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.

PHMSA Class Location Methodology Workshop Announced

THE DOT’s Pipeline and Hazardous Material Safety Administration (PHMSA) published a meeting notice in today’s Federal Register (79 FR 16421-16422) announcing a public workshop looking at whether applying the gas pipeline integrity management (IM) requirements beyond high consequence area would mitigate the need for class location requirements. The workshop will be held on April 16^th, 2014 in Washington, DC.

Background

This workshop is a follow up to a notice of proposed rulemaking (ANPRM) on the subject published on August 25^th, 2011 and a subsequent notice of inquiry published on August 1^st 2013. Public comments from both of those actions will be addressed during this workshop.

This workshop is being conducted as part of the PHMSA response to the integrity management directives found in §5(a)(2) of the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 (PL 112-90).

Agenda

The Draft Agenda for the workshop indicates that there will be five panel presentations. Those presentations include:

• PHMSA – Class locations vs HCA requirements;

• NAPSR perspective on class locations vs HCA requirements;

• Public perspective

• Pipeline operator presentations – Gas transmission; and

• Pipeline operator presentations – Gas distribution and gathering

There will be question and answer sessions after both the morning and afternoon presentations.

Public Participation

PHMSA is soliciting public participation in this workshop. You can attend in person, view the webcast (live or delayed) or you can just submit written comments. You can register for the workshop on-line. Public comments may be submitted via the Federal eRulemaking Portal (www.Regulations.gov; Docket # PHMSA-2013-0161). Those comments must be submitted by May 27^th, 2014.