What’s in Your PIM Future? Consider “Re-centralization.”

A conscious move to “re-centralizing” all elements of pipeline integrity management could be the real solution, which EMS Group examines in detail.

For an industry that prides itself on the safety and integrity of its infrastructure, the Natural Gas Distribution Incident Data from the US Office of Pipeline Safety makes sober reading. So does the daily newspaper.

Despite the fact that fundamentals of pipeline management are well known and established (including increasingly rigorous oversight by the US Department of Transportation), despite the drive toward structured risk-based integrity management programs by senior management, the best-laid pipeline integrity management (PIM) plans continue to break down at lower levels of pipeline operator management.

The coin has two sides. Our industry maintains that there’s no safer (and certainly no less expensive) way to transport hydrocarbons. It’s far safer than rail and truck. Our industry says that its infrastructure is safe, relatively speaking. In fact, the industry has an exceptional safety record – relatively speaking.

But it’s not perfect: the failures are catastrophic, or can be. Failures are high-profile incidents, which cause an immense hue-and-cry. The public shrugs off the fines that are imposed on operators, no matter how high. Americans are more concerned about personal injuries and property damage, environmental damage, even the effects of the incidents on at-the-pump gasoline prices. In their view, failures are 100% preventable – and completely unacceptable. Since the pipeline industry won’t take the necessary steps, the government will and is doing so.

It is reasonable to expect that if everybody follows the exacting regulations, incidents will decrease. DOT is extremely aggressive and now is looking for more mature plans. PIM procedures should by now be routine and firmly embedded in companies’ operations.

History, however, is not on our side.

The 2002 law mandated a speed-up in the frequency with which natural gas and liquid pipelines are inspected and imposed tougher penalties than in the past.

Two years later, in 2004, then-Inspector General of DOT Kenneth Mead said, “We are concerned that the 1.8 million miles of natural gas distribution lines don’t have to undergo safety inspection, even though they have the worst safety record of all pipelines.”

Mead pointed out that improvements like the development of pipeline evaluation standards and the creation of mapping systems to better target safety concerns had succeeded. But, he acknowledged that many lines are not regularly inspected.

All pipeline operators were required to write plans, then lay down a baseline for ongoing measurement. All gas pipeline integrity management program requirements are in place. A specific Pipeline Integrity Program has to meet these specific DOT requirements, painstakingly detailed, on a segment-to-segment basis.

In December, 2005, “Integrity Management for Gas Distribution: Report of Phase 1 Investigations” was issued. The work/study groups concluded that “current pipeline safety regulations (49 CFR Part 192) don’t really convey the concept of a risk-based distribution integrity management process and that it would be appropriate to modify the regulations to do so.”

The report stated that all distribution pipeline operators, regardless of size, ought to implement a PIM program that included seven key elements. Every operator should:

1. Develop and implement a written integrity management plan.
2. Know its infrastructure.
3. Identify threats, both existing and of potential future importance.
4. Assess and prioritize risks.
5. Identify and implement appropriate measures to mitigate risks.
6. Measure performance, monitor results, and evaluate the effectiveness of its programs, making changes where needed.
7. Periodically report a limited set of performance measures to its regulator.

DOT regulations are a response to a series of failures in the system, a large number of damaging incidents.

We all know the challenges, though. Pipeline assets are constantly in motion, with disparate practices or sets of practices in conflict with one another, depending on who’s aggregating the assets. Regions and districts continue to consider their own circumstances as their primary focus, regardless of corporate mandates.

There is also constant pressure from every level to keep costs under control. High-level risk mitigation strategies are not a common consideration at lower levels when they’re making cost decisions, even when clear policy guidelines and corporate standards for pipelines are in place.

There is a gap between what is and what should be. Is it impractical to establish and maintain prescriptive requirements that would be appropriate for all circumstances?

The answer is, “No, it’s not impractical, but…”

Divisional or splintered integrity practices work against effectiveness. Localized management efforts, no matter how well established and apparently “cost-effective,” conflict with the proven capability of a centralized Integrity Management Program.

Individual anomalies get fixed, to be sure. But the industry also recognizes that the surrounding “best practices” procedures, mandated by DOT and so necessary for additional and ongoing learning, are not being properly implemented and maintained.

The loop’s not being closed. So some operators are not doing enough to enable or maximize future prevention.

A single, unified Integrity Management Program pulls together different operating divisions into a centralized management process. Inspection and repair can be made uniform throughout an operating organization, and centrally managed. This is about more effective organization and control, right down to the way the hole is dug. It is about “re-centralization.”

There is a need to establish consistent risk assessment procedures and repair policies throughout the entire organization, centralized in a single unit. The defect has to be quantified and reported before the fix. All information about the defect, the assessment of its risk, the way in which the defect is corrected, and the metrics of the remediation, has to be fed back to the primary “authority” for analysis.

Once analysis is complete, the information should be incorporated as best-practice procedures into operations and maintenance manuals, whose guidelines are then also rigorously managed and followed. At the same time, standardized procedures only work if the same people are used to correct the anomalies every time. All the data is reviewed the same way, every time.

At this point, you’re saying, “How are we going to get this done?”

Routine maintenance crews are not the solution. There is a need for dedicated PIM people, crews, departments to cover everything system-wide, either internal to the operator or as a third party.

EMS Group, for example, uses a turnkey approach to pipeline integrity management. We recommend the best strategies for companies to comply with federal and state pipeline integrity management rules (e.g. 49 CFR 192 Subpart O, 49 CFR 192.452). This includes risk assessment methodologies for right-of-way and high consequence areas, where ruptures could have severe impacts; and risk mitigation programs.

So whether a company operates one pipeline or a complex interstate network, we can help develop a plan, first of all, that satisfies specific regulatory requirements.

We believe a high-quality Operations, Maintenance, and Emergency Response manual provides the central control mechanism of a company’s DOT compliance program. So we work with customers to create customized company-wide and pipeline-specific manuals that are functional, easy to follow and conscientiously updated for the entire organization, top to bottom.

Most critical to the idea of “re-centralization,” we can undertake the entire spectrum of pipeline operations and maintenance. This can encompass dedicated O&M, compliance work and DOT audit support through a single control center.

This isn’t a pipedream (no pun intended). It can and is being done. But the punitive nature of a pipeline failure suggests a change of philosophy by pipeline management, a commitment to “re-centralization.”

Failure-resistant PIM cannot be effectively controlled and reported any other way. Especially if you’re facing your next DOT inspection.