PHMSA Announces Pipeline Risk Modeling Workshop

The DOT’s Pipeline and Hazardous Material Safety Administration (PHMSA) published a meeting notice in today’s Federal Register (80 FR 48620-48621) for a PHMSA Pipeline Risk Modeling Methodologies Public Workshop on September 9^th and 10^th, 2015 in Arlington, VA.

PHMSA notes that the “workshop will focus on advancing risk modeling approaches by looking at risk modelling methodologies for pipeline and non-pipeline systems, and practical ways that operators can adopt and/or adapt them to the analyses of their systems”.

The draft agenda can be found on the meeting web site and will be updated as the meeting date approaches. That agenda currently includes:

∙ Current Regulatory Requirements for Evaluations of Risk

∙ State Regulatory Perspective

∙ Industry risk improvement approaches post-San Bruno and Marshall events

∙ International Regulatory Perspective - Risk Evaluation Approaches

∙ Other Industry Regulatory Risk Requirements and Approaches

∙ Practical Risk Modelling Challenges

∙ Path Forward (PHMSA)

∙ Panel Discussion / Q&A Opportunity

This is the same meeting that I posted about last month. Where the earlier PHMSA notice was more of a request for abstracts for possible presenters at the meeting, this is a notice about the actual meeting itself. Copies of the submitted abstract can be found here.

This is a public meeting and it will be web cast. Registration for either live attendance or via the web cast can be done on the meeting web site. Public comments on the topic may be submitted before or after the workshop via the Federal eRulemaking Portal (www.Regulations.gov; Docket # PHMSA-2015-0139).

Commentary

While most people consider pipeline risks to be associated with the physical integrity of the pipeline and perhaps preventing damage to the pipeline from a physical attack, it is becoming more and more obvious that gas and hazardous material pipelines are also subject to attacks and accidental damage due to control system hazards.

The introduction to this notice states that:

“To support integrity management requirements, a risk analysis modeling approach must be able to adequately characterize all pipeline integrity threats [emphasis added] and consequences concurrently, and the impact of measures to reduce risk must be evaluated.”

It is disappointing to see that this cyber threats (both deliberate and incidental) do not seem to have been addressed by any of the abstracts submitted for this workshop and it is not mentioned in the draft agenda for this workshop. Perhaps a discussion about the need to include the cyber perspective in any comprehensive risk model for pipelines should be added by PHMSA.