Energy Infrastructure and Safety

Mark Green
Posted January 8, 2016

The United States is overdue for a fact-based conversation about energy infrastructure. The needs are great. IHS estimates that needed energy infrastructure through the middle of the next decade could spur $1.15 trillion in private capital investment and support more than 1 million jobs. But there are roadblocks.

The long fight over the Keystone XL pipeline has anti-progress, anti-fossil fuel advocates targeting other needed projects. During his State of American Energy 2016 remarks this week, API President and CEO Jack Gerard warned that ideological opposition to infrastructure will hurt the United States:

“The demonization of the Keystone XL pipeline remains a powerful cautionary tale of the dangers of energy policy driven by ideology rather than economic reality and has a chilling effect on expansion efforts for our nation’s energy infrastructure. That’s not just bad national energy policy. It is also bad news for our nation’s economy.”

Thus the need for a rational conversation about the country’s infrastructure needs that’s based on fact. Such as: America’s more than 199,000 miles of liquid pipelines deliver about 16 billion barrels of crude oil and petroleum products a year, with a safety rate of 99.999 percent. And another: Industry keeps working toward a goal of zero incidents by continually improving safety in the infrastructure sector. You can visit our new infrastructure website for information on the components of the U.S. energy delivery network – which keeps America running.

Industry’s commitment to continuous improvement in energy infrastructure safety is seen in three new recommended practices, as well as in constructive comments to the U.S. Pipeline and Hazardous Materials Safety Administration (PHMSA) on its proposed pipeline rule. API Midstream Group Director Robin Rorick briefed reporters during a conference call:

“Industry continues to work toward its goal of zero incidents through continual safety improvements, including – most recently – the release of three new recommended practices. This work has taken place because of leadership by our industry and our core value of safety, not regulatory requirement. While we welcome regulatory certainty promised by a new proposed rulemaking on hazardous liquids from the Pipeline and Hazardous Materials Safety Administration, and the proposal makes some necessary updates to regulations, we are concerned that some of its provisions may ultimately hamper successful safety practices detailed in the existing and currently-released API documents.”

Rorick said the PHMSA proposal pipeline operations vary from line to line and that a one-size-fits-all approach to rulemaking won’t always allow for needed engineering judgment and analysis to fit spedific circumstances. Under the proposed rule, he said, operators would be required to expend resources on  unnecessary inspections on low-risk piping instead of giving them the flexibility to protect more sensitive locations. PHMSA also proposes inspections within 72 hours after an extreme weather event, which Rorick said could actually decrease safety by requiring company workers to access a facility when dangers from a hurricane or earthquake are still present. Industry also is concerned about duplication in the proposal and an overreliance on technology. Rorick:

For example “when we look at leak detection the rule focuses heavily on technology, and it presents technology as almost a panacea to fixing a lot of the issues with leak detection. When we look at leak detection as an industry we take more of a programmatic or systems approach, and so in [API Recommended Practice] 1175 the recommendation there for companies is to conduct an assessment, based on risk, and develop a whole program that includes but does not limit itself to technology.”

Rorick continued:

“Technology is a piece, but then based on the risk associated with that [pipe]line … then you layer on top technology, assessments, walking the line, flying the line, working with the communities to ensure that they’re aware of the line, that they’re helping with the assessment as well, that they know who to call if they think that there’s a leak. So, as an industry we’re trying to get out ahead of that, and we’re trying to work with PHMSA and NTSB [National Transportation Safety Board] to take a more systems approach.”

This approach is supported in recommended practices that help companies achieve the industry-wide goal of zero incidents:

• RP 1173 establishes the “Plan-Do-Check-Act” cycle for companies to review their safety management systems while adapting to industry best practices.
• RP 1174 gives operators an enhanced framework for continual improvement of the pipeline emergency planning and response process.
• RP 1175 assists with the development, implementation and management of sustainable leak detection programs.
• RP 1176 is in the process of being finalized. It will strengthen the industry’s current capability to predict and prevent crack-related pipeline failures.

Rorick:

“It is efforts like these by our industry that will help us continue to provide the energy this country needs safely and reliably. And, if we are to realize our nation’s true potential as an energy superpower, we need the best infrastructure in the world and government rules that support, not hinder building and maintaining that infrastructure. Industry will continue to lead on creating new standards to enhance pipeline safety as part of these broader infrastructure goals for our country, and we look forward to working with PHMSA and other stakeholders in this effort, as well as advancing and improving the new rule.”