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192 vs. 195 Gap Analysis

192 vs. 195 Gap Analysis. July 14-15, 2009 Arlington, VA. 192 vs 195 – Why are we Here?. Regulations started at different times, developed separately There are differences & gaps Differences raise questions – usually ‘Why?’ Management needs to understand biggest differences/gaps and why.

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192 vs. 195 Gap Analysis

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  1. 192 vs. 195 Gap Analysis July 14-15, 2009 Arlington, VA

  2. 192 vs 195 – Why are we Here? • Regulations started at different times, developed separately • There are differences & gaps • Differences raise questions – usually ‘Why?’ • Management needs to understand biggest differences/gaps and why

  3. Example – BP Alaska Spill • March 2, 2006 – release on North Slope • Release of 4800 barrels affected 2 acres of tundra • Low pressure pipeline; not subject to regulation • At Congressional hearing – Why? • No good answer; subsequent rule change

  4. 192 vs 195 – What Management Wants • What are the major differences? • Why do they exist? • Are they still justified? • What differences should be eliminated? • What other “holes” exist in the regulations? • Which holes should be fixed? • Better answer for next Congressional question

  5. 192 vs 195 – Action Plan • Three phase approach • Phase 1 – head-to-head comparison • Completed • Results presented in spreadsheet distributed to the team • Useful to focus/direct our work, but probably too complicated for outside use • Phase 2 – Why? Are the differences still appropriate? • Phase 3 – What should we fix and in what priority?

  6. 192 vs 195 – Phase 1 results • There are four worksheets • The “guts” are in the comparison worksheet

  7. 192 vs 195 – Phase 1 “Ground Rules” • No judgments • Different is different • No “but this isn’t needed here” • Purely editorial differences ignored • Violates “no judgments” but … • Deals only with what is there • No treatment of “holes” (e.g., low-stress HL pipe in March 2006)

  8. 192 vs 195 – Phase 1: Major Gaps • Class locations: gas yes (192.5, 609, 611), liquids no • Minimum setback: gas no, liquids yes (195.210) • Pressure relief design: gas yes (192.199), limited requirements for liquids (195.406(b)) • Alternative MAOP: gas yes (192.112, 620), liquids no • Repair: gas yes for transmission only (192.711-717), liquids no • Component design requirements: gas yes (192.143), liquids no

  9. 192 vs 195 – Phase 1: Major Gaps • Station design requirements: gas yes (192.163), liquids no • Wrinkle bends: gas precluded (192.315), liquids not • Casings: gas yes (192.623), liquid no • Corrosion control for converted pipe: gas, yes if can (192.452), liquids more limited treatment (195.557(b), 563(b)) • Remediating corrosion: gas yes (192.483), liquids no

  10. 192 vs 195 – Less Major Gaps • Uprating: gas yes (192.553, 555, 557), liquids no • Protection from hazards: gas yes (192.317), liquids no • Pressure testing for low stress: gas yes (192.507 – 513) liquids no • Assist in investigation: liquid yes (195.60), gas no • Plastic pipe: no provisions for liquid (but non-steel requires approval of Administrator)

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