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)