Case Study: Gas Transmission Enforcing Natural Gas ...
Transcript of Case Study: Gas Transmission Enforcing Natural Gas ...
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