Why was B31.8S Developed in the First Place?

Rhett On this episode of Pipeline Things, we have a return guest that joins us again talking about the ,I'm going to say, origins of B31.8S. Some of my favorite parts in this episode is maybe changing your thinking around B31.8S as not seeing it just as integrity management, but a risk reduction document. And we talk a lot about some of the challenges in developing it when it began, and we close stick around for if you were to change it or regulation moving forward, how would you go about it? It's a fun episode with a return guest. Think you'll enjoy it. Thanks for joining us on Pipeline Things. Rhett Welcome to this edition of Pipeline Things as we continue our discussion with the sages, one that I really enjoyed. We can debate whether this is my favorite next to the Failure Files or second favorite, but it's not important. It's going to be a great episode. Chris, I don't know what you guys over the summer were up to, but you embarked on watching old movies from the 80s for a while. And you know what's funny about old movies from the 80s? All right, let me give you some time to think about those. Chris The music, the hair. Rhett Yeah, some of them age well and some of them don’t. Chris Have you, Ninja Turtles in the 90s? It's fantastic. Rhett You see, that's one, okay, this is good. Did it age well? When's the last time you watched it? Chris It aged amazing. So we did this too, probably late last year. Amanda was like, but 90s, not 80s. She was like, she looks at our kids and she's like, do you know who Rookie of the Year is? No. Have y'all seen The Sandlot? No. Ninja Turtles? No. Guess what we started doing. Rookie of the Year, fan favorite now. Sandlot, 100%. Kids watch it all by themselves. Rhett I could see those being great examples. Chris They're still not on the Ninja Turtles yet, though. They think it's creepy. Rhett Well, because of those costumes at that time. I mean, they're so accustomed to the world of CGI and whatnot now. But in our, see, we went different 80s movies. So, like, one of them, and this isn't 80s. This is true. This is 90s. We went Dumb and Dumber. Dumb and Dumber did not. It didn't age. Chris My kids are too young for that movie. I can't put that on yet. Rhett And then what made me think about this is I ended up watching the Netflix series The Hawk, which is recent. But it has Will Ferrell, who again comes out of like late 90s, early 2000s. And it's like an older version of Will Ferrell that's acting like the younger version of Will Ferrell. And I'm like, oh, my God. Chris That's his persona. But he doesn't age well. And the kids might not appreciate you. Rhett I'm not even enjoying it 20 years later, Chris. I'm laughing. I'm like. I'm watching it and I'm like, this is nice. Chris Things are not always wine or tequila. This is true. Rhett But you know what movie did age well? Top Gun. Top Gun has aged okay. Chris You know which one didn't? Godzilla. Which Godzilla? Just one of the Godzilla. Like the old one? Yeah, like the late 80s. Yeah, it was pretty bad. Because I put Godzilla versus King Kong on for Lael. Lael's eight guys, just for reference. And he absolutely loved it. Even some of the older kids would pass by and then they got stuck halfway. Or like King Kong, Godzilla, fighting monsters. They love that. It's like, dad, can we watch one of the old ones? And I put one of the old, like, it's like probably like late 70s, early 80s, where it's like this thing that randomly moves. And like the moth is like, you could see it suspended. Like we were like 10 minutes in and it was like, dad, please turn it off. Yeah, I kind of agree. Rhett So if you haven't figured out where I'm going with that segue is. The topic of conversation today is ASMEB 318S, which is the integrity management standard for natural gas pipelines in the United States. Chris Incorporated by reference. Rhett Incorporated by reference. For the audience, just so you guys know, I'm vice chair of the ASMEB 318 committee on O&M. Chris So what that means is you can blame him for all this stuff. You have the ability to influence it. Rhett 318S is one of the documents that we oversee. And I actually think 318S. has aged quite well as a document. If you look at the gamut of standards, it really has. I think our guest today will agree with that. So audience, we have a returning guest. Andy Drake is joining us again. And the last time, Andy, welcome to the show. Andy Good to be back. Rhett He came back, which tells you this is the place to be. Andy, the last time we had you on was August 2024. And the name of that episode, audience, if you want to shape it up, was called Take It Back. And we were actually looking at the origins of what Christopher likes to call IMP 1.0. Today, we're looking at like the origins of B31.8. But I'd like to hear from you. What have you been up to since August 2024? Really, almost two years to the date? Andy Almost two years to the date. That's exactly right. I took over an asset up in New England, the Portland Natural Gas Transmission System. We acquired it in BlackRock, and Morgan Stanley made a bid to acquire it from TC Energy. And we've been working to stand that asset up. It's a cool project. None of the standards, procedures, processes, systems conveyed with the sales, so we basically started it from a white sheet of paper. We had nothing, which is great. Never did that before, 45-year career. But it was fun. And because we were able to dial those systems into that asset. And it's a really cool asset because it's homogenous. It's a 190-mile system that was all built in 1999. All X70 pipe, good fracture toughness, all FBE pipe coated, 100% piggable, great records. Just what every pipeline is, you know, right? Chris I mean, it sounds easy. It sounds really easy. Andy And then we really looked at it. And given the unique characteristics of the pipe, having these kind of attributes, just what would you do if you had a Ferrari? You know, what would you do with it? You know, it's like, well, I don't need to drive it like I have a Pinto. I have a Ferrari. I can go play this. Chris No, that's so good, Andy, because some people would say you put it in the garage, right? They don't put miles on it. Others are like, well, let's go. Andy So we've dialed the systems in on an asset that's new. And so we're doing really some fun things, I think, that are leading edge. Quantitative risk assessment. One version of the truth. The GIS system has all the data in it. So we can integrate data real quick and make decisions very, very quickly. Complex decisions. It's kind of fun. It's like looking forward. Rhett It wasn't hard to drag you out of retirement to do this? Andy No, it was just, it was a cool opportunity. I don't intend on staying there forever. I think, you know, the retirement my wife says is in my near future and I need to listen to her. But it was really fun. It's been a really, really cool opportunity to look at an asset that had those kind of attributes. Because I think you do start to look at possibilities of the future very differently. You know, a lot of times we say, well, we can't do that, and it's why. Well, it's too heavy. It's too this. It's too that. It's like, what if it was really easy? Chris I'll give you an outsider's perspective, and that's you were managing a lot of assets for a very large company for a very long time, and now you're managing an asset that allows you to really put some focus onto it and start tinkering and have some fun. So I bet that's also a pretty cool dynamic for you. Andy It is. It is. I sleep. a little better maybe and you know have more spare time than i used to have which is also a good thing Chris easy to implement ideas i bet Andy yeah and it's and i think the thing that's fun about it is it's it's a very small company so we're very nimble very quick so ideas about thoughts can get into practice very very fast uh any kind of thought we had to buy some property next to a compressor station you know and it literally took us an hour so okay we're gonna do that we're gonna buy it we bought the property and even even the president company said Wow, that's cool. We can just do those things. I guess we can, actually. If it makes sense, we just do it. Rhett So, audience for today, Andy, you already alluded to the fact... to chat with you about 318S and where that document came from. Can you help me set the stage where, because I want the audience to appreciate your role and what you were doing at that time. When 318S was being written, what was your role and how did you get pulled into the development of 318S? Andy I wasn't actually chairman of B318 at the time. I was very active in Inga. I later became chairman of B318, as you know. When we were talking about developing the S document, there had been several incidents in the industry that were causing PHMSA and the public a lot of angst. And there was a concern that the rule book wasn't working and it wasn't addressing all the things that could happen and how do we manage risk more effectively. And so the thought was at the time was, we'll just throw out these rules and we'll write a bigger rule book. And I remember thinking, well, that isn't going to work. Trying to think of every possible thing that could happen and writing a rule for every combination and permutation of things that could possibly happen, the rule book would be 10 inches thick and no one would read it and you'd be right back to not managing risk well. So we really paused in that conversation with the regulator. I said, let's take... A few minutes to measure twice and cut once. Let's think through this before we start doing things. And so we looked out at other industries. We looked at the airline industry particularly. We looked at the chemical refinery industry, nuclear industry. It seemed unpopular at the time. But they had some serious learnings. In some places, they had almost near-death experiences, about not learning fast enough. And they made some very significant changes in their strategy and their approach to managing risk. And we wanted to lever those lessons learned. You know, it's like bonus points. If I get to learn from you and I don't have to go through stubbing my toe, that's bonus points, you know. So we've tried to leverage the learnings that they had quite a bit. And we brought in people like Mark Harreth. Mark Harreth came from the Hartford steam boiler, not Hartford, the insurance company, Hartford steam boiler. Brought a bunch of people, Radian, people from the nuclear industry. And they brought with us a different mindset of how to manage risk. And I can remember then they said, so what's the current theme? And we're saying, well, a lot of people are thinking is we'll just write more prescriptive regulations. And I can see them just almost kind of turning gray. It's like, that's absolutely the wrong answer to this equation. It's not going to help you manage risk more proactively, more effectively. You need to get more. you know, of an understanding in the community about what causes risk. You know, the rules read almost like do this. It doesn't say why. It just says do it. Okay, well, I'm doing it. I'm doing it. You're not really understanding risks or what drives the risks or what drives variability in the pace the risk occurs. And so the point was shift everybody up forward two or three notches. thinking more about what is the risk, what drives the risk, what drives the pace that the risk is realized on, what drives your certainty around conclusions about mitigation even. And if you start to think up on that front end, then prescriptive regulation doesn't really work because it doesn't tell you how to think. It just tells you what to do. And so you're just reacting constantly or just doing. in absence of thinking. And that was the goal was this document was really intended to transition to more of a risk understanding. And if you really look at the document and you back away a little bit and you plug in safety management systems, one of the things we learned from those groups was a lot about safety culture and safety management systems. If you look at the document, you will see, and kind of given this away, it's okay. It was written as a primer on SMS. If you look at it, there was very much a tenant of these are the elements of a safety management system in how the document was organized. It was designed to start people thinking about how do you manage risk technically and actually as a business and start thinking about it more proactively, more as just a core part of how you approach the asset. And one of the first things that we did as we were going through this, the measuring twice, cutting one thought, was we needed to understand where did the rules in ASME come from. And that was fortunate. You know, the document was written back in the 50s, early 50s. You know, there were precedence documents before that in the late 40s. And so we thought, well... of these people are still alive because we knew them. They were our bosses, bosses so many years prior, you know. And so we said, well, let's get these folks all together. And so we had a GRI study called the Emeritus Report where we brought all the authors that were still alive together in the basement of the Hess Building in Houston. And we just asked them questions, you know, and I mean, just as an anecdote. These folks were old. I mean, we had to have a nurse. Rhett I've heard stories. I've heard stories that they came in an oxygen tank to manage the oxygen tanks that were in the room. Andy And it was sort of fun because it was a reunion for them. Chris This had been the highlight of their whole year. They were like, oh, yeah, we're back in the game, baby. Andy Had a pretty early part in my career. It was very rewarding and very insightful to see them come back together again. and how much of a community they had been in the 50s. So this is now almost 50 years later. It looked like you're like 90, literally. And what we came out of that way, so asking them questions, where did 72% smice come from? And they were very matter of fact and all aligned on it. It was basically we assumed that you had a 90% hydratatic test in the mill. So we knew we could assume that was done because that was an API standard requirement. And we wanted to set an 80% confidence interval around that number. So 80% of those 90 was 72. Rhett 0.9 times 0.8. Andy And it's like, but what if we test it to 100%? And then I said, well, you should be able to operate at 80%. Literally, bang, that quick. It was like, whoa. okay, we can do that. And that was literally a derivative of a conversation about where we went with 80% SMICE operation in the United States. We took that information to PHMSA and said, 72% is based on an 80% competence interval, I assume 90% test. But if we test to 100%, that gets rid of that concern. We should be able to float up. And of course, we learned much more than that. And so obviously with 80% came IM. Well, we'll do more aggressive integrity management as well. You know, things like valve spacing. You know, why are these numbers in here? Where did these come from? Why are these a class one? They're this far apart class two. And they said it was the distance between the roads in those environments. Think about how far parts roads are in section roads. And then it was like, OK, well, that's interesting. They said it was all about how fast you could get to the valve. Time was the key, not distance. So we were hoping that people would put the valves near the road so they could get to them quickly and close them because time was the issue. So you're like, oh, well, that would be different than what people are thinking now. They're thinking that number is like set in stone. It's sacrilegious to change it. So if you could just change the time to respond, the number, the distance is irrelevant. They all said, of course. It was like, duh. That, I think, was important. Before we started trying to change things, understood why those numbers, what was the thinking, what the basis of some of those numbers, some of them had very little technical basis. It was something convenient. Or it was something that was rev-limited by the technology they had at the time. You know, and even in my career, not even in my career, I'm now an elder statesman. I may be one of the emeritus people here pretty quickly. That's the whole point of this conversation. But, you know, I think that what we saw when we wrote B31.8S is different now. We would change. I hope that there is a willingness to change the document. The document was intended to be dynamic and live and adjust and adapt. That was the very thinking that went into it is keep refreshing it because things are going to keep changing and learning. And I think that, you know, classic, we were talking about dents, you know, prior, you know, 6% dents and dents with metal loss are an immediate anomaly. Well, that's... old technology right now. I mean, dents with metal loss really came up when inline inspection tools couldn't see inside the dent, that the resolution of the tool, and you lost contact. And caused issues. And so if they thought they saw something in the dent, they had to assume it was bad, so it was immediate. But if you could see inside the dent, which we can now for a lot of dents, and you can actually do... elementals on the metal loss in the dent, why are you digging it up? And why is it an immediate anything? Chris I think the highlight from what you've said, at least one of my big takeaways is, you know, Rhett and I serve a lot of customers, right? So for at least the last 15 or so years, we've been serving clients instead of being on the operator side. And there very much is a style of integrity management that fully revolves around a BAP. And I think that's really important to recognize, right? Because this whole time you've said risk management, risk management, risk management, risk management, right? Integrating data, getting more data, making decisions. That's very different than managing a BAP, right? It's one thing to say, like, we'll talk to a customer and say, I'll pick a random threat. What would you say is a state-of-the-art new geohazards management? They're like, oh, we're trying to get it into our BAP, or we're trying to understand that threat first. And I think there's some very good parts to that statement, but the denominator remains the BAP, which I think is really interesting. Right. And people really revolve around. I'm like, hey, so what do you do for me? Oh, I'm an integrity manager. I'm like, oh, that's awesome. I love integrity. What part of it? Because now you don't get engineers that do all of it anymore. Now it's like they're in a part of it. Right. I do risk or I do assessments or project management or remediation. And they say, oh, yeah, I execute our BAP. And I'm like, that's really interesting. So what does that mean? He goes, well, risk tells me what our threats are. And then I pick the vendors and I'm like, hmm. And so you're really hopeful that all of these elements are coming together into what you kept reiterating. It was always about risk management versus these tasks revolved around what we said earlier. Prescriptive base tells you things to do. Rhett Yeah, you know, so it's kind of funny. That was really what I caught too, Andy, was you kept describing 31.8S in terms of a risk standard. And I was like... funny. I think of it as an integrity management, the gas integrity management standard. That's what I think. I don't think about it as a risk-based standard, although I completely agree with you that so many of those elements are there. And then what I was processing, and I'm curious what your reaction is, is we still live in a prescriptive environment. Y'all might have wrote a primer or a starter for something that's absolutely got risk-based elements in there, but it has a lot of prescriptive elements in it too. And I'm wondering if maybe you can help me understand. So I'll give you a really good example of one. around, for instance, response timelines. Y'all don't explain only, I'm going to say, it doesn't only say you should use these tools or these procedures to develop response times. It also gives you a set response timeline, for instance, for figure four. It's no longer figure four for the audience, but the famous figure four, which is labeled for time-dependent threats, but was developed around corrosion. And that is, well. was interpreted as prescriptive-based. Regulation adopted it as prescriptive-based, although it sits within a risk-based standard. So I think my question that I want to ask you is, I don't think the standard is completely like risk or performance-based. It definitely has prescriptive elements that have worked its way in there. Was that a result of compromise with the regulators at the current time, or was that protection for other operators? Help me understand that. Andy A little of both. I mean, just from a practicable standpoint, where was the thinking at the time? The regulators were very used to prescription. There were a lot of different sizes and still are a lot of different sizes of operators, some of whom don't have the resources, the capabilities to do detailed engineering assessments. So we were trying to not meet in the middle, but try to come up with something that was a step forward. pressing people to think proactively. And some tools just use this. Rhett You have nothing else, just use this. Just use this. Andy And there's no magic really in the figure four. I mean, there was a lot of thinking that went into it, but basically bell curve distributions of corrosion growth, assumptions that went into how fast this could happen in aggressive environments. So you're trying to do 95 percentile confidence interval. This number is going to work. It's going to be conservative. You know, and operators are obligated to not have their pipe blow up. Period. Integrate data. Yeah. If you have a hostile corrosion growth, you need to do what you need to do. Independent of that. Regardless of figure four. Absolutely. And that was in there, too. It was like, you can follow this, or you should be more aggressive in situations where you know the growth rate is bigger than this. So there's incumbent... an obligation to the operator to know more. Yeah, you can use this. And, you know, juice is red squeeze. If it works for you and you know you're not more aggressive than that, then you really don't need to spend a lot of energy trying to figure out, well, it could be six and a quarter years rather than seven. It's like, okay. Chris Something that goes to resonate with me is I'm going to go south of the border a little bit. So I recently had some experience looking at working with some integrity-related efforts south of the border in Mexico. And one of the documents that was requested was the philosophy of integrity. And I kind of sat back a little bit and I was like, philosophy? I was like, oh, this is going to be good. And so I read the document and it was kind of what we're talking about here. It's not the procedures and it's not the standards. It was the regulator wanted to understand what your philosophy for integrity management was. And I was like, this is incredible because it now no longer focused around what you're going to do and if that meets the standard, but rather what is the philosophy I can hold you to. And that keeps resonating with me to where the philosophy at this time was risk management, risk management. But that philosophy obviously has not carried over because of all of the things that we've been talking about. So that whole idea just came back. Andy I think that's good insight. I think that, you know, when you look at Canada, the CER is a lot... of a detailed conversation with more of an outcome expectation. We expect zero incidents. So what are you going to do about it? And then the conversation starts in the last weeks. Okay. Those are intense. And you bring Ian Calhoun to the room and you better bring your A-game. That's what he's talking about. And Joe and the regulator, they're very intelligent. And they can do it because there's... a limited number of operators in Canada. And they're more contiguous in size. So you can have that kind of conversation. If you tried to do that in the United States, you'd never finish the conversation. You've got thousands of operators, all kinds of sizes. It would be impracticable to do that. So prescriptive regulation has a home to cover. A lot of very small operators make those conversations more expeditions, more focused. We know you're inside the box. You're okay. You're following this, you know. And then you start dealing with creating risk-based conversations and you create, you know, if you know more and you have a lot more data, then maybe we'll give you some more flexibility moving into a more quantitative, you know, or probabilistic sort of regulatory platform. I think that those are... I think those are all very real places that will happen in the future in the United States. I do. I think that it's just a matter of growing. But to protect something as sacrilegious is paralyzing because understand where it came from, understand where it is. And the intent was. manage the risk, which means you need to understand the risk. You need to understand the basis of the requirements around the risk. You need to understand the tools and the evolution of the tools and moving capabilities. It's alive. It's alive. It needs to be alive. Chris I'm just thinking we might have to produce some kind of marketing material with figure four on it. How funny would that be. It's going to be an image of Moses coming down and he's going to have a figure four on it and be a figure four. Rhett So it's because it's funny to me and I think I'm starting to appreciate. Maybe a little bit more in a way that I didn't, which is you guys set out to create a risk-based document that would set the groundwork for, I'm going to say, performance-based integrity management. But you couldn't just develop and put forth a performance-based integrity management document. It had to have prescriptive elements. But the prescriptive elements, I think, are what a lot of programs got built on or got put as the minimum bar. And those are very, very difficult to change, right? And this is, I'll give you another example, SEC. There's limited guidance. The SEC guidance in B31.8S is honestly really old. And we're in the process of trying to overhaul it. But when you try to create awareness, so something as simple as 60%, that's the number everybody has in mind. But there were numerous failures at less than 60%, right? And so we tried to work in there like, hey. You should be aware that failures have happened at less than 60%. Oh, my God. You cannot put that in here. I'm just trying to create a where- Chris Trying to vote you off the island? Rhett They almost voting me off the island, yeah. Because they're like, if you put that in there, they'll start making us do all this at facilities. I was like, no, I'm not- Chris Do you have stock in EMAC? Rhett No, but I'm not trying to take it and say you must apply this to everything that operates at greater than, for instance, 40% SMICE. What I am trying to tell you is that- not unheard of it for it to happen. So you as an operator should be aware of the possibility and don't close your eyes to it just because you open at 60%, right? I think that kind of gets more to the heart of performance and being aware and trying to learn. But when it's mixed with prescription, prescription says 60%, they're like, don't you change 60%. Leave it at 60%. Andy Yeah, I think one of the fundamental precepts that I've come to appreciate is risk elimination is the enemy of risk management. If you try to eliminate risk, you're pouring resources into very small risks and returns. That is diminishing probably where you should be putting the energy is the next biggest thing. And we see that the shiny thing gets people distracted. Oh, there was a hard spot failure last year. And it's like, okay, well, there was a hard spot. And it was on some unusual kind of pipe. It's like... so that's happened one time in the history of the universe. How excited? We don't want to ignore it, but that doesn't mean we're going to start running the hard spot tool on every single kind of pipe we have. That would be reckless and negligent because we should be running some SEC tools in some pipes in lieu of that. And it gets you out of your game. And I think that's very dangerous, but it kind of falls back into that trap of prescription. The goal of the regulations, it says it in the early regulation, in the early part of 192, if you read it, it says the obligation of the operator is to eliminate failures, manage the pipe and make sure failures don't happen. And it overarches the federal regulations. And then quite quickly, they move into all these prescriptive things you're supposed to do that they don't tell you why you're doing them. It's like, well, if I'm supposed to manage risk and make sure nothing bad happens, I need to understand what causes them. And I have to break that paradigm of, well, the next page says, do this, do this, do this, do this, do this. This is for 200 pages. And you're like, so you're getting rope-a-doped out of your game. And the regulator also is rope-a -doped out of the game. So this wasn't just SME figuring out what to do here. This happening in parallel with PHMSA. I was on the advisory committee at that time. That was when I first got drafted into the advisory committee years ago. And Stacey Gerard at the time, it was the associate administrator with PHMSA, used the GPAC, the advisory committee, as well as anybody I've ever seen. We met during this transitional period. We were meeting every month or every other month at least. Currently, the GPAC meet two at the time. Rhett Bush administration, Bush 2.0. Andy This is Way back. Oh. Yeah. This is back in 1999, 2000, 2003, right in that time frame. She was using the GPAC meetings. We were meeting 6 to 10 times a year. Now we, and since then, I mean, the GPAC meets maybe quarterly at most, maybe more like two or three times. You know, so she was using that thing. What she was using it for was get the community together. Go through this journey as a group because both sides have a big ship to turn. And that was wicked smart, as they would say up in Boston. That was wicked smart. I mean Chris It took me a second to figure out what he was saying. All right. Wicked smart. Rhett So we take a break here, audience. When we come back, I want to talk with, I want to pick Andy's brain a little bit about this as we have these balanced documents. How do we go about changing some of these documents and the challenges? And in a perfect world, how might he do it? So hang on and we'll be right back on this episode of Pipeline Things. Rhett All right, welcome back to Pipeline Things as we continue our conversation with Andy Drake. So on that first segment, I just want to rehash for our audience a little bit. Andy brought up the emeritus report from B31.8S. I want you guys to know that that is available through ASME. And it is a report that really, I think, was foundational and many people not aware of it, of outlining where very important things came from. We talked a lot about B31.8S being a risk-based document. And where we left that conversation at the end was kind of around... Chris, would you say that? Chris Just the relationship. Yeah, the relationship between regulators, like rule makers and industry. And the mechanism for that is often like the GPAC. Yeah. Right. And just your thoughts and you're obviously been involved in it for a long time. Like over the years, what have you witnessed? You know, you said, oh, Stacey, you know, it was like almost 10 times a year and now it's a lot less. Just wanted to get your thoughts on this relationship and the importance of it. Andy I think the GPAC, I've been on it, I had been on it. It just got off it here a year ago. 22 years on GPAC. Long time. Five administrations, a lot of different perspectives and challenges. But I really think that the GPAC provides a really valuable forum, venue, to get all the stakeholders together and share your perspectives. You know, what is the public concerned about? What do they need? What do they want? You know, regulators, what do they need? How do they want? How can they regulate? Operators, you know, and consultants, you know, what are the risks? What's the issues about how to manage risk and how to practically put this into play? And I think getting all those stakeholders together in one forum and talk about pressing issues, integrity management, leak detection, class location, whatever, helps you develop a really well-rounded and practicable solution. You know, the last several votes that we had, very complex issues about the next, you know, integrity management, you know, what they call a mega rule. And it's called the mega rule on purpose. It's big, you know. And things like leak detection. We were able to get through those discussions. Most all the votes were unanimous. That's a compelling guidance to PHMSA. When you come to make a rulemaking, it's like, we've already had the forum with the operators, with the service providers, with the public, with other regulators, and they all agree this is the right path forward on this issue. Not that that predicts what PHMSA needs to do. PHMSA needs to maintain their arm's length and, for a lot of other reasons, do some different things. But it gives them a good basis to work from. And I think that the more complex the problem, and I do think, you know, we will continue to face. more and more complex issues that we go forward, the more we need to communicate with each other, the more the forms are really important. Or you get to measure once and cut five times. You know what I mean? It's like, well, that's not working. We keep doing this over because we didn't know that when we made this decision. So I think the GPAC is a really important forum, and it's been used by each of the administration's different challenges in each one. But this administration, I think, values. those inputs, and I think that they can see that for them. This administration is talking about another regulatory platform, quantitative risk assessment, allowing operators more flexibility if you know more, which is really the whole point, back to the point about the code. The goal is don't let the pipe create these societal impacts. Okay. It doesn't say, and only follow these rules. It says, Don't let this happen and follow these rules or do whatever you need to do. Rhett Let's play a game here, Andy. Because quantitative risk assessment is a good one. Because quantitative risk assessment, I would argue, let me preface it. In your opinion, does quantitative risk assessment appear in 192 right now? Andy No, not really. Rhett We agree on that. Does it appear in B31.8S in a manner that's... you could follow? Not alluded to, because I would argue that it's alluded to, but I don't think there's a framework there for applying it. Andy No, I think it's more conceptual. Knowing more is valued. Good. And what does that mean? You need more construct around. So there's another guidance document out there. Rhett Oh, you're good. I want to give you some options. If PHMSA came to you and said, Andy, we want to build. quantitative risk assessment, and the current edition of the code. And this is why I think it's difficult to change things. Because when people want to do that, they start, the first instinct is to start with the existing code or existing standard and then bolt that on. You know what? If it's B31.8S, for instance, we'd say, let's create a... Chris Many people would say that's the appropriate path. You have industry come together. That's what I'm saying. Rhett Let me give him the thing. We would put a non-mandatory appendix Q. for quantitative risk assessment. But I want to ask you, if you had to do it in regulations, and I gave you two options. One is I said, hey, Andy, I have a reserved section of code. It's 192-9XX, and it's reserved. And what I'm going to do is you can write QRA into that section. And somehow you get from the main body the code into that section. I don't know what that link looks like. Or alternatively, I said, that's one option. So option one is you only get to write it as a section. Option two is, I tell you, you know what, Andy, we want to overhaul 192 altogether. Chris With a focus on integrity. Rhett With a focus on integrity. The parts of 700. And you can write QRA into it however you see fit, but I almost want you to start from a blank slate such that you could write it where QRA would truly fit as one option amongst a several available. Which way would you prefer to go? Andy Well, I'm going to resist the urge to answer right away, but I have a very clear answer because I've been, you know, consistent with why we're having this conversation is why would I choose that would be as important, I think, as the answer itself. So I can give you the answer and then give you a why or I can give you the why and then the answer. Rhet It's up to you. Andy I think you have a host of problems to solve. And I think that's really important to keep in mind, you know. We talked about earlier, a lot of numbers of operators, a lot of very big variability in size and capability as operators. So ripping... The clarity of the regulation out with prescription would really be disruptive to a lot of small operators. They don't. Rhett I built my entire program on this document. Andy They may not even have the capability to do that. Even if they gave them a seven-year ramp down. Chris I'll also go the other way. Like one of our Canadian friends said that the Canadian regs are written by engineers for engineers. And ours is not like that. So keep going. Rhett You don't have to think of the police. I agree with you. If we took 192.712 and threw it in the trash and started over. Andy It would be hugely disruptive. Hugely disruptive. And not necessarily progressive. It would be, the juice may not be worth the squeeze. You would cause a lot more trauma than you solved. Rhett The operator's dead all over the floor. Andy It would be bad, I think, for a lot of folks. And really unnecessarily so. They may not be as efficient in some of these things, but they're safe in the things that they're doing, largely. Rhett So then your only option is you write it into... a portion of a prescriptive code. Andy I think the other part is when you write a QRA regulation in there, the challenge that this country will have that other countries don't know is safer than what? Rhett Safer than one E to the minus six deaths per mile. Andy Exactly. But who gets to decide? That's going to be a slippery place in the United States. Countries that have decided safer than 10 to the minus 6 or whatever also are the operator. It's a state-run utility. So the government is accountable to decide the societal risk... that that entity is going to place on the community. We don't have that. Individuals operate the pipe and I don't know that PHMSA or any regulator right now is ready to assert a willingness to tolerate. a threshold of acceptable risk. That would be a very big discussion in the United States with all the tort reform. It would take 100 years to work through that number. So safer than what in this environment? We can reference the UK and Canada and others who are doing this. And it's some sort of precedence, some sort of benchmark anyway. This is kind of what others are doing that are in this space. They're kind of like us. It's not like they're a renegade country that's willing to tolerate huge amounts of risk. I mean, these are countries like us in Europe and places. But I think, so having that stepping stone, and I'm getting somewhere. I'm going to come back to dents. So dents with metal loss. So if you have a prescription regulatory requirement, safer than what? It's dependent on what... prescription regulation is trying to accomplish or what it's based on. So if you say, well, any dent with a metal loss has to be immediate cutout, unless you know more. Well, then in the prescriptive regulation, in this new appendix that's added to a prescriptive regulatory base, you could say, as long as you use finite element analysis done to this kind of standard, site of standard, and you can prove that you have tolerances... around your tools and all considered that that anomaly will not grow inside the next re-inspection period. You're good. That could be what you need to know. That could be the probabilistic QRA approach that you're adding to. I think that QRA and probabilistic is not going to be... The thing you're going to try to solve also is ramp up. you're going to be selective in doing QRA. You're not going to say, well, we're just going to do QRA everywhere. It doesn't even make any sense. It's back to that risk elimination, you know, where it has value and do it there and do the regulations, the other regulations that, you know, maybe you use prescriptive on some things, maybe you use risk-based on some things, then you use QRA on some things. Fine. That makes sense. And then over time, you may get more data, you know, which is the real driver to probabilistic. You know, now a new system, we have the advantage of we have the data. We can deploy it on a big scale. A lot of people don't have that data. So to get the data is the rev limiter to running in that space. Chris I'd like to ask you a question about a little bit about rulemaking process and the role of standards. And it should be, I just want your opinion on it real quick. So we've heard, and I actually kind of believe it a little bit, is it's this idea of like industry should develop a standard. And then that standard should be vetted if it's incorporated by reference. Or is your position or what are your thoughts on it being actually the regulator should be establishing what that standard is? Because we see it kind of both, right? We see like more recently we've heard people say, hey, is this RP ready? Because if it's ready, then maybe we consider it being incorporated by reference. But now we have the history of, well, if you're not careful and you incorporate something by reference, that may be what stays incorporated for a long time. And that defeats the purpose of what we thought was going to happen. Right. High level, what are your thoughts on the role of RPs or standards in rulemaking? Andy I think it's a both and proposition. I think we can look back and see it. The SMS standard we talked about earlier. Yeah. PHMSA really drove organizing that. They drove it through API, and so API ended up writing the recommended practice, but PHMSA was the coordinating force behind that. And industry participated heavily, and kudos to PHMSA for bringing in the community to help develop that because it's actually quite a good document, and that's going to be sustainable. I think industry has a great space to be active here, and that is... Keep driving to continuously improve. I'm very proud to be a part of this industry because this industry really took its accountability to heart. We're accountable and have demonstrated it through actions, not words, over decades and decades to try to continue to get better, better tools, better thinking, better models, better regulatory approach, learn from other industries. Keep that continuous improvement engine driving. And I think industry has... It has a great role there that they've been in very actively shaping geohazard standards. There was no regulation on geohazard standards. They just basically, the regulation said, don't let geohazard things happen to you. Well, that's interesting, but there's no guidance on what to do about that. That's if he's there. There was no industry standards. So, industry stepped in. Industry standard. Now, that's something to point to that's more tangible in those conversations, which is helpful to everybody. It floats all the boats. Rhett So, this is clear. Andy, I want to thank you again for joining us. I feel like I honestly, I really don't want this conversation because I feel like I could keep going. There are things I wanted to dive into with 318S where I'd be like, you know, what if we had to rewrite it now? But those are questions that maybe we'll have to bring you back on again for another time. Audience, I hope you enjoyed this ride with us as we talked a little bit about 318S and, you know, the origins of that document and how we got here. Again, Stick around. In two more weeks, we'll have another guest on as we continue our discussion around the stories maybe that you don't know so well on Pipeline Things. Thank you for joining us. This episode of Pipeline Things was executively produced by Kara Turner. I wish to thank our guest, Andy Drake, and the venue, Texas Collective Studios.