192 vs. 195 Gap Analysis

July 14-15, 2009Arlington, VA

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

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

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

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?

192 vs 195 – Phase 1 results

• There are four worksheets

• The “guts” are in the comparison worksheet

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)

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

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

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)