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Compliance and Integrity Resource Needs Oklahoma City, OK October 2016 IC-‐Solu8ons-‐LLC
www.ic-‐solu8ons-‐llc.com Oklahoma City, OK dkelly@ic-‐solu8ons-‐llc.com
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2004 -‐ Part 192, 97 Amendments (130 pg) 2015 – Part 192, 120 Amendments (153 pg)
Senate unanimously approves pipeline safety reauthorization bill Nick Snow – O&G Journal Apr 4, 2016 “...finish implementing 2011 reauthorization bill..”, “...increase inspection & enforcement staff..”
Senate vote sends 2016 pipeline safety bill to White House Nick Snow – O&G Journal June 20, 2016 “...PHMSA wide-range emergency order authority..”, “...operators spend more than $2 billion to evaluate, maintain, and perform preventative maintenance on their pipelines.”
Upstream Independents protest PHMSA’s proposal for gathering lines Nick Snow – O&G Journal July 25, 2016 “The producers particularly protested PHMSA’s proposing to define “onshore production facilities” as “terminat[ing] at the furthermost downstream point where: measurement for the purpose of calculating minerals severance occurs; or there is commingling of the flow stream of two or more wells.”
Regula8on -‐ UPDATES
2 pages & 2 amendments per year to evaluate applicability, revise procedures, and implement.
Organiza8on Total Assets
Conserva8on Interna8onal Founda8on 251,532,294
Na8onal Audubon Society Inc 450,334,791
MassachuseZs Audubon Society Inc 243,744,134
Student Conserva8on Associa8on Inc 24,259,646
Appalachian Mountain Club 133,871,838
Rocky Mountain Ins8tute 18,910,188
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Aug-‐95
Jun-‐96
Apr-‐97
Feb-‐98
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Jun-‐01
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Number of Registered Organiza4ons NTEE cat. C30 -‐ Natural Resources
Conserva4on & Protec4on
Source: Na8onal Center for Charitable Sta8s8cs (NCCS)
Annual growth rate of 4.7%
NTEE Code major category “C – Environment” annual growth 2.3%
Built on Rocky Mountain Ins8tute’s 30 years of research and work in the field, Reinven@ng Fire maps pathways for running a 158%-‐bigger U.S. economy in 2050 but needing no oil, no coal, and no nuclear energy.
Organization Total Assets
Conserva8on Interna8onal Founda8on 251,532,294
Na8onal Audubon Society 450,334,791
MassachuseZs Audubon Society 243,744,134
Student Conserva8on Associa8on 24,259,646
Appalachian Mountain Club 133,871,838
Rocky Mountain Ins8tute 18,910,188
C -‐ Environment 2015 gross receipts $12.1B
Regula8on Incubators
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2009 2010 2011 2012 2013 2014 2015 2016
ILI miles
PT mileage
Total inspect miles
Feature excava8ons
Gas Transmission Inspec8on
Data Source: PHMSA Annual Report
4.4% annual
ILI Terms: POD POI, and Sizing
Inspec8on and ILI – Gas Transmission • 2010-‐2015 Time Frame
• Total inspec8on mileage increases by 4.4% per year avg. • Total mileage decreases by 0.15% per year avg.
• 2012-‐2015 subset to remove 2011 anomalies. • Total inspec8on mileage increase by 6.95% per year avg. • Feature excava8ons because they met operators criteria increase by 34.9% per year
avg.
Takeaway-‐ We are looking more pipe every year and we are finding a greater number of excava@on qualifying features.
Tool advancements and a more complicated ILI Decision Corrosion Inspec8on: Caliper MFL Ultrasound Eddy Current EMAT Laser
Addi8onal Service and Data: Informa8on XYZ Sweeping & Scrapping Speed Control Mul8-‐diameter PMI
1960 2020
1999 2015
2007GE Multi-‐diameter MFL
1977BG high-‐res MFL
2001DOT 195 App C
1993PII wheeled UT
2004DOT 192 Subpart O
1972KALIPER â
1964Tuboscope 90°
May 04Act Speed Cntrl
Dec 2004IMU
1963Shell eddy current patent
Sep 02EMAT
1986UT tool
Dec 99TFI crack tools
Sep 08GE MagneScan Train
Jun 14PMI
2012SmartPlug
82% of 2015 inspected pipe
ILI technology Renaissance
Cost of Compliance incident review Line 901, Plains Pipeline, Santa Barbara County, CA 5/19/2015-‐ Line 901, a 24” buried and insulated pipeline carrying heated crude oil from Exxon Mobile storage tanks in Las Flores Canyon to the Plains Gaviota Pumping sta8on ruptured and released and approximate 2,934 bbl of crude oil of which 500 bbl migrated thru a highway culvert to the Pacific Ocean. No fatali8es were associated with the release, property damage and cleanup cost are at $142,931,884 as of 12/23/2015. for images hZps://www.flickr.com/photos/jw4pix Penal8es and Lawsuits phases are just beginning. • Central Coast Regional Water Quality viola8on $25,000/day & $25/gal • PHMSA es8mated $200,000 penalty assessment for single day spill PHMSA Failure Inves8ga8on Report iden8fied contributory causes include: • Ineffec8ve protec8on against external corrosion; coa8ng & insula8on system, CP system not effec8ve beneath pipeline
insula8on. • Failure to detect; ILI tool and analysis of ILI data did not characterize the extent of the depth. • Lack of 8mely detec8on;
• SCADA system lacked safety related alarms and staff did not iden8fy abnormal condi8ons • Pipeline controller restarted Line 901 ater rupture. • Pipeline leak detec8on system lacked instrumenta8on and algorithms to monitor line pack. • Lack of training for control room staff related to ER, shutdown, and leak detec8on.
Failure site feature: 12.1”x7.4” 0.318 depth ~89% wall loss ILI survey feature called (13 days before): 5.38”x5.45” 47% wall loss
Where does Compliance ac8vi8es end and Asset Management begin? • Do you design and monitor cathodic protec8on for non-‐jurisdic8onal pipe? • Are you mapping your non-‐jurisdic8onal pipe? • Are your environmental risk(s) greater for your non-‐jurisdic8onal pipe? • Are your economic impacts as significant or more for your non-‐jurisdic8onal pipe? • Do you op8mize your ILI and inspec8on excava8ons to document and inves8gate any
immediately adjacent features?
Asset Management can be tailored to make $ense.
• PetroSkills Pipeline and Terminal course content
• “...key considera8ons for public and governmental interac8on…” • “...Safety, quality control, system reliability, availability, and regulatory
compliance are integrated throughout the course...” • “...regulatory and environmental compliance issues;..”
• Clarion Technical Conferences annual aZendance to PPIM, Pipeline Pigging and Integrity Management averages great than 2,200 aZendees.
• Clarion offers 18 various training, forum, or workshops related to pipeline inspec8on, integrity, compliance, and design.
Rule changes are requiring an increased commitment to compliance training.
Industry Training and Conference growth
IC-‐Solu8ons-‐LLC Services Integrity Opera8ons Cathodic Protec8on Inspec8on Coordina8on
IC-‐Solu8ons LLC brings together 40 years of mid-‐con8nent pipeline opera8ons, integrity, construc8on, and op8miza8on experience. Our focus and primary product is regulatory compliance. We will u8lize our extensive experience and background to ensure your
assets remain compliant and free of any jurisdic8onal interrup8ons; thereby leaving your schedule open for revenue genera8ng and expense management ac8vi8es. Our years of experience inside mid-‐sized organiza8ons has established a value driven approach with all projects. We can help you unlock underu8lized capacity and assist with opera8onal challenges that appear in the form of
regulatory restric8ons, inefficiencies or losses.
Darrell Kelly – BSME, Texas Tech University, Lubbock Texas. Darrell has served a broad range of engineering and construc8on capaci8es within the oil and gas industry during his 20 year career. With each employer, Darrell’s knowledge and skill sets associated with compliance and integrity have been u8lized to develop and administer opera8on and integrity programs that ensured DOT compliance and cost effec8vely insure company assets retain integrity, value, and opera8onal purpose. Darrell has represented the industry during DOT rule making and pipeline service determina8on proceedings. Along the way he has iden8fied compliance issues, developed IMP, revised opera8onal prac8ces, adopted best prac8ces, prepared field staff for state and federal audits in four states, and provided engineering services to inves8gate and resolve opera8onal and integrity iden8fied concerns.
Derek Sollberger, PE – BSME, Texas Tech University, Lubbock Texas. Derek has served in engineering and construc8on roles from the end user to the well head. Derek has served in opera8onal support du8es for state & federal compliance efforts. Derek has had IMP administra8on responsibili8es and his projects have included: ILI technology selec8on, ILI bid process, ILI tool confirma8on & remedia8on, line lowering, due diligence, and regulator audit prepara8on and representa8on.