Episode Transcript
Rhett Dotson: Have you ever been curious how we got to the identified sites that exist? And 190 to 4 HCAs? Have you ever been curious how or why MCAs made their way into the updated gas rule? What happens when maybe the threat to life isn't the only thing that we should consider when we talk about the severity of pipeline.
Today that's what we get into when we talk about two notable incidents, one that occurred over two decades ago and one that's a little more recent. Both of them having massive implications on the original IMP 1.0., sometimes we like to call it, and in our updated gas rule. Hope you enjoy this episode of Pipeline Things.
Rhett Dotson: All right. Welcome to today's episode of Pipeline Things. We are sitting here carefully trying to get into our chairs underneath the acute direction of our new producer who has, I might say, furnished some excellent upgrade slash additions to the podcast. Yeah.
Christopher De Leon: I'm mildly awkward. Like, I don't know how to sit in this thing and like I can’t touch the mic. It’s so weird, dude.
Rhett Dotson: Okay, well, as Christopher gets situated and figures out how to I deal with advanced surroundings. I am your host, Rhett Dotson. You've already met. I'm sure, before my co-host, Christopher De Leon. And we are here continuing our series on notable pipeline failures, but definitely wanted to give a shout out to we have we renamed a week ago. I don't know if I'm allowed to use the old name on air anymore. Did she restrict that?
Did you restrict that or are we good second string?
Christopher De Leon: I kind of like CD. Creative Director.
Rhett Dotson: Yeah. Creative director.
Christopher De Leon: Creative director. Make it easy. Something like that.
Rhett Dotson: She's so created will soak that up. Right. We gave her that. I mean, we.
Christopher De Leon: Got new.
Rhett Dotson: All right, so our new creative director has again, you know, I.
Christopher De Leon: Actually I like the bit of the Ms. Producer. I like Creative Director. It's a new, new era, new face.
Rhett Dotson: All right. She smiling. I mean, she's happy. Probably did everyone well. All right. So today, if you're joining us again, really excited on this particular arc that we're doing of covering, I say notable pipeline incidents. I maintain that it is it's always important to know the events that shaped us, shaped our history. As we said time and time again, the only thing we learn from history is that we don't learn from history.
And I think it's very important that as pipeline operators, as pipeline integrity engineers and as consultants, we remember the events that were significant in our history. And so today we're actually going to bring you two notable pipeline incidents that are, I think, linked by a common thread. And there's a reason that we're going to bring you to one of them might feel a bit out of place.
And that's because we decided, Chris and I made the decision to actually put that one in a slightly different place because of the thread that ties it together with the second failure. So, without further ado, Chris, are you ready?
Christopher De Leon: I'm excited. You know, I like this stuff.
Rhett Dotson: Yes, you've called it story time with Rhett.
Christopher De Leon: Story time with Rhett Dotson. Well, it's fantastic.
Rhett Dotson: Okay.
Christopher De Leon: For the audience out there, I would just encourage all the podcast listeners, don't put it on like 1.2 or 1.5. Like, you have to like, listen to like the way he emphasizes things and all that fun stuff. So, it's got to be on 1x.
Rhett Dotson: I'll try it out. I'll try to keep the speed down. But you know what, it's interesting because the two failures we're talking about today, they don't have I will say let's you know, the maybe the focal point, I almost want to say the drama or the drawn-out characteristics in the control room that the previous two had, that's actually.
Christopher De Leon: Maybe was not the right way to describe it. I would say maybe they're maybe they don't have the...
Rhett Dotson: The complete weight.
Christopher De Leon: Maybe the weight. I would say the week like if you were to go and say hey integrity person or pipeline you know person in the industry for at least five years, name one or two significant incidents they wouldn't name one of these two, even though one of them, as you said, you probably want to threads the needle to kind of how we got here in the first place, which.
Rhett Dotson: And I think depending on what you do, both of them, both of them impact us. So, Chris, we're going to start August 19, 2000. August 19, 2000, that's pretty that's pretty close to your birthday. Where were you in 2000?
Christopher De Leon: Oh, was in high school.
Rhett Dotson: You were in high school?
Christopher De Leon: Yeah, I was probably running cross-country right about right now.
Rhett Dotson: I was actually about to start my first year at Texas A&M. Yeah, that's where I was.
Christopher De Leon: That was pretty close to when you decided you didn't want to be in Louisiana anymore, right?
Rhett Dotson: I had already decided I want to be in Louisiana, and we'd already moved on past that. That was another time. I was fully in Texas by this point in time.
Christopher De Leon: But this was and this is also after you had that whole driving incident, right, where...
Rhett Dotson: No, that was my second year.
Christopher De Leon: Oh, that was in college.
Rhett Dotson: You know, you know, you got to see that material for another episode. And we can we can talk about how...
Christopher De Leon: I mean, since we're talking about infrastructure.
Rhett Dotson: For me literally falling asleep at the wheel. But no, August 19th, 2000. 5:26 a.m., I actually need to take you and our audience to Carlsbad, New Mexico. I do think this is an incident that many people aren't familiar with. But I think that the interesting tie for me is I do a lot of camping. It's something I've gotten into with my kids the last several years.
And notably, campgrounds typically are in, I'll say, maybe more rural areas because you typically want to camp away from humanity. And it's no different here. So, what happens is...
Christopher De Leon: It isn't one of your favorite meals, what do you call them? Walking tacos?
Rhett Dotson: Walking tacos are amazing. Yeah. So for the audience out there...
Christopher De Leon: I guess that would be a cool name for a food truck or something. I don't know.
Rhett Dotson: You take a Frito, take the small Frito bag three to a little bit of taco meat.
Christpher De Leon: Yeah. Not even the real. Not Tostitos.
Rhett Dotson: The little small Frito bags. You know that thing? A taco meat dude, you get some pico de gallo, some taco meat, and shredded cheese, and you just throw it all up in the bag and the kids walk around with it at the campsite and they just eat it straight out of the bag with a spoon. It's amazing. Yeah, it's a favorite meal for my kiddos. Walking tacos. I didn't name it.
Christopher De Leon: It, so basically it replaces the tortilla with plastic, is that what you said? You said the Frito bag...
Rhett Dotson: Fritos. You don’t eat the Frito baggy, the Fritos are inside the bag.
Christopher De Leon: So where does the taco come? Because, you know, I don't know.
Rhett Dotson: And I told you it's Fritos.
Christopher De Leon: So, it's maize, which is what corn tortillas are made out of.
Rhett Dotson: I think for those of you in the audience, Chris is having an epiphany. While we delay the start to the show, we're going to cut right to the chase. August 19th 2000 5:26 a.m. a 30-inch natural gas pipeline that was operated by El Paso. Natural gas fails. I don't want to go too much into the details again, because it's not the main focal point of the story, but it was a it was a massive rupture.
What I would encourage, if you get a chance, it's hard for me to describe the photo to you because this this fireball ruptures obviously in the middle of the night and it happens behind a pipeline suspension bridge right. So, a lot of the photos, you can actually see the suspension bridge in the foreground and you can see this fireball in the background.
And it is it is amazing because it gives you a full perspective of how large the incident, how large the impact was and how significant, you know, some of these gas pipeline ruptures can be. I mean, we talked about San Bruno in a previous episode. This is another massive fireball. But again, in a more rural area. To give you some idea, it creates a 51-foot crater, 113 foot wide, and the fire burns for 55 minutes.
The real travesty, though, here in this failure is that there's a family of 12 people who were camping under the bridge that supported the pipeline and all of them were killed and three of the vehicles were destroyed. And not as you get into the incident reports. And, you know, I always assumed when I read this that 12 people were killed incident or were killed instantly.
They actually weren't. Unfortunately, several of them tried to crawl into the nearby river as the fire was burning and a few of them actually died after the incident. So, it's really, really, I'd say, a very horrific like kind of mind jarring accident again, with, you know, a family camping there. When this accident occurs. And the significance of the event, I'll say the significance of the event from why it actually occurred was this was a non-packable segment.
It failed due to internal corrosion, all things that we would say today. We have a handle on the integrity management of that. But the significance of this event and you take the audience back I mentioned it's 2000 this is pre-IM 1.0. This is actually pre any type of what we would consider modern or significant integrity management regulation.
And so, one of the reasons I wanted to bring this event up for us is, is twofold. After this incident occurs, we see the initial regulations come down from PHMSA and their statement when they issued the original IM rule was as follows. I'm just going to read it to you verbatim because I think it helps them understand why the original integrity rule was written with the focus that it was written with.
Know it says, this is PHMSA speaking, “When we issued the final rule defining these areas,” by these areas they mean covered segments. That's what they're talking about, “We agreed that impacts to critical infrastructure could have detrimental impact, but that such impacts would not likely include death or serious injury. A major purpose of the integrity management rule is to focus the highest level of operator attention on those portions of the pipeline that can have the most severe safety consequences, i.e. can cause death and injury.”
Rhett Dotson: So, what we see come out is when the definitions of eight series and the original rule comes out, there is very much a focus on preventing life, the loss of life and injury. And I'd say, you know, again, if you're not aware or you've ever wondered for our gas operators out there, when you read the definition of eight series, they identify eight series and then they identify identified sites.
Christopher De Leon: Yeah, which is caused by outcomes and. Right. And so, this, Carlsbad, if you read again, I'm a big advocate of everybody reading preambles. Right. Especially with the new gas regulations that have come out and there's you know, been some indications that there could be some new liquid regulation, whether it be focused on, you know, CO2 or other things, NPV. The point is when there's new regulation, I think it's important to read the preamble.
You learn a lot about it. And if you do pay attention to, you know, the preamble, what you'll find is, is, you know, PHMSA specifically stated in named this incident and when we've already covered as driving forces for what we call IP 1.0 and this.
Rhett Dotson: Is the preamble to be clear to the audience for the original notice of proposed rule.
Christopher De Leon: No, this one is for the new gas rule.
Rhett Dotson: Okay, So in the preamble to the new gas rule.
Christopher De Leon: And so, what we find in in the preamble, which is a good nugget, is that both building in Washington for the liquid side and this one in Carlsbad was where we had significant fatalities around 2000. And they're like, we need to do something about this. And so, what you find is it's in the gas side. You get a new subpart in regulation right at the time Subpart O, we'll call IP 1.0, and Subpart O or integrity management was really focused on covered segments, i.e. HCAs.
Christopher De Leon: Right. So we went through this span of you have certain amount of time to identify your HCAs, develop a baseline assessment plan, and on the gas side, you have until the end of 2012 to assess 100% of all of your acres and so this is kind of where Carlsbad, we feel, had a relevant spot, right? So, while the integrity threat was internal corrosion and there may be not an ILI component to it, the reason why we wanted to bring it into the fold is it was one of those incidents where it's tragic fatality.
As an industry, we didn't put a good light on ourselves. It wasn't our brightest moment and something needed to be done. And so, between Bellingham, Washington and Carlsbad, we find the birth of integrity 1.0 and hence HCAs, and in this case, identified sites. Right? So, if we needed to look at acres, i.e. covered segments. Where do we find ourselves?
Rhett Dotson: And it's a identified site comes in because if you have an identified site that's in your PR, they defined it as an outside area or open structure that is occupied by 20 or more people for at least 50 days. And then in parentheses, they put examples beaches, playgrounds, campgrounds. So that's where you see Carlsbad. It just explicitly included in regulation.
And again, as a direct result, I think of the I would say almost like the shock value of it. Right. Like Americans, people, we don't like to see those types of things happening around pipelines. Right. So that that incident in particular had a very direct impact, like explicit impact on code, if you will. I think the significance you mentioned there isn't an ILI component, but it was a non-piggable segment.
They were we didn't go into details on why the corrosion wasn't found and some of the other things because I think it's less applicable today. But it's fair to say that the region would have been identified as an identified site, which means it would have fallen underneath the rule that came afterwards, which means that in-line inspection could have been a means by which the integrity of that site was made.
Christopher De Leon: It was piggable.
Rhett Dotson: It was made piggable.
Christopher De Leon: Even though they still could have done some kind of DEA program where they could have understood that there was incidents that happened in the corridor that you could then integrate and find. But I think, again, with our audience generally being people who are focused on pipeline integrity, a big takeaway that if anybody has ever worked on our on our team in some kind of training capacity, I've always been big on understanding consequence, right?
And I don't just mean quantitatively, I mean qualitatively sufficient, right? If you get a dataset, I'm always real big of understanding. If it's on the gas side.
What's your classification, right? What's your HCA rating? And I often quiz people a bit and saying, you know, what is an HCA? What defines in HCA? Right? What defines an identified site? What's the difference being class locations and an HCA? And now we have some new language we're going to introduce in this podcast, but I do think that's really important, right?
And understanding why these things matter, because, as integrity engineers, we're trying to protect human life, the environment and operations.
Rhett Dotson: And, you know, again, I read that statement to you earlier about PHMSA’s intent because it ties directly into the second year we're going to talk about today. And they focused attention on the areas that had the most severe safety consequences, namely death and injury. But PHMSA’s also made it clear in later statements we intended you to do it in acres first and then do it everywhere else after.
Right. Like PHMSA has made that statement publicly multiple times. We did not intend for integrity management to stop at HCAs as we defined them and laid out and regulation in 2003.
Christopher De Leon: It's a it's a great point. Right. So unfortunately, what we've seen in the US is that we need failures to kind of have shifts in our safety culture. Unfortunately, you know, and I use the word safety culture, not just integrity, right? Because when you think of integrity, often, unfortunately it is tied to regulation, which means compliance, right? Which means I can do it here and you tell me to do it over there.
So that's why I did it, right. Whereas in this case, like we said, you have Bellingham, Washington, you have Carlsbad, you have people dying. This is fatalities. There are significant injuries independent of location. One is clearly in HCA, one maybe depending on how you want to talk about it. But the idea was it's let's get something going.
And like you said, PHMSA was very clear. Our goal is you're going to start here. And as you learn and mature, your plan, your integrity management plan or program in the broader scheme of things, you should be seeing this on other parts right in. And part of that, and I know the macro is important, you know, we don't want to necessarily completely separate them as it's and that's why we begin to see part of what we're going to talk about in the second failure, right, is how they really said, okay, fine, what has happened between roughly 2000s and the new gas rule that we need to make sure we incorporate in what we're going to call IMP 2.0.
Rhett Dotson: So let's fast forward to December 11th, 2012. So we are over 12 years later and Chris, we're going to be dealing with another non-pigged pipeline, let's call it that. I don't want to use the term non-piggable because at the time of the failure to actually been made payable but it.
Christopher De Leon: Had it not been inspected.
Rhett Dotson: Not been inspected. So, on this on December 11th, 2012 there was a 20-inch natural gas transmission pipeline operated by Columbia Gas Transmission and it ruptures about 106 feet west of Interstate 77, near Sissonville, West Virginia. So ,this anvil becomes what this with this failure is coined. And, you know, again, a lot of the previous storyline that you see in the failures isn't here on this one emergency response and medical response or on point.
This failure happened at 12:41 so it's literal middle of the day. The gas control center is aware of the failure and identified it as being associated with their system. Less than 15 minutes after the failure occurs, they were notified by a gas controller from another control center. But again, point is within 15 minutes they get the situation under control and know that it's associated with them.
So, you don't see any of I say the previous issues that we talked about in the other ones. What is significant about this one is that three houses are destroyed and the fire destroys an area that's 820 feet wide and over a thousand feet long along the pipeline right away. And as a portion of that, it actually burns a portion of Interstate 77 and closes Interstate 77 and interstate, not country highway, but closes it for 19 hours because the fire burns so hot that it completely destroyed the pavement and the pavement had to be replaced.
Rhett Dotson: And so, what happened here? How did this failure occur? So, again, I want to give you a little bit of the background on this pipeline is I think I think that there's some similarities and some warning signs to the to the previous one. So, the pipeline in question here, if you go and look as SM80, it was installed in the 1950s, is actually an uncoated pipeline and a portion of it had been replaced in 1967 when I-77 was built. And so, it was in a class two location and it was operating at 929 PSI.
Christopher De Leon: So just interject. Class two would effectively mean likely. Not an HCA.
Rhett Dotson: Yes.
Christopher De Leon: Right. So, unless there's anything if I'd say right. So we haven't gone through all the definitions, but right now we're thinking Subpart O doesn't apply. If you're a gas operator.
Rhett Dotson: Subpart O does not apply to this particular portion of somebody. The integrity had happened. They'd been twice pressure tested twice in 1967, once whenever the replacement project happened, and eventually they did a hydrostatic test on the entire segment of SM80, and both of the tests were for 8 hours and were held to well above the operating pressure of 929.
But again, that was in 1967. We're in 2012 whenever the incident occurs. So, you already mentioned that it was in class two not covered by Subpart O.
Christopher De Leon: It could have been an HCA, depending on your opinion, if it had 20 structures. But us knowing a little bit of the information, if you're using one of the two options to determine an HCA, it's very likely this was not considered an HCA.
Rhett Dotson: Right. So ,it's interesting in the report, the NTSB report actually calls it out specifically that way. And as a result of not being in an HCA, it wasn't required to be assessed by in-line inspection or any other assessment method. So basically, it's let's say off the radar, if you will, for required integrity assessments, one of the three methods.
Yeah, but what's interesting about this line is it wasn't the only line in the right away. There were two other adjacent larger diameter lines. There was a 26 and a 30-inch line that were nearby that were both designated to be in HCAs, and they had both previously been inspected with ILIs and both had a history of corrosion damage within this area, with repairs that had happened within 500 feet.
That's how the NTSB report to find it. As they said, hey, you, these two sister lines both had corrosion issues. Both had corrosion issues that had been repaired within 500 feet. But you took no action on a pipeline of comparable age. Everything else, all things being similar, opposite diameter, essentially the same pipeline, and you took no action on them.
Right. And so that's kind of what the NTSB report hones in on, which is, by all accounts, this pipeline looked like the tube next to it, minus the diameter of them, and it had a failure. And we know that had it been in an HCA, had it been inspectable, you would have detected us.
Christopher De Leon: The challenge with this scenario, at least the way it's presented there, is it's that's fact finding. Right. And so, it's easy to draw what seem as simple conclusions. Right. But when you're looking at a large network of pipelines, it's incredibly difficult. I mean, this could almost be this is a rare event, right? It almost becomes a needle in a haystack.
How did I know that this very, you know, discrete part of the pipeline at this point was going to fail? And you and say, oh, because you had already done remediation next to it a couple of years back, you would say, “Yeah, but I've done a lot of remediations over my whole network over a couple of years back.”
How do you hone in on this? Right? And that's the difference. I think just to highlight this, the challenge that that pipeline operators have in their integrity programs is it's a program, right? It's a system in which I'm slowly but surely chomping at the bit, gathering more data and trying to make decisions. So, I just wanted to almost soften the message there a little bit, right? Because at first it seems kind of obvious, but hindsight's 2020, right?
Rhett Dotson: And that's how I feel like a little bit when I read this report was, I feel like we see data integration popping up again. And it's not that it wasn't a fair point on the NTSB. Yeah, but it also feels like, man, in hindsight you have the luxury of looking at all the data and saying, yeah, maybe I should have done that.
But when you're forward thinking and you're managing lots of systems and so much data and again, this is 2012, not that it's not a valid point, but I think it's it again feels a bit like 2020 hindsight.
Christopher De Leon: So, for me the perspective, at least when I looked at this is again, obviously is I don't know if it's fair to approach it from a compliance perspective, but I think data integration is very valid. But I think what we find some of the definitions that we are going to see updated we're going to talk about here in a bit is it's you have to consider consequence, right?
So, what separates all the other repairs we've done where we have parallel lines where I've maybe dug on the 26 inch and the 30-inch, but not the not the 20. Why haven't I dug on the 20? What maybe is a dealbreaker? There is. It's is it next to Interstate 77? Is it next to a campground next to?
Rhett Dotson: Actually, we're going to pause because I want to come back. I want to hash it out a little bit with you, because when we talk about HCAs, a lot of times we still focus on life and the loss of life. Yeah, And I don't know if everybody's first instinct is to look at a highway and think loss of life.
So if you haven't figured out yet how Sissonville is going to impact regulation, stick around with us until after the break. And we will take it up. But I have a quick break and we'll be right back to you.
Rhett Dotson: All right, so, welcome back. To Chris, right before the break, you mentioned that you always talk about looking at consequence, right? Nice things are not always...
Christopher De Leon: Oh, I mean, it's helpful to do that, right?
Rhett Dotson: It's helpful to do that. But I think it's be interesting here is that we often focus on buildings and structures. That's our natural inclination counts, right? In this particular situation, yeah, there was no loss of life, but the NTSB report actually explicitly goes into that because it says for that original statement, I read to you before where I talked about the original IM rule.
They thought about including critical infrastructure but didn't because they decided to focus on death and injury. Yeah. Regarding Sissonville, the same report has this to say, “Had the accident occurred during commuting hours,” remember I told you it happened at 12:40 so we’re at lunch time. “This is not a back and forth when traffic would have been significant severe air or fatal injuries could have occurred. Both the system bill and the Palm City accidents,” Palm City’s another incident that's referenced in this report, but we're not going into it, “show the vulnerability of highways or principal arterial roadways that are close to high pressure pipelines and the threat that proximity poses to the safety of people and property. Therefore, the NTSB concludes that if pipelines in proximity to highways had been included in the HCA classification, the ruptured area of line SM80 would have been covered by the I am regulation and would have been evaluated.”
So that's the link going back to Carlsbad that I mentioned to you earlier. Right. Carlsbad wasn’t and at the time of the regulation, because HCAs didn't exist after the initial regulation was included, Carlsbad would have fallen into that would have been assessed likely as.
Christopher De Leon: As an HCA.
Rhett Dotson: As an HCA.
Christopher De Leon: So, we know the answer to this. So now that means arteries are going to be HCAs.
Rhett Dotson: So that is the recommendation that PHMSA recommends, right?
Christopher De Leon: No, that NTSB recommends.
Rhett Dotson: The NTSB recommends. They recommend, I'll read it, “Revise title 49 to add principal arterial roadways, including interstates, other freeways and expressways and other principal arterial roadways as defined in the Federal Highway Administration's,” blah, blah, blah “to the list of identified sites that establish a high consequence area.”
The NTSB report want to arteries roadways identified as sites.
Christopher De Leon: Because of the potential sites. Imagine there's a traffic jam. Things align, catastrophe.
Rhett Dotson: But that's not what actually happened. Chris, this is a chance. This is me... I'm lobbing the softball to you. How did this system will actually get implemented into the updated guest rule?
Christopher De Leon: I'll speculate a bit. So, I'll first I'll say so we see that as moderate consequence areas. Right? And so, you would say what's a moderate consequence area? I would say it's similar to an HCA. It has two components. One is structure count and then the other one is it's some form of identified site, right? So, acres have a structure count and a way to identify the structures within some area and then identified sites in a similar there's a structure count.
So, losing acres is that magic number is around 20 structures within some area. MCAs is 5 structures within some defined.
Rhett Dotson: So, this is a new definition.
Christopher De Leon: It's a new definition of is moderate consequence areas.
Rhett Dotson: But we have no regulatory and agency is right.
Christopher De Leon: What we do. And so, in the identified site in this case is per se if you were to do that parallel is arteries and this is where I say I'll speculate a bit and you would say, but why is it not an HCA? And so, you asked me a question, one of the last pockets. You're like, “Hey, is this the first time that that FEMSA has tried to get rid of the grandfather clause?”
And I was like, I knew of it, but I don't know the details of it. And so, you mentioned Palm City, and my question to you was going to be, did you know of any other circumstances where there was a failure near a highway or a roadway or an artery that had any type of consequence? Were you aware of that before this?
Rhett Dotson: No, I was not. Yes.
Christopher De Leon: So, I didn't either. But I did some homework. So, there's at least two other times when it had happened. One was in 2007 in Louisiana on I-20, where there was actually a fatality. And there was another one in 2016 where it was in Pennsylvania and there was an injury. And so, it's possible to say, look, well, what does data tell us?
Data tell us is that we've been lucky.
Rhett Dotson: This is true.
Christopher De Leon: That when pipelines fell near transportation infrastructure, i.e., roadways, fortunately, there's not a lot of people there. But I mean, that's kind of chance. And so, it's just that's a little bit of my speculation, my conjecture there. But the point is, yeah, I mean, ultimately it manifested itself as MCAs and now there are regulatory requirements, right? MCAs.
Rhett Dotson: Yeah, let's go into it. So, they had to introduce both a new definition and then they had to introduce the integrity management around that new definition. Right. And it does beg the question, I'm curious why they didn't just lumped in with, with, with HCR, but that's probably because of some of the pushback back and forth with, you know, public comment on the definition of acres.
Either way, it works itself in as an MCA.
Christopher De Leon: Yeah, so maybe to shine some light there, right? If you're an integrity engineer or you're in the integrity space and you don't spend a lot of time in code, what's interesting, right, is acres from a gas component, were pretty much confined to what's called Subpart O, right? And there's an applicability clause in there, right, that says if you were in each of these conditions in the 900 series of code, these are the things you need to do.
And that's really the birth of integrity manager for the gas pipelines. So, what we find, though, is it's well, MCAs are now defined in the general section of gas code. That means more of the gas regulation is applicable. And we actually find that unlike in the 900 series where you have to do inspections or assessments on HCAs, we find that it's in the 700 series. And what that means is it's not within the integrity management subsection, which is Subpart O. So, we find is that if you have MCAs, the regulations for MCAs, they're outside of Subpart O in the 700 series, namely 192-710, which is assessments outside of HCAs or non-covered segments. But there's a lot of parallels with what you see in the 700 series and what we are traditionally known to understand in the 900 series.
Rhett Dotson: You know, and I think the interesting thing here again is that any time you have an incident where you have loss of life for the potential for loss of life, you see an expansion of code, right? So, I go back to Chris I made the comment films are always intended for regulations to be applied outside of case. And this is a good example where, I mean, they basically say, “Hey, had this had been an HCA, you would have found it.”
I mean, the corrosion, we didn't get into the details, but the corrosion was 70%, more than 70%. Any ILI tool, MFL tool in the plant, was going to have found that corrosion apps that have been piggable, it absolutely would have been found and dealt with. No doubt about it. Hands down it goes to the argument of pigging makes pipelines safer, which is why you see the focus on making things more piggable and the NTSB wanting to see inspections and ILI use more frequently. We've already talked about that.
Christopher De Leon: And it's not just in I said this in our last podcast right It's not just the NTSB right. It's also Congress. Right? So, Congress sends mandates out through the federal pipeline safety statues. And in 2011, after San Bruno, when they were like, “Hey, we really want all these maximum allowable operating pressures to be to be addressed,” in it there are clear expectations by Congress. And in the statute, there's requirements for testing. Right. Where they're basically saying, hey, for review, we want testing. And you would say, ooh, okay, So, they're just going to basically straight up take the NTSB recommendations. Well, not entirely. They more set an expectation and then expectation was it's in testing. They want alternative methods to higher testing, namely in-line inspection.
So, we said that the last time we just keep driving that. Right. And the intent is once you have data, oftentimes what ILIs can give you, they allow you to make educated decisions and allocate resources. The right way. So, you can also speculate, well, you know, an integrity management, you know, this this incident happened in 2012, which means, you know, they didn't know what time frame they would have inspected the Sissonville pipeline.
So, depending on the growth rate, who knows? We would have found it doesn't matter.
Rhett Dotson: But I want to point out...
Christopher De Leon: You would have had the data.
Rhett Dotson: Yes, and we still know that there's a substantial number of non-inspected. All pipeline segments were.
Christopher De Leon: Not inspected.
Rhett Dotson: Not inspected, and maybe even not inspected all pipeline segments. And you wonder what the next incident would be like that will lead to the expansion of the rule. I Just going to say, Chris, you and I are young, you're younger than me. I don't think we're done witnessing the expansion of regulation in our lifetime.
Christopher De Leon: Well, if we're going to speculate, I would say it's probably pure speculation. Is it? At some point we're going to start seeing safety management systems come in place where integrity becomes a component of safety manager systems, right? Where safety management, if I was to summarize it in a couple of words, it's more of a safety culture where integrity management is a component of that versus it being just compliance with integrity management, right?
So, it's more performance based, right? It's not did you comply with this code, but rather you have to convince us that you couldn't have done a better job, right, because you have a safety culture, right? So it's a shift in mentality, but I don't want to go that way. You know, what I want to see is it some we actually talked about an incident...
Rhett Dotson: Is going to be prescriptive regulation. I think they're just going to draw I'll give you a scenario, you know, because I was thinking right now, when's the last time we had rain in Texas? It's been like...
Christopher De Leon: Didn't it rain over in Harvey, like two days ago?
Rhett Dotson: Dude, it's so bad. Like, everything's dead outside, right? And I was thinking, you know, we always hear about these wildfires and pipelines. A lot of times you look at it in the middle of forest. Yeah, middle of nowhere. And I was like, when does it eventually happen that you get a failure?
Christopher De Leon: It ignites.
Rhett Dotson: That ignites and just burns stupid large swaths of forest as a result of that does it similar to this doesn't injure anybody but you have so destructive in its environmental impact...
Christopher De Leon: Well you have to be careful right in in somebody can fact check me here but there was a West Coast utility company that due to their transmission of electricity. Yes. Caught wildfire that burned up a lot of predominant homes and important people. And not shortly after, I think we saw some financial implications on that. Right. So, again, it's.
Rhett Dotson: It's easy to say, but I'm just saying it's easy to speculate and say, hey, that was a class one location. And then they say, you know what, Class one locations.
Christopher De Leon: But what, you brought over it. And this is where we're going to play off each other. We probably haven't done this in a podcast in a while, so I'll instigate it. Right? It is. It's we recently talked about a failure rate that also had an NTSB report that we went through, which kind of gave us the idea of why don't we do this more?
So, we talked about Danville and the 30-inch Enbridge line with hard spots. And what you started this with is it's you know, there's this constant theme of data integration, data integration, data integration. We've seen that all the way back to when we talked about Bellingham. And what I would say is it's at some point our integrity management plan. We need to take advantage of geo databases, IMU data. You know, you and I, we love the value of our IMU data and it's not that hard to navigate your line and understand pretty quickly as an integrity engineer or as an analyst to understand what is the potential consequence of this if this flaw here. Right? So, if we look at Danville, that wouldn't have classified as it possibly could have been identified site, right, depending on how we look at it.
But it was mobile home park. Right. And we had fatalities there and you had ILI data. But the decision however you got there was complicated in that hey we have something here and there is a potential consequence. But how do you make that decision right? So, for me I think my plug there is it's we keep seeing this recurring opportunity for data integration to solve challenges, but there's an infinite amount of data that we can integrate.
So, what I would what I would kind of propose or one of the themes that I like to do when we're looking at stuff as consultants is if you have, I mean, data, where is this stuff, right? Pull up Google Earth. Sorry, it's producer, I hit the mic. Yeah, sorry, creative director, but throw it on Google Earth. Throw it, you know, use a GPS and find out where this stuff is.
Rhett Dotson: Right? It's located in the middle of a national forest. Nowhere. Yeah, I don't do anything or. But then the national forest burns down.
Christopher De Leon: Yeah, well, that's a little bit different than...
Rhett Dotson: What I'm saying...
Christopher De Leon: But then all I'm saying is this. That's a little bit different than saying, “Hey, this pipeline runs right next to I-10.”
Rhett Dotson: It's a little bit different. I'm just telling in our lifetime. So, you see there's...
Christopher De Leon: Finite resources.
Rhett Dotson: But, you know, you have 10,000 acres burned and then PHMSA comes down and says, you know what, Class one locations within 200 miles of a forest will be. You know, I'm just telling you, I'll get them. I'm throwing money on the wall. I'm saying, yeah.
Christopher De Leon: I think the safety management system comes in before that.
Rhett Dotson: How can we place a long-term bet? Is this one of those things that we put it on.
Christopher De Leon: The board or isn't it fantasy football season? Put it on the board?
So, but anyways, again, the whole point of that is it's, you know, for sure, lesson learned is, is we have IMU data plotted stuff on a map, walk the line on your GPS and started under trying to understand what are potential consequences here more literal versus potentially just keeping your assessment to spreadsheets to software programs that are running calculations even probabilistic put this stuff on a map, find out where it is and integrate data and sharing.
You know what? If I lived here, right? What if this was my mobile home or if I had to drive on that freeway, I have to drive on that freeway.
Rhett Dotson: Absolutely.
Christopher De Leon: So, in just another plug, you would say, well, you know, how common is that? I would say back to that federal statue, you know, we saw or you can find in there that there was the birth of the national pipeline mapping system, which is basically a map of a bunch of pipeline related information. We can find things like acres and pipeline roadways and all that stuff.
So, I think we're headed in that direction. But just a little plug for that collaboration between GIS and geospatial related information and making integrity-based decisions.
Rhett Dotson: Absolutely. So, you know, Chris, I think it's a good place to go ahead and wrap it up. So I think, again, Sissonville doesn't have all of the action associated with some of the other ones. But really, thankfully, what I hope, thankfully, I would say, yeah, because unfortunately Carlsbad did what I really hope to drive home is that when a failure happens and it has consequences that often drives regulation.
We see that both in Carlsbad and Sissonville. And I think we as operators, when we consider the potential or consultants or pipeline integrity engineers, have to consider, hey, if we have a failure, how does it influence potential regulation? And again, I think it's always it's always with what I remember where we came from.
So, as we look at it today, you know, when you think about acres, you know, remember Carlsbad, when you think about those principal arterial roadways and modern consequence areas, that’s Sissonville. And God willing, you know what, I hope that the expansion of regulation stops, you know, maybe because we get to that zero-incident culture. But until then, you know, it was I mean.
Christopher De Leon: We have the right initiatives, right? You have guys like us that try to put this information in front of people in social media. And you've got organizations like YPP that does a fantastic job of doing knowledge share. You have PPIM, IPC, all these conferences, AGA’s exhibition, lots of information out there, right? So, I mean, ultimately, it's up to us, the listeners, right?
Everybody to listen to the podcast to say, you know what? If I'm ultimately responsible, I'm going to ask more questions, I'm going to challenge Norm, right? And the norm is whether it's in an HCA or a class one or class four. If I think there's something here, we're going to I'm going to do my best to keep it round, sound it in the ground. And that may mean running or digging.
Rhett Dotson: So absolutely. All right. Well, Chris, I'm going to wrap up this chance, this week's up. So, we look forward to seeing you back in two weeks when we talk about another failure. And thanks for joining us on this. This week's edition of Pipeline Things. We'll see you again next time.
