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

U. S. Department of Transportation Pipeline and Hazardous Materials Safety Administration. www.dot.gov. Alabama Gas Pipeline Safety Seminar Montgomery, AL December 11, 2007 Joe Mataich U.S. DOT/PHMSA Southern Region. PIPES ACT OF 2006 PUBLIC AWARNESS (API RP1162) CORROSION CONTROL UPDATE.

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

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  1. U. S. Department of Transportation Pipeline and Hazardous Materials Safety Administration www.dot.gov

  2. Alabama Gas Pipeline Safety Seminar Montgomery, AL December 11, 2007 Joe Mataich U.S. DOT/PHMSA Southern Region

  3. PIPES ACT OF 2006 • PUBLIC AWARNESS (API RP1162) • CORROSION CONTROL UPDATE

  4. PIPES ACT Pipeline Inspection, Protection, Enforcement, and Safety Act of 2006

  5. Main Provisions • Damage Prevention • Enforcement Transparency • Integrity Management

  6. Damage Prevention • Creates national focus Damage Prevention Programs • Federal One-Call Civil Enforcement • State Grants • 811 – National One Call Number

  7. FACILITY OWNERS AND OPERATORS —Any owner or operator of a pipeline facility who fails to respond to a location request in order to prevent damage to the pipeline facility or who fails to take reasonable steps, in response to such a request, to ensure accurate marking of the location of the pipeline facility in order to prevent damage to the pipeline facility shall be subject to a civil action under section 60120 or assessment of a civil penalty under section 60122.

  8. PHMSA Enforcement Authority Only if State Program is “inadequate” Criteria for Adequacy needs to be Established Rulemaking? Criteria will show States what to aspire to PHMSA does not want to wade into States with a “big stick” Civil One-Call Enforcement Authority

  9. To Agency Designated by State Governor Must have Effective Program OR substantial progress toward one Criteria: 9 Essential Elements of an Effective Damage Prevention Program (DIMP Phase 1 Report) CGA Best Practices in place for each Essential Element Damage Prevention Grants

  10. 9 Essential Elements(paraphrased) • 1.) Enhanced Communication between Operators and Excavators • 2.) Fostering Support and Partnership of all Stakeholders • 3.) Operator’s use of Performance Measures • Pipeline Locating (QA)

  11. 9 Essential Elements (paraphrased) • 4.) Partnership in Training, ALL STAKEHOLDERS • Operators • One Call Center • Enforcing Agency • Excavators • Locators

  12. 9 Essential Elements (paraphrased) • 5.) Partnership in Public Education • ALL STAKEHOLDERS • 6.) State Authority’s Role • Partner & Facilitator to Resolve Issues • 7.) Fair & Consistent Enforcement of Law

  13. 9 Essential Elements (paraphrased) • 8.) Fostering & Promoting New Technologies to enhance; • COMMUNICATIONS • LINE LOCATING • ANALYSIS OF LOCATING PROGRAMS • 9.) Process for CONTINUAL Evaluation & Improvement of Damage Prevention Program

  14. Hits and 911 • MUST CALL911: Pipeline Damaged and Product Released • Contractors and Operators • CGA BP 5-25 – call 911 and pipeline operator • Need Improved Incident Perimeter Control • PUBLIC SAFETY

  15. 811 Campaign Recognition • Grants for Promoting Public Awareness • www.call811.com

  16. Enforcement Transparency • http://primis.phmsa.dot.gov/ • OPS Communications Initiatives

  17. Pipeline Safety Websites ops.dot.gov primis.phmsa.dot.gov npms.phmsa.dot.gov

  18. Integrity Management • Certification of Pipeline Integrity Management Performance Reports • Senior Executive Officer of Pipeline Operator certifying that— ‘‘(1) the signing officer has reviewed the report; and ‘‘(2) to the best of such officer’s knowledge and belief, the report is true and complete.’’. • Advisory Bulletin ADB-07-01 (April 23, 2007)

  19. Integrity Management • EXCESS FLOW VALVES • Single Family Residences • Service Lines Operating at 10 psig or More • Installed/Replaced after June 1, 2008

  20. Integrity Management • Distribution Integrity Management (DIMP) • HCA Concept Does Not Apply • ILI, Hydro Test, ECDA Do Not Apply • Focus on Damage Prevention • Focus on Leak Evaluation/Management

  21. Integrity Management • DIMP Rulemaking • NPRM publication ~ November ’07 • GPTC Guidelines • APGA (SHRIMP) • Simple Handy Rule based Integrity Management Plan • Guidance for Small Operators, MMO’s

  22. Public Awareness Programs for Pipeline Operators

  23. PHMSA’s Public Awareness History • Pipeline Safety Regulations Requiring: • Damage Prevention awareness for Excavators • Emergency Plans for Fire, Police, & Public Officials • Public Education • Participant in American Petroleum Institute (API) committee to create API RP 1162 • Operator workshops in 2003 and 2005 • Final Rule published May 2005 requiringRP 1162-style programs by June 20, 2006

  24. New Features of Public AwarenessEvaluating Program Effectiveness • Due at 4 year intervals • Survey Stakeholder Audiences to Determine • Percentage of Audience Reached • Understandability of the Message • Desired Behaviors by Audience • Achieving Bottom-Line Results • Revise Program Based on Evaluation

  25. Implementation ofCompleted Program • There is no single “due date” for distributing RP 1162-style awareness materials to stakeholders • “Due date” calculated by a simple formula:June 20, 2006 + RP 1162 Frequency • First evaluation of effectiveness due inJune 2010

  26. Written Program Review • PHMSA Advisory Bulletin published June 16, 2006 requested submission of programs by October 8, 2006 • 8 States decided to conduct independent reviews • As of June 25, 2007, 1,441 Programs covering 1,835 OpIDs have been received • Programs are being reviewed by a central Clearinghouse with feedback to the jurisdictional pipeline safety agency

  27. Establishing the Clearinghouse • PCCI Marine & Environmental under contract • Gas Dist and Gathering Written Program review began in October 2006 • Gas Trans & Haz Liq Program review began in late January 2007. • Review Criteria for the Clearinghouse have been developed jointly by National Association of Pipeline Safety Representatives (NAPSR) & PHMSA • Review of the written program will be concurrent with implementation of the program by operators

  28. Clearinghouse Results • Review of programs stored as database • For each operator, the pipeline safety agency(ies) will receive • List of program aspects that deviate from RP 1162 recommendations • List of supplemental elements implemented • Pipeline Safety Agency(ies) and Operator need to resolve deviations and supplemental element issues

  29. Clearinghouse Progressas of 06-25-2007 • 1,296 Reviews completed • 90% of submitted Programs • OPS and States still trying to elicit Programs from several hundred operators

  30. Over 50% DeviationsElements Common to All Operator Types • No process and procedure to determine whether Supplemental Elements will be implemented in response to Third-Party Damage and other considerations listed in RP-1162 Section 6.2 • No Management Statement of Support • Evaluation of effectiveness not called for at maximum four year intervals • No annual implementation audit

  31. Over 50% DeviationsGas Distribution • Lack of damage prevention awareness and pipeline purpose and reliability messages to General Public • Message delivery method to Excavators and Emergency Officials not specified or deviates from RP 1162 • No awareness of hazards and protective measures undertaken message to Affected Public

  32. Over 50% DeviationsGas Trans & Haz Liq • Insufficient pipeline location or NPMS information to Local Public Officials and Emergency Officials • Insufficient pipeline location and NPMS information to Affected Public • No process and procedure to determine whether Supplemental Elements will be implemented in response to High Consequence Areas

  33. Over 50% DeviationsGas Gathering • Materials to Local Public Officials do not include copies of materials provided to Affected Public and Emergency Officials

  34. Significant Incidents caused by Excavation Damage2002 thru 2006 • Liquid Pipelines • 14% of Significant Incidents • 63% of Fatalities and 16% Injuries • Gas Transmission Pipelines • 13% of Significant Incidents • 80% of Fatalities and 23% Injuries • Gas Distribution Pipelines • 37% of Significant Incidents • 28% of Fatalities and 32% Injuries

  35. Supplemental Elements • Additional actions beyond the Baseline implemented by an operator in response to one of 12 specific considerations listed in RP 1162 • Considerations include Third-Party Damage and High Consequence Areas • Section 6.2 of RP 1162 provides leading questions for each Stakeholder Audience

  36. Supplemental Elements • Only 17% of Programs reviewed implement Supplemental Elements in response to Third-Party Damage • Only 36% of Gas Trans and Haz Liq Programs reviewed implemented Supplemental Elements in response to HCAs • Gas Integrity Management regulations require external communication program for the public equivalent to Supplemental Elements

  37. Implementation Inspections • PHMSA Regions will inspect implementation records as part of an operator Standard Inspection • NAPSR members may inspect intrastate operators • Pipeline Operators and Pipeline Safety Agencies will both experience a learning curve, especially regarding Supplemental Elements • PHMSA inspection goal is to Foster Improvements, not to cite for non-compliance

  38. Revising MessagesNPMSwww.npms.phmsa.dot.gov • April 2007 changes to the National Pipeline Mapping System (NPMS) • Public access to maps in one County at a time, including attributes such as operator name, product, and operator contact • Local public officials can get electronic data layer AND add this layer to their own GIS • Operator messages about NPMS should be modified to reflect new capabilities

  39. Revising Messages811www.call811.com • National “Call Before You Dig” number officially launched on May 1, 2007 • Market research demonstrates homeowners often don’t make the call • CGA DIRT report of CY 2004 and 2005 shows 31% of damages and near misses have a root cause of “No Notification to One-Call Center” • 811 should have a prominent role in Public Awareness Programs.

  40. Corrosion Update • NACE TG360 Revising SP0169-2002 • Two Main Criteria • -850 mv Polarized Potential • 100 mv of Cathodic Polarization • “ON” Potentials that Equate to Main Criteria are Acceptable • Alternative Criteria Achieving Corrosion Control Comparable to Main Criteria are Acceptable

  41. Corrosion Update CP Coupons Cylindrical CP Coupons

  42. Test Head PVC Tube Portable Reference Electrode Pipeline Wire Connection to Test Head Soil Stationary Reference Electrode Pipeline Coupons Corrosion Update CP Coupon Test Station Installation

  43. Corrosion Update • You Can Join NACE STG 35 and VOTE • You Can Submit Comments/Concerns • Jim Chmilar – Chair TG360 • jimchm@telus.net • Daniela Malakoff – Secretary TG360 • daniela.malakoff@nace.org

  44. Pipeline Safety Websites ops.dot.gov primis.phmsa.dot.gov npms.phmsa.dot.gov

  45. joseph.mataich@dot.gov 404-832-1159

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