Presentation on theme: "PHMSA Western Region Overview Tempe, AZ August 20, 2014"— Presentation transcript:
1 PHMSA Western Region Overview Tempe, AZ August 20, 2014
2 PHMSA Region UpdatesRelatively Quiet Year for Accidents but busyTotal Switch to Integrated Inspection Process (II)Use the Integrated Inspection Assistant Tool (IA)Continued Construction Oversight of pipeline boom in MT, WY and NE ColoradoAging Workforce and More DeparturesFocus was on:Lesson Learned from Near Misses and AccidentsJump on even smallest incidents hard and anticipate questions, e.g. flooding, Bakken crude
3 PHMSA Region Contacts & SMEs Chris Hoidal – Director of Western RegionBryn Karaus – Western Region CounselHuy Nguyen, Jeff Gilliam, Terry Larson– SupervisorsPeter Katchmar – Accident CoordinatorRoss Reineke – Construction CoordinatorTom Finch and David Mulligan – Community Assistance and Technical Services (CATS)David Mulligan and Kim Nguyen - Inspection Assistant Power UsersDustin Hubbard and Claude Allen - PDM and Mapping IssuesJerry Kenerson – Safety Related Condition Follow-up
5 Western Region Offices Western Region Office – 16 Engineers West Dakota Avenue, Suite 110 Lakewood, CO Satellite offices in: Cheyenne, WY (Accident Investigator) Billings, MT (1 engineer) Reno, NV (1 engineer) Ontario, CA (3 engineers) Anchorage, AK (5 engineers) One Regional Attorney – DC Openings – One Engineer/Inspector
6 Recap of Western Region Priorities – (2010-2013) Continue to roll on more accidents, even low level onesMultiple Orders completed or finishing up.Construction Oversight of Bakken Field pipelines (Intense public scrutiny due to commodity characteristics)Get Better at II, IA and tweak process – Better not greatFinish CRMs and DIMP - COMPLETEDDo more IMP validations in field (mandated by HQ)Moving to Next Level of IMP (Focus on Prevention and Mitigation Measures)
7 Incidents Continue to Set Pipeline Safety Agenda Integrity Management Regulations prompted by: Olympic Pipeline Rupture in Bellingham, WA (6/10/99) El Paso Pipeline Explosion in Carlsbad, NM (8/19/00) PG&E Pipeline Fire in San Bruno, CA (9/9/10) SCADA/CRM, remote valves, and Leak detection prompted and/or reinforced by the above and the more recent failures Enbridge Pipeline Spill in Marshall, MI (7/25/10) Chevron Pipeline Spills (Salt Lake City) June/Dec 2010 Exxon/Mobil Spill into Yellowstone River (7/1/11)Bellingham, 3 dead; 3rd party damage, 16 inchEl Paso 12 dead Thus, water and contaminants such as chlorides, O2, CO2, and H2S all likely contributed to the observed corrosion damage. The Safety Board therefore concludes that the corrosion that was found in line 1103 at the rupture site was likely caused by a combination within the pipeline of microbes and such contaminants as moisture, chlorides, O2, CO2, and H2S.; PG&E 8 dead, 70 homes, 30 inch pipeline, couldn’t shut valvesMarshall, MI – BBLs into Kalamazoo River
8 2013/2014 Accidents – High Profile Recent Accidents and Near Misses:7/2/13 – P66 Seminoe P/L, Crow Nation, Wyoming9/10/14 – Alyeska failure of encapsulation, MP 383/31/14 – Plymouth, WA LNG Plant –WUTC (lead) and PHMSA investigating
9 P66 Seminoe Pipeline Spill Crow Nation near Lodge Grass, MT July 2, 2013 Compression and buckling of 8-inch refined products line resulted in 600 BBLs released on to Crow Nation landCrow Nation cooperative but demanding of P66. Wanted routine updates from PHMSATerrain was hilly but not particularly steep, evidence of soil movementNo CAO issued due to fast response by operator and couldn’t add anything
11 P66 Actions Taken Replaced 500 feet of pipe. Relieved stress on over 4000 feet of pipe based on Geotechnical Engineer evaluation.Installed additional strain gauges in the area of the failure post stress relief and monitor for a year to validate if there was movement.Stand up test to ensure no other seepers in area.Perform weekly aerial patrols on pipeline until the completion of a deformation/strain tool and other slope movement areas remediated.
12 Seminoe Pipeline Lesson Learned Ground movement doesn’t need to be a sudden catastrophic slope failure to fail pipeILIs should be selected to look for deformation, ovality, and wrinkles caused by ground movementRemember to treat incidents on Sovereign Nations differentlyCompanies must consider land movement and water crossings in their IMP preventative and mitigative measures.
13 Alyeska Vent Encapsulation Failure September 2013 Large 10-inch diameter coupon of carrier pipe found in Valdez Back Pressure ValveRecent ILI data showed that it had come from recently installed vent encapsulation over 400 miles to northNo release but encapsulation and hole sleeved. It appears epoxy in sleeve expanded and pushed carrier pipe inwardsOver 100 of these had been put on during previous 2 yearsSimulated encapusulation in Fairbanks yard failedIssued Order to investigate other encapsulations on pipe requiring additional testing, ILI runs, and repairs
16 Lesson LearnedDon’t use untried methods of repair that don’t follow manufacturers guidelines.Need boots on ground – neither us or JPO knew these were being put on.
17 P66 Spill “Out of Service” Pipeline Spill Wilmington, CA – March 17, 2014 On March 17, 2014, Phillips (P66) is notified by emergency responders of crude oil leaking up from below pavement in a residential area of Wilmington, California. While leak was close to a P66 Wilmington refinery, they didn’t think it was theirs.
18 P66 Wilmington, CA spillOn March 18th, P66 excavated the leaking pipeline and determined it was actually their line. P66 had purchased the pipeline from the previous operator in P66 thought it had been properly abandoned and purged prior to their purchase.The leaking pipeline was a 10-inch diameter, 0.25 inch thick wall, carbon steel pipe installed in The cause of failure was an internal “pinhole” corrosion leak on a weld.P66 estimates that 39 barrels of crude oil was released and recovered. Estimated property damage reported $400,900.
19 Lesson LearnedPipelines are either active or abandoned. There is no “out of service” or “idled” designation for pipelines under Parts 192 or 195.Even if the previous operator says lines were abandoned make sure you review how it was done and confirm it is actually isolated, cleaned and purged.Treat idled lines like active lines under IMP.California Congresswoman may propose legislation clarifying and confirming status of pipelines.
20 Williams LNG Facilty Plymouth, WA – March 31, 2014
21 Lesson LearnedLook at pre-liquefaction processes or any processes that could affect LNG facilityEvacuation zones are much wider than is common knowledgeChange must be focus, e.g. this plant had had its adsorbers recently overhauledGood State Agents Garner Public Confidence and are Priceless to PHMSA (WUTC will cover in more detail)
22 Accidents w/ Oversight Impact July 2011- June 2013 Exxon Mobil Silvertip Pipeline Spill – July 1, 2011TransCanada Bison Pipeline Rupture – July 20, 2012Chevron Willard Bay, Utah Spill – March 2013
23 Exxon Mobil Pipeline Spill July 1, 2011 Exxon Mobil Pipeline spills 1500 BBLs into Yellowstone River during record flooding.CAO issued 7/5 to take out of service until they put HDD under Yellowstone River, did water crossing surveys and remediation, rework SCADA training and abnormal operating procedures.
25 Preliminary FindingsExxonMobil Silvertip pipeline released estimated 1500 barrels of crude oil into the Yellowstone River near Laurel, Montana; Est. $42M damagesRiver scour is cause of ruptured pipelineEMPL was aware of the flood conditionsEMPL detected pressure drop at river and shut pipeline pumps down in 7 minutesDespite having numerous remote actuated valves at rivers, controllers took 56 minutes after first alarm to close valve adjacent to river allowing crude oil to drain into the river
26 Montana Governor’s Task Force Reason for Study: As a result of the July 2, 2011 crude oil spill into the Yellowstone River, ensure the integrity of petroleum pipelines at major water crossings that affect rivers in Montana.Primary Purpose: Collaborate with State of Montana to compile an inventory of petroleum pipelines at water crossings and determine if they are currently safe.
27 Other Purposes of Survey and Lessons Learned Determine if additional steps are required before Spring 2012 run off.Determine adequacy of pipeline operators’ patrolling methods and remedial actions at water crossingsDevelop recommendations regarding:Enhance PHMSA inspection guidance to ensure operators are meeting all aspects of regulations, particularly with respect to protecting their pipelines from water-related damage.Identify possible regulatory changes to PHMSA leadership expanding the requirements for water crossings.
28 TransCanada Bison Rupture Near Gillette, WY July 20, 2012 Pipeline ruptured within 6 months of being put into servicePipeline was first pipeline to be put into service using the Alternative MAOP regulationCAO issued on 7/21 requiring DCVG, completion of ILI run and remediation digs.Metallurgical analysis
30 TransCanada Lesson Learned Pipeline companies still need to ensure there is good quality control during all phases of construction.The defect can manifest itself before the baseline pig run, in this case 6 months, can be analyzedHappened within a few days after being smart piggedDCVG revealed other areas of “lowering in” damage.Relative low Charpy value in steel (still met API 5L)
31 Chevron Pipeline Spill March 18, 2013 Chevron Products Pipeline spilled 500+ BBLs adjacent to Willard Bay due to corrosion near longitudinal seamsplit on Low Frequency ERW pipe.CAO issued 3/22 to reduce pressure, hydrotest LFERW pipeline in area of Willard Bay, notify emergency responders and stakeholders during start up, and conduct metallurgical examination of failed pipe.Will expand CAO scope based on these findings.
32 Chevron Northwest Products _ Willard Bay, UT – March 2013
33 Lesson Learned Ensure that IMP program reflects all of line pipe Match up alignment sheets with corporate IMP plansJust because LFERW has not failed doesn’t mean it’s not seam susceptibleSpike Hydros do have placeCan not communicate enough – Keep logs of contacts
34 Older Accidents w/ Oversight Impact June 2010- June 2011 Major Accidents:Bridger Lake Spill April 2010Chevron Crude Oil Spill June 2010Chevron Crude Oil Spill in December 2010Alyeska PS9 Tank Overfill in May 2010Alyeska PS1 Corrosion Leak at PS1 in January 2011PG&E San Bruno, CA explosion in September 2010
35 Pipeline Spill April 5, 2010Unknown crude oil line spills 2000 BBL near Mt View, WYCAO issued 4/28 to take out of service until O&M, OQ, and ILI conducted. Tank allowed to come back into service.
36 Lessons LearnedInspectors missed this pipeline by not looking around for new pipelines when in the areaCheck out pipeline facilities in person; we called about this one and took operator’s word of regulatory exemption without verifying
37 Another High Profile Accident in Alaska Alyeska Pump Station (PS) 9 – May 25, 2010Overfilled Breakout Tank at PS 95000 BBLs spilled out vents and into containment area.Failed Unit Power System (UPS) prevented communications, tank monitoring and valve control.Tank appears to be damaged.Issued a CAO requiring full time monitoring at PS9 and staffing by OQ personnel at site. Verification that pipeline could operate without PS 9 relief.
39 Lessons LearnedMaintain Close Working Relationship with State and Federal OSCsMove Fast – Have an Enforcement Strategy to Move QuicklyFocus on Change During InspectionsEnsure Operators have Some or Sufficient Qualified Individuals Present During All Maintenance Operations
40 Chevron – Salt Lake City, June 12, 2010 Approx 750 BBL of crude spill into Salt Lake City creeks and small lakes on June 11/12, 2010.Power company built substation immediately adjacent to pipeline. Fence post directly on top of pipeline.Fault current burned dime sized hole in pipeline.
42 Lesson Learned Roll quick and get there quick Personal experience is to lean into itPut someone embedded in Unified Command during High Profile AccidentsJust because you are talking to Operator and FOSC doesn’t mean your message is getting out; Goes better when people know someone is in charge (people want to be in loop)Keep State Partner informed firstWork with Mayors or County CommissionersVolunteer to Speak at Community MeetingsTalk to Congressman
43 Lesson Learned We need to spend more time on the right of way AC and fault current mitigation not being looked at hard enoughROW patrol methods are not appropriate for terrain or foliage coverPrediction – Rulemaking for remote valve actuation, or stronger focus on the preventative and mitigative part of IMP
46 Lesson LearnedDon’t have a release in same area after remedial actionsMake sure that the operators fix or your remedial actions didn’t introduce other risksOutreach needs to be even greater – Now regulator’s ability is in question.Figure out someway to give other stakeholder inputWorked with Mayor’s consultantRealize that even then, you need to give local officials some credible input – valve placement planning, extra time.
47 Alyeska Pump Station 1 January 8, 2011 A crude oil release was discovered on the Trans-Alaska Pipeline (TAPS) at Pump Station #1 (PS1).The leak source was from below ground piping that led to the basement of the of booster pump building. The piping was encased in concrete and could not be accessed.The TAPS could not be operated without the booster pumps so the entire pipeline system needed to be shutdown to stop the leak and enact the repairs.
48 Alyeska Pump Station 1Cold weather and lowering crude oil temperatures within the TAPS pipeline became a serious concern.If the temperature on TAPS got much below freezing on other sections of the 800-mile long pipeline, or on idled North Slope production lines, there was a strong possibility of other crude oil releases occurring during the shutdown period or after eventual restart of the systems
49 Alyeska Lesson Learned PHMSA needs inspectors to focus more on station piping during IMP inspections.Sync up expectations with other responders; in this case we were lucky to have a long standing relationship where we were comfortable recommending line be restarted with leak.Sometimes it is better to let someone else take lead and work behind scenes.
51 PG&E, San Bruno, CA September 9, 2010 30 inch gas transmission pipeline in dense suburbRuptured at 6:11 pm during rush hour8 fatalities, over 50 injuries38 homes destroyedOver an hour to close two valves less than a 1 ½ miles apartGrandfathered Pipelines (1948 and 1956) – No hydroPG&E used Direct Assessment
52 Lesson Learned Feds and State Need to support each other - Gas IMP rule is interpreted differently by different operators, States, and FedsNTSB doesn’t conduct investigations – they coordinateHelps if you have a strong enforcement record with operator in pastDirect Assessment is being misapplied – many companies do not know what they have in groundWestern Region had many small operators that had not gone through and IMP review in CA.
53 Integrated Inspections System approach – contiguous, same vintage, same risks, one or more inspection unitsHeavy focus on Preparation to determine what to ask prior to inspectionsTap multiple expertsData driven approach to determine where we focus our inspection resourcesAre beginning to find common precursors to recent incidents, e.g. hydraulic changes, parallel structures, AC interference, type of assessment
54 Integrated Inspection Time consuming and labor intensive – taking 6 to 15 months from start to finishTeams are hard to assemble and coordinateOperators are complaining about time to conductStaff committed to inspections for months – lose management ability to re deploy staffConcerns that if we wait too long to conduct periodic inspections that operator will backslideInconsistency on II approach between regions needs to be reduced further