WEBVTT 00:00:10.439 --> 00:00:13.179 Hello everyone. My name is Jennifer De la Cruz. I'm 00:00:13.179 --> 00:00:17.640 a pipeline safety inspector in the Houston region and 00:00:17.640 --> 00:00:21.620 I'm presenting today on some updates we made to the 00:00:21.629 --> 00:00:26.910 standard comprehensive inspection checklists on integrity 00:00:26.910 --> 00:00:29.640 management. 00:00:29.640 --> 00:00:33.710 Just a reminder, the powerpoint is available for download 00:00:33.719 --> 00:00:37.049 from the RRC website at this url, which 00:00:37.060 --> 00:00:40.969 should be posted in the Q&A box already. And 00:00:40.969 --> 00:00:44.250 you can get to it from our web page. I 00:00:44.250 --> 00:00:48.640 believe it's one of the first banners. 00:00:48.640 --> 00:00:53.479 Okay then I'm gonna jump right in. So why did we add 00:00:53.479 --> 00:00:58.140 this new section to the checklists? There was a meeting 00:00:58.140 --> 00:01:04.060 with PHMSA and the Commission, with PHMSA wanting 00:01:04.060 --> 00:01:09.069 the integrity programs inspected every year and just 00:01:09.079 --> 00:01:12.560 in Texas with the number of operators we have and the 00:01:12.560 --> 00:01:16.790 number of inspectors, it's not really possible. So 00:01:16.799 --> 00:01:20.469 the Commission's response to address this was, what 00:01:20.469 --> 00:01:25.370 if we capture at least a high level review of integrity 00:01:25.629 --> 00:01:29.640 during the standard inspections, which we do much more 00:01:29.640 --> 00:01:32.260 often right? We typically see the large operators for 00:01:32.260 --> 00:01:37.540 sure a few times a year. At least. So if we 00:01:37.540 --> 00:01:40.329 could do this review during standards, we would be able 00:01:40.329 --> 00:01:44.239 to see those integrity programs much more often, even 00:01:44.239 --> 00:01:47.269 if it's at a high level and just for the specific pipelines 00:01:47.269 --> 00:01:52.439 we're inspecting. 00:01:52.439 --> 00:01:55.620 Okay. So like I mentioned, it would be during standard 00:01:55.620 --> 00:02:00.129 inspections. So the forms that we've updated are the 00:02:00.129 --> 00:02:03.150 forms 1 and 3, which we use during the standards. 00:02:06.640 --> 00:02:10.069 And there were two tabs here that were changed. The 00:02:10.069 --> 00:02:14.629 first one is the programs and reporting tab. So one of 00:02:14.629 --> 00:02:17.770 the items we wanted to review is going to be just when 00:02:17.770 --> 00:02:20.960 was the last review completed for the integrity program. 00:02:21.340 --> 00:02:24.819 And this first tab has all the programs, so operator 00:02:24.819 --> 00:02:28.219 qualification, and O&M, drug and alcohol, etcetera. 00:02:28.229 --> 00:02:31.199 And just for uniformity, we've added this column to 00:02:31.199 --> 00:02:34.069 all the programs so we'll be capturing the last review 00:02:34.069 --> 00:02:37.840 date for all of them. And then really the big chunk 00:02:37.840 --> 00:02:41.169 here is going to be the record review tab which will 00:02:41.169 --> 00:02:45.449 have the integrity review and this is nine total questions 00:02:45.449 --> 00:02:48.159 for each and that's what I'm going to go over today. 00:02:51.639 --> 00:02:54.520 Okay, so the first question starting off is going to 00:02:54.520 --> 00:02:59.000 be high consequence areas or HCAs, and here we're looking 00:02:59.000 --> 00:03:02.960 for the latest analysis. So when was it completed? 00:03:03.939 --> 00:03:07.810 What were the results? And just as an example, I've 00:03:07.819 --> 00:03:10.900 I've already done a few operators this year. Because 00:03:10.900 --> 00:03:14.360 we started using the forum June 1, it became effective. 00:03:14.740 --> 00:03:19.689 So one of them showed with their GIS Map. Right, so 00:03:19.689 --> 00:03:22.960 the 10 pipelines or however many I was looking at 00:03:23.340 --> 00:03:26.280 you know, they can filter to it and show me here are 00:03:26.370 --> 00:03:30.689 HCAs or another example would be alignment sheets. 00:03:30.689 --> 00:03:33.360 Right, that's another, I think, typical way we see them. 00:03:34.139 --> 00:03:38.319 So we would just be looking at the results. And then 00:03:38.319 --> 00:03:42.590 also moderate consequence areas or MCAs, which are 00:03:42.590 --> 00:03:47.189 only for gas. These are not as relevant to the Commission 00:03:47.319 --> 00:03:51.490 since the Texas Administrative Code or TAC already 00:03:51.490 --> 00:03:56.259 requires integrity assessments even for non HCA pipelines 00:03:56.939 --> 00:04:00.300 But that requirement to do this analysis is still there 00:04:00.300 --> 00:04:03.379 right on the FEMSA side so we will be checking at 00:04:03.379 --> 00:04:05.819 least for the documentation portion, you know, did 00:04:05.819 --> 00:04:09.430 you do this MCA analysis? So that will be part 00:04:09.430 --> 00:04:14.439 of this question as well. 00:04:14.439 --> 00:04:18.370 Okay, and then the next question is a TAC requirement 00:04:18.379 --> 00:04:23.250 So are you risk based or prescriptive? And just a reminder 00:04:23.250 --> 00:04:25.870 there is no longer a requirement to submit this to 00:04:25.870 --> 00:04:30.529 the Commission but you still have to document it so 00:04:30.540 --> 00:04:35.060 you can do risk-based or prescriptive per segment, so you 00:04:35.060 --> 00:04:38.660 can have both for, you know, it can change per pipeline 00:04:40.240 --> 00:04:43.639 and that's perfectly fine. 00:04:43.639 --> 00:04:46.050 And then the next question is going to be the risk 00:04:46.050 --> 00:04:49.709 analysis. So this is not going to be a deep dive into 00:04:49.709 --> 00:04:53.860 risk. This can get pretty complex for smaller operators 00:04:53.860 --> 00:04:57.540 who we understand you probably contract this out. So 00:04:57.550 --> 00:05:01.129 again, not a super deep dive into it, but just 00:05:01.129 --> 00:05:06.339 we'd like to see familiarity with your model and we're 00:05:06.339 --> 00:05:10.120 gonna be looking at what are the major threats and 00:05:10.120 --> 00:05:13.699 risk drivers for each pipeline. So this is going to 00:05:13.699 --> 00:05:18.480 be, for example, corrosion or 3rd Party Manufacturing, 00:05:18.490 --> 00:05:21.779 etcetera. Again, since we're looking at a specific 00:05:21.779 --> 00:05:26.160 set of pipeline during a standard comp, it should 00:05:26.160 --> 00:05:30.490 be a little easier I think to go through these. And 00:05:30.629 --> 00:05:34.600 again, an example that I saw this year was it was a 00:05:34.610 --> 00:05:38.569 relative risk model. So they presented their, just 00:05:38.569 --> 00:05:41.800 their results and no rankings and they just filtered 00:05:41.810 --> 00:05:44.839 to the number of pipelines we were looking at. It's pretty 00:05:44.839 --> 00:05:48.680 easy to see what was the highest risk from the ones 00:05:48.680 --> 00:05:52.000 we were looking at and also in comparison to their 00:05:52.000 --> 00:05:56.790 system as a whole, just where it lies. So yeah, just 00:05:56.790 --> 00:05:59.660 the results. What are the results of the risk and what 00:05:59.660 --> 00:06:06.240 are those threats and risk drivers? 00:06:06.240 --> 00:06:09.290 Okay. Next question is pretty straightforward. This 00:06:09.290 --> 00:06:13.220 is going to be the assessment schedule. So we'll be 00:06:13.220 --> 00:06:16.500 looking at the previous assessments. Did they meet 00:06:16.500 --> 00:06:19.720 the interval requirements? So for liquids is going 00:06:19.720 --> 00:06:23.410 to be five year max and seven year max for gas, for 00:06:23.410 --> 00:06:26.899 the most part. So this one should be pretty straightforward. 00:06:26.910 --> 00:06:31.560 We'll probably look at what is your next assessment 00:06:31.569 --> 00:06:34.870 due date or we've already scheduled it, and again, does it 00:06:34.870 --> 00:06:40.639 meet these intervals. 00:06:40.639 --> 00:06:43.990 All right. Next question would be the anomalous conditions. 00:06:44.000 --> 00:06:48.259 So first question is, were there any integrity digs 00:06:48.259 --> 00:06:51.939 completed? And these are going to be digs that criteria, 00:06:52.149 --> 00:06:56.209 PHMSA criteria. So like the immediate, 60 day, 180 00:06:56.209 --> 00:07:01.300 day for liquids. So we'll be looking at the time 00:07:01.300 --> 00:07:04.949 frame. Did you get to those digs in time? If 00:07:04.949 --> 00:07:07.649 not there would be some additional requirements. So 00:07:07.660 --> 00:07:10.759 we would kind of go down that road if we need to. 00:07:11.439 --> 00:07:14.759 And just a reminder, this is based off of discovery 00:07:14.759 --> 00:07:17.860 date. Right? So the clock starts at time of discovery 00:07:18.439 --> 00:07:21.439 So this is the time frames that we're looking at and 00:07:21.439 --> 00:07:24.529 that discovery date has to be documented. So we'll 00:07:24.529 --> 00:07:28.180 be looking for that, and these are in line for inline 00:07:28.180 --> 00:07:30.959 inspections. So these are going to be highly specific 00:07:34.939 --> 00:07:38.029 Moving on to record retention. For integrity, this is 00:07:38.029 --> 00:07:42.589 going to be for a life of pipe and integrity includes 00:07:42.589 --> 00:07:45.769 everything. Right? So decisions made, which I know 00:07:45.769 --> 00:07:50.589 can sometimes be a little harder to document, but it 00:07:50.589 --> 00:07:53.560 can be as simple as if you had a meeting, you know 00:07:53.560 --> 00:07:57.490 a meeting invite with attendees and minutes because 00:07:57.490 --> 00:08:00.399 this will include if you decide not to take an action, 00:08:00.410 --> 00:08:03.540 you know, what was the justification? We can just look 00:08:03.540 --> 00:08:08.240 through that. 00:08:08.240 --> 00:08:11.660 And then the annual report. So we'll be focusing on 00:08:11.660 --> 00:08:14.500 the integrity sections of the annual report, which 00:08:14.500 --> 00:08:18.310 are going to be parts F and G. And then G1 00:08:18.310 --> 00:08:22.629 for liquids. So this is going to look at things 00:08:22.629 --> 00:08:24.949 like the baseline and reassessments conducted that 00:08:24.949 --> 00:08:31.250 year as well as any repairs for any criteria digs and 00:08:31.740 --> 00:08:34.450 you know, for the larger operators, the annual report 00:08:34.450 --> 00:08:37.159 will have probably way more than just pipelines 00:08:37.159 --> 00:08:40.519 we're looking at. But the way we can check it is if 00:08:40.529 --> 00:08:44.570 we know one of the pipelines we were inspecting had a 00:08:44.570 --> 00:08:48.789 reassessment or baseline in that year. We'd like to 00:08:48.789 --> 00:08:54.940 see at least that minimum in the report. 00:08:54.940 --> 00:08:59.850 Okay. And this last one here is for liquids only. So 00:09:00.539 --> 00:09:05.129 195 454 is a new rule. It became effective October 00:09:05.129 --> 00:09:09.679 1st of last year. So really this year, this october, 00:09:09.679 --> 00:09:14.289 would be the first year that it's due, and this is for 00:09:14.289 --> 00:09:17.370 certain underwater facilities. There's a whole paragraph 00:09:17.370 --> 00:09:21.799 on it. But it's for facilities that are greater than 00:09:21.799 --> 00:09:26.450 150 ft below the surface of the water. So if you meet 00:09:26.840 --> 00:09:28.799 all the criteria, it is a little bit more than that. But 00:09:28.799 --> 00:09:32.129 if you meet all the criteria then you have to conduct 00:09:32.129 --> 00:09:36.950 an ILI every 12 months and based on a risk assessment, 00:09:37.840 --> 00:09:41.519 any other assessments that the risk is pointing you 00:09:41.519 --> 00:09:44.840 towards. So this is an and. If you need to do both, 00:09:44.840 --> 00:09:48.240 you would do both or more. 00:09:48.240 --> 00:09:52.519 And I believe that's the last question. So here's my 00:09:52.519 --> 00:09:55.710 contact information. That says Commissioner, I'm not 00:09:55.710 --> 00:09:58.100 a Commissioner. I just realized that's incorrect. I 00:09:58.100 --> 00:10:01.610 apologize, but that's my contact information. If I went 00:10:01.610 --> 00:10:04.980 over any of this too fast, please feel free to give 00:10:04.980 --> 00:10:06.740 me a call or send me an email and I'll do my 00:10:06.740 --> 00:10:10.159 best to answer your questions. We will have a Q&A 00:10:10.159 --> 00:10:15.750 in a second, and I also want to remind you 00:10:15.750 --> 00:10:19.240 to please complete the evaluation. It's also available 00:10:19.240 --> 00:10:23.950 on the website at this url. And the there will 00:10:23.950 --> 00:10:28.830 be a link available for this video on that same website. 00:10:28.840 --> 00:10:33.669 But for now Nicholas, were there any questions in the 00:10:33.679 --> 00:10:37.940 Q&A? 00:10:37.940 --> 00:10:43.429 Yes. So there is a question there from William, he 00:10:43.429 --> 00:10:47.779 says repeat your comment with cited regulation for 00:10:47.779 --> 00:10:53.840 the last slide on liquids. 00:10:53.840 --> 00:10:58.429 So I guess we're talking about this one. That's 195 00:10:58.429 --> 00:11:08.340 454. 00:11:22.639 --> 00:11:30.629 And we got another question from Michael, it 00:11:30.629 --> 00:11:34.860 says PHMSA just issued an interpretation of this 00:11:35.639 --> 00:11:40.049 and has only identified one line that meets this requirement. 00:11:41.139 --> 00:11:48.740 I'm not sure what that's talking about, what the question is. 00:11:48.740 --> 00:11:53.279 So okay, I'm assuming this might be, I remember talking 00:11:53.279 --> 00:11:55.779 with someone about this. So I think PHMSA, the intent 00:11:55.779 --> 00:12:00.250 behind the rule was for a specific pipeline, I think 00:12:00.250 --> 00:12:02.600 in the Great Lakes or something along those lines. 00:12:02.600 --> 00:12:05.730 I just didn't realize that an interpretation had been 00:12:05.730 --> 00:12:09.889 finalized. So I will look into that. But yes I know 00:12:09.889 --> 00:12:13.159 that there were some clarification going on. So if 00:12:13.639 --> 00:12:16.090 this doesn't apply to you based on that interpretation 00:12:16.090 --> 00:12:19.139 then this wouldn't be a requirement for you but thank 00:12:19.139 --> 00:12:21.941 you for bringing that up. 00:12:21.965 --> 00:12:24.429 He has a follow 00:12:24.429 --> 00:12:29.309 up question. He says there are no line in Texas that meet 00:12:29.309 --> 00:12:32.043 this requirement, is that correct? 00:12:32.067 --> 00:12:33.720 Oh I don't 00:12:33.720 --> 00:12:39.039 know off the top of my head. 00:12:39.039 --> 00:12:45.870 Okay. The question right here. So the inspectors 00:12:45.870 --> 00:12:51.159 will review all specialized plan reviews each standard 00:12:51.159 --> 00:12:52.405 comp? 00:12:52.429 --> 00:12:56.190 No we won't go, so there will be a separate inspection 00:12:56.190 --> 00:12:59.139 for each of the specialized programs but we're just 00:12:59.139 --> 00:13:02.389 gonna want to see the latest review date. So if you 00:13:02.389 --> 00:13:04.950 could just, you know, this is typically pretty quick 00:13:04.950 --> 00:13:08.279 if you could pull up your O&M, and we'll just 00:13:08.279 --> 00:13:11.090 look at the latest review date, that's, you know, 00:13:11.090 --> 00:13:14.419 a sign in sheet or whatever. We won't be going in depth 00:13:14.419 --> 00:13:29.639 into each during the standard. 00:13:29.639 --> 00:13:34.840 And another question from Simon. 00:13:34.840 --> 00:13:41.210 If a non AC liquid pipeline was built in 2014 but was 00:13:41.210 --> 00:13:47.360 acquired by a new operator in 2019 under the TSC rule 00:13:48.240 --> 00:13:53.549 So the first hydro test in 2014, the starting point 00:13:53.549 --> 00:13:58.259 to conduct a test for the new operator 00:13:59.639 --> 00:14:03.139 let me see if I get that right, 00:14:03.139 --> 00:14:07.549 if a non AC liquid pipeline was built in 2014, 00:14:09.039 --> 00:14:15.299 but acquired by a new operator in 2019 under the TAC 00:14:15.299 --> 00:14:21.870 rule is the first title test in 2014, I believe he's 00:14:21.870 --> 00:14:25.659 trying to say is their first title test applicable? 00:14:29.539 --> 00:14:31.009 How is it acceptable? 00:14:31.033 --> 00:14:33.139 Yeah, if you want to use your 00:14:33.139 --> 00:14:39.139 construction hydro as the baseline, yes you can. 00:14:39.139 --> 00:14:42.419 And a lot of operators will do that. And then after 00:14:42.419 --> 00:14:46.169 that, that's when you, you know, you would do whatever 00:14:46.169 --> 00:14:48.629 intervals you're going to do. But yes, you can use 00:14:48.629 --> 00:14:55.139 the construction hydro as your baseline. 00:15:20.139 --> 00:15:28.340 Another question coming in from Vincent Harris. 00:15:28.340 --> 00:15:34.529 It says 150 ft under the surface of the water, just 00:15:34.529 --> 00:15:37.980 to be clear, if the depth of the body of water is 00:15:37.980 --> 00:15:43.230 a 100 ft will that mean if we bored 50 below, we 00:15:43.230 --> 00:15:51.740 will be subject to the requirement of 454? 00:15:51.740 --> 00:15:54.919 I believe so, but I think the interpretation that somebody 00:15:54.919 --> 00:15:57.360 mentioned earlier, I think that's exactly what it goes 00:15:57.360 --> 00:16:00.700 into, because I think that question came up for several 00:16:00.700 --> 00:16:05.720 operators. So if you wanna send me an email, go ahead, 00:16:05.730 --> 00:16:09.370 and I can send you that interpretation and I'll 00:16:09.370 --> 00:16:13.740 read into it as well. But 00:16:13.740 --> 00:16:16.250 yeah, let me read that interpretation. I'm sorry. 00:16:16.250 --> 00:16:18.799 And I'll, like I said, if you would send me an 00:16:18.799 --> 00:16:33.539 email and I can get back to you. 00:16:33.539 --> 00:16:39.340 And Michael is confirming 00:16:39.340 --> 00:16:42.429 your response, your earlier response, that you're correct 00:16:42.429 --> 00:16:46.639 Jennifer, HDD are not included in the intent of the 00:16:46.639 --> 00:17:08.640 rule. 00:17:08.640 --> 00:17:12.349 I guess that's all the question. Okay, we got 00:17:12.839 --> 00:17:19.970 another question from Stacy Trevino. The interpretation 00:17:19.970 --> 00:17:26.859 states PHMSA did not interpret 454 or section 25 of 00:17:26.859 --> 00:17:31.569 the 2016 pipe sites to apply to pipelines directionally 00:17:31.579 --> 00:17:36.029 drilled deep below the surface of our shallow water 00:17:36.029 --> 00:17:38.993 body. So I guess she's just-- 00:17:39.017 --> 00:17:41.160 Putting this, okay. 00:17:41.160 --> 00:18:15.740 Okay, thank you Stacy. 00:18:15.740 --> 00:18:19.230 I guess we can wait another two minutes for if there 00:18:19.230 --> 00:19:19.839 are any new questions. 00:19:19.839 --> 00:19:42.240 That's all the questions we got, Jennifer. 00:19:42.240 --> 00:19:44.170 Okay. Since there are no more questions, your good 00:19:44.170 --> 00:19:46.359 to go ahead and close jennifer.