Case Study: Gas Transmission Enforcing Natural Gas Pipeline

Safety Regulation in Washington State 12/4/2014 Joe Subsits

Core Building Blocks

• Inspections • Compliance /Enforcement • Rulemaking • Risk Assessment • Emergency Preparedness • Investigations

Authority

• Definition of responsibility • Authority to write rules • Authority to write inspect • Authority to review records • Authority to photocopy records and collect evidence • Authority to investigate accidents • Authority to charge fees • Authority to penalize • Authority to stop operations

Rulemaking

• Transparency/involvement • Minimum allowable level of performance • Development strategy • Types of rules • What to address by rule

Type of rules

• Reference based • Prescriptive • Performance Based • Management based

What to address in rulemaking

• Definitions • Reporting requirements • Material specifications • Design and requirements • Construction requirements • Operating manuals/abnormal operation • Emergency Procedures • Operations requirements • Maintenance requirements • Operator Qualifications • Integrity Management

Design/ Construction requirements

• Establish allowable operating pressure • Welding procedures and qualifications • Inspection of work • Cover/clearance • Repairs • Coating application • Cathodic protection • Hydrotesting

Bath tub Curve

Operations • Public Awareness • Odorization • Control Room Management • Damage Prevention • Maintaining allowable operating pressure

Maintenance

• Valves • Pressure Control • Leak surveys • Patrolling • Corrosion Control

Integrity Management • Identify receptors (high consequence areas) • Identify threats • Risk Assessment • Assessments • Repairs • Monitoring

Type Inspections

• Procedures review • Construction • Records review • On-site visit • Operator qualifications • Integrity management work • Follow up visits

Inspection results

• Use of checklist • Exit interview • Write report • Submit findings to operator • Closure or compliance

Compliance

• Present findings • Provide time limit for response • Closure, follow up, enforcement

Enforcement

• Civil • Criminal

Why enforce

• Fairness • Credibility • Trust • Safety • Deter unsafe activity

Evidence

• Records • Photographs • Portions of O&M Manual • Statements • Previous inspection reports • Reports • witnesses

Enforcement activities

• Hearings • Penalties • Corrective actions • Judicial Action

Considerations when establishing penalties

• Authority • Gravity • Culpability • Violation history • Ability to pay • Ability to continue business • Good faith in attempt to comply • Benefits gained from non-compliance

Bellingham

Bellingham

Bellingham

Effects • 3 fatalities • $45 million in property Damage

What Happened? 16 inch product line ruptures and spills 237,000 gallons of gasoline into Whatcom Creek

Bellingham

• Causes – Third Party Damage – Failure to monitor known construction work – Failure to dig detected anomaly – Delivery Installation of wrong spring – Failure to determine cause of excessive relief valve use – Testing existing SCADA system on live system – Inadequate training, procedures and record keeping

Bellingham

Penalty • $3,050,000 civil penalty assessed • 3 people go to jail

Bellingham

Corrective Actions • Reduce operating pressure to 80% • SCADA system evaluation • Develop training program for SCADA operators • Internal inspection program and repair program • Hydrotesting • Procedures review

Lake Tapps & Toledo

Lake Tapps & Toledo

Lake Tapps & Toledo

Lake Tapps & Toledo

• Ruptures caused by stress corrosion cracking • 80% pressure drop required • Line replacement of existing 26-inch line • Development of integrity management program

Falsification of Documentation

Falsification of Documentation

• Leak surveys were performed by Company contractor

• Anonymous tip reports falsification of records • 6,300 records reviewed, 84 instances of falsification

were found • Investigation of records revealed that surveys were

not done but results were reported

Falsification

• Company(not contractor) was fined $1.25 million. • Third Party management audit conducted • Revision of QA/QC program required • Contractor lost major contract with gas company

Cast Iron Replacement

Cast iron Replacement

• Leak surveys missed • Leak survey procedures inadequate • Cathodic protection reading not collected • Cathodic protection readings were inadequate

Results • $1,000,000 penalty • 287 miles of cast iron pipe replaced • Procedures required revision • Training was conducted

Centralized Changes

• Inconsistent management of field offices • Inaccuracies in mapping • Leak surveys missed • Some valves not inspected • Procedures not applied consistently • Wrong set points for pressure control equipment • Follow up corrosion records late or missing

Centralized changes

• $2,225,000 penalty issues • Centralized QA/QC maintenance tracking process

requires • Management of change procedures required • New GIS mapping system developed and

incorporated

Conclusion

• Strong authorities, rules and inspection program are a part of the foundation to meaningful regulatory programs

• Compliance/Enforcement is a tool to make improvements in safety – Penalties can deter non-compliance – Corrective actions can be used to influence major change

within an organization