Episode Transcript
Rhett: Welcome to today's episode of Pipeline Things. I think you're gonna find it particularly enjoyable. Our guest is rich in the history, working with the development of standards, going all the way back to the Office of Pipeline Safety.
In this show, I've fully become a believer and acolyte of prescriptive regulation in the United States. You're gonna wanna pay attention to that. But no, more importantly, this is the final episode of our Sage series, and it's worth every minute of understanding how we got where we're at in this prescriptive regulatory environment.
What a zero incidence looks like today, and even maybe what does the role of the environment look like moving forward, and how do we talk about that in our industry? Think you're going to enjoy it? Thanks for joining us today.
**Intro**
Rhett: Oh gosh, that was a fail, Chris, but it's still a good start to the show. Welcome to today's episode of "Pipeline Things." I'm your host, Rhett Dotson, my co -host Christopher De Leon. And again, we consider, we continue our journey through the "Sage" series.
Chris- I love the series, Dude, it's I've heard all of not only when they write right pre -release. I've heard them at least two times I just love them.
Rhett: Um, yeah, you know, so very few people little audience inside here when I film the podcast, I actually feel like I go into a zone and I retain almost none of what happens in the podcast because it's like I'm focused on so many different things so when I go back and listen to them I –
Chris: That was pretty good.
Rhett- Yeah, sometimes, and other times I'm like, I don't know how I did so well there. But the Sage series, I've had the chance to listen to a few of those already and thoroughly have enjoyed what we've been able to do here.
Chris: Yeah, original gangsters, OGs, geezers.
Rhett- I think OG series still would have been a good title. Sure, we could have gone for it.
Chris- But I think we did a good job of achieving the objective.
Rhett: I think so you know man and so for me I was thinking about so you know I just got back a little audience insight I've had a good a good summer vacation this year my family had a chance to do a lot of the national parks California highly recommend if you get the chance to do national parks but you know what's amazing about the national parks Chris is, and it ties in very well to this episode is
understanding how the national parks came to be because they weren't always there and believe it or not we actually have pretty strict laws on what can become a national park and actually the difference between the national park and I learned a national monument but if you go back and look at the history of the national parks in the early 1900s, Teddy Roosevelt actually played a role in that They did it because they realized if they
didn't preserve what was there in the United States it wouldn't remain and would likely get commercialized. So, we actually had some really funny things happening. Like if anybody's ever been to Niagara and you see how commercialized Niagara Falls is,
the Europeans were actually making fun of us when that happened. And the United States were all like, hey, we have these gorgeous infrastructure we need to protect. And then at the same time in California,
the redwoods are Majestic, but like anything that's majestic. It also has a lot of wood they needed wood in California for the gold rush and other things that were going on, so people were cutting these amazing trees down and the national public had this huge outcry.
So, if you actually Look at the National Park Service badge. I learned this when we were there, it actually has a sequoia tree in the background as a reminder of why that institution exists today and it's to protect the resources and the beauty that we have.
So, I think that history is just, it's cool to understand how and why we have those things. – Chris: It's also been inspiring, right? Kind of makes you think like, oh, I want to help that. I want to contribute towards that.
Rhett:- Yeah, when you're there, you're like, I want this to stay like that. I don't want people to be anywhere near this.
Chris:- Why are you dropping that on the floor? Pick that up.
Rhett:- Yeah, I'm getting really upset.
Chris: Why's there mess here? - Do you see how beautiful this is?
Rhett:- Yes, like this is General Sherman tree. This dude's 24 years old. You don't leave a plastic water bottle near the General Sherman tree. So yeah, it's really great. But you know, I think it also—
Chris- The funniest part is like,
I could totally see you doing that. Like I can already hear you yelling at Caleb. Why are you doing that Caleb?
Rhett:- No, my family knew. Like you might have been like on like probation, like missed the rest of vacation if you had done that.
Chris- I will put you on a plane, you're going home.
Rhett:- God forbid, like if I would have seen my kids break out a pocketknife and try and carve into something, there probably would have been, I don't know, CPS would have been called or something. But it really ties in,
I think, with what we've been trying to do in the Sage series, and in particular today's guest. So, I wanna let the audience know, we do show prep before, I have been very excited about this episode because this particular guest has been in the industry like all of our Sages, a long time and brings a rich understanding of the history of how and why we got to the regulatory environment that we have today.
Yeah. And I'm looking forward to him being able to share that with you.
Chris: And you know, again, one of the reasons why I feel like we've done a pretty decent job in and putting this the series together and obviously kudos to everybody that's joined us all of our guests is they all kind of bring a different perspective, so they all have been in the industry 30 plus years they've all kind of had a
focus right so I mean if we whether we look at Dr. Lavis or we look at Jerry or Dr. Dave you know Russell whoever it is that we that we brought on they all kind of give us a perspective all looking towards the same thing but in their own view right so we can kind of learn a little bit from all of them so it's really exciting.
Rhett: Yep, so without You know again,
we're gonna go ahead and bring our guest on, you know what you want to introduce him.
Chris: No go ahead
Rhett: Alright, so we are gonna bring Andy Drake, please come on take a seat and join us here It's really my pleasure to bring Andy on and I'm gonna let him introduce himself so Andy.
What did you think of that that that segue? Were you were you just marveling
Andy: I'm impressed with the passion the energy. I have to admit I'm honored to be It's part of the Sage series and not the old geezer series.
It really felt like quite a promotion actually right away.
Rhett- You gotta thank Dr. Dave for the geezer term. We made it quite clear in that episode that it was his term, about hours it was applied. So, if you don't choose to self -ascribe that term,
it's okay, we'll go with Sage.
Andy- I'm proud to hang out with folks like that. That's a good group. Sage or old geezer either way works great. –
Rhett So Andy, I kind of alluded to it in the introduction. I'm really excited to you on because the just the history and perspective that you bring with so many more years of experience I don't want to say if you add Chris and I's experience together you probably have more than
that and certainly to a lot of our listeners who are younger I mean we bring maybe on average three five ten years of experience and you have substantially more than that so
Chris: I want to add to that if I can really quick but it's also the type of experience yeah right like Russell you know,
brought that whole perspective of control management and, you know, the evolution of like paper to automation and how in technology can support with things like focusing where you need to.
And I won't go through all of them. The point is everybody's had a different perspective. And, you know, uh, one of the things that I appreciated is just, just your role in industry, right? Not just on consensus standards,
right? Like standards development or R and D, but rather that that role of helping make choices right from a regulatory perspective right so I just wanted to surface that as well you know you've been a really important role in that obviously I wasn't around for the formation of IMP 1.0 but obviously on the gas side for what we call IMP 2 .0 or the new gas room I mean you were front and center there with the
with the G -PAC
Rhett: so, we're getting a little ahead of ourselves yeah that's okay and if you don't mind, Andy will you introduce yourself to the audience? There's probably a lot of them that may not be familiar with you, didn't have the luxury of working with you.
Who are you and what brings you on as a sage in the natural gas or pipeline industry?
Andy: Well, 42 years ago, I graduated from the Ohio State University of Background and Mechanical Engineering.
Welding is my background. I actually have been a welder one long period ago. Not on the pipeline,
unfortunately, for the pipeline people, but I have, you know, I've been very fortunate to work with Texas Eastern, start to work with Texas Eastern right out of college,
and have stayed basically with Texas Eastern and subsequent companies since then through Enbridge. And I was fortunate enough to get involved in some of the technical research work at a very young age.
Construction work out on the projects got involved in failure investigations because of my background very early in my career which is very eye -opening. You know to see to see a failure hands -on right there to see what can happen you know when things go wrong and then try to focus on what on what needed to happen to avoid that is quite a personal lesson,
you know, a very personally powerful message. But I was then moved into basically working with the ASME committees and ended up being the chairman of the ASME gas pipeline standard and was chairman of the effort that led to the B318S document that became the subpart of the regulations and worked with a great group of people,
folks like Dave Johnson, Alan Eastman, Mark Harris, Keith Lee was people like this, just super, super great people, very intelligent people to help kind of make a step change in the industry around where do we want to take integrity management?
2 .0, so to speak, you mentioned that. How do we want to advance the standard care? And then was asked to serve on the advisory committee to the secretary,
what they call the Gas Pipeline Advisory Committee, to PHMSA on all rule makings. That was 22 years ago.
Rhett: So, 22 years ago you were asked to serve on the advisory committee for gas pipelines,
that pre-1.0, so pre the first regulation.
Andy- That was the first regulation. Rhett:- Wow.
Andy- That's when I was chair running with ASME, they asked me to sit on it because of the work we were doing on the S document.
And sat on it ever since. That was 20 years ago, it's been a long ride, getting back on it, that was, wow, that's been a long time.
Rhett: This is gonna be great. So, you were around when the OPS existed before FIMSA was even formed.
Andy: Yes. Rhett: Yeah, you've seen it all.
Andy: You know, PHMSA was really struggling at the time with a lot of issues from public confidence about incidents that had happened and whether the current regulatory structure was adequate and whether they were aggressive enough and whether industry was subscribed enough to try to prevent incidents.
There was a huge concern by the public about operator diligence and PHMSA's diligence even. And so that's really where I think the press came on to step up our game,
so to speak. And at the time, what we really did was, you know, looked at other industries. Rhett: When you say at the time, you mean at the time of like 2001?
Andy: No, no, this is back in the mid 90s. Rhett: Okay, mid 90s.
Andy: Mid 90s. We really were looking at other industries to try to see what were other industries that actually had their life social license challenged,
you know, things like the nuclear industry, the medical industry, the aviation industry, where the society really stepped in and said, we're not okay with the track that you're on right now, or this is so scary from a consequence standpoint.
We really need to make sure, we're sure. And what did they do to really step up their game? What did they really do to improve the confidence and the decisions they were making on managing integrity?
And so, we borrowed heavily from those industries, you know risk management approach. And that was really the foundation of the S document.
And we really brought people like Mark Harris and Bernie Selig and from other industries from the Hartford -Steam Boiler nuclear industry background people that had done those things and said, hey, you know,
we're gonna come up learning curve a heck of a lot faster because we're gonna borrow and heavily leverage what you've already done and know and apply it to this industry. And that was huge. It helped us collapse the time that it took to get those things into place.
And a lot of different thinking was going on at that time. And kudos to people that stepped into those committees and worked on the job because they were really being challenging paradigms that were very old,
you know, by how we approached things, why we were doing certain things. And one of the things that we really coupled that with was some work that Keith Lee was personally very involved in,
and that was what we call the emeritus report. And that was go out and interview the writers of the original code. Why did these requirements exist? Where did 72 % come from?
Well, it was an 80% confidence interval around it, and assume 90 % higher test. So, if we test to 100% percent, we could get to,
we got over 80 percent, which is literally where the AMOP conversation came from. Where did section valves come in from? Well, that was the distance between roads in different parts. You know, section roads were so far apart and as you got to urban,
more urban environments, the roads were so far apart. So, it wasn't so much about a specific distance. It was really more about getting to the valve quickly because the road is near the, you know, you want to be near a road.
So, it was more about shutting the valves quickly than it was specific distance. But understanding that helps us then understand if that was the goal or that was what was really important in the development of the regulation or those requirements that even preceded the regulation.
Now we understand how to protect the intent. And that was really important. What was the intent of some of the regulations and what were they trying to accomplish. And then we can marshal efforts and adjust things to try to achieve those same goals or even improve on our ability to achieve those goals with different practices,
but protect the original intent.
Rhett:- You know, it's really funny as you were saying, I didn't realize y 'all borrowed from other industries so heavily in the writing of 318S. But it was funny as you were saying, you were referencing the nuclear industry.
As I look at pipelines, I'm like, pipelines are a lot older and more mature than those industries in many ways. But those industries developed integrity plans probably because of public awareness sooner than pipelines did,
which is just, it was kind of making me laugh a little bit. I'm like, yeah, the pipeline industry is probably at least two or three times as old as the nuclear industry. But we had to go to the nuclear industry to take some of their concepts.
That's just, that's funny to think about, right? It shows you how maybe little awareness there is of pipelines a lot of times in people's day -to -day lives, I think.
Andy: It's true. I think we, you know, run silent, run deep,
worked for years for a long time. People didn't know we were there. And I think that was that was working for folks, but for a while. But I think,
you know, over time, you know, incidents started to happen in more populated environments or in settings where society was not willing to tolerate that and I think that's an important thought is you know we are an imposed risk we're not like when you decide to drive a car so they say well we're safer than driving a car it's like well yeah but people decide to drive a car they didn't decide to have a pipeline in
their backyard so now we're imposing a risk on people and so the standard of care that they expect is very high because the person who's the risk is imposed upon isn't necessarily in control of the risk.
So, they're trusting us and they're trusting a fabric or a series of barriers around that risk to be effective. They're trusting the operator to be effective. They're trusting the regulator to be effective, and they require all of those barriers to be working that they may not have direct control over really don't have direct control over, but they want some line of sight and some confidence and effectiveness of those barriers.
And I think that's really important for our industry to understand is we have an obligation to protect people. That is our number one objective, is to protect them while we do our work to transport fuel.
Rhett: That's an amazing, honestly, Andy of that concept is amazing, just 'cause as you're saying it, I mean, most people when they choose to live somewhere, don't assess whether or not there's a pipeline near it.
Thankfully, most people aren't even aware of whether there is a pipeline near it. And I mean, I'm thinking just my own life, like, I'm flying with my wife tomorrow to go somewhere, but we choose to take, you know, that risk to get on the plane,
right? And you're right, I can expect a burden of care, but I think when something is, you don't have a choice in a matter, I think your expectations are higher,
right? When, you know, we just went through all these power outages in Houston, And I'm thinking like, people expect to have power because they need it to go about their daily lives.
People expect to be able to live safe and free from environmental disaster even if they don't know that pipeline is right there. And that expectation is very high on public utilities.
Andy: The public really depends on us and the regulator. And I think that sort of sets a tone of how clear the regulatory guidance or the regulatory presence is.
You know, a lot of people talk about prescriptive regulation, which is, you know, a definitive set of guidelines that you have to meet versus more performance -based regulation, which is more of a goal outcome.
Don't let this happen or do whatever you need to do to prevent this. And there is an active debate has been for many, many years.
Rhett: Look, I've been caught up on it myself.
Andy: You know, about prescriptive performance, you know, how, who, and why, and which one's better, you know. I think it's an and proposition, and I think that's really important. In Canada,
a lot more performance -based regulation, and it works, it works great. But there's an and it deploys easier and more logically in Canada than in the U .S.
The number of operators is exponentially fewer in Canada so there's more opportunity for a very intensive conversation around performance expectations and plans to meet them and that's really important because performance -based regulations in essence are very vague and they're clear in their goals but they're vague in how to so public confidence is yielded in confidence around the how what are you going to do to achieve that
outcome because the more operators that you have obviously the more variability you have in the possible permutations combinations of things that are put into that are people are marshaling to achieve that outcome, so the regulatory obligation then is to step into that space to make sure those folks are diligent And the more vague the guidance is,
the more the conversation is really important about our operators considering that issue appropriately and thoroughly.
Chris: And if we take the public perspective and not, we're in this industry perspective,
it's the idea of like, how do you hold, how do you address accountability? How do you account, you said marshaling, but I'll say policing and enforcing, Right, and so I really appreciate the idea of the and proposition,
right? It's like the idea of prescriptive kind of leans you to believe I've always thought of it's a to get to a standard of care Right, you got to get to a standard That's where the prescriptive regs are trying to get you and then back to what even B318 The way was designed is it's and then you have the option to move to risk -based engineering through performance -based plans,
right? And so it's that and proposition we see that as early as the B318s.
Andy: Absolutely, I think that it's a balancing act. And you're trying to provide enough guidance and clarity to manage,
especially when you have lots of operators and you have lots, different sizes of operators with lots of different capabilities and competencies and capacities. And you're trying to say, okay, for a little operator,
we need to give them a lot more definitive guidance. Big operators with lots of capacity and competency you know that okay they can do some sophisticated stuff and we might want to give them flexibility to be able to do something different you know more risk -based
Chris: and also the ability to learn from each other though also too right I mean sometimes there's often a sense of you know we say sometimes that relationship between the
operator and regulator can be adversarial but I mean it's not uncommon for us to see that information is also withheld as a competitive advantage, right? And so again, interesting topic,
and I know there's a lot of efforts to try to break those down, but whether it's technology companies, consultants, operators, there's still this vibe of sharing we will do,
but only potentially to some point, and everybody has to go on a learning curve, is I guess what I wanted to get to. And that's where that prescriptive reg, I feel like supports that balancing act, right? It allows that journey of learning and going through,
you know, treading through the mud until you understand your system enough, understand the process enough and all that stuff to potentially offer you the idea of performance -based approaches.
Andy: You know, I think it's true. I'd like to say that we try not,
you know, there's a general sense that we don't compete on safety. We try very hard to share information, try to define best practices and get industry standards developed that helps kind of disseminate what is an appropriate approach.
But there's a lot of operators out there and there are a lot of different sizes of operators and a lot of different levels of engagement. And I think that's what we have to be conscious of on the operating side is that the public isn't so much concerned about the greatest common denominator.
They're worried about the least common denominator. That's the person that may be imposing the risk on them.
Chris: Who is the guy that runs the pipeline next to my house?
Andy: And their ability to differentiate the two. Yeah, it's like, well, y 'all,
look the same to me? I don't know you. Yeah, but we doesn't see a difference. I don't know you.
Chris: There's one reg, and you're a pipeline.
Andy: So their confidence is really short up on prescriptive baseline.
You can't drop below this, and the regulator is going to be active to make sure we don't drop below that. And that provides some baseline of confidence for the public.
Rhett: So you said something,
Andy. It just sparked a thought in my mind, which is-- and I've never thought about it, because again, I've had a lot of my own struggles in prescriptive versus performance regulation. And with the number of operators,
is it fair for me to say that if you have a performance -based regulation, it requires more interaction, or maybe a different or more intensive interaction between the operator and the regulator than a prescriptive?
Andy: I think it requires different, I mean, maybe more intensive conversation because it's not clear, it's not like do this and then the check box,
yeah, you did it, you did it, you did it, it's more like why?
Rhett: And they have to understand.
Andy: And then there's a conversation, why did you do that? What were you trying to accomplish, how does this work? Do you have data to show that that works?
And then I think there's just a little bit more intensive conversation about the why part of it. With the prescription, there's an intensive audit going on, which is more of a checklist. This says you have to do this,
you have to do this, did you do it, yes, yes, yes, no, that's not good. And then they're just working down on it.
Rhett: - Yeah, 'cause I'm trying to imagine, with PHMSA, even PHMSA limited resources,
what a performance -based implementation would have looked like in the United States would have been, I mean I have to believe the number of resources you needed on the regulatory side would have been more and even more technical.
Did y 'all have, was that part of the conversation in the 90s where y 'all, we all talking as y'all were thinking about drafting? I mean you, you were advisory, what, what did that, was that part of the conversation?
Chris: This is your fault, explain it. Rhett: Yeah, this is your fault. - Oh, let's go, Andy. I'm gonna give you a why. Chris: Why didn't you do that, Andy?
Andy: Well, it was thoughtful and discussed explicitly, and it becomes almost pragmatic.
We've got hundreds and hundreds of operators, and then you'd need to have that many or more enforcement people. And the problem is,
is when you get that many more people participating, You get a lot of variability in what good enough looks like. And what is the conversation, the more vague the conversation becomes, the lots and lots of variations of what acceptable looks like.
And that becomes extraordinarily frustrating to both parties. So there needed to be some clarity about a target. What is good enough? What is something that you should be basing this discussion off and then it's back to your point,
sort of a both and sort of a balancing act. You know, we needed a prescriptive base that was clear and diligent enough to pass the red face test, which was a challenge that we put out to ourselves back then.
Regardless of where the regulatory world is right now, we need to pass the red face test with a landowner that we're doing the right thing because that's our obligation.
and then set those requirements into place and then create a platform where you have the opportunity to vary from that. But it's clear what you're varying, more clear what you're varying from. It's not just totally goal -oriented.
It's there's a prescriptive standard and an expected outcome there, which is a goal that helps us be a little bit more centered, less variable around the prescriptive conversation.
So the two kind of fit together, they kind of knit together.
Chris: I want to share like a little bit of a personal perspective. So obviously when I first came in, I was one of those engineers responsible for making that decision of what am I gonna do?
And I wanted to make a database decision and I couldn't because there was prescriptive regulation. And I also had a real big internal conflict in this 'cause I knew where I needed to send resources And I saw budgets and I couldn't because I had to go do these other things that I'm required to do right and it's very easy to want to challenge that but on the flip side.
I'll say this, having been through a pipeline where you're doing baseline assessments trying to understand what active threats you have on it Understanding that it may not be a class 2 class 3 class 4 HCA But I know my right away and there is a home within A PIR and I don't know anything about that pipeline in that area.
And so what I can say is I have first hand experience of saying I've been through that process of I learned a lot about my pipeline thanks to prescriptive regulation, potentially things that I wouldn't have known about had we not have prescriptive regulation.
Not only did I learn about my pipeline, but as an engineer also developed. So I think of like this inauguration of integrity because didn't always exist, Right and so I can imagine you guys back then trying to say okay.
How do I develop this? That makes most sense. Why would say one of the things that we got though, is it provided a runway for learning not just learning about my asset, but learning what is integrity engineering, right? We have all this research that's being done for pipeline threats.
Well, what are the pipeline threats, right? How do I address it? You know, we're still learning about hard spots. I'm that's just a buzzword lately, right? It's been around for a long time but it's kind of like that prescriptive reg I do feel like yes it maybe there were more economical ways to allocate resources economic conscious ways not economical like less dollars but I mean there's still some meridian is all I
want to say you know it has provided industry with a lot of data a lot of activity to learn how to do this right if that makes sense you know and
Rhett: Look, you two I'm on board okay I'm I am a reformed thinking we always need to have performance -based regulation.
I'm on board. I'm good with prescriptive regulation now. In the wake of the failure files in this conversation, I Rhett Dotson ascribed to the prescriptive regulations that we have in CFR 192 and 195,
and hold none of the old Sages responsible for that. Actually, I also wanna let the audience know, I'm looking at our show notes. I have a million questions I wanna ask Andy, and I feel like we could make this a four hour episode,
but we need to take a break so I can regroup with Andy, make sure that we can get all the content we want for you guys. We'll be right back in just a moment on Pipeline Things.
*** break ***
Rhett: Hi, welcome back to Pipeline Things where we continue our Sage series discussion with Andy Drake on regulation. It has been a lot of enjoyment for me so far. I don't know if I've ever been so quiet on a singular episode,
But it's because I really don't feel the need to interrupt Andy. I'm just like he's just going I just want to let him talk and I want to actually just sit here and listen to what he's dropping But you know, we are gonna we're gonna pick up we're gonna go in a very specific direction now Andy because you've seen,
you know, again The advent of IMP 1.0 and then I know for sure since I've been working in this industry, which is circa 2005 We heard this introduction of zero incidents and zero incidents became a big push and I'm my first reaction full disclosure And I hope you don't get upset.
I rolled my eyes when I heard zero incidents and it's because I'm like, that's stupid I'm like, I'm sorry. That's never we don't accept zero incidents in anything that we do and it's not achievable So I felt like from my perspective I struggled with zero incidents when it was rolled out And I'm curious,
your thoughts, what does zero incidents look like today, and what are your thoughts on a zero incident culture? Oh, you grimaced. I like this.
Andy: Well, I can appreciate the complexity of that. And certainly when we rolled it out, it was met with a lot of, you know, a lot of pushback. You know, why are you doing this? This is an unrealistic expectation. And it was, no,
actually, this is a commitment that we have to make to the public, that no accident is acceptable, that we work very hard, very tirelessly, very diligently,
to try to make sure that we operate and get the highest safety standard. No breakdown is acceptable. Now, the pragmatic side of that is perfection is quite a journey.
And I think that's a good word here, is a journey. Well, we were really, I think, also promoting with zero was a mindset. A mindset of no tolerance, a mindset of constant learning,
pushing to challenge ourselves to learn and improve, and to make martial good risk management choices. And what does that really play is, well,
if we seek perfection on one attribute, it can draw our attention off of other issues that might cause a problem. That's poor risk management. When we look to advancing the standard of care,
the first thing I have to do is what is the largest thing, what is the biggest opportunity we have to advance the standard of care? What is the biggest threat that people are experiencing and what can we do most to move the needle? And that's where we should put energy.
That doesn't mean we don't put energy elsewhere, but we work on that prioritization schema because if we don't keep plugging that schema and that logic in, you get distracted. Well, we're on this issue.
And if we just did a little bit more, we'd be perfect. And there becomes an exponential level of energy that you're pouring into it to get that last little micron of safety that if you put that same block of energy into something else,
another threat, you can make a huge change in risk. That's prudent. And that's the journey. And we are constantly impressed with that. And the regulators have to be on that journey too.
And the public has to come on that journey with us as well. But we need to be able to articulate that logic and that journey. We are on a path to make sure no one is ever hurt.
We are committed to do that. We are marshaling all of our energy and our efforts to get there. The how to do it is risk management. It is constantly plugging back into where do we make the next biggest improvement and putting our energies there.
It doesn't get lost on the journey and marshal infinite amounts of energy into infinitely small amounts of improvement. That's irresponsible actually.
That's irresponsible. So people that draw us down into the perfection challenge are actually anti -risk management people. And I think we have to push them back and say that's not prudent.
Rhett: So why don't you call it no accident is acceptable rather than zero risk?
I like no accident is acceptable. The journey is zero.
Andy: It's a part of a conversation. This is the public's expectation and you're coming out to the middle of the field with the public saying no incident is acceptable.
Now. We're on a quest to get to there. Here's how that quest works. Yeah, and this is prudent and Frankly, that's how the airline industry works.
That's how the nuclear industry works. Yeah No nuclear incident is acceptable. No, it's not okay. No airplane accident is acceptable No, it's not okay And you have to start there because that's where the public who's experiencing this imposed risk sits,
they have to know that you care about them and you are trying diligently, deliberately to make sure nothing happens to them. And it's logical and it's diligent and it's a process that you use to get there.
Chris: That builds trust. Andy: That builds their trust and confidence, which is huge.
Chris: It builds trust. And I would say, you know, Andy, I always like to try to tie some of these discussion points back together because again we've talked about this a lot and I know some of our audience maybe are learning a lot from this year so I like to tie things together a bit and if you have anything to add to it please do.
The idea is it's you know we talked about prescriptive versus performance right and the idea how sometimes you have prescriptive regulation it can kind of restrict you on that journey to zero right because you're forced to put resources in one place where you have data and you know you should be put in that somewhere else But I think that one of the things that you guys did a very good job of,
like I said, because you were on the G -PAC when what we call, on this show, we call IMB 2 .0 came out as it's, I do think y 'all worked really hard. And I remember watching you guys to make that step forward in having what you said earlier is that and proposition.
It's prescriptive and performance. And one of the places where I see it, where I saw it the most, at least in my opinion, is an example that's how we manage debts. So for example,
again, there is a perspective component that is required, and I think that you still have to do risk assessments. That's prescriptive. You don't have a choice. You will do risk and you will use data and you will integrate a ton of data.
So we see words like ‘any’ and ‘al’l all the time as it relates to data integration and that will be prescriptive. But where we have that, that balance was and now what we respond to.
And I think that's where we're starting to see some more of those performance based influences in regulation that you guys did move. So whether you're back in the nineties, consulting, you know, and advising to now,
I think that we are seeing some of that evolution, right? Towards that and proposition of saying, look, we know there's dents here, and because of IP 1 .0, we know a lot of these dents, we can profile which dents are injurious and which ones we think we can manage.
How are we going to do that now? So now there's regs that allow us to do that, right? And it allows that notification to PHMSA that say, "Hey, here's what I want to do. Can we engage in the how and be selective about where we bring in this performance -based type theories and culture?" And so just I wanted to tie all that together to say,
"I think that a lot of those efforts are coming together and for the audience that are doers, that's kind of where some of it's coming from." And I wanted to help tie that together. comments.
Andy: Very insightful because they are integrally connected.
The performance -based regulation and approach can fuel a change in the regulations. If you get your industry leaders, so to speak, people have the capability, the competency, the capacity to do more deliberate evaluations,
data gathering, and analysis, engineering analysis, they will come up with a better mousetrap. They will develop a better tool, they'll develop a better algorithm, there will be a better risk assessment protocols.
And once that is definitive, they can put that into an industry standard that then becomes a template that everybody can follow in a prescriptive regulation,
Chris: And potentially incorporated, -- it feeds like a flywheel kind of
Andy: Exactly just like a flywheel. So the performance based option actually can continue to evolve the prescriptive regulation clarity and flexibility to better get a better fit because right now the prescriptive regulations can be very you know broad and generic to cover the most the worst -case scenario but over time you want to use the performance based solution to fine -tune that to dial it
in so what if you had this data or if you had this information you could do something a little different in the prescriptive regulation which is
Rhett: Touching on what some of the other stages have said,
you know, that requires both operators to be investing in research to be investing in advancement, investing in the standards if you're gonna get that cycle that Jerry talks about right,
which is where ideally, you know Research precedes standards, which then precedes regulations, right? You think about the performance -based stuff that that would have to happen as a result of that You know,
I had one thought as you We're talking about it's I'm still and I don't want to continue the conversation too much on zero But zero is because you know you said you know no accident is acceptable I do agree with that in any industry,
but things happen that we don't foresee Fukushima happen, right? We didn't foresee a tidal You know the tidal wave that would come in and wipe that out the flooding the typhoon that ultimately brought that on, I think sometimes like Malaysia Airlines 370, nobody could have foreseen that you were going to lose that airline the way that we lost that airline Or maybe even the one that was shut down the shut down over Ukraine
things happen in those industries that we still consider I would say acceptable Maybe the the landing in New York Harbor where the birds hit the plane and and they took it down And so I think in in our even I was thinking like we just lost power for a week in Houston If you said something like no power outage is acceptable.
Nobody in Houston is willing to pay for that. Nobody, I promise. We are going to tolerate some level of power outage as a result of incidents. I still think that there is,
there is some, I like the journey discussion. That's what I like. But in our lives, we tolerate and understand that nothing is perfect. And even in pipelines, it's a journey.
No accent is acceptable, but we will in the duration of our life, continue to have incidents because something's going to happen that we didn't know about or worst case scenario, you're going to have a third party accident, somebody's going to strike a pipeline.
Chris: So I mean, but I think the word is culture, right? I mean,
Rhett: culture and transparency
Chris: and and I think the the message is it is unacceptable.
Rhett: It is unacceptable. - I do agree with that.
Chris: And you can feel that, right? Like Again, I read, I think I speak for both of us when I say we love what we do. W Right. And we say round sound in the ground. That is what we're here for and not just D2 integrity,
but that's what we as an industry are here for. And so I think it is fair to say it is unacceptable. Yep. Right. However, unfortunately things happen. And you want to be transparent when they happen.
And the culture of how we address that I think is where potentially there's opportunities, I'll say it that way, right? Because I mean, this is very complex and you've said that and you've made that clear,
right? As it's the intent and always valid, right?
Rhett: And I think as an industry, I feel like we're doing good. I feel like when we have failures now, I don't necessarily feel like there's a defensive posture. I feel like there is more of a knowledge sharing posture.
I think the operator often comes forth and says that the accident is unacceptable. And I'm like, whoa, this accident happened and we're Okay, with it, because we can't manage all of this. And look, we're actually having less accidents now than we had 20 years ago,
and we're repairing, they don't put this defensive posture forth that upsets the public. And so anyway, all right, let's leave zero incidents, 'cause I feel like we could just, we could go on. Maybe that's a roundtable discussion.
The last point I wanna close with you, Andy, was the original rule focused a lot on protecting life. We talked a lot with Keith Lavis about that. When he talked about, hey, you know, the original PIR circle and 90 % lethality,
everything, you know, they took a method that was reserved around protecting life. And even the introduction of moderate consequence areas and the updated rule, when the NTSB advocated for that,
they mentioned that, you know, that that failure location that happened so close to a major arterial right away could have resulted in loss of life and they wanted to begin protecting against that so they expanded it with moderate consequence areas.
I feel like lately we've seen a huge shift or maybe a shift in the conversation to focus on environmental consequences and I feel like that's coming for the pipeline and the pipeline industry where we might see PIRs that are based on consequence area or HCA's that are It's not on proximity to life,
but how much of a release you might have in the event that the failure occurs here. Do you have any thoughts on that, on whether or not you see, how you see environmental impacts coming into regulations,
Chris: or influence,
Andy: or influence, or maybe what I -- The climate. Right? Yeah.
Andy: I will, I'm going to touch on something that you mentioned because I think it's really important you said that We are now being asked to extend integrity management to MCAs because of events.
If you read the S document, you'll notice it doesn't really talk about limiting integrity management to HCA's. It talks about this is how you do integrity management everywhere and HCA's were defined as a prioritization schema.
When we did this 20 years ago, we knew, we intended this to be deployed to the pipeline system. HCA's was just a starting point. We knew there would be HCA's, MCA's,
LCA's, low consents, and the goal was to have deployed everywhere. And I think that's important. That was the original design.
Rhett: You're consistent with Keith. Keith said the same thing. He said Inga actually had a commitment to have everything fully covered,
I think by 2024. And then they revised it to 2035 later on.
Andy: We revised our goal and we talked to Carl Weimer about how many people are we protecting? Not how many miles of pipe are we protecting?
Shift the conversation. This is about protecting people. How many people? What is the percentage of the population that has provided protection, confidence, via an integrity management plan? And then how do we,
what's the next tranche? And what's the next tranche? And I think that's important because, you know, conceptually, we wanted to define an integrity program that would deploy to all pipes.
It was just then, well, that's too big a, that's back to us, that's too big an asset right now. So we start with where the high consequence are, then we work to the next tranche. That's risk management. And so that was fundamentally part of the design.
The end, I didn't mean to cut you off, I'm trying to answer his question.
Chris: No, but I had to jump in, right? Because again, I just, I want to share this, right? As it's, we just talked about like the message that zero put out,
right? And I think something I wanted to highlight is it's prescriptive regulations can be hard because sometimes you don't see the value. But what we keep saying is it's people. And if you keep using the word people,
people, life, people, things just begin to make more sense. And it provides a goal, right? It provides a, an ambition, a desire, right? So if I'm an integrity engineer,
or I'm an ILI analyst, you know, listening to this podcast, or, you know, I'm a potential future leader that's going to be on the G PAC or the L PAC or whatever, it's like, it is not hard now for us to understand are there features or threats on the pipeline that will affect people.
And that's easier to tie to then a PIR or a class location or a distance of pipe right it's my aim is very clear now when I'm looking at these inspection results. Where am I going to where am I affecting people right and I just feel like it's a little bit easier to hold because I mean I'm telling you Andy you look at these and you're trying to do your dig program you're trying to establish your reassessment
intervals you're trying to fight for budget dollars all of these things and it's like okay class locations and seven -year inspection interval you think about regulation but if as the integrity and decision maker I'm thinking great communicate this in terms of people all of a sudden it becomes easier in my opinion
Andy: It really helps if you understand why you're doing something,
then what you do makes more sense. If you understand if you're going on a journey, have a destination, know you're trying to go, that's really helpful in most journeys, but getting that clarity is really important.
And I think one of the things we have to deal with, and this is back to your question, is what does society expect out of us? And now, society's expectations of us is changing.
You know, Climate change is out there. People are very anxious about that. You've got a lot of pressure from society that this is something they're worried about. I wouldn't say everybody, but a lot of people. A lot of people enough to get a lot of energy around this,
a lot of emotion around this, too. So now we're being asked to complement that with an and -proposition of a different kind. We want you to protect people
Everyone: and the environment.
Andy: When gas pipelines were designed back in in the '50s, '60s, '30s, go back and forth one ago, went way back when gas pipeline standards were being developed.
Primary concern was people's safety and that methane was not viewed as an environmental hazard. So releasing methane to the atmosphere was not a big deal.
And the systems were designed that way. ESD systems were designed that way. It was designed, put it to the atmosphere, and protect safety. Okay, well, as we talk about now,
you know, society wants us to look at environmental impacts also, like, okay, well, that's not the way the system was initially designed. So we have some very significant issues to deal with,
not just leaks, but fundamental operational issues like valve packing and, you know, rod, our rod packing on equipment and, you know, leaking seals here and there,
fugitive emissions, you know, blowdowns, ESDs, pigging. How the system was designed wasn't designed around that premise. So we have to rethink that whole premise,
which society is asking us to do, which is fine. It's just back to risk management. Okay, how do we go about making a big improvement on this.
And I think this is really important for industry, rather than arguing with society over what they want is right or wrong. It's what society wants is what society wants. It's our obligation to deliver what they want.
And then how do we do that? And create, we own our space, not just safety, but the environmental impact. And we're gonna own that. We're gonna own a plan on minimizing our footprint because that's our societal obligation is respond.
So that I think is a big part of the leak detection rule that was in place you know and it's gonna be another journey and that's another risk manager.
Pick the biggest things that you can that make a big difference and then work to the next and work to the next and work to the next and I think that will you're starting to see that effectuated whether that's through EPA with,
you know, emissions from, you know, prime movers or PHMSA with, you know, leak containment, you know, those are, those are all going to be just part of our obligation.
Yeah.
Chris: And one of the, I want to ask you this question, Andy, it's kind of to get your thoughts on.
Andy: He has to answer in 60 seconds.
Chris: It's okay. It's, it's his show. Didn't we - We're gonna run out of battery?
No, I'm just kidding. I'm just kidding. Andy: Yeah, the battery's gonna run out.
Chris: You know, one of the beauties of this series that I appreciated is it's there's so much to learn from you guys. And one of the topics we mentioned,
I used to call the Silver Tsunami, right? And the idea of loss of knowledge capital when certain human resources decide to retire or move on. And you have this generation that is relying on data systems and processes and other resources to learn.
That's one of the things when we were thinking about the podcast was it's like, you know, it's hard for us. We've both been very privileged to have access to individuals and research and mentors. So we kind of wanted to stand some of that up with the podcast and make it available to people to be able to hear and latch on to.
So I wanted to ask you, you know, with this mindset of this incredible journey you've had in pipeline and all your exposure. Any comments to maybe some of the next generation as it relates to,
you know, just general advice to, hey, get involved here or be cautious with this or, you know, XYZ?
Andy: It's a great question, you know,
because I do think that, you know, history has a funny way of repeating itself. If you don't know, if you don't know what caused things, don't understand the basis of history, then you have a great chance to repeat.
And these learning curves were hard -earned. There was a lot of energy, a lot of money and effort put into these things. I think it's really important for people to make efforts to understand the why questions,
the five why. Why did we do this? Why? Why? Why? Why? Why? Why? Why? Really push yourself to understand and to try to not recreate work that's been done,
but to collect it and understand. I think that's really the beauty of the podcast, this series like this, where people kind of download what the thinking was at the time so that the next generation doesn't have to repeat it.
It's like, "No, we know that. We don't have to build that it's already exists we just build from it and I think that's what I hope as we continue on that journey is don't don't get too lost in the journey understand the journey don't get frustrated with it too much you know ---- it's a worthy purpose and understand and to keep trying to advance it,
keep asking the why questions to advance it.
Chris: I just wanna echo that, Andy Bravo, I love it, because how many times have we been in a room where there's an idea proposed to do research that we've already done?
- Yeah.
Chris: And your statement of, hey guys, and we're talking to the audience, I'm talking to the audience now, before you propose a research idea, propose a budget to learn what's already been done,
right? Build on the work that's been done. You know, the lessons are hard learned. There's a lot of effort and it's kind of what we tied to prescription regulation have allowed us to spend a lot of resources learning a lot of things.
Let's collect that, let's gather that, that's render that and then look at how we build on that.
Rhett: You know, and on that note, Chris, I'm gonna wrap it up. This has been an absolutely great conversation,
Andy. I wanna thank you for joining us. I actually sincerely hope it's not the last time that we talk. You sparked a desire in me to want to do more with you and some of your other colleagues. And I want to thank you for sharing,
you know, that history and your wisdom with the audience. And so to our audience, I want to say thanks for listening. Hopefully you enjoyed this Sage series. If you did, give us some feedback and let us know maybe punch the like button or send us an email directly if you have ideas of other Sages you think that be a good idea to have on this podcast.
But wrapping it up here, I'm your host, Rhett Dotson, my co -host, Christopher De Leon. Thank you for joining us on Pipeline Things.
