Are you prepared to identify and track threats as per RIN2, Gas Mega Rule
PHMSA’s Mega Rule (192.917) reinforces the importance of selecting a partner that is not only in tune with the regulations but also engages with customers to continuously improve risk modelling for the industry
The causes of pipeline accidents are diverse and almost always triggered by a confluence of multiple factors. Take, for instance, the 2010 San Bruno incident. Investigations revealed that insufficient quality assurance and quality control, an inadequate pipeline integrity management program, and ageing pipelines all played a role in the explosion of the pipeline. The incident exposed several problems in how operators collect and manage pipeline condition data, showing that some operators have inadequate records regarding their pipelines' physical and operational characteristics. The conclusion was obvious; the use of erroneous or incomplete information leads to an insufficient understanding of pipeline risks and incorrect integrity-related decision-making.
In response to the San Bruno incident, PHMSA concluded a decade-long effort to amend its regulations governing onshore natural gas transmission pipelines and released the ‘Mega Rule’ to 49 CFR 192. To reduce the risks of pipeline incidents, PHMSA has amended the regulation with RIN2 to clarify the Integrity Management (IM) requirements; improve the management of change (MOC) process; strengthen corrosion control requirements; provide parameters for inspections following extreme weather events; strengthen requirements related to the IM assessment methods; and improve the repair criteria for pipeline anomalies.
The question: Is your organization ready?
Can you demonstrate to regulators that your risk model includes all the required pertinent data?
PHMSA has reinforced the need to account for all pertinent data in a risk model, including the minimum set of verified and validated data defined in 192. As the report states, “Comprehensive data is the best way to ensure an appropriate assessment and, in turn, reduction of risk.” ‘Pertinent data’ emphasizes the importance of verified, validated, and constantly increasing volumes of data used to make smarter decisions.
For robust threat evaluation and risk assessment, you need an integrity management tool that can bring siloed datasets in various formats together for use in analytics. DNV’s pipeline risk & integrity management tool, Synergi Pipeline, for instance, integrates data from GIS systems, Enterprise Asset Management systems, maintenance management systems, spreadsheets, and various other sources. With its ability to interconnect and converge multiple types of data, Synergi Pipeline provides asset-related information and analytics-driven insights related to operations and maintenance. The open model builder and interactive diagram view of the Analysis models easily provide users with an intuitive graphical tool to visualize all the data inputs that are feeding into the risk model. It creates a vehicle to support customer understanding, training, and audits.
Does your risk model adequately analyze the expanded list of individual and interacting threats from 192.917?
With the change of language from ‘consider’ to ‘adequately analyze’ in the Mega Rule, PHMSA underscores the need to comprehensively gather and quantitatively analyse data to arrive at informed decisions. Users also need a flexible modelling tool to adapt to changing requirements and emerging threats which must be accounted for.
A robust integrity management software, such as Synergi Pipeline, can help you analyze all the pertinent data and help ensure you are getting an accurate understanding of the threats to your system. Synergi Pipeline not only serves as the vehicle to pull together data from across the organization but can also execute risk runs efficiently using parallel processing. Generated risk results can be aggregated, or ‘rolled up’, to specific parts of the hierarchy. A configurable risk matrix is provided for a high-level view of the results, with a drill-down capability into individual assets for viewing risk values for each threat and consequence and individual factors within the model.
Can you show how you are accounting for and compensating for uncertainties in the risk model and input data?
DNV believes that the Probabilistic Risk (PRA) methodologies are the ideal assessment tools for use in situations where incomplete data sets are common. Instead of simply eliminating critical inputs in the model in these cases, a distribution of estimated input values is efficiently defined based on a combination of operator subject matter expertise and industry data sources.
DNV’s methods consider the uncertainty associated with using these estimated data sources, enabling the operator to quantify the source’s effect on the overall risk picture. Quantifying this uncertainty into the most likely scenario (P50) and the worst-case scenario (P99) facilitates a sensitivity analysis to guide additional data collection in areas having the highest effect on calculated pipeline risk, thereby optimizing the collection process.
The core of DNV’s PRA risk framework is transparent, data-driven risk modelling, which produces absolute and quantitative risk results in terms of dollars per incident. PRA models provide detailed insight into the actual state of the pipeline network. The results will deliver a long-term decision-support tool that can be directly integrated into an overarching Asset Management Decision Making platform.
Are you able to adequately show how the potential risk reduction of candidate risk reduction activities is calculated?
Preventive and Mitigative (P&M) measures to address risk have been a requirement of pipeline safety regulations for a while, but the ‘Mega Rule’ sees PHMSA strengthening the specificities. The regulations recognize that beyond adequate P&M evaluations, the robust processes, calculations, and comprehensive documentation truly distinguish a good IM program.
Operators who are proactive about uncertainty rely on ’what-if' analysis and comparisons to determine mitigation strategies. Synergi Pipeline helps them run system-wide 'what-if' analyses, baseline assessments, and location-specific 'what-if's to determine how a decision impacts a risk measure or how to choose the right mitigation strategy to minimize risk. Operators are able to measure risk in dollars, enabling subsequent cost-benefit analysis to aid in long-term decision support. Our customers also use the software to evaluate and compare risk-reduction measures to assess risk changes to their systems proactively.
Are you able to adequately show which candidate risk reduction activities have been considered and why they have or have not been implemented?
You have all the pertinent data, run the right risk models, run ‘what-if’ scenarios, and compare risk reduction measures to arrive at the right strategy tailored to you. But how do you decide where to record all that you have done? How can you break down organization silos to enable quicker, better-informed decision-making?
An integrity management tool that supports ’Operational Planning and Monitoring’ alongside best-in-class risk management may be the key. Invest in a software solution that enables and simplifies efficient pipeline operations, documents risk, tracks regulatory compliance and gives a clear overview of the risks across your system. Being able to plan, date, and upload documents with justifications for decisions would simplify your audit process, making sure you are ready with answers to the What, When, Where, Why and How for all your risk reduction activities.
In summary...
Risk evaluation has been gaining greater visibility across the industry and continues to evolve with PHMSA’s Mega Rule increasing requirements for transmission pipeline operators to perform a thorough threat identification (192.917) as part of their integrity programs. This only reinforces the importance of selecting a partner that is not only in tune with the regulations but also engages with customers to continuously improve risk modelling for the industry.
Synergi Pipeline is a next-generation solution which is leading the transformation of DNV solutions from traditional desktop applications to next-generation enterprise solutions, both on-premise and cloud-based. The core value elements of Synergi Pipeline help eliminate information silos, span operational boundaries, and provide industry-leading integrity and risk support on a flexible platform that grows and adapts not only to the industry needs but the needs of individual customers. The software empowers you to comply with the regulations, while our risk experts can help you improve efficiency.