Reporting of Over Pressurization Events

1
Reporting of Over Pressurization Events

• Restoring Trust in Pipeline Safety
• Nov 2nd 3rd, 2006
• New Orleans, LA

2
Over Pressurization

• Todays Focus on Transmission Pipelines
• Allowed Accumulation over MOP/MAOP
• MOP Maximum Operating Pressure (liquid)
• MAOP Max Allowable Operating Pressure (gas)
• For Sound Pipeline/Welds Not a Problem
• High SMYS Tolerance
• Large Safety Factor on Properly Tested/Inspected
  Systems
• Exceeding Regulatory/Code Pressure Accumulation
  Limit
• Suggests Serious Loss of Operator Control of
  Pipeline
• Calls into Question Management Processes

3
Over Pressurization

• The Belief - Canvass the Operators
• No one Exceeds Accumulation Limit
• A Serious Regulatory/Code Violation
• The Reality
• Many Forces Increase Risk of Over Pressure
• Seeing too Often
• No Real Defense for this Violation
• Loopholes in Regulatory Reporting
• Biases the Database
• Misstates Pipeline Failure Mode Distribution
• Taints IM Risk Approaches

4
Over Pressurization

• Current Regulations
• Allow Avoiding Reporting to PHMSA
• Past Argument Burden of Reporting
• No Failure Whats the Concern?
• Loose Requirement for Certain Pressure Records
• How Can One Have an Effective IM Program?
• Drivers of Overpressure Events
• Very Poor Management Practices
• Serious System Breakdowns - No Accident
• Cost Reduction and Efficiency Forces
• Over Reliance on Electronics as Fail Safes
• Changing Role of Transmission Pipelines

5
Over Pressurization

• Regulatory Recommendations
• Eliminate Reporting Waivers in Pipeline
  Regulations
• 191.23(b)(4) - gas, 195.55(b)(3) - liquid
• Mandate Simple Electronic Reporting within 24
  hours (all events in Excess of Permitted
  Accumulation Pressure)
• Strengthen System Pressure History Recordkeeping
• Outcomes
• Public Confidence and Creditability in Database
• Strengthens Certain Risk Approaches for Pipelines
• Protects the Pipeline Operator and the Public
• All Parties Have Same Objective - Keep the
  Pressure Within the Pipe