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• Anthony Rosa

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Hazardous Liquid Integrity Management Risk Analysis May 24, 2016

Agenda • • • • •

Define risk and pipeline risk How pipeline operators conduct risk analysis Facility risk analysis Re-evaluation of risk Complete cycle of integrity management

Integrity Life-Cycle HCAs & Segment Identification

Program Evaluation

Continual Process of Evaluation

P&MMs

Risk Analysis

Integrity Assessments and Results Review

Remedial Action

Pipeline Integrity Management in HCAs 49 CFR 195.452(l)(1)(ii) • (l) What records must be kept? – (1) An operator must maintain for review during an inspection: • (i) A written integrity management program in accordance with paragraph (b) of this section. • (ii) Documents to support the decisions and analyses, including any modifications, justifications, variances, deviations and determinations made, and actions taken, to implement and evaluate each element of the integrity management program listed in paragraph (f) of this section.

No “Magic Bullet”

Hazardous Liquid Integrity Management The Liquid IM Rule specifies how pipeline operators must identify, prioritize, assess, evaluate, repair and validate the integrity of hazardous liquid pipelines that could, in the event of a leak or failure, affect High Consequence Areas (HCAs) within the United States.

Why Do Risk Analysis?

Bellingham, Washington

Mayflower, Arkansas

San Bruno, California

Complete Cycle HCAs

Repairs/P&MMs

Risk Analysis

Assessment

Applicability • Hazardous Liquids Pipelines • Facilities (e.g. breakout tanks)

Risk Analysis Training Goals • What is the significance of risk analysis in an Integrity Management Program? • How are risk analysis programs developed and implemented?

Risk Analysis • 49 CFR 195.452(g) – What is an information analysis? In periodically evaluating the integrity of each pipeline segment (paragraph (j) of this section), an operator must analyze all available information about the integrity of the entire pipeline and the consequences of a failure.

• 49 CFR 195.452(i)(2) – Risk Analysis Criteria. In identifying the need for additional preventive and mitigative measures, an operator must evaluate the likelihood of a pipeline release occurring and how a release could affect the high consequence area. This determination must consider all relevant risk factors.

• API 1160, Managing System Integrity for Hazardous Liquids Pipelines – Risk estimation is the process of combining frequency and severity estimates into a risk value.

Defining Risk Risk is the chance of a negative outcome event occurring (likelihood) and the impact that negative outcome has (consequence)

Likelihood

Consequence

Risk

Pipeline Risk Assesses the chance that a failure could occur (likelihood) and the negative effects (consequences) that could result from a pipeline release.

Risk Analysis Process Segment ID Results

Risk Factor Information (Likelihood & Consequence)

Method of Analysis/Integration

Risk Analysis Results

Assessment Methods & Schedules

P&MMs

Likelihood of Failure Likelihood

Consequence

• Pipeline Threat Categories – – – – – – – – –

Third Party Damage External Corrosion Internal Corrosion SCC Weather & Outside Forces Construction Manufacturing Equipment Incorrect Operations

Risk

Threats

Threats

Interactive Threats • Definition – Coincidence of two or more threats on a pipeline segment

Earth movement exacerbating construction-related defects

Incorrect operations in an area with SCC (pressure spike on weak pipe)

Interactive Threats • Example: Earth movement exacerbating constructionrelated defects

Interactive Threats • Example: Incorrect operations in an area with SCC (pressure spike on weak pipe)

Consequence of Failure Likelihood

• Impacts to: – – – –

Population Environment Business Other

• Impact Severity – – – –

Product Volatility Spill Volume Spill Transport

Consequence

Risk

How Operators Conduct Risk Analysis

Risk Analysis Methodologies

• Matrix Model • Indexing Model • Probabilistic Model

Matrix Model • Subject Matter Experts (SME) • Simplistic scaling (ex. High, Medium, Low)

Matrix Model • Limitations – Reliance on SMEs – Unable to conduct “drilldowns” or dynamic segmentation – Does not allow for complex mathematical relationships – Non-comprehensive analysis

Matrix Model Subjectivity SMEs

Risk Analysis

Rankings

Indexing Model • • • •

Relative risk Data driven Risk ranking Risk driver analysis and drilldowns • P&MM decision support

Indexing Model • Risk Assessment Methodology – API 1160

Likelihood of Failure

Consequence of Failure

(LOF)

(COF)

Risk of Failure (ROF)

Indexing Model

Indexing Model • Limitations – Relative Risk vs. Actual Risk – Often employs incomplete/inaccurate data – Weightings and mathematical relationships (algorithms) are vendor driven vs. operator driven (weightings based on vendor opinion) – Software errors – Outputs often inconsistent with field SME feedback – Ability to sufficiently demonstrate risk reductions – Difficult to account for interactive threats

Probabilistic Models • Complex mathematics/statistics • Less subjectivity – Quantitative • Increasing use in the industry • Data driven analysis • Predictive Tool

Probabilistic Models • Limitations – Relatively new to the industry – Requires more sophisticated software – Heavy reliance on complete/accurate data – data completeness/quality issues – Software errors – Requires more complex mathematics, statistics, and logic – Can require that the algorithm be based on actual and verifiable pipeline performance/history – Requires significant documentation/justification

Risk Analysis Tools: Software • Various software platforms employed by the industry – Range in complexity from simple screening to complex software tools

Vendor Algorithms • Canned math – “Black Box” algorithm and defaults – Off the shelf math – Operator cannot demonstrate math or data flow – Not a reflection of operator’s operational history – No incorporation of lessons learned/insights gained from IM activities – Inaccurate picture of risk

Historical Issues • Simplistic risk approaches that do not provide comprehensive or meaningful risk analysis • Use of vendor software without incorporating lessons learned, history, etc. • Insufficient technical justification • Immature and inconsistently implemented risk analysis programs

Risk Process Algorithm Definition

Data Acquisition

Data Validation

Input Data into Model

Algorithm Review

Review and Validate Results

Run Risk Model

The process of Risk Analysis should be explicitly documented to enable systematic and repeatable execution of the process.

Facility Risk Analysis • Different assets, different methodologies • Process approach – Type of equipment – Facility comparisons

Common Facility Threats • Dead leg pipe • Abundant aboveground • Unmarked belowground • Lots of moving parts Source: PHMSA OPS. Building Safe Communities: Pipeline Risk and its Application to Local Development Decisions. October 2010.

Historical Issues • Implementation – it’s just not happening • Disjointed organizations – facilities managed independently from line pipe • Pipeline risk models are linear – facilities are not

Documentation • Clear intent, purpose, and objectives • Responsibility for each task • Clearly defined data/information/resources required to complete the task • Explanation of task execution method, frequency, and process triggers • Documentation method and retention • Communication of results • Improvement process

Qualifications • Training qualifications of staff implementing risk analysis – Operator defined training requirements – Documentation – Industry conferences/training – Vendor training – Work experience

Historical Issues • Insufficient process documentation/language • Omission of training/qualification criteria for risk personnel

Risk Analysis - IMP ILI Analysis Corrosion Management

Maintenance

1Call / Public Awareness

Operations

Assessment Program

Risk Analysis GIS

P&MM

Pipeline Construction

Leak Detection

Field Personnel

Pipeline Inspection

Algorithms • Operator specific and transparent – Based on product type/operational history – Weightings defined – Justification/rationale documented

Data

Data Integration

• Import from database of record (e.g., PODS, APDM) • Other data sources?

Risk Analysis Software Database of Record (PODS/APDM)

Third Party Software

MS Excel/Access

GIS Design Data

Data Challenge

Risk Analysis Software

Data Challenge Data Quality/Import Issues?

Risk Analysis Software

Data Challenge • Poor Data Quality – GIS databases (PODS/APDM) often have substantial data gaps or inaccurate data (e.g., incorrect valve types, locations, etc.)

Risk Management Pipeline Data

Pipeline risk management is the “act of measuring pipeline risks, and acting on that information to reduce risks”

High Risk Pipeline Risk Analysis Software

Moderate Risk Pipeline Low Risk Pipeline

Results Validation • Operator SMEs review software outputs and documents • Feedback loop based on validation • Changes to results?

Risk Analysis Outputs • Risk Ranked Segments List • Threat Drivers • Risk “Cross Section”

Use of Results • Assessment Planning – Prioritized – Method selection – Interval determination

• P&MMs • Program Evaluation

Historical Issues • Risk outputs not validated by SMEs • Risk outputs are not consistently employed in other program elements • Keeping data fresh year over year • Default values

Re-evaluation of Risk • • • • • • • • • •

HCA Changes Operational changes (including change in MOP) Pipeline physical modification (including diameter changes) Change in product Pipeline reroute, new construction Correction to pipeline centerline New integrity assessment information Periodic update Change to risk model Documentation

Historical Issues • Failure to re-evaluate risk model scoring/weightings on a consistent basis • Failure to re-analyze risk to account for lessons learned, new industry information, and data changes

Validate Algorithm • Industry incident data • Company incident, near miss, and maintenance history

Complete Cycle HCAs

Risk Analysis

Assessment

Repairs/P&MMs

Risk Analysis • 49 CFR 195.452(g) – What is an information analysis? In periodically evaluating the integrity of each pipeline segment (paragraph (j) of this section), an operator must analyze all available information about the integrity of the entire pipeline and the consequences of a failure.

• 49 CFR 195.452(i)(2) – Risk Analysis Criteria. In identifying the need for additional preventive and mitigative measures, an operator must evaluate the likelihood of a pipeline release occurring and how a release could affect the high consequence area. This determination must consider all relevant risk factors.

• API 1160, Managing System Integrity for Hazardous Liquids Pipelines – Risk estimation is the process of combining frequency and severity estimates into a risk value.

Questions to Ask • What risk analysis methodology are you employing? • Are you using third party software? • What is your process for integrating data? Do third parties support this effort? • What is your process for accounting for subjectivity involved in risk analysis? • What’s the technical basis for your risk calculations (algorithm)?

Questions to Ask • How do you ensure data completeness and quality? • Can we trace data from field activities to your risk analysis? • What are your highest risk segments? • What’s driving your overall system risk? • For your highest risk segments, what are your risk drivers?

Questions to Ask • Are risk results consistent with SME views/opinions? • How do you ensure systematic and repeatable implementation of your risk process? What are your training requirements associated with risk analysis? • How are risk results used? How are they communicated?

Questions to Ask • How does new information make it into your risk process? • How often do you review your risk algorithm? How often is it updated to reflect lessons learned, new insights, etc.? • How have risk results improved your overall system integrity?