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U.S. Department of Transportation

Pipeline and Hazardous Materials

Safety Administration

Federal Regulations Reviewand

Inspection Updates

Public Awareness Program




Topics

PHMSA 2013 Data Update

Public Awareness Regulations Review

Public Awareness Inspection Review

Gathering Line Overview

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What We RegulatePipeline Miles by System Types – end of CY 2012, as-of 3/7/2014

System Type Miles %Total # Operators

Hazardous Liquid 185,629 7% 410

Gas Transmission 303,308 11% 953

Gas Gathering 16,728 1% 342

Gas Distribution

(Mains & Services )2,138,676 81% 1,356

Total 2,644,341Some Operators

have multiple

System Types

Liquefied Natural Gas 130 Plants 203 Tanks 82




Categories of Incident Reports

4

All Reported – everything operators report

Serious – fatality or injury requiring in-patient hospitalization, but Fire First excluded. Fire First are gas

distribution incidents with a cause of “Other Outside Force Damage” and sub-cause of “Nearby Industrial, Man-made, or Other Fire/Explosion”

Significant include any of the following, but Fire First excluded: 1. Fatality or injury requiring in-patient hospitalization 2. $50,000 or more in total costs, measured in 1984 dollars 3. Highly volatile liquid (HVL) releases of 5 barrels or more 4. Non-HVL liquid releases of 50 barrels or more 5. Liquid releases resulting in an unintentional fire or explosion




Serious IncidentsAll System Types downward trend continues in 2013

5

84% Gas Distribution

12% Hazardous Liquid

4% Gas Transmission




Fatalities and InjuriesFatality count continuously down since 2010

6

Injury count down from 2012




2013 Gas Distribution IncidentsTop Causes

• Excavation Damage

• Other Outside Force Damage

Serious Top Causes


• Other

7





8

Gas Distribution downward trend continues in 2013




Significant IncidentsAll System Types slight rise in 2013

9

Gas Distribution slight rise in 2013




Gas DistributionSignificant Incidents by Cause

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2013 Gas Gathering Incidents

11

Top Causes

• Corrosion

• Other

No SeriousIncidentssince 2006





12

Gas Gathering slight decline in 2013




- 13 -

Gas GatheringSignificant Incidents by Cause




2013 Gas Transmission Incidents

14

Top Causes

• Material/Weld/Equip Failure

• Corrosion


Serious Incident caused by Corrosion





15

Gas Transmission dips down to one again in 2013





16

Gas Transmission slight rise in 2013




- 17 -

Gas TransmissionSignificant Incidents by Cause




GT Significant Incidents in

HCA per HCA Mile

Interstate Rate Less Than

18

Intrastate Rate




2013 Hazardous Liquid Incidents

19

Top Causes

• Material/Weld/Equip Failure

• Corrosion

• Incorrect Operation

Serious Incidents

• Other and Outside Force



Safety Administration Serious IncidentsAll System Types downward trend continues in 2013

20

Hazardous Liquid rises to three in 2013





21

Hazardous Liquid rises to the highest level since 1997




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Hazardous LiquidSignificant Incidents by Cause



Safety Administration HL Large Spills in HCA per HCA Mile

23

Large Spills are accidents including one or more of these consequences:

• death or personal injury requiring hospitalization

• property damage greater than $50,000 in 1984 dollars

• more than 5 barrels released

• fire or explosion

• pollution of water




Public Awareness ProgramRegulations Review




Background

• Regulatory Background

– Gas

1970: 192.615 (Emergency plans)

1983, 1995: 192.614 (Damage prevention )

1995: 192.616 (Public awareness)

– Liquid

1980: 195.440 (Public awareness)

1995: 195.442 (Damage prevention)

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Why Public Awareness? It’s the Law

• Pipeline Safety Improvement Act of 2002

– Each pipeline facility operator “shall carry out a

continuing program to educate the public…”

– “The Secretary may issue standards prescribing

elements of an effective public education program

• Final Rule in May 2005 (Docket RSPA-03-15852);

effective June 20, 2005

– 192.616 for Natural Gas Pipelines

– 195.440 for Hazardous Liquids Pipelines

– Incorporated by reference the guidelines

in API RP 1162, Public Awareness Programs for

Pipeline Operators, 1st Edition- 26 -




Subpart L – Operations

192.616

Transportation of

natural and other gas

by pipeline

Parts 186 to 199

Subpart F – O&M

Part 195.440

Transportation of

hazardous liquids by

pipeline

TITLE 49

Subtitle B Chapter I

Subchapter D

(Pipeline Safety)

Where are Public Awareness Rules?

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§192.616/ §195.440 Public Awareness

a) * Must develop and implement a written continuing public

education program that follows the guidance provided in the

API RP 1162.

b) * Must follow general program recommendations of API RP

1162 and assess the unique attributes and characteristics of

operator’s pipeline and facilities.

c) * Must follow general program recommendations, including

baseline and supplemental requirements of API RP 1162, unless

operator provides written justification why compliance with all

or certain provisions of the recommended practice is not

practicable and not necessary for safety.

Public Awareness Regulations

* Master meter & petroleum gas operators exempt (unless transports gas as primary activity). - 28 -




§ 192.616/ §195.440 Public Awareness

d) * Program must specifically include provisions to educate the

public, appropriate government organizations, and persons

engaged in excavation related activities on:

(1) Use of a one-call notification system prior to

excavation and other damage prevention activities;

(2) Possible hazards associated with unintended releases

from a pipeline facility;

(3) Physical indications that such a release may have occurred;

(4) Steps that should be taken for public safety in the event

of a pipeline release; and

(5) Procedures for reporting such an event.







e) * Program must include activities to advise affected

municipalities, school districts, businesses, and

residents of pipeline facility locations.

f) * Program and the media used must be as

comprehensive as necessary to reach all areas in which

the operator transports gas.

g) * Program must be conducted in English and in other

languages commonly understood by a significant

number and concentration of the non-English speaking

population in the operator's area.






§192.616/ §195.440 Public Awareness

h) Operators in existence on June 20, 2005, must have

completed their written programs no later than June 20,

2006 (June 13, 2008 for master meter or petroleum gas

system operators).

i) Program documentation and evaluation results must be

available for periodic review by appropriate regulatory

agencies.






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j) Unless the operator transports gas as a primary activity,

master meter or petroleum gas system operators are not

required to develop a public awareness program as

prescribed in paragraphs (a) through (g). Instead must

develop and implement a written procedure to provide its

customers public awareness messages twice annually.

The message must include:

1) A description of the purpose and reliability of the

pipeline

2) An overview of the hazards of the pipeline and

prevention measures used;

3) Information about damage prevention;

4) How to recognize and respond to a leak; and

5) How to get additional information.




Other Relevant Sections

• Public Awareness interacts other sections of code

– Damage Prevention

• §192.614 and §195.442

– Emergency Response

• §192.615 and §195.402(e)(8)

– Integrity Management – Subpart O

– Alternative MAOP - §192.620

– Special Permits

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API RP 1162, 1st Edition, Dec 2003

• Incorporated by reference (in its entirety)

into Parts 192 and 195

• Contains additional requirements

– Message Frequencies

– Message Content

– Supplemental Enhancements

– Program Evaluation

- 34 -




Related Advisory Bulletins

• PHMSA-2010-0307: Pipeline Safety: Emergency Preparedness

Communications

• ADB-05-03: Planning for Coordination of Emergency Response

to Pipeline Emergencies

• ADB-03-04: Pipeline Safety: Pipeline Industry Implementation of

Effective Public Awareness Programs

• ADB-03-08: Self-Assessment of Pipeline Operator Public

Education Programs

• ADB-93-02: Advisory to Owners and Operators of Gas

Distribution and Gas Transmission Facilities; Continuing Educational

Program for Gas Customers and the Public

• ALN-91-04: NTSB recommendations S P-91-3/P-91-4, 03/15/90

NY leak/explosion: Requiring operators to extend their public

education/emergency preparedness programs - 35 -




Additional Guidance

• The intent of the regulation is that messages should

provide “enough information so that in the event of a

pipeline emergency, the intended audience will know

how to identify a potential hazard, protect

themselves, notify emergency response personnel,

and notify the pipeline operator” (API RP 1162,

Section 4)

• Generic messages do not meet the intent of the PAP

regulations because they do not necessarily provide

“awareness”

• Message content must be pipeline system and

product specific

- 36 -




Resources• Regulatory Requirements

• API RP 1162

• Public Awareness Program Workshops

• Inspection and Enforcement Documents

• FAQs

http://primis.phmsa.dot.gov/comm/PublicAwareness/PublicAwareness.htm?nocache=8605- 37 -




Public Awareness ProgramInspection Status

- 38 -




• PAP Inspection timeline:

– Federal PAP Inspections completed by end of 2012

– Interstate agent inspections completed by end of 2012

– States are also incorporating PAP inspections into their normal inspection cycle by end of 2013

• Finalized documented published online:

– PAP Effectiveness Inspection Form

http://www.phmsa.dot.gov/pipeline/library/forms

– PAP Enforcement Guidance Document

http://www.phmsa.dot.gov/foia/e-reading-room

PAP Inspection Updates

- 39 -




PAP Completed Inspections:

– Total PAP Inspections end of 2012

»313

– PHMSA lead Inspections end of 2012

»135

– States Lead PAP inspections end of 2012

»178


- 40 -




PAPEE Completed Inspections

End of 2012 End of 2013

Total Inspections 313 614

PHMSA Lead 135 135

State Lead 178 477


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Public Awareness InspectionsSection One (2012)

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Public Awareness InspectionsSection One (2013)

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2012SECTION AGENCY

HEADER Satisfactory UnsatisfactoryNot

ApplicableNot

Checked total % Unsat

1.01 PHMSA Written Public Education Program 561 53 3 4 621 8.53%

1.02 PHMSA

Management Support 535 75 4 6 620 12.10%

1.03 PHMSA Unique Attributes and Characteristics 533 73 10 5 621 11.76%

1.04 PHMSA Stakeholder Audience Identification 512 98 3 5 618 15.86%

1.05 PHMSA Message Frequency and Message Delivery 574 42 0 5 621 6.76%

1.06 PHMSA Written Evaluation Plan 508 102 4 5 619 16.48%

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2013SECTION AGENCY

HEADER SAT UNSAT N/ANot

Checked total % Unsat

1.01 PHMSA Written Public Education Program 112 20 2 1 135 14.81%

1.02 PHMSAManagement Support 108 22 2 3 135 16.30%

1.03 PHMSAUnique Attributes and Characteristics 106 25 2 2 135 18.52%

1.04 PHMSAStakeholder Audience Identification 81 49 1 2 133 36.84%

1.05 PHMSA Message Frequency and Message Delivery 118 14 0 2 134 10.45%

1.06 PHMSAWritten Evaluation Plan 91 40 2 2 135 29.63%

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1.04 – Stakeholder Audience Identification

• Missed Audiences/ Parts of Audiences

• Didn’t include other information in audience

ID (IMP) to Establish distance either side of

pipeline

1.06 – Written Evaluation Plan

• Written plan to conduct and evaluate

• Correct Frequencies

• Statistical Sample Size, Confidence Level and

M.O.E., by Stakeholder Audience

Section One

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• Written program described who, what, when,

where, how, why

• Cross referenced to other company procedures

such as:

– Emergency response plans

– Integrity management plans

• Unique attributes not listed or specific, missing:

– System type

– Types of products

– Lines and/or facilities covered

– All company assets/facilities covered

Written PAP

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Public Awareness Inspections Section Two (2012)

- 48 -




Public Awareness Inspections Section Two (2013)

- 49 -




2012

SECTION2.01 PHMSA English and other Languages 508 86 24 3 621 13.85%

2.02 PHMSA Message Type and Content 487 129 1 4 621 20.77%

2.03 PHMSAMessages on Pipeline Facility Locations 488 100 30 4 622 16.08%

2.04 PHMSA Baseline Message Delivery Frequency 498 113 4 4 619 18.26%

2.05 PHMSAConsiderations for Supplemental Program Enhancements 511 96 9 4 620 15.48%

2.06 PHMSAMaintaining Liaison with Emergency Response Officials 509 99 5 4 617 16.05%

- 50 -




20132.01 PHMSA English and other

Languages92 39 2 2 135 28.89%

2.02 PHMSA Message Type and Content

79 53 1 2 135 39.26%

2.03 PHMSA

Messages on Pipeline Facility Locations

114 15 4 2 135 11.11%

2.04 PHMSA

Baseline Message Delivery Frequency

108 23 2 2 135 17.04%

2.05 PHMSA Considerations for Supplemental Program

Enhancements

103 26 4 2 135 19.26%

2.06 PHMSAMaintaining Liaison

with Emergency Response Officials

97 32 3 3 135 23.70%

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2.01 - English and Other Languages

Process, Frequency, Source

2.02 - Message Type and Content

Message Mapping (1162 / PAP/ Brochures)

2.04 - Delivery of materials and messages

Meet or exceed the baseline frequencies

specified

2.06 - Maintaining Liaison with Emergency

Responders

ERP Available, Sharing Capabilities

Non-Attendees (Closing the Loop) every three yrs

Section Two

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• Defined process with thresholds for actions

• Commonly provided in Spanish (as default)

• Emergency Response & Public Official

(English only)

• (800) Translation number on print material

• TDD/TYY (speech - hearing impaired #on print

material)

ImplementationLanguages

- 53 -




• Increased message delivery frequency

• Messages in multiple languages

• Emergency # translates to other languages

(Spanish, French, Japanese, Russian, Korean,

Arabic, etc)

• 24 hour public awareness phone #

• Agricultural mailings

• Scratch and sniff NG cards

• ER website portal to get operator specific

information (capabilities across the state)

ImplementationSupplemental Enhancements




Operator

Specific

Collaborative

Educating Stakeholders

???

ImplementationMessages




• Collaborative operator public meetings (limited

specific operator interaction)

• Tracked who attended meetings and followed up

• Verified ER lists for accurate contact information

• Generic information sent may not motivate to

attend

• Inconsistent information shared from ER plan

• Difficult getting ER officials engaged

ImplementationMaintaining Liaison w/ ER Officials




Public Awareness InspectionsSection Three (2012)




Public Awareness InspectionsSection Three (2013)




2012

3.01 PHMSA Measuring Program Implementation 427 179 9 4 619 28.92%

3.02 PHMSA Acceptable Methods for Program Implementation

Audits 520 83 13 4 620 13.39%

3.03 PHMSA Program Changes and Improvements 480 117 16 4 617 18.96%




20133.01 PHMSA

Measuring Program

Implementation

87 42 4 2 135 31.11%

3.02 PHMSAAcceptable Methods for

Program Implementation Audits

116 13 4 2 135 9.63%

3.03 PHMSAProgram Changes

and Improvements

101 28 3 2 134 20.90%

Averages 101 28 4 2 135 21%




3.01 - Measuring Program Implementation

• Documents that Verify Annual Review

• Guide a Consistent Process.

3.03 - Program Changes and Improvements

(Document what was reviewed, Considered,

Decisions, implementation, by whom and

by Date Due)

Section Three




Some operators:

• Documented meetings, dates, participants, agenda

• Meeting with cross-functional review teams (or prevent

silos)

• Defined/monitored metrics

• Combined annual audit & effectiveness evaluation in

year 4

• Linked timing and review with other programs:

• Integrity management

• Emergency response

Evaluations (Annual Audits)




• Changes/documented tracked?

• Implemented changes during next year

• Verified adequate resources were available

• Updated written plan

• Obtained current management support

• Reviewed supplemental enhancements

• Changes to print material

Program Changes and Improvements




Public Awareness InspectionsSection Four (2012)




Public Awareness InspectionsSection Four (2013)




2012

4.01 PHMSAEvaluating Program Effectiveness 386 200 25 7 618 32.36%

4.02 PHMSA Measure Program Outreach 424 152 35 8 619 24.56%

4.03 PHMSA Measure Percentage Stakeholders Reached 421 153 36 8 618 24.76%

4.04 PHMSAMeasure Understandability of Message Content 413 165 33 8 619 26.66%

4.05 PHMSA Measure Desired Stakeholder Behavior 421 151 33 10 615 24.55%

4.06 PHMSA Measure Bottom-Line Results 412 164 33 9 618 26.54%

4.07 PHMSA

Program Changes 429 140 36 10 615 22.76%




20134.01 PHMSA

Evaluating Program Effectiveness

74 47 11 3 135 34.81%

4.02 PHMSAMeasure Program

Outreach81 41 10 3 135 30.37%

4.03 PHMSAMeasure Percentage

Stakeholders Reached

77 44 11 3 135 32.59%

4.04 PHMSAMeasure

Understandability of Message Content

73 49 10 3 135 36.30%

4.05 PHMSAMeasure Desired

Stakeholder Behavior

73 46 9 5 133 34.59%

4.06 PHMSAMeasure Bottom-Line

Results93 28 9 4 134 20.90%

4.07 PHMSA Program Changes 82 37 10 3 132 28.03%

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4.01 - Evaluating Program Effectiveness

4 years from Implementation, Sample Size, MOE,

Confidence Level

4.02 - Measure Outreach

Actual Number by Stakeholder Audience

4.03 - Percentage of Stakeholders Reached

4.04 - Understandability of Message Content

4.05 - Desired Stakeholder Behavior

4.06 - Bottom Line Results

Considered other Bottom Line Measures

4.07 - Program Changes

Document Changes -

Section Four

- 68 -




How effective is the operator’s public

awareness program?

• Collecting data is not the only component to

completing an effectiveness evaluation.

• Operator effectiveness evaluations should:

• Identify program metrics

• Describe evaluation methodology

• Summarize findings or conclusions

• Identify changes in written plan and/or

implementation

Section Four




• Most operators putting forth effort and

improving programs with creative approaches

• Process/methodology improvements are needed

with annual audits/effectiveness evaluations

• Motivating stakeholders to stop, listen, and

change

• Balancing information overload with specific

messages

Conclusion




Gathering Pipelines

• What is a gathering pipeline?

transport gases and liquids from the commodity's

source - to a processing facility, refinery or a

transmission line.

• Gathering lines are defined as:

For natural gas, a pipeline that transports gas from a

current production facility to a transmission line or

main (49 CFR 192.3) as determined using an industry

standard (49 CFR 192.8).

For hazardous liquids, a pipeline 219.1 mm (8 5/8 in) or

less in nominal outside diameter that transports

petroleum from a production facility (49 CFR 195.2).- 71 -




Gas Gathering

• §192.8 How are onshore gathering lines and

regulated onshore gathering lines determined?

An operator must use API RP 80 (incorporated by

reference, see §192.7), to determine if an onshore

pipeline (or part of a connected series of pipelines) is

an onshore gathering line. The determination is subject

to the limitations listed below.

After making this determination, an operator must

determine if the onshore gathering line is a regulated

onshore gathering line under paragraph (b) of this

section. (Type A or B)- 72 -




Gas Gathering

• §192.9 What requirements apply to gathering

lines?

Offshore gas gathering pipelines and high-

pressure onshore lines (Type A) must meet all

requirements of 49 CFR192 applicable to gas

transmission pipelines.

Onshore gas gathering pipelines that operate at

lower pressures (Type B) must comply with a

subset of these requirements specified in 49 CFR

192.9.

- 73 -




Liquids Gathering

• §195.11 What is a regulated rural gathering line

& what requirements apply?

A regulated rural gathering line means an onshore

gathering line in a rural area that has: a nominal

diameter from 6 5/8 inches (168 mm) to 8 5/8 inches

(219.1 mm); is located in or within one-quarter mile (.40

km) of an unusually sensitive area as defined in

§195.6; and operates at a maximum pressure

corresponding to a stress level greater than 20-percent

of the specified minimum yield strength of the line

pipe; or if the stress level is unknown or the pipeline is

not constructed with steel pipe, a pressure of more

than 125 psi (861 kPa) gage.- 74 -




Liquids Gathering

• §195.11 What is a regulated rural gathering

line & what requirements apply?

Prepare, follow, and maintain written procedures

Identify all segments of pipeline meeting the criteria.

Design, install, construct, inspect, and test the in compliance with this part.

For non-steel pipelines constructed after, notification requirement.

Reporting requirements in subpart B.- 75 -




Liquids Gathering• §195.11 What is a regulated rural gathering line

& what requirements apply?

Establish maximum operating pressure.

Install and maintain line markers.

Continuing public education program.

Damage prevention program.

External corrosion control for steel pipelines.

Internal corrosion prevention and mitigation for steel pipelines.

Operator Qualification.- 76 -




Gathering Pipelines

• If regulation is eventually extended to all

onshore gathering pipelines, who will be in

charge of regulating them?

Most onshore gathering pipelines begin and end in

the same state. While PHMSA is responsible for

conducting inspections on pipelines that cross state

boundaries, individual states' w/certified pipeline

safety agencies govern lines that do not. Intrastate

pipelines are regulated by these agencies through

adoption and enforcement of PHMSA Federal safety

standards. PHMSA's role is to oversee state agency

performance. The State maintains direct regulatory

authority, but must maintain Federal Regulations.- 77 -




Links to PHMSA Gathering Pipeline Information

http://www.phmsa.dot.gov/

http://phmsa.dot.gov/pipeline/guidance

http://phmsa.dot.gov/pipeline/regs/advisory-bulletin

- 78 -



http://phmsa.dot.gov/pipeline/regs/advisory-bulletin




Questions

Contact: William (Bill) LowryCommunity Assistance & Technical Services

[email protected]

Thank you!

mailto:[email protected]

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