safety Trust Annual Conference New Orleans, Louisiana

Inspections

Alan Mayberry November 8, 2012

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration

The Heterogeneous Environment

•  Hundreds of pipeline operators; thousands of “systems”

•  Sizes range from mega-corporations to “mom and pop”

•  Multiple product mixes

•  Varying pipeline ages and materials

•  Pipelines traverse long distances with different operating environments (geography, soil, weather, etc.)

•  Pipelines can be impacted by “outsiders” (public, excavators, farmers, etc.)

•  Pipelines crisscross the country, involving every state

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration

Underlying Principles

•  It is the responsibility of pipeline operators to understand and manage the risks associated with their pipelines

•  PHMSA’s primary role is to establish minimum safety standards (defined by required risk control practices) and to ensure that operators perform to these standards

•  PHMSA also strives to impact operator performance beyond mere compliance with the regulations

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration

PHMSA Objectives •  Our fundamental goal is to protect the public and

environment from pipeline accidents

•  We do this by impacting operator performance: reducing the number and severity of pipeline accidents

•  Inspection of pipeline operators is one of our major tools to accomplish this goal

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration

Inspections: Our charge for today

•  What does the term really mean? ...some call it by other terms

•  Difference between, and descriptions of, regulator and operator inspections

...and where we are headed!

•  Is there room for improvement and greater transparency?

…results pre-decisional versus final

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration

What does the term really mean?

•  “Inspection” (versus “audit”)

Inspections are the review the operator’s documented processes, procedures and records; observation operator employees performing work in accordance with the operators processes and procedures, and the check of operating records to ensure the operator’s pipeline systems are operated at or below the maximum parameters allowed by regulations.

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration

Differences between and descriptions:

•  System-wide inspections

– Operations and Maintenance

– Integrity Management

– Operator Qualification

– Integrated (data-driven, risk-informed: combination of all inspection types)

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration

Differences between and descriptions:

•  Site-specific Field Inspections

– Unit (standard) inspection (before 2013)

– Integrity management field

– Operator qualification field

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration

Differences between and descriptions of: (continued)

•  Targeted inspections/investigations – Pipeline failures – Public awareness effectiveness – Control room management – Specialized inspection – Construction – Drug and alcohol – Others

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration

Integrated Inspection Illustration

IM

OQ

O&M Std. II

T

T

T

T

T T

T

NI

NI NI

NI

NI NI

NI

NI

NI = Non-Issue

T = Threat or

Concern

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration

So, how does PHMSA decide who and where to inspect?

•  Risk Ranking Index Model (RRIM) •  Data Analysis

–  Inspection history –  Incident/Accident History –  Location –  Region knowledge –  Other factors

•  Inspection planning

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration

Is there any room for improvement and greater transparency?

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration

Improvement Opportunities

•  The current program direction addresses many opportunities

•  Improve on new risk ranking tool (RRIM) •  Critical review of operators’ integrity

management and other programs •  Identify potential improvements to inspection

questions and guidance

•  Employee recruitment, training and retention

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration

Greater Transparency

•  Operator inspections are posted to website

•  Current initiative to develop and implement improved metrics, including the public posting

•  Simplifying access and data presentation

•  NTSB Recommendation 11-19

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration

NTSB Recommendations

•  11-19 - develop a standard for IM and other performance-based safety programs that requires operators to regularly assess program effectiveness using clear and meaningful metrics, and to identify and correct deficiencies.

Make those metrics available in a centralized data base.

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration

For more information:

http://primis.phmsa.dot.gov/comm/Index.htm?nocache=7537

1.  Click “Regulatory Oversight” in left column

2.  Select “Operator Information” from drop-down menu

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration

Thank you