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Pipeline Safety Standards Incorporated Into Federal Regula7ons
Carl Weimer Execu7ve Director
h@p://www.pstrust.org
What’s The Big Deal? • Once standards are incorporated into the regula7ons they become part of the law
• Currently the actual standards are not included in the Code of Federal Regula7ons
• To see what the law requires you have to purchase the standards from the groups that draL them
• OLen the groups that draL the standards are made up primarily of industry personnel crea7ng the appearance of a conflict of interest.
Why Has This Become An Issue Now?
LIMITATION ON INCORPORATION OF DOCUMENTS BY REFERENCE.
Beginning 1 year aLer the date of enactment of this subsec7on, the Secretary may not issue guidance or a regula7on pursuant to this chapter that incorporates by reference any documents or por7ons thereof unless the documents or por7ons thereof are made available to the public, free of charge, on an Internet Website.
Why does the public (including local governments) care about access to incorporated pipeline standards?
How Else Would They Know What The Law Says?
Examples: • Integrity Management • Gathering Lines • Public Awareness Info • Leak Detec7on
San Bruno, California -‐ 2010
Gas Transmission Pipeline Integrity Management § 192.907 What must an operator do to implement this subpart?
b) Implementa)on Standards. …an operator must follow the requirements of this subpart and of ASME/ANSI B31.8S
§ 192.923 How is direct assessment used and for what threats?
(b) Primary method. An operator using direct assessment as a primary assessment method must have a plan that complies with the requirements in—
(1) ASME/ANSI B31.8S , sec7on 6.4; NACE SP0502-‐2008
Massive expansion of gathering line systems in many parts of the country
§ 192.8 How are onshore gathering lines and regulated onshore gathering lines determined? (a) An operator must use API RP 80 to determine
if an onshore pipeline (or part of a connected series of pipelines) is an onshore gathering line.
Produc7on lines are unregulated and gathering lines are less regulated than transmission lines
§ 195.444 CPM leak detecNon. Each computa7onal pipeline monitoring (CPM) leak detec7on system installed on a hazardous liquid pipeline transpor7ng liquid in single phase (without gas in the liquid) must comply with API 1130 in opera7ng, maintaining, tes7ng, record keeping, and dispatcher training of the system.
§ 192.616 Public awareness. & § 195.440 Public awareness.
each pipeline operator must develop and implement a wri@en con7nuing public educa7on program that follows the guidance provided in the American Petroleum Ins7tute’s (API) Recommended Prac7ce (RP) 1162
Why it is important that the public be given free and easy access to standards
• Because they are part of the federal laws
• Because they are some7mes created by groups with poten7al conflicts of interest to the public interest
• Because the industry consensus based standards process may not lead to the best standards
Because they are part of the federal laws
Extent of Problem
Because they are created by some groups with poten7al conflicts of interest to the public interest
AGA – “Focuses on the advocacy of natural gas issues that are priori7es for the membership and that are achievable in a cost-‐effec7ve way.” “Delivers measurable value to AGA members.”
PRCI – “PRCI is a community of the world’s leading pipeline companies, and the vendors, service providers, equipment manufacturers, and other organiza7ons suppor7ng our industry.”
API – “We speak for the oil and natural gas industry to the public, Congress and the Execu7ve Branch, state governments and the media. We nego7ate with regulatory agencies, represent the industry in legal proceedings, par7cipate in coali7ons and work in partnership with other associa7ons to achieve our members’ public policy goals.”
PPI – “PPI members share a common interest in broadening awareness and crea7ng opportuni7es that expand market share and extend the use of plas7cs pipe in all its many applica7ons.” “the mission of The Plas7cs Pipe Ins7tute is to make plas7cs the material of choice for all piping applica7ons.”
The consensus based standards process may not lead to the best standards
Without all stakeholders a consensus based process “does not lead to the best standard but to the best standard everyone will agree to.”
In other words the lowest common denominator
Possible solu7ons for implementa7on of the Congressional mandate
• API Model • PHMSA could develop it’s own standards • PHMSA could pay SDOs to develop standards for them.
Ways to poten7ally pay for changes to standard access
• Increase user fees to cover costs
• Industry cover costs from savings they get from use of such standards The Benefits of Consensus Standards – A Pipeline Case Study
www.p-‐pic.com/files/conferencereports/IPC_paper_benefits.pdf
“The 7mely publica7on of B31.8S is expected to save the industry $4.2 Billion over a 20 year period.”