WEBVTT
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All right, good
morning, everyone.
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I have nine o'clock on the clock
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I'm going through and
looking at right now,
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and it seems like we've had
a decent amount of people
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go through and join in.
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So, welcome to the presentation
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on the Railroad
Commission, Pipeline Safety,
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specialized pipeline inspections.
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A couple of housekeeping items
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before we go through
and get to the presenters
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to go through and
talk about their topics.
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First off, please do know that
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this PowerPoint is ready for download.
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If you go to the RRC website,
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go through and follow
the link right here,
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that's on the slide.
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It should also go through and be posted
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in the Q&A section of the Zoom meeting.
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So you should be able
to find it there as well.
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So you can go through and
do as a simple copy and paste
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and all of that.
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So if you know that you can
go through and get ahold of that
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to go through and follow along with us
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or just to go through and
have it after the presentation
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is over with.
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So, to go through and
kind of get us started
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and get us gonna know what's going on
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with all this right here,
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whenever we go through
and do specialized inspections,
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one thing that the Railroad Commission
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always likes to try to go and do,
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is make sure that whenever
we go through and call anyone,
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if you, your company is a
subsidiary of your company's,
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anything along those lines,
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we wanna make sure that we get everybody
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that's underneath the
umbrella of that specific plan
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that we're going
through and talking about.
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That way we can go through and kind of
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cut down on the number of inspections
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and the number of times
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we had to go through and meet with you
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or others in your company.
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So, let's say, for example,
you go through and have,
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four or five different companies
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under your little umbrella that you have
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for whatever reasons you
go through and have them.
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We wanna make sure that
we get all four or five of those
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done at one time,
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that way we don't have
to go through and see you
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four or five different times
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and be looking at the same
thing over and over again,
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that we've already seen.
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So whenever an inspector from our group
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goes through and calls you,
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and asks, "Hey, I want
to go through and do
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a specialized operator
qualification inspection,"
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let them know right there on
the phone when they call you,
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"Hey, by the way,
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I've got all these different
companies right here as well.
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Can we get them all done at one time?"
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We wanna go through and do that
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to make it easier for y'all
and for us at the same time.
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Another item is make
sure that you go through
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and know that whenever we
go through and do one of these,
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we're gonna be looking at
both Texas Administrative Code,
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which is the state code,
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and 49 CFR or Code
of Federal Regulations,
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which is basically the
federal or PHMSA code
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at the same time when we're doing
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an inspection on one of your programs.
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So do be aware that we will
be asking questions about both.
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Also, we do have someone
that is going through
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and manning the questions
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in the question and answers
section of the presentation,
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so feel free to ask your questions
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throughout the presentation,
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and we'll do the best that we
can to get you an answer there
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when you've asked it.
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If there happens to
be one that we cannot,
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we will go through and do
our best to get you an answer
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as quickly as we can afterwards.
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So, to get started,
we're going to go through
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and have Mr. Ross Richardson go first,
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who's gonna be talking
about new construction.
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So Ross, whenever you're ready.
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Thank you, Michael.
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Hello everyone, good morning.
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My name is Ross Richardson.
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I am the new construction
lead for the state of Texas,
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Pipeline and Safety division.
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When we're talking about construction,
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new constructional pipelines,
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what are we talking about?
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Well, this can be new pipeline systems,
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extension of an
existing pipeline system,
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relocation of an
existing pipeline system
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or a placement of a pipeline.
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So why is new construction important?
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New construction is our top priority
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here in Pipeline Safety.
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And the reason being is,
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it all starts with the
construction of a pipeline.
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If you construct a pipeline safely,
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you get out on the right foot.
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So, it all starts with construction
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and it is a top priority.
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So, how does the Railroad
Commission track new construction?
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We utilize what is called a PS-48 form.
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That form is filled out by the operator
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and it basically states
what the project is,
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what it will involve,
where it's located,
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and that type of information.
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PS-48 forms can be
found here at this link,
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which is on the RRC website.
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So, what rules regulate
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the reporting of a new
pipeline project construction?
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You have your federal codes,
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that will be 49 CFR
191.22, for gas pipelines.
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And then you have, 49 CFR 195.64,
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and that would be for liquid pipelines.
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And then you also have Texas
Administrative Code 8.115,
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which is a general for all regulated
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jurisdictional pipelines
within the state.
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And then also for H2S pipelines,
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you have Texas Administrative
Code 3.36 and 3.106.
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So when we come out and do
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a typical new construction inspection,
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what is involved?
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Well, your first step is going
to be your pre-inspection.
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This is when, I, the
inspector, or other inspectors,
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reach out to the operator
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and get an explanation
of the scope of project
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to help better schedule
for that week of inspection
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and/or weeks of inspection.
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This will involve, like I said,
the scheduling, the scope,
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notify the operator what is
expected during this inspection
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and that type of information.
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The second step, is gonna be
procedures and records review
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and the details of the project,
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on-site and/or recently
virtually, due to COVID,
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the review of those records
and procedures virtually as well
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can be conducted.
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And this covers, like
I said, all the details,
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procedures, records,
all that information.
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And then the third would
be the field inspection.
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This would be our,
the inspector, myself,
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will go out to the field
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and conduct the visual
field inspection portion
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of the pipeline that's
either being constructed
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or has been completed,
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you know, the construction is completed.
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And then fourth, will be
the closing and the findings.
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And there will be a closing
at each week of inspection
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or each inspection closing
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to notify you of alleged
violations of findings,
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that type of information.
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So why do we conduct
new construction inspections
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with the Railroad Commission of Texas?
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Number one, is public safety.
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We conduct these to keep the public safe
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and to also keep the
environment safe and property safe.
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And here's my contact information.
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If you have any questions
now or moving forward,
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again, I am the new construction lead.
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My cell phone number
there, 512-436-5308,
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give me a call anytime.
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And then of course, my email address,
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and that's
ross.richardson@rrc.Texas.gov.
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Thank you for your time.
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All right.
Thank you, Ross.
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So next up we have Mr. Jose Cheverez
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or as he likes to go through
and be called, Chevy.
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And he's gonna be talking about
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operations and maintenance.
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So Chevy, whenever
you're ready to get started.
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Good morning, everybody.
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Like Michael said, I
usually go by Chevy.
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So if you'd call me, I'll answer Chevy,
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pretty much the entire Railroad
Commission knows me as Chevy
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and a lot of operators.
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So, everyone knows about that nickname.
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So today we're gonna
cover the inspection format,
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how we do our O&M inspections,
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the documents and records
that we're gonna look at
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as well as any common
concerns that we have in Texas
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for each pipeline system type.
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Next slide.
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So the inspection format
is like Michael said earlier,
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we're gonna start with
the opening meeting,
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we're gonna determine
how many operator IDs
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or company IDs are
covered under that inspection,
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to make sure we have the entire scope.
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And how your O&M is broken apart,
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and whether it's all
encompassing or not,
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and what sections there are.
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Then we'll do the procedural
review of all the procedures,
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which we'll talk about more.
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The documents or records,
we'll talk about more.
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And then we'll have that
same closing meeting
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where we'll cover all
the goods, the bads,
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the notes, the findings,
and the alleged violations.
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Next slide.
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So the inspection forms we use for O&M's
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can be provided by the
inspector prior to the inspection.
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We use three Railroad Commission forms,
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we've adopted forms 8.1, 8.2, and 8.3,
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specifically for each type,
transmission, distribution,
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and hazardous liquids, respectively.
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And then for an LNG facility,
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we still use the PHMSA form
since Texas does not add any,
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or at least Pipeline Safety
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does not add any additional
regulations for LNG.
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Next slide.
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So, once we start on that O&M,
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we're gonna go through the entire O&M
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from start to finish,
page one to page 999.
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We're gonna go through
every single procedure
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and look for the compliance
with the federal code
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and the minimum expectations.
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That's going to include
any local or regional
00:10:19.620 --> 00:10:22.620
standard operating
procedures that you have,
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if they're specific to an
area or to a specific pipeline.
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So we'll need you to bring those along
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if you're gonna do an inspection,
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as well as the original
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equipment manufacturer specifications.
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These are part of the O&M
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because the manufacturer
has specific requirements
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on how to maintain that equipment,
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and you'll have to follow those
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in order to stay in compliance.
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The standalone programs
that we do exclude
00:10:48.380 --> 00:10:50.680
are basically the other inspections
00:10:50.680 --> 00:10:53.020
that we're gonna cover today.
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Like Ross before, new
construction is a separate inspection.
00:10:57.497 --> 00:10:59.690
And the other inspectors
that'll follow me,
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the leads that'll follow me,
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those programs are
standalone inspections.
00:11:04.360 --> 00:11:07.000
And so, we won't cover
those during the O&M.
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We may have a little overlap
00:11:08.670 --> 00:11:10.560
just because of the
way the rule is covered,
00:11:10.560 --> 00:11:12.700
but we're gonna try to stick to the O&M
00:11:12.700 --> 00:11:13.963
as much as possible.
00:11:15.720 --> 00:11:19.070
So this is a short list of the reports,
00:11:19.070 --> 00:11:22.530
records, and details we're
gonna look at during an O&M.
00:11:22.530 --> 00:11:25.490
If you notice, this is a
lot of the high level stuff,
00:11:25.490 --> 00:11:28.950
that's gonna be applicable
to the entire O&M
00:11:28.950 --> 00:11:30.900
or to the company as a whole,
00:11:30.900 --> 00:11:32.880
or to an entire pipeline system,
00:11:32.880 --> 00:11:35.930
not just a single segment or region.
00:11:35.930 --> 00:11:38.710
We're trying to cover
what the company is doing
00:11:38.710 --> 00:11:40.550
at the high level,
00:11:40.550 --> 00:11:42.610
because once we know
the procedures and policies
00:11:42.610 --> 00:11:45.710
are accurate and
effective at that level,
00:11:45.710 --> 00:11:49.630
then we get into the standard
comprehensive inspections
00:11:49.630 --> 00:11:53.370
to make sure that that's being followed.
00:11:53.370 --> 00:11:55.950
And of course, the
inspector always has the right
00:11:55.950 --> 00:11:58.090
to request additional documentation
00:11:58.090 --> 00:12:01.790
based off what he asked
for prior to the inspection
00:12:01.790 --> 00:12:04.293
or anything he finds
during the inspection.
00:12:06.980 --> 00:12:09.340
So, common concerns we've had.
00:12:09.340 --> 00:12:13.510
This data comes from the last two years
00:12:13.510 --> 00:12:16.620
since we didn't have
the presentation last year.
00:12:16.620 --> 00:12:21.620
I've covered this from September
1st of fiscal year or 2019,
00:12:21.930 --> 00:12:23.563
all the way to July 1st.
00:12:24.520 --> 00:12:26.650
So for gas transmission companies,
00:12:26.650 --> 00:12:29.600
we had some issues with the O&M updates
00:12:29.600 --> 00:12:31.820
and the annual reporting.
00:12:31.820 --> 00:12:34.420
So the annual reporting
is either not there
00:12:34.420 --> 00:12:37.660
or it's been late or it's inaccurate,
00:12:37.660 --> 00:12:40.540
it doesn't match your T4 miles.
00:12:40.540 --> 00:12:42.550
So your T4 regulated miles
00:12:42.550 --> 00:12:45.480
and your annual report
Texas miles should match,
00:12:45.480 --> 00:12:48.240
because that's all of
your regulated piping
00:12:49.330 --> 00:12:53.020
for both Texas and for the feds.
00:12:53.020 --> 00:12:54.490
And so those two numbers should match,
00:12:54.490 --> 00:12:56.630
and if they don't within
a certain tolerance
00:12:56.630 --> 00:12:59.920
or you can't justify why
those numbers don't match,
00:12:59.920 --> 00:13:02.240
that's where we have the concern.
00:13:02.240 --> 00:13:03.610
Same with the O&M updates,
00:13:03.610 --> 00:13:08.000
we've had a lot of rule
changes in 2020 and 2021.
00:13:08.000 --> 00:13:10.950
And so, those rules
need to get into the O&M
00:13:10.950 --> 00:13:14.933
by the effective dates or
else you're not in compliance.
00:13:16.330 --> 00:13:18.530
For gas distribution,
00:13:18.530 --> 00:13:20.410
record keeping has become a problem,
00:13:20.410 --> 00:13:21.970
especially with the municipality
00:13:21.970 --> 00:13:24.633
or with private distribution operators.
00:13:25.810 --> 00:13:26.940
The rules are all there,
00:13:26.940 --> 00:13:29.360
we look at the O&M to meet compliance,
00:13:29.360 --> 00:13:31.170
but then you have to show compliance
00:13:31.170 --> 00:13:33.460
with all of those regulations as well.
00:13:33.460 --> 00:13:36.090
And so, the record
keeping has to be sufficient,
00:13:36.090 --> 00:13:39.570
it has to be dated
and written correctly,
00:13:39.570 --> 00:13:41.770
and it has to cover all the details
00:13:41.770 --> 00:13:44.403
to prove compliance
with the regulations.
00:13:46.500 --> 00:13:48.300
We're not concerned
with the clerical errors,
00:13:48.300 --> 00:13:50.300
we're concerned with
things being missing,
00:13:50.300 --> 00:13:52.260
things being inaccurate,
00:13:52.260 --> 00:13:55.713
because the information is
inaccurate, not because of typos.
00:13:57.000 --> 00:13:58.420
With municipalities,
00:13:58.420 --> 00:14:00.790
the leak complaints
have become an issue,
00:14:00.790 --> 00:14:01.990
both in the procedures,
00:14:01.990 --> 00:14:05.800
as well as the 10:00 AM
reviews by supervisors
00:14:05.800 --> 00:14:07.030
the next business day,
00:14:07.030 --> 00:14:09.040
they're just generally not there,
00:14:09.040 --> 00:14:11.520
either in the procedure or the record.
00:14:11.520 --> 00:14:13.300
So we're really cracking down on that
00:14:13.300 --> 00:14:14.993
to make sure it gets covered.
00:14:16.450 --> 00:14:18.780
For liquid operators,
00:14:18.780 --> 00:14:22.490
for the last two years, we're
giving them a thumbs up.
00:14:22.490 --> 00:14:25.850
We've had over 100
inspections of liquid operators,
00:14:25.850 --> 00:14:29.900
and we have only had
two violations repeated
00:14:29.900 --> 00:14:32.330
on two separate occasions,
00:14:32.330 --> 00:14:37.330
a P5 not being filed, either
not being filed or delinquent,
00:14:37.520 --> 00:14:40.920
and then the emergency
plan training and review
00:14:41.980 --> 00:14:46.040
was not either recorded or completed.
00:14:46.040 --> 00:14:49.100
So, we understand that COVID-19,
00:14:49.100 --> 00:14:52.460
and 2020 was a very difficult year,
00:14:52.460 --> 00:14:55.920
but those records still
need to be in compliance.
00:14:55.920 --> 00:14:56.917
And they still need to be there,
00:14:56.917 --> 00:14:59.300
and the training still needs to be held.
00:14:59.300 --> 00:15:00.650
Other than that,
00:15:00.650 --> 00:15:05.650
we had nearly over 70 of
the 115 liquid inspections
00:15:07.390 --> 00:15:09.710
that were done in those two years,
00:15:09.710 --> 00:15:11.770
did not have any violations.
00:15:11.770 --> 00:15:15.000
So, hazardous liquids, in general,
00:15:15.000 --> 00:15:17.693
have done very good
in the last two years.
00:15:19.230 --> 00:15:24.230
And for O&Ms across the
board, all of three types of O&M's,
00:15:24.860 --> 00:15:27.660
it's a general lack of specificity.
00:15:27.660 --> 00:15:29.920
The rules require you
to stay in compliance.
00:15:29.920 --> 00:15:32.860
And a lot of the rules
are written in a manner
00:15:32.860 --> 00:15:36.300
to allow the operator to make
the decisions on their own.
00:15:36.300 --> 00:15:37.260
When it's written that way,
00:15:37.260 --> 00:15:40.230
you have to make those
decisions and put them in writing.
00:15:40.230 --> 00:15:43.140
So every procedure
should have a who, what,
00:15:43.140 --> 00:15:46.430
where, when, and how,
for every single procedure,
00:15:46.430 --> 00:15:48.830
every single thing that you're doing.
00:15:48.830 --> 00:15:51.110
And some of those are
given to you by the code,
00:15:51.110 --> 00:15:53.960
the rest have to be
decided by the operator.
00:15:53.960 --> 00:15:55.420
So we need to see all of that
00:15:55.420 --> 00:15:57.523
in every single procedure we look at.
00:15:58.760 --> 00:15:59.593
Next slide.
00:16:01.420 --> 00:16:05.799
So, we covered how we
do the O&M inspections,
00:16:05.799 --> 00:16:08.170
a short list of the
documents and records
00:16:08.170 --> 00:16:10.540
that we use and what we look at,
00:16:10.540 --> 00:16:12.210
and the common concerns we've had
00:16:12.210 --> 00:16:13.663
in the last couple of years.
00:16:14.540 --> 00:16:16.610
If you download this presentation,
00:16:16.610 --> 00:16:18.360
there are some helpful links
00:16:18.360 --> 00:16:20.387
in the notes section of the slides
00:16:20.387 --> 00:16:24.590
that you can use to help
prepare for an inspection.
00:16:24.590 --> 00:16:26.990
I've also included
my contact information
00:16:26.990 --> 00:16:31.633
if you need to call or email
me for any O&M questions,
00:16:31.633 --> 00:16:35.040
but that's all I've got
for right now and today.
00:16:35.040 --> 00:16:35.873
Thank you.
00:16:37.230 --> 00:16:39.020
Thank you, Chevy,
00:16:39.020 --> 00:16:40.730
Up next, we have Mr. Blaine Jacobs,
00:16:40.730 --> 00:16:41.563
who's gonna be going through
00:16:41.563 --> 00:16:43.330
and talking about drug and alcohol.
00:16:43.330 --> 00:16:45.323
So, Blaine whenever you're ready sir.
00:16:46.400 --> 00:16:47.830
Yes, my name is Blaine Jacobs.
00:16:47.830 --> 00:16:49.970
I am the lead for the drug and alcohol
00:16:49.970 --> 00:16:51.533
specialized inspections.
00:16:56.000 --> 00:16:57.310
The agenda we'll be going over today
00:16:57.310 --> 00:16:58.720
are the agencies involved
00:16:58.720 --> 00:17:03.137
with the drug and alcohol
programs, regulations,
00:17:03.137 --> 00:17:06.910
the inspection process,
common inspection issues,
00:17:06.910 --> 00:17:10.483
and at the end, there'll be
some informational websites.
00:17:12.940 --> 00:17:16.063
The agencies involved
with the drug and alcohol,
00:17:16.900 --> 00:17:19.080
the main one is U.S
Department of Transportation,
00:17:19.080 --> 00:17:21.140
they oversee the movement of everything
00:17:22.279 --> 00:17:25.610
in the United States as
far as drug and alcohol.
00:17:25.610 --> 00:17:27.550
Under that, will be the
Office of Drug & Alcohol
00:17:27.550 --> 00:17:29.520
Policy and Compliance.
00:17:29.520 --> 00:17:33.180
Basically, that is the
entity that is responsible
00:17:33.180 --> 00:17:36.070
for publishing the
rules and regulations,
00:17:36.070 --> 00:17:37.820
and they are the ones who interpret
00:17:39.047 --> 00:17:40.810
the rules and regulations.
00:17:40.810 --> 00:17:43.760
And then under that,
there are various agencies
00:17:43.760 --> 00:17:46.380
that fall underneath that blanket,
00:17:46.380 --> 00:17:48.040
Office of Pipeline Safety,
00:17:48.040 --> 00:17:51.620
which is Pipeline Hazardous
Material Safety Administration
00:17:51.620 --> 00:17:52.453
is one of them.
00:17:52.453 --> 00:17:55.340
You've also got Federal Motor Carrier,
00:17:55.340 --> 00:17:58.823
you have the U.S
Coast Guard, you have
00:18:01.420 --> 00:18:02.450
Federal Aviation.
00:18:02.450 --> 00:18:04.830
Different ones that are
involved in transportation,
00:18:04.830 --> 00:18:06.720
and each one is required to have
00:18:06.720 --> 00:18:10.550
a drug and alcohol plan and procedures,
00:18:10.550 --> 00:18:13.650
each one have their
specific requirements.
00:18:13.650 --> 00:18:18.190
So you need to make sure
that your plan is designed
00:18:18.190 --> 00:18:20.200
and meets the requirements for
00:18:20.200 --> 00:18:22.700
Pipeline Hazardous
Material Safety Administration.
00:18:25.370 --> 00:18:28.020
The regulations that
you're gonna be dealing with
00:18:28.020 --> 00:18:29.847
is gonna be 49 CFR 199
00:18:31.425 --> 00:18:34.340
and 49 CFR Part 40.
00:18:34.340 --> 00:18:37.514
199 basically tells what DOT
00:18:37.514 --> 00:18:40.130
and OPS require an operator to do
00:18:40.130 --> 00:18:42.253
as far as our policies and procedures.
00:18:43.314 --> 00:18:45.160
For now, CFR Part 40,
00:18:45.160 --> 00:18:47.900
addresses the parties
who conduct testing
00:18:47.900 --> 00:18:49.683
and how the test will be conducted.
00:18:53.370 --> 00:18:55.460
Inspection process.
00:18:55.460 --> 00:18:56.850
The pre-inspection operator
00:18:56.850 --> 00:18:59.630
will be notified by the inspector.
00:18:59.630 --> 00:19:01.840
At that time, the operator
can request a copy
00:19:01.840 --> 00:19:05.110
of the inspection form
that we use, protocol form,
00:19:05.110 --> 00:19:06.840
so that you have an idea of what it is
00:19:06.840 --> 00:19:09.962
we're gonna be looking
for during the inspection.
00:19:09.962 --> 00:19:12.510
The inspection itself will
be a review of the plan
00:19:12.510 --> 00:19:14.570
and supporting documents.
00:19:14.570 --> 00:19:17.880
The inspection is designed
00:19:17.880 --> 00:19:22.333
or geared towards your
designated employee representative,
00:19:23.660 --> 00:19:27.710
which is the person who manages
your drug and alcohol plan.
00:19:27.710 --> 00:19:30.850
It's usually somebody, depending
on the size of the company,
00:19:30.850 --> 00:19:33.183
is usually somebody
in the HR department.
00:19:34.210 --> 00:19:37.090
Then possibly, be
a collection site visit,
00:19:37.090 --> 00:19:40.740
depending on what's
found in the initial part
00:19:40.740 --> 00:19:43.103
of the inspection process.
00:19:45.720 --> 00:19:50.190
Common issues that
have been come across.
00:19:50.190 --> 00:19:52.670
Operator did not have a plan
that met all the requirements
00:19:52.670 --> 00:19:56.583
of Parts 199 and Part 40.
00:19:57.990 --> 00:19:59.760
Then again, they must
contain all the elements
00:19:59.760 --> 00:20:01.003
required by PHMSA.
00:20:02.910 --> 00:20:06.120
Basically, you've got 199 and Part 40,
00:20:06.120 --> 00:20:08.470
and both of those have to be,
00:20:08.470 --> 00:20:11.530
has specific issues
or since specific items
00:20:11.530 --> 00:20:12.930
that need to be contained
00:20:12.930 --> 00:20:14.993
within your drug and alcohol plans.
00:20:17.550 --> 00:20:20.940
Another one is, no process
to ensure contractors
00:20:20.940 --> 00:20:24.680
or service providers were
compliant with regulations.
00:20:24.680 --> 00:20:29.680
As an operator, you've
hired third-party contractors
00:20:29.930 --> 00:20:34.900
or third-party service
providers to perform functions
00:20:34.900 --> 00:20:37.470
associated with your
drug and alcohol plan.
00:20:37.470 --> 00:20:41.150
And you, as the operator,
responsible for ensuring
00:20:41.150 --> 00:20:44.490
that those individuals
are performing those tasks
00:20:44.490 --> 00:20:46.083
according to regulation.
00:20:47.915 --> 00:20:50.530
I99.115, the operator is responsible for
00:20:50.530 --> 00:20:53.080
contract compliance with regulations.
00:20:53.080 --> 00:20:56.760
And 40.11 and 40.15, is said that it is,
00:20:56.760 --> 00:20:58.140
where the operator's responsible
00:20:58.140 --> 00:21:01.003
for Service Agent
compliance with regulations.
00:21:05.130 --> 00:21:06.540
Collection site monitoring.
00:21:06.540 --> 00:21:09.010
We run a across a lot of operators
00:21:09.010 --> 00:21:12.470
who have no documentation
showing that they are
00:21:12.470 --> 00:21:15.493
making sure that the collection
sites are in compliance.
00:21:16.530 --> 00:21:20.180
That's under
199.115 and 199.245,
00:21:21.850 --> 00:21:26.330
based on whether
it's the drug side of it
00:21:26.330 --> 00:21:29.233
or the alcohol misuse
prevention portion of the plan.
00:21:32.140 --> 00:21:35.080
Well, here's some informational
websites that you can go to
00:21:35.080 --> 00:21:37.180
that have what...
00:21:38.020 --> 00:21:41.270
As specific information
that as an employer
00:21:41.270 --> 00:21:43.320
or operator, you need to know,
00:21:43.320 --> 00:21:46.240
and answers any questions
you might have as far as
00:21:46.240 --> 00:21:48.510
what needs to be in your plan,
00:21:48.510 --> 00:21:53.510
they also offer a pamphlet
that PHMSA put out last year,
00:21:53.850 --> 00:21:57.843
they go step by step on how
to inspect a collection site.
00:22:00.580 --> 00:22:03.020
Again, there's my contact information.
00:22:03.020 --> 00:22:04.700
If you have any questions,
00:22:04.700 --> 00:22:07.640
don't hesitate to reach out
and get in touch with me.
00:22:07.640 --> 00:22:08.840
Thank you for your time.
00:22:10.320 --> 00:22:11.763
All right.
Thank you, Blaine.
00:22:13.010 --> 00:22:16.220
Next up, we have public
awareness and damage prevention,
00:22:16.220 --> 00:22:18.960
it's gonna be talked
about by Mr. Pete Longoria.
00:22:18.960 --> 00:22:20.760
So whenever you're ready, sir.
00:22:20.760 --> 00:22:21.610
Okay.
00:22:21.610 --> 00:22:23.130
Good morning, my name is Pete Longoria,
00:22:23.130 --> 00:22:24.170
and I'm the team lead
00:22:24.170 --> 00:22:26.320
for public awareness
and damage prevention.
00:22:27.610 --> 00:22:29.210
So a quick overview of everything
00:22:29.210 --> 00:22:30.330
that I'm gonna cover today.
00:22:30.330 --> 00:22:31.330
So we're gonna start with
00:22:31.330 --> 00:22:33.293
the importance of public awareness,
00:22:34.410 --> 00:22:37.100
then we're gonna move
on to the regulations
00:22:37.100 --> 00:22:39.210
that govern public awareness,
00:22:39.210 --> 00:22:41.710
the public awareness
and inspection process,
00:22:41.710 --> 00:22:44.480
some quick information
on damage prevention,
00:22:44.480 --> 00:22:46.840
damage prevention regulations,
00:22:46.840 --> 00:22:49.350
the inspection process
for damage prevention,
00:22:49.350 --> 00:22:51.360
common issues found
during public awareness
00:22:51.360 --> 00:22:54.050
and damage prevention inspections,
00:22:54.050 --> 00:22:56.200
and then of course,
my contact information.
00:22:57.860 --> 00:23:00.430
So, why is public awareness important?
00:23:00.430 --> 00:23:03.600
Well, we raise the awareness
of presence of pipelines
00:23:03.600 --> 00:23:06.750
to the intended stakeholder audiences.
00:23:06.750 --> 00:23:11.020
And so, really the goal is to
increase public understanding
00:23:11.020 --> 00:23:13.050
on the role of pipelines.
00:23:13.050 --> 00:23:16.360
So helping them understand
that pipelines are the most,
00:23:16.360 --> 00:23:18.360
the safest and most reliable way
00:23:18.360 --> 00:23:21.780
to transport natural gas,
crude, and refined product.
00:23:21.780 --> 00:23:25.690
And in turn, this also
helps you as an operator,
00:23:25.690 --> 00:23:27.500
is promoting the safe
operation of pipeline.
00:23:27.500 --> 00:23:29.960
So in the case of the public awareness,
00:23:29.960 --> 00:23:31.610
kind of getting ahead
into damage prevention,
00:23:31.610 --> 00:23:33.920
but 811 is a big thing that we stress,
00:23:33.920 --> 00:23:35.070
calling before you dig.
00:23:36.000 --> 00:23:38.770
Letting the public know that
there's a pipeline in the area,
00:23:38.770 --> 00:23:40.590
that can decrease
your third-party strikes.
00:23:40.590 --> 00:23:43.560
And also, the information
that you provide
00:23:43.560 --> 00:23:46.800
to the stakeholders has key information
00:23:46.800 --> 00:23:49.780
on how to identify
potential leaks or hazards
00:23:49.780 --> 00:23:52.010
associated with pipeline releases,
00:23:52.010 --> 00:23:54.580
they could potentially have them
00:23:54.580 --> 00:23:56.830
notifying you before
you have a bigger event.
00:23:59.290 --> 00:24:01.510
So, under federal regulation,
00:24:01.510 --> 00:24:04.370
each operator must establish
a public awareness program.
00:24:04.370 --> 00:24:06.387
So there is a gas and
the liquid requirement,
00:24:06.387 --> 00:24:10.200
so that is 49 CFR 192.616, for the gas,
00:24:10.200 --> 00:24:12.580
and 195.440 for liquid.
00:24:12.580 --> 00:24:17.580
In addition, API RP 1162
is incorporated by reference.
00:24:17.620 --> 00:24:21.170
This is where you as an
operator find resources as far as
00:24:21.170 --> 00:24:23.530
how to identify your
stakeholder audiences,
00:24:23.530 --> 00:24:25.320
how frequently you
should be corresponding
00:24:25.320 --> 00:24:27.400
with these stakeholder audiences,
00:24:27.400 --> 00:24:31.050
and also, methods to
evaluate your program
00:24:31.050 --> 00:24:33.913
and see whether or not
the program is effective.
00:24:34.960 --> 00:24:37.480
Keeping in mind... Oops, sorry.
00:24:37.480 --> 00:24:39.070
So just real quick on the previous one,
00:24:39.070 --> 00:24:41.290
keep in mind that
there are two additional,
00:24:41.290 --> 00:24:42.610
there are additional regulations
00:24:42.610 --> 00:24:44.360
in Texas Administrative Code
00:24:44.360 --> 00:24:47.130
for conducting liaison
activities once per calendar year,
00:24:47.130 --> 00:24:51.323
not to exceed 15 months,
and these are, TAC 8.235
00:24:52.779 --> 00:24:55.163
and TAC 8.310.
00:24:56.400 --> 00:24:59.210
So the inspection process
for public awareness is,
00:24:59.210 --> 00:25:00.540
as everybody else mentioned,
00:25:00.540 --> 00:25:02.040
we wanna make sure that we're capturing
00:25:02.040 --> 00:25:06.200
any and all subsidiaries under
that are covered by the plan.
00:25:06.200 --> 00:25:08.950
So, after we go ahead and verify that,
00:25:08.950 --> 00:25:11.150
we're gonna verify the
miles of regulated pipeline.
00:25:11.150 --> 00:25:12.860
So, we're gonna break it down
00:25:12.860 --> 00:25:15.330
by gas gathering, gas transmission,
00:25:15.330 --> 00:25:17.230
liquid gathering, and liquid pipelines,
00:25:17.230 --> 00:25:19.710
and the miles associated with each.
00:25:19.710 --> 00:25:23.800
And after that, the
main records portion is,
00:25:23.800 --> 00:25:26.120
identification of your
stakeholder audiences,
00:25:26.120 --> 00:25:30.233
are you making the appropriate time,
00:25:32.430 --> 00:25:34.160
correspondents at the appropriate times
00:25:34.160 --> 00:25:35.770
to your stakeholder audiences?
00:25:35.770 --> 00:25:38.270
And then the biggest
one is your annual reviews
00:25:38.270 --> 00:25:40.440
and your effectiveness evaluations
00:25:40.440 --> 00:25:42.740
to determine where it
is that your program is.
00:25:47.760 --> 00:25:49.590
So, coming into damage prevention.
00:25:49.590 --> 00:25:51.570
So the leading cause
of pipeline incidents
00:25:51.570 --> 00:25:53.090
is third-party damage.
00:25:53.090 --> 00:25:55.190
So the goal of damage prevention
00:25:55.190 --> 00:25:58.180
is to prevent damage to
pipeline and its facilities.
00:25:58.180 --> 00:26:00.220
So again, as I mentioned before,
00:26:00.220 --> 00:26:03.360
public awareness damage
prevention go hand in hand.
00:26:03.360 --> 00:26:04.710
You reach out to the public,
00:26:04.710 --> 00:26:08.000
you make them aware of
the pipelines in the area,
00:26:08.000 --> 00:26:10.203
and we can help bring
these numbers down.
00:26:11.110 --> 00:26:12.880
And so, just quick definition,
00:26:12.880 --> 00:26:16.320
excavation includes
digging, trenching, blasting,
00:26:16.320 --> 00:26:17.453
and anything similar.
00:26:20.460 --> 00:26:22.060
So just like with public awareness,
00:26:22.060 --> 00:26:24.680
an operator must carry out a
damage prevention program.
00:26:24.680 --> 00:26:27.487
So here you have 192.614 for gas,
00:26:27.487 --> 00:26:31.280
195.442 for liquid,
And in addition to that,
00:26:31.280 --> 00:26:34.310
there is Texas Administrative
Code Chapter 18,
00:26:34.310 --> 00:26:37.283
which has requirements for
both excavators and operators.
00:26:40.320 --> 00:26:42.760
So just as with public awareness,
00:26:42.760 --> 00:26:47.350
we'll do a breakdown of
mileage by commodity.
00:26:47.350 --> 00:26:48.670
And then in addition to that,
00:26:48.670 --> 00:26:50.610
the difference here
is we're gonna look at,
00:26:50.610 --> 00:26:52.840
are you identifying your excavators?
00:26:52.840 --> 00:26:54.480
And we're gonna verify
your one-call tickets.
00:26:54.480 --> 00:26:58.270
So, regulation requires you
to keep them for five years.
00:26:58.270 --> 00:27:01.180
And in addition, we'll
compare your numbers
00:27:01.180 --> 00:27:03.510
reported to PHMSA for third-party damage
00:27:03.510 --> 00:27:06.393
and your Texas damage
reporting form submissions.
00:27:10.080 --> 00:27:12.760
So the most common issue,
it's mainly with public awareness,
00:27:12.760 --> 00:27:15.270
and it's incomplete
effectiveness evaluation.
00:27:15.270 --> 00:27:18.590
So the big three are either
the effectiveness evaluations
00:27:18.590 --> 00:27:20.363
are exceeding the four-year mark,
00:27:21.620 --> 00:27:23.470
stakeholders aren't understanding
00:27:23.470 --> 00:27:25.530
the material being provided,
00:27:25.530 --> 00:27:28.740
and also, some operators
are gathering the information,
00:27:28.740 --> 00:27:30.760
but they're not able to
come up with a conclusion
00:27:30.760 --> 00:27:33.280
as to whether or not
their program is effective.
00:27:33.280 --> 00:27:36.477
So those are the big
three issues that we see.
00:27:41.070 --> 00:27:43.310
And so, here's my contact information.
00:27:43.310 --> 00:27:46.290
If you have any questions,
feel free to reach out to me.
00:27:46.290 --> 00:27:47.123
Thank you.
00:27:48.770 --> 00:27:51.340
All right.
Thank you, Pete.
00:27:51.340 --> 00:27:53.610
Up next, we have control room management
00:27:53.610 --> 00:27:55.360
and Mr. Mark Herrin is gonna go through
00:27:55.360 --> 00:27:57.080
and talk on that subject.
00:27:57.080 --> 00:27:58.720
And, whenever you're ready, sir.
00:27:58.720 --> 00:28:00.590
Right, good morning everybody.
00:28:00.590 --> 00:28:03.360
I'm the current control room
management active lead,
00:28:03.360 --> 00:28:05.380
and here to talk about control room.
00:28:05.380 --> 00:28:08.820
So I pulled the
definitions from the code.
00:28:08.820 --> 00:28:10.720
Control room, do you
have a place and location
00:28:10.720 --> 00:28:13.270
for your controllers or personnel
00:28:13.270 --> 00:28:16.280
that's gonna be watching
the SCADA system below?
00:28:16.280 --> 00:28:17.810
But you need a kind of
computer based system
00:28:17.810 --> 00:28:19.950
that you get the information
from your pipeline,
00:28:19.950 --> 00:28:24.090
pressures, anything of that
nature into the control room.
00:28:24.090 --> 00:28:25.540
Go on the next slide, please.
00:28:26.840 --> 00:28:28.150
And then we have the controller,
00:28:28.150 --> 00:28:30.310
and they could define
here by somebody that
00:28:30.310 --> 00:28:32.810
remotely monitors and controls
the safety related operations
00:28:32.810 --> 00:28:35.590
of a pipeline facility
with a SCADA system.
00:28:35.590 --> 00:28:38.120
So from this, we can see that,
00:28:38.120 --> 00:28:39.630
you know, control room is,
00:28:39.630 --> 00:28:41.820
you got a system, you
see the information,
00:28:41.820 --> 00:28:44.490
and they can control
it one way or the other.
00:28:44.490 --> 00:28:45.323
Next slide.
00:28:47.700 --> 00:28:51.230
And the FAQ A.07, which
I have the link to the FAQ's
00:28:51.230 --> 00:28:52.480
at the end of this slide.
00:28:53.910 --> 00:28:55.430
This has a definition of,
00:28:55.430 --> 00:28:57.310
it helps you identify a controller.
00:28:57.310 --> 00:28:58.520
It's anybody that,
00:28:58.520 --> 00:29:00.130
whether you interact
with the SCADA system
00:29:00.130 --> 00:29:01.230
to manipulate a valve
00:29:01.230 --> 00:29:03.920
or you call anybody else
that can manipulate that valve
00:29:03.920 --> 00:29:04.820
or take care of an issue
00:29:04.820 --> 00:29:06.910
you see on a system or monitor.
00:29:06.910 --> 00:29:08.410
Those are controllers.
00:29:08.410 --> 00:29:09.243
Next slide.
00:29:10.820 --> 00:29:12.540
So, we'll talk about what to expect
00:29:12.540 --> 00:29:14.060
during the CRM inspection.
00:29:14.060 --> 00:29:17.630
So, generally we're going to determine
00:29:17.630 --> 00:29:20.770
what of your facilities are
control rooms specifically.
00:29:20.770 --> 00:29:22.640
So, everything we're gonna talk about,
00:29:22.640 --> 00:29:24.470
we're gonna look at the process you use,
00:29:24.470 --> 00:29:26.170
procedures and documentation
00:29:26.170 --> 00:29:28.460
for everything throughout the process.
00:29:28.460 --> 00:29:29.293
Next slide.
00:29:31.640 --> 00:29:33.730
What is your effective
data and control room plan
00:29:33.730 --> 00:29:34.960
and when was it implemented?
00:29:34.960 --> 00:29:36.640
The original date, original time
00:29:36.640 --> 00:29:38.300
when the control room was either active
00:29:38.300 --> 00:29:40.400
or the control room
plan went into effect.
00:29:44.870 --> 00:29:46.890
Then we'll go into roles
and responsibilities.
00:29:46.890 --> 00:29:48.550
What's the Controller Authority?
00:29:48.550 --> 00:29:49.383
Does he have authority
00:29:49.383 --> 00:29:51.380
to do everything he needs in his powers?
00:29:51.380 --> 00:29:53.220
Does that cover abnormal operations
00:29:53.220 --> 00:29:55.020
and emergency operations?
00:29:55.020 --> 00:29:56.790
What is his physical domain?
00:29:56.790 --> 00:29:58.570
Is it the one console
that covers everything?
00:29:58.570 --> 00:30:01.840
Does that console only
cover certain pipeline facilities?
00:30:01.840 --> 00:30:03.730
We'll talk about shift change.
00:30:03.730 --> 00:30:05.110
What are your procedures for that?
00:30:05.110 --> 00:30:06.343
How do you document it?
00:30:07.330 --> 00:30:09.340
We'll go through all of that good stuff.
00:30:09.340 --> 00:30:10.173
Next slide.
00:30:12.110 --> 00:30:14.870
All right, so do you give
anyone to supersede
00:30:14.870 --> 00:30:16.790
or direct your controllers?
00:30:16.790 --> 00:30:18.760
So it's very important
that you need to say,
00:30:18.760 --> 00:30:21.330
if they don't, nobody else
can tell them what to do,
00:30:21.330 --> 00:30:22.270
need to put in your plan
00:30:22.270 --> 00:30:24.423
that it's either allowed or not allowed.
00:30:25.420 --> 00:30:26.520
How are they qualified
00:30:26.520 --> 00:30:28.800
if they are allowed to supersede them?
00:30:28.800 --> 00:30:32.730
And has there been any
record events that's happened?
00:30:32.730 --> 00:30:33.563
Next.
00:30:35.570 --> 00:30:38.350
In your plan, you need to
define what additions, expansions,
00:30:38.350 --> 00:30:40.640
or replacements are
within your facilities.
00:30:40.640 --> 00:30:42.840
What are your procedures
going to be for that?
00:30:42.840 --> 00:30:45.763
FAQ's C.15 and C.19 are good for that.
00:30:46.760 --> 00:30:48.290
All right, then next we're gonna look at
00:30:48.290 --> 00:30:50.280
your implementation of 1165.
00:30:50.280 --> 00:30:51.680
Procedures, documentation,
00:30:51.680 --> 00:30:54.400
talking about how your screens look,
00:30:54.400 --> 00:30:55.690
how all that stuff was implemented.
00:30:55.690 --> 00:30:57.230
Did you have a checklist?
00:30:57.230 --> 00:30:58.480
Or we just gonna look at it.
00:30:58.480 --> 00:30:59.313
Next slide.
00:31:01.790 --> 00:31:04.400
All right, safety related points.
00:31:04.400 --> 00:31:06.530
What is your process
of going through those
00:31:06.530 --> 00:31:09.140
and making sure that
everything that's safety related
00:31:09.140 --> 00:31:10.640
is in the SCADA system?
00:31:10.640 --> 00:31:11.570
What's the records of that?
00:31:11.570 --> 00:31:13.530
Do you have a master list?
00:31:13.530 --> 00:31:15.600
I have the point to point verification,
00:31:15.600 --> 00:31:17.080
going out there saying,
00:31:17.080 --> 00:31:19.250
all right, this
communicates, it's working,
00:31:19.250 --> 00:31:21.040
they have accurate information.
00:31:21.040 --> 00:31:21.873
Next slide.
00:31:23.560 --> 00:31:25.660
What is your internal
communication plan?
00:31:25.660 --> 00:31:26.920
Do you call everybody?
00:31:26.920 --> 00:31:28.500
What's your procedures and process?
00:31:28.500 --> 00:31:30.640
Do we call everybody, get their names?
00:31:30.640 --> 00:31:32.290
Make sure that the phone
numbers are still good
00:31:32.290 --> 00:31:33.970
in an emergency.
00:31:33.970 --> 00:31:35.770
Do you have a backup SCADA system?
00:31:35.770 --> 00:31:38.110
So we need to find out if you have one,
00:31:38.110 --> 00:31:39.070
we'll take a look at it,
00:31:39.070 --> 00:31:41.130
if not, it's something we
don't have to look at at all.
00:31:41.130 --> 00:31:44.663
So, the process of how
you go out to it, check it,
00:31:45.720 --> 00:31:47.310
logistics of how to getting out there,
00:31:47.310 --> 00:31:49.840
what's your timeline and
then the records of all that?
00:31:49.840 --> 00:31:50.673
Next slide.
00:31:55.420 --> 00:31:56.403
Fatigue management.
00:31:57.510 --> 00:31:59.340
Something that has
been missed lately is,
00:31:59.340 --> 00:32:01.130
operator specific fatigue risks,
00:32:01.130 --> 00:32:01.963
it could be anything
00:32:01.963 --> 00:32:04.510
specific to your control
room specifically,
00:32:04.510 --> 00:32:07.560
such as Downtown Houston
traffic could cause an issue,
00:32:07.560 --> 00:32:09.240
you might've changed your start times
00:32:09.240 --> 00:32:11.670
for you controllers specifically.
00:32:11.670 --> 00:32:12.653
We'll talk about,
00:32:14.030 --> 00:32:17.000
did your controllers have
any accidents or incidents
00:32:17.000 --> 00:32:18.510
and did fatigue play a role in that?
00:32:18.510 --> 00:32:20.280
How did you investigate that?
00:32:20.280 --> 00:32:22.060
If you did investigate
that and found nothing,
00:32:22.060 --> 00:32:23.260
did you document it?
00:32:23.260 --> 00:32:24.450
If there was something that happened,
00:32:24.450 --> 00:32:26.190
how did you document that?
00:32:26.190 --> 00:32:28.010
Then you're gonna talk
about, the shift lengths.
00:32:28.010 --> 00:32:29.160
How did you determine that?
00:32:29.160 --> 00:32:30.940
Is there, did you do a study?
00:32:30.940 --> 00:32:32.730
Did you use a pre-approved?
00:32:32.730 --> 00:32:34.810
Then we're gonna do fatigue training.
00:32:34.810 --> 00:32:36.570
What did you use? Presentations,
00:32:36.570 --> 00:32:38.830
how do you continue
that training as well?
00:32:38.830 --> 00:32:39.663
Next slide.
00:32:41.810 --> 00:32:43.540
Go into the alarm management.
00:32:43.540 --> 00:32:45.330
So what is the philosophy that you use
00:32:45.330 --> 00:32:48.200
for your alarm
management, rationalization?
00:32:48.200 --> 00:32:50.353
And then we're going to
your safety related points
00:32:50.353 --> 00:32:51.660
that we looked at earlier.
00:32:51.660 --> 00:32:52.900
What are those set points?
00:32:52.900 --> 00:32:55.320
We'll go through and see what you got.
00:32:55.320 --> 00:32:56.720
Then you'll need to
do your annual review
00:32:56.720 --> 00:32:58.410
of your alarm management plan,
00:32:58.410 --> 00:33:00.410
one year not to exceed 15 months.
00:33:00.410 --> 00:33:03.530
So, you can't have that
15 months and skip a year,
00:33:03.530 --> 00:33:04.980
you have to do it every year.
00:33:05.870 --> 00:33:06.703
Next slide.
00:33:08.610 --> 00:33:09.723
Monthly analysis.
00:33:10.600 --> 00:33:11.650
What you took off scan,
00:33:11.650 --> 00:33:13.830
did you inhibit any
alarms, false alarms?
00:33:13.830 --> 00:33:15.730
Did you have any forced values?
00:33:15.730 --> 00:33:17.510
If so, how are you monitoring that?
00:33:17.510 --> 00:33:19.410
Are you making any corrections?
00:33:19.410 --> 00:33:21.820
Is there a timeline to get things fixed?
00:33:21.820 --> 00:33:24.550
And then, the timeline
we're talking about promptly,
00:33:24.550 --> 00:33:28.850
that you define promptly
fixing it as a week, a year,
00:33:28.850 --> 00:33:31.530
you might be a little long
for a SCADA system point.
00:33:31.530 --> 00:33:32.783
So, next slide.
00:33:35.640 --> 00:33:36.750
Measuring your workload.
00:33:36.750 --> 00:33:38.070
How do you know workload studies,
00:33:38.070 --> 00:33:40.710
making sure that
they're not overburdened
00:33:40.710 --> 00:33:41.817
or they can't get their work done
00:33:41.817 --> 00:33:44.520
and in case something happens?
00:33:44.520 --> 00:33:46.620
So, we'll look at the
workload study you're doing,
00:33:46.620 --> 00:33:48.180
how did you measure the metrics,
00:33:48.180 --> 00:33:49.540
if the metrics make sense,
00:33:49.540 --> 00:33:52.150
and how many records do you have?
00:33:52.150 --> 00:33:54.320
Look at your alarm
deficiency resolution.
00:33:54.320 --> 00:33:56.560
FAQ E.16 is very good for this
00:33:56.560 --> 00:33:57.890
to give you an idea of what to do
00:33:57.890 --> 00:34:00.080
if you don't already have an idea.
00:34:00.080 --> 00:34:00.913
Next slide.
00:34:02.750 --> 00:34:04.010
Change management.
00:34:04.010 --> 00:34:07.420
So, you're changing
a valve out in the field
00:34:07.420 --> 00:34:10.330
to another location and
that valve no longer exists.
00:34:10.330 --> 00:34:11.750
Did you inform the control room
00:34:11.750 --> 00:34:14.450
or have anybody from
the control room participate
00:34:14.450 --> 00:34:16.620
in how that might affect the pipeline?
00:34:16.620 --> 00:34:20.000
So that's one of the change
managements that we'll look at.
00:34:20.000 --> 00:34:20.950
Next slide, please.
00:34:22.960 --> 00:34:24.170
Lessons learned.
00:34:24.170 --> 00:34:27.230
So, did your company have
any incidents or accidents
00:34:27.230 --> 00:34:28.950
or any, you know, near misses that
00:34:28.950 --> 00:34:31.580
you could take to the
control room or anywhere
00:34:31.580 --> 00:34:33.600
and apply that as a lessons learned.
00:34:33.600 --> 00:34:35.280
If something outside
the company happened
00:34:35.280 --> 00:34:37.890
that could potentially
help your company.
00:34:37.890 --> 00:34:39.510
So, you would recommend
00:34:39.510 --> 00:34:42.120
adding any of that stuff you can find.
00:34:42.120 --> 00:34:42.953
Next slide.
00:34:44.720 --> 00:34:45.950
We're going to training.
00:34:45.950 --> 00:34:49.520
So, what are the qualifications
to become a controller?
00:34:49.520 --> 00:34:52.112
And when do you determine
them to be qualified?
00:34:52.112 --> 00:34:54.670
Because you can complete
CBT's relatively quickly
00:34:54.670 --> 00:34:58.030
if you're using CBT's
on the job training.
00:34:58.030 --> 00:34:59.290
You probably wouldn't have somebody
00:34:59.290 --> 00:35:01.230
two weeks into their training
00:35:01.230 --> 00:35:03.590
to start working on a controller.
00:35:03.590 --> 00:35:05.660
So when do you determine
them to be qualified
00:35:05.660 --> 00:35:07.230
to run as a controller.
00:35:07.230 --> 00:35:08.070
And then you'll wanna review
00:35:08.070 --> 00:35:10.120
your current training
program every year.
00:35:10.980 --> 00:35:11.813
Next slide.
00:35:13.180 --> 00:35:16.090
This one is relatively new,
the control room team training.
00:35:16.090 --> 00:35:17.530
You need to identify
00:35:17.530 --> 00:35:20.600
who works with the
control room personnel.
00:35:20.600 --> 00:35:23.030
So that's gonna be people in the field,
00:35:23.030 --> 00:35:26.170
that's gonna people
who do anything out there,
00:35:26.170 --> 00:35:28.030
schedulers,
00:35:28.030 --> 00:35:31.090
do they talk to any other
company controllers?
00:35:31.090 --> 00:35:32.740
You just need to talk to
anybody within your company
00:35:32.740 --> 00:35:34.000
that you can get on that.
00:35:34.000 --> 00:35:35.210
And then what are your procedures
00:35:35.210 --> 00:35:37.490
for identifying those people?
00:35:37.490 --> 00:35:39.200
How do you get their training done?
00:35:39.200 --> 00:35:42.000
If you have new hires into the field,
00:35:42.000 --> 00:35:44.890
when do you establish they
need to have this training done?
00:35:44.890 --> 00:35:47.340
We'll look at the
documentation that you have.
00:35:47.340 --> 00:35:49.470
And then, FAQ's PHMSA put out,
00:35:49.470 --> 00:35:51.680
H.05 through H.09 is very helpful
00:35:51.680 --> 00:35:54.410
and I recommend going
through those for this program.
00:35:54.410 --> 00:35:55.310
Next slide please.
00:35:57.280 --> 00:36:00.060
And here's the link to the
FAQ's as I was talking about,
00:36:00.060 --> 00:36:01.980
this will bring you, I
checked it today again,
00:36:01.980 --> 00:36:04.293
and this is still a good link.
00:36:06.020 --> 00:36:07.260
Recommend going through this,
00:36:07.260 --> 00:36:08.920
it's a little lengthy,
00:36:08.920 --> 00:36:10.870
but it's got great
information for control rooms
00:36:10.870 --> 00:36:12.220
and control room operators.
00:36:13.640 --> 00:36:14.473
Next slide.
00:36:15.900 --> 00:36:18.250
And this is my contact information.
00:36:18.250 --> 00:36:20.400
Again, I'm the current
control room lead.
00:36:20.400 --> 00:36:21.760
If you have any questions
00:36:21.760 --> 00:36:23.950
and you need some help or guidance,
00:36:23.950 --> 00:36:27.350
please contact me and we'll
work through whatever you got.
00:36:27.350 --> 00:36:28.350
Thank you very much.
00:36:29.940 --> 00:36:31.780
All right.
Thank you, Mark.
00:36:31.780 --> 00:36:33.790
Up next, for operator qualification,
00:36:33.790 --> 00:36:35.890
we have Mr. Derek Lawrence.
00:36:35.890 --> 00:36:37.390
So whenever you're ready, sir.
00:36:38.390 --> 00:36:39.440
Thank you, Michael.
00:36:40.580 --> 00:36:41.413
My name is Derek Lawrence,
00:36:41.413 --> 00:36:44.100
I am the OQ lead for the state of Texas.
00:36:44.100 --> 00:36:47.387
Today we'll be covering what
to expect on an OQ inspection
00:36:47.387 --> 00:36:50.870
and as well as some of
the code references for that.
00:36:52.340 --> 00:36:55.990
We starting with covered
tasks and the definitions of that,
00:36:55.990 --> 00:36:57.320
OQ evaluations,
00:36:57.320 --> 00:36:58.780
then we'll go over record maintenance,
00:36:58.780 --> 00:36:59.613
program review,
00:36:59.613 --> 00:37:01.593
and then commonly cited violations.
00:37:03.300 --> 00:37:05.503
The covered task is,
00:37:08.370 --> 00:37:11.510
is a part of any task, that
is, meets the four-part task,
00:37:11.510 --> 00:37:14.573
which is a requirement
of state or federal code,
00:37:17.560 --> 00:37:20.930
an operation or
maintenance task, and is...
00:37:24.290 --> 00:37:25.123
My apologies.
00:37:27.290 --> 00:37:28.720
Is performing a pipeline facility
00:37:28.720 --> 00:37:31.990
and is detrimental to the safety
00:37:31.990 --> 00:37:34.313
of the pipeline system itself.
00:37:37.160 --> 00:37:39.630
Just so you know, the
Texas Administrative Code
00:37:39.630 --> 00:37:42.553
is applicable to the
rule for the four-part task.
00:37:44.070 --> 00:37:45.380
One thing we've been seeing in the field
00:37:45.380 --> 00:37:47.970
is generic covered tasks,
00:37:47.970 --> 00:37:50.310
where we'll go through
an operator's OQ plan,
00:37:50.310 --> 00:37:51.880
and we're noticing that,
00:37:51.880 --> 00:37:53.800
they all have a list of covered tasks
00:37:53.800 --> 00:37:56.500
that are applicable to the rule,
00:37:56.500 --> 00:37:58.290
but they're not using it all.
00:37:58.290 --> 00:38:00.760
So, one thing that might
be helpful to you guys
00:38:00.760 --> 00:38:02.570
to know which tasks do
you need is to go through,
00:38:02.570 --> 00:38:04.280
and when you're doing
your review of your program,
00:38:04.280 --> 00:38:07.240
make sure that the tasks
that are in your program
00:38:07.240 --> 00:38:09.970
are applicable to your
pipeline that you're using.
00:38:09.970 --> 00:38:11.510
For example, if you have gas
00:38:11.510 --> 00:38:14.870
and you don't do any liquid pipelines,
00:38:14.870 --> 00:38:16.810
you probably don't need,
00:38:16.810 --> 00:38:19.820
you know, starting up a
pump as a covered task,
00:38:19.820 --> 00:38:21.993
because that would
be related to liquid lines.
00:38:26.610 --> 00:38:27.443
We're gonna start with
00:38:27.443 --> 00:38:29.530
what we're gonna look
for in an OQ evaluation.
00:38:29.530 --> 00:38:32.890
This will come from the
definitions page right now,
00:38:32.890 --> 00:38:36.780
and that's 192.803 and 192.503.
00:38:36.780 --> 00:38:39.000
Is for you to get our
definition for AOC,
00:38:39.000 --> 00:38:41.190
which is an operators are
asked to ensure that AOC,
00:38:41.190 --> 00:38:43.190
which is that abnormal
operating conditions,
00:38:43.190 --> 00:38:45.420
are noted on their evaluations
00:38:45.420 --> 00:38:46.930
along with the appropriate responses
00:38:46.930 --> 00:38:49.740
to ensure that the
responses are correct,
00:38:49.740 --> 00:38:51.250
basically, you need to make sure that
00:38:51.250 --> 00:38:53.550
someone who is qualified
can perform the covered tasks
00:38:53.550 --> 00:38:55.317
and recognize and react to an AOC.
00:38:56.410 --> 00:39:00.410
The evaluation methods
listed in code are several,
00:39:00.410 --> 00:39:02.390
and you can use written evaluation,
00:39:02.390 --> 00:39:05.160
oral evaluation, Work
Performance History Review,
00:39:05.160 --> 00:39:08.010
observation during
performance on the job,
00:39:08.010 --> 00:39:09.610
on-the-job training or simulations
00:39:09.610 --> 00:39:11.110
or another form of assessment.
00:39:15.462 --> 00:39:16.643
192.805 and 195.505,
00:39:19.400 --> 00:39:22.080
this is where you get the
bulk of your OQ program from.
00:39:22.080 --> 00:39:24.560
You need to identify covered tasks,
00:39:24.560 --> 00:39:27.570
ensure through evaluation
that individuals are qualified
00:39:27.570 --> 00:39:29.230
to perform covered tasks,
00:39:29.230 --> 00:39:32.010
that you have procedures
for directing and observing
00:39:32.010 --> 00:39:36.250
non-qualified individuals
under a span of control.
00:39:36.250 --> 00:39:38.610
This is only if you allow
non-qualified individuals
00:39:38.610 --> 00:39:40.921
to perform covered tasks
on your pipeline facility.
00:39:40.921 --> 00:39:44.560
If you're requiring
only covered individuals
00:39:44.560 --> 00:39:46.060
to perform covered tasking,
00:39:46.060 --> 00:39:48.070
I wouldn't say you need to
worry about direct and observe,
00:39:48.070 --> 00:39:50.280
but it's always helpful to
have that procedure in there
00:39:50.280 --> 00:39:52.850
in case you have a new trainee coming on
00:39:52.850 --> 00:39:55.330
who would do the tasks, you
need to make sure that you have
00:39:55.330 --> 00:39:57.030
your span of control setup
00:39:57.030 --> 00:39:59.840
which is the number
of how many individuals
00:39:59.840 --> 00:40:04.840
a person who is qualified can
observe performing said tasks.
00:40:06.330 --> 00:40:09.160
You need to be able to evaluate
an individual's performance
00:40:09.160 --> 00:40:10.683
contributed to an incident.
00:40:12.420 --> 00:40:15.930
One thing we're seeing is
that some operators are using
00:40:15.930 --> 00:40:19.030
suspension and
disqualification interchangeably.
00:40:19.030 --> 00:40:21.060
We would highly recommend that you
00:40:21.060 --> 00:40:23.670
figure out what those
terms are for your plan
00:40:23.670 --> 00:40:25.430
and use them where they belong,
00:40:25.430 --> 00:40:27.800
such as, do you suspend someone
00:40:27.800 --> 00:40:29.350
when there's an accident occurred
00:40:29.350 --> 00:40:30.830
and they were performing covered task
00:40:30.830 --> 00:40:34.460
until you have time
to do the investigation
00:40:34.460 --> 00:40:35.570
to determine whether or not
00:40:35.570 --> 00:40:39.440
they contributed or
caused that incident?
00:40:39.440 --> 00:40:42.150
Disqualification would
be after you've determined,
00:40:42.150 --> 00:40:44.800
yes, they've been, you
know, they contributed to that.
00:40:44.800 --> 00:40:46.740
Then you would be
able to go back and say,
00:40:46.740 --> 00:40:48.720
you need to go back
through your training.
00:40:48.720 --> 00:40:50.710
You need to be able to evaluate if
00:40:50.710 --> 00:40:52.550
individuals are no longer qualified
00:40:52.550 --> 00:40:53.520
to perform covered tasks.
00:40:53.520 --> 00:40:56.910
This could be from observing
them perform the covered task,
00:40:56.910 --> 00:41:01.910
maybe they've had a long
absence from that covered task,
00:41:01.940 --> 00:41:05.160
whether that's through sickness, injury,
00:41:05.160 --> 00:41:07.130
just it's not something
that they've done
00:41:07.130 --> 00:41:08.300
in a couple of years,
00:41:08.300 --> 00:41:10.370
maybe they need to be re-evaluated.
00:41:10.370 --> 00:41:12.070
So you would wanna
have procedures in place
00:41:12.070 --> 00:41:13.403
to look into that.
00:41:14.536 --> 00:41:16.180
You need to be able to
communicate changes
00:41:16.180 --> 00:41:17.013
to your individuals,
00:41:17.013 --> 00:41:21.270
is that through meetings,
emails, telephone calls,
00:41:21.270 --> 00:41:22.490
updates to your, you know,
00:41:22.490 --> 00:41:26.450
publishing updates of your
manual to all of your employees.
00:41:26.450 --> 00:41:28.950
Ensuring that individuals
have the necessary
00:41:28.950 --> 00:41:29.783
knowledge and skills.
00:41:29.783 --> 00:41:31.610
So, when they're qualified,
00:41:31.610 --> 00:41:33.210
it's important that they don't just have
00:41:33.210 --> 00:41:34.560
a theoretical knowledge,
00:41:34.560 --> 00:41:37.323
they have the ability
to actually do the tasks.
00:41:38.180 --> 00:41:40.110
We've seen cases where some operators,
00:41:40.110 --> 00:41:41.360
they don't have a way
00:41:41.360 --> 00:41:46.210
that either they weren't
doing any CBT's or test,
00:41:46.210 --> 00:41:49.420
there was no way for them to indicate
00:41:49.420 --> 00:41:52.020
whether that an individual
had the knowledge
00:41:53.530 --> 00:41:56.097
or skill sometimes to
perform a covered tasked.
00:41:57.180 --> 00:41:58.730
And you need to have procedures
00:41:58.730 --> 00:42:00.500
to update PHMSA and
the Railroad Commission
00:42:00.500 --> 00:42:03.173
of significant changes to your program.
00:42:07.026 --> 00:42:09.410
Important to note
that during evaluations,
00:42:09.410 --> 00:42:11.550
we are gonna be looking
to make sure that you,
00:42:11.550 --> 00:42:13.790
you as an operator are
not using observation
00:42:13.790 --> 00:42:18.140
of on-the-job performance
as a sole method of evaluation.
00:42:18.140 --> 00:42:20.730
And same with Work
Performance History Review,
00:42:20.730 --> 00:42:23.160
neither of these can be
used as a sole method.
00:42:23.160 --> 00:42:24.790
And this was back in 2002
00:42:24.790 --> 00:42:26.270
for Work Performance History Review
00:42:26.270 --> 00:42:28.900
and on-the-job performance in 2004.
00:42:28.900 --> 00:42:32.060
So by now, these should
not be used as sole methods,
00:42:32.060 --> 00:42:33.410
you can combine them with others,
00:42:33.410 --> 00:42:37.283
whether that's a written
test, oral tests or the like.
00:42:39.750 --> 00:42:43.933
Records, records are covered
by 192.807 and 195.507.
00:42:46.120 --> 00:42:48.540
These records need to
be for your employees
00:42:48.540 --> 00:42:50.030
and for your contractors.
00:42:50.030 --> 00:42:53.190
Please have a method of
obtaining contract records
00:42:53.190 --> 00:42:57.630
before we get to the
inspection, having them available.
00:42:57.630 --> 00:42:59.580
You need to make sure for both employees
00:42:59.580 --> 00:43:02.140
and contractors that are qualified,
00:43:02.140 --> 00:43:03.380
that you have an identification
00:43:03.380 --> 00:43:05.200
of who the individual is in the record,
00:43:05.200 --> 00:43:06.950
the identification of the covered tasks
00:43:06.950 --> 00:43:08.420
that the individual can perform,
00:43:08.420 --> 00:43:10.330
the dates of the current qualifications
00:43:10.330 --> 00:43:12.853
and the method used
to qualify the individual.
00:43:14.090 --> 00:43:16.070
We are seeing cases where
some of this information
00:43:16.070 --> 00:43:17.460
is being left out.
00:43:17.460 --> 00:43:19.370
It's important that for the
records to be complete,
00:43:19.370 --> 00:43:20.920
that you have those four things.
00:43:20.920 --> 00:43:23.590
Ensure that for both
employees and contractors,
00:43:23.590 --> 00:43:26.590
that you are keeping
records for five years
00:43:26.590 --> 00:43:28.613
after the last time that task,
00:43:30.330 --> 00:43:32.590
last time that person
was qualified for the task,
00:43:32.590 --> 00:43:36.040
whether that be they've
gotten re-qualified on a task.
00:43:36.040 --> 00:43:38.340
So you will need to hold
the old record for five years,
00:43:38.340 --> 00:43:39.980
or maybe they've retired
00:43:39.980 --> 00:43:42.300
or have left the company
for some other reason,
00:43:42.300 --> 00:43:44.940
or just maybe they
were promoted to a task
00:43:44.940 --> 00:43:47.863
that no longer requires them
to perform covered tasks.
00:43:49.617 --> 00:43:51.240
You need to keep those
records for five years
00:43:51.240 --> 00:43:53.973
from the date they're no
longer performing those tasks.
00:43:58.290 --> 00:44:00.350
For the program review,
00:44:00.350 --> 00:44:03.540
you can send them to
safety@rrc.Texas.gov.
00:44:03.540 --> 00:44:05.510
This is anytime you
make a significant change,
00:44:05.510 --> 00:44:07.460
or if you just wanna send it in,
00:44:07.460 --> 00:44:09.940
when you develop a new plan.
00:44:09.940 --> 00:44:11.150
I know sometimes we have operators
00:44:11.150 --> 00:44:12.710
who develop new plans periodically,
00:44:12.710 --> 00:44:14.287
they just decide, you know what?
00:44:14.287 --> 00:44:15.800
we're gonna scrap
this and just start over.
00:44:15.800 --> 00:44:17.443
Send that in to safety@rrc.Texas.gov
00:44:17.443 --> 00:44:19.107
so that we can review it.
00:44:19.107 --> 00:44:20.930
And this will not
count as an inspection,
00:44:20.930 --> 00:44:24.363
but is something that we
do require that operators do.
00:44:25.530 --> 00:44:29.530
Also, please note that OQ and
O&M manuals go hand in hand.
00:44:29.530 --> 00:44:33.000
So it is very important to
make sure that your tasks
00:44:33.000 --> 00:44:35.050
that you have for in your O&M manual,
00:44:35.050 --> 00:44:36.340
cause they're operation
and maintenance tasks
00:44:36.340 --> 00:44:38.250
which is part of the four-part task,
00:44:38.250 --> 00:44:40.133
that you have OQs for those tasks.
00:44:43.360 --> 00:44:45.210
Commonly cited
violations that we're seeing,
00:44:45.210 --> 00:44:46.440
wanna make you guys aware of,
00:44:46.440 --> 00:44:49.150
you have a chance to
look through your program,
00:44:49.150 --> 00:44:52.150
determine if you have some
of these issues and fix them,
00:44:52.150 --> 00:44:54.330
is that operators are failing to notify
00:44:54.330 --> 00:44:56.970
the Commission of significant changes.
00:44:56.970 --> 00:44:59.810
So, a significant change is
determined by you, the operator,
00:44:59.810 --> 00:45:02.110
it should be written in your procedures.
00:45:02.110 --> 00:45:04.830
When you meet that significant change
00:45:04.830 --> 00:45:06.600
based on something
you've done to your manual,
00:45:06.600 --> 00:45:08.950
you need to go ahead and
send it into the Commission
00:45:08.950 --> 00:45:10.280
and let us know.
00:45:10.280 --> 00:45:12.130
It is helpful if you tell us,
00:45:12.130 --> 00:45:14.210
maybe with the manual,
when you send it in,
00:45:14.210 --> 00:45:16.080
what it is that the
significant changes are,
00:45:16.080 --> 00:45:18.823
and it really helps us in
reviewing your manual.
00:45:20.810 --> 00:45:22.610
We're also seeing that
the operators are using
00:45:22.610 --> 00:45:24.940
Work Performance History Review
00:45:24.940 --> 00:45:27.220
as a sole method of evaluation.
00:45:27.220 --> 00:45:30.210
Just remember that
that is no longer allowed,
00:45:30.210 --> 00:45:33.503
but it can be used in
conjunction with another task.
00:45:34.780 --> 00:45:36.210
We're seeing that the operators
00:45:36.210 --> 00:45:40.890
are not following procedures
as outlined in their OQ plan,
00:45:40.890 --> 00:45:44.700
meaning either as
something like they're not,
00:45:44.700 --> 00:45:48.260
they may have an annual
review written into their plan
00:45:48.260 --> 00:45:49.250
and they're not doing it.
00:45:49.250 --> 00:45:50.630
So if you have something
when written in your plan,
00:45:50.630 --> 00:45:51.463
we follow it.
00:45:51.463 --> 00:45:53.820
But also, your individuals
that are qualified,
00:45:53.820 --> 00:45:58.190
make sure that they are
able to do the task steps
00:45:58.190 --> 00:45:59.813
as outlined per your OQ plan.
00:46:00.690 --> 00:46:01.523
Excuse me.
00:46:02.580 --> 00:46:05.134
We're also seeing operators
not have procedures
00:46:05.134 --> 00:46:08.740
and/or records for contractors
performing covered tasks.
00:46:08.740 --> 00:46:10.890
The operator is ultimately responsible
00:46:10.890 --> 00:46:12.950
for all work done by a contractor
00:46:12.950 --> 00:46:17.150
and is responsible for
having their OQ records
00:46:17.150 --> 00:46:20.590
and procedures to allow
those individuals to work,
00:46:20.590 --> 00:46:23.710
whether that is how you're going to
00:46:23.710 --> 00:46:24.770
bring them into your plan,
00:46:24.770 --> 00:46:26.060
are you gonna train them on your plan?
00:46:26.060 --> 00:46:28.940
Do they have their own plan?
Have you reviewed that plan?
00:46:28.940 --> 00:46:30.560
These kinds of things
need to be considered
00:46:30.560 --> 00:46:33.460
in your procedures when
developing contract for personnel.
00:46:36.290 --> 00:46:38.880
In summary, we've covered
today, covered tasks,
00:46:38.880 --> 00:46:42.143
OQ evaluations, record
maintenance, and program review.
00:46:42.980 --> 00:46:45.740
Just remember that the covered task
00:46:45.740 --> 00:46:48.400
is something that
meets the four-part tasks.
00:46:48.400 --> 00:46:52.357
That operators should
develop a tasks list
00:46:53.950 --> 00:46:57.810
for their company and for the
tasks that they are performing
00:46:57.810 --> 00:46:59.337
with the span of control.
00:46:59.337 --> 00:47:01.460
And the years of the evaluation is good
00:47:01.460 --> 00:47:05.310
for whether that's one,
two, three, four, five,
00:47:05.310 --> 00:47:08.680
and it should be able to justify
00:47:08.680 --> 00:47:12.900
what the reasoning for
those evaluation intervals
00:47:12.900 --> 00:47:14.410
based on difficulty
00:47:14.410 --> 00:47:18.523
or how often is
performed and other items.
00:47:20.640 --> 00:47:22.170
I thank you so much for your time.
00:47:22.170 --> 00:47:24.090
My contact information
is provided on the screen.
00:47:24.090 --> 00:47:25.240
Again, my name is Derek Lawrence,
00:47:25.240 --> 00:47:27.280
I am the OQ lead for the state of Texas.
00:47:27.280 --> 00:47:30.640
My number is 512-971-3067,
00:47:30.640 --> 00:47:35.180
and you can reach at
derek.lawrence@rrc.Texas.gov.
00:47:35.180 --> 00:47:36.013
Thank you.
00:47:38.070 --> 00:47:39.393
Thank you, Derek.
00:47:40.940 --> 00:47:42.730
Up next, for talking about
00:47:42.730 --> 00:47:44.640
both gas and liquid
integrity managements,
00:47:44.640 --> 00:47:46.243
we have Miss Jennifer Delacruz.
00:47:47.640 --> 00:47:48.473
Good morning, everyone.
00:47:48.473 --> 00:47:49.860
My name is Jennifer Delacruz.
00:47:49.860 --> 00:47:53.170
I'm the lead for liquid integrity,
00:47:53.170 --> 00:47:56.570
and Evon Boothe is
actually the lead for gas.
00:47:56.570 --> 00:47:59.840
So just starting with
the applicability for gas,
00:47:59.840 --> 00:48:01.750
this is gonna be any
gas transmission pipeline
00:48:01.750 --> 00:48:03.770
that could affect an HCA.
00:48:03.770 --> 00:48:07.100
And for liquids, it's
each hazardous liquid
00:48:07.100 --> 00:48:09.750
and carbon dioxide pipeline
that could affect an HCA.
00:48:13.470 --> 00:48:15.500
And then, for the state regulations,
00:48:15.500 --> 00:48:17.870
this is gonna cover basically all other
00:48:17.870 --> 00:48:21.490
intrastate transmission
pipelines not affecting HCAs,
00:48:21.490 --> 00:48:23.483
and this includes gas and liquids.
00:48:25.820 --> 00:48:28.730
Okay, so some common
issues that we see in integrity,
00:48:28.730 --> 00:48:31.930
the main one's gonna be
documentation or integrity.
00:48:31.930 --> 00:48:34.050
All decisions need to be,
00:48:34.050 --> 00:48:35.800
really everything you
do related to integrity
00:48:35.800 --> 00:48:37.300
needs to be documented,
00:48:37.300 --> 00:48:40.400
and this will include
decisions to not take an action.
00:48:40.400 --> 00:48:42.090
So just as an example,
00:48:42.090 --> 00:48:44.080
you conduct an EFRD analysis,
00:48:44.080 --> 00:48:45.680
and you conclude that you don't need
00:48:45.680 --> 00:48:48.000
to install any additional ones.
00:48:48.000 --> 00:48:50.293
That's totally fine, just document that,
00:48:51.170 --> 00:48:52.823
and the justification behind it.
00:48:54.400 --> 00:48:57.310
An HCA determination needs
to be done by all operators.
00:48:57.310 --> 00:48:59.967
So even if you don't have any HCA,
00:48:59.967 --> 00:49:02.350
so you still need to complete this part
00:49:02.350 --> 00:49:05.253
of the integrity requirement,
00:49:06.530 --> 00:49:08.193
and document that as well.
00:49:09.330 --> 00:49:10.960
Please keep in mind that
when you're responding
00:49:10.960 --> 00:49:13.270
to any alleged violations,
00:49:13.270 --> 00:49:15.750
keep them very concise and specific
00:49:15.750 --> 00:49:18.930
to what the violation
was in reference to,
00:49:18.930 --> 00:49:23.543
and that way we can tell
how you're correcting it.
00:49:27.050 --> 00:49:29.400
Okay, so to touch a little bit on
00:49:29.400 --> 00:49:31.620
Texas integrity management rules
00:49:31.620 --> 00:49:34.210
and some of the terms used.
00:49:34.210 --> 00:49:38.390
They don't always line up
with the federal regulations,
00:49:38.390 --> 00:49:41.270
so just risk-based and prescriptive.
00:49:41.270 --> 00:49:45.880
For Texas rules, you have to
select whether you're gonna be
00:49:45.880 --> 00:49:48.270
risk-based or prescriptive per segment,
00:49:48.270 --> 00:49:49.490
that can change so you can have
00:49:49.490 --> 00:49:51.470
some risk-based, some prescriptive.
00:49:51.470 --> 00:49:53.320
When we're talking about risk-based,
00:49:53.320 --> 00:49:55.510
we mean based on a risk model.
00:49:55.510 --> 00:49:59.020
And then for prescriptive,
it's a set interval
00:49:59.020 --> 00:50:01.453
based on figures 1
and 2 and TAC 8.101B2,
00:50:02.620 --> 00:50:06.550
and that's gonna be
based on diameters, class,
00:50:06.550 --> 00:50:08.833
products and some
other parameters as well.
00:50:09.740 --> 00:50:11.140
Please keep in mind direct assessment
00:50:11.140 --> 00:50:12.730
is only allowed for risk-based programs.
00:50:12.730 --> 00:50:14.270
So if you choose to be prescriptive,
00:50:14.270 --> 00:50:17.313
you cannot use ECDA as an
integrity assessment method.
00:50:20.020 --> 00:50:21.590
Okay, so for the federal rules,
00:50:21.590 --> 00:50:24.083
again, this is only
for could affect HCAs.
00:50:25.188 --> 00:50:27.540
And then again, with
the terms here for gas,
00:50:27.540 --> 00:50:30.560
a prescriptive is really
a simple risk plan.
00:50:30.560 --> 00:50:32.680
And then you've got performance,
00:50:32.680 --> 00:50:37.420
which is a robust risk plan
based on 21 thread categories.
00:50:37.420 --> 00:50:38.360
And just FYI,
00:50:38.360 --> 00:50:43.360
I've never seen an operator
use the performance method.
00:50:43.460 --> 00:50:46.010
For liquid, it's gonna be a risk model.
00:50:46.010 --> 00:50:48.470
And again, if it's an non-HCA pipeline,
00:50:48.470 --> 00:50:50.343
you'll follow Texas rules.
00:50:54.470 --> 00:50:57.480
Okay, so for gathering
under the gas rule,
00:50:57.480 --> 00:50:59.490
they are exempt from integrity,
00:50:59.490 --> 00:51:01.413
but do expect an inspection.
00:51:03.150 --> 00:51:04.920
Just that we might conduct one
00:51:04.920 --> 00:51:08.690
just to verify that the
determination was made properly
00:51:08.690 --> 00:51:11.980
and the documentation of how
you came to that conclusion.
00:51:11.980 --> 00:51:14.620
And then for liquids,
really the only exemption
00:51:14.620 --> 00:51:17.843
is for Category 3 low
stress pipeline in a rural area.
00:51:22.280 --> 00:51:25.170
There was a new liquid rule
00:51:25.170 --> 00:51:28.342
that became effective July 1st, 2020,
00:51:28.342 --> 00:51:29.410
and this is for assessments
00:51:29.410 --> 00:51:32.150
for certain underwater
facilities in HCAs.
00:51:32.150 --> 00:51:34.630
There's a whole paragraph there in 454
00:51:35.550 --> 00:51:38.830
that describes the
whole applicability there,
00:51:38.830 --> 00:51:43.400
but really, it's facilities that
are greater than 150 feet,
00:51:43.400 --> 00:51:44.760
under the surface of the water,
00:51:44.760 --> 00:51:48.160
and you'll need to do
an ILI every 12 months,
00:51:48.160 --> 00:51:51.490
and any other pipeline
integrity assessment
00:51:51.490 --> 00:51:53.170
completed on a schedule based on risks.
00:51:53.170 --> 00:51:55.070
So you would have to do both of these.
00:51:57.900 --> 00:52:01.190
And here's mine and
Evon's contact information,
00:52:01.190 --> 00:52:03.730
please feel free to reach
out with any questions.
00:52:03.730 --> 00:52:04.563
Thank you.
00:52:08.062 --> 00:52:09.733
All right.
Thank you, Jennifer.
00:52:10.600 --> 00:52:13.600
Up next, for distribution
integrity management,
00:52:13.600 --> 00:52:14.980
since we consider those to be separate,
00:52:14.980 --> 00:52:16.053
Mr. Isaac Monrreal.
00:52:17.710 --> 00:52:18.610
Thank you, Michael.
00:52:18.610 --> 00:52:19.617
My name is Isaac Monrreal,
00:52:19.617 --> 00:52:23.033
I'm the lead for the distribution
integrity management,
00:52:24.880 --> 00:52:26.780
what we most affectionately call DIMP.
00:52:27.660 --> 00:52:30.430
Just kind of briefly
go through a lot of this,
00:52:30.430 --> 00:52:32.490
we do have a new DIMP form
00:52:32.490 --> 00:52:34.990
that we are updating periodically.
00:52:34.990 --> 00:52:39.800
So, whenever you get a phone call to,
00:52:39.800 --> 00:52:42.670
for an inspector to come
out and conduct an inspection,
00:52:42.670 --> 00:52:45.543
please ask them for the new DIMP forms.
00:52:46.410 --> 00:52:49.380
That is a combination of
both state and federal codes,
00:52:49.380 --> 00:52:54.020
including the TAC 8.209.
00:52:54.020 --> 00:52:55.280
So when you do get that phone call,
00:52:55.280 --> 00:52:57.610
please be aware that
please come prepared
00:52:57.610 --> 00:53:02.610
for all additional records
and operating personnel,
00:53:02.640 --> 00:53:06.380
and most specifically, other
manuals that you may have.
00:53:06.380 --> 00:53:10.587
Sometimes what we see is
that you'll have your procedures
00:53:10.587 --> 00:53:12.980
in other manuals,
00:53:12.980 --> 00:53:14.760
such as your operation
and maintenance manual
00:53:14.760 --> 00:53:18.770
for your leak complaints,
leak management programs.
00:53:18.770 --> 00:53:20.760
So, just please come prepared with that,
00:53:20.760 --> 00:53:22.170
it kind of goes a long way
00:53:23.200 --> 00:53:25.840
for whenever we're
conducting an inspection.
00:53:25.840 --> 00:53:27.750
One thing that I
always like to highlight
00:53:27.750 --> 00:53:30.300
and talking about baseline
00:53:30.300 --> 00:53:31.420
and the difference between
00:53:31.420 --> 00:53:34.330
transmission and distribution
integrity management.
00:53:34.330 --> 00:53:35.920
Specifically for distribution,
00:53:35.920 --> 00:53:38.740
we're really talking about
baseline for performance measures
00:53:38.740 --> 00:53:40.140
and that's generalistically,
00:53:41.299 --> 00:53:44.650
basically, a year or a series of years
00:53:44.650 --> 00:53:46.453
that then an operator establishes
00:53:46.453 --> 00:53:49.480
for each mandatory performance measure
00:53:49.480 --> 00:53:52.650
under 192.1007 Part E.
00:53:52.650 --> 00:53:54.190
And then for those of y'all
00:53:54.190 --> 00:53:56.930
who are using the SHRIMP program,
00:53:56.930 --> 00:53:58.410
which is a Simple Handy Risk-based
00:53:58.410 --> 00:54:02.630
Integrity Management Program
that PHMSA gave a grant for.
00:54:02.630 --> 00:54:04.610
The SHRIMP program does
not do the baseline for you,
00:54:04.610 --> 00:54:05.810
it gives you a little bit of guidance,
00:54:05.810 --> 00:54:09.350
but it's that extra step
that you have to do
00:54:09.350 --> 00:54:12.010
in order to meet
compliance with the code.
00:54:12.010 --> 00:54:15.180
So, some of the common issues
that we've been running into
00:54:15.180 --> 00:54:18.670
is again, kind of we're
talking about for baseline
00:54:18.670 --> 00:54:21.820
is that you're not doing
all of the five mandatory,
00:54:21.820 --> 00:54:24.210
the performance measures,
that you're not documenting them,
00:54:24.210 --> 00:54:26.190
or you're not establishing them.
00:54:26.190 --> 00:54:29.150
Some other issues that
we've run into quite frequently
00:54:29.150 --> 00:54:31.240
is for your periodic reviews,
00:54:31.240 --> 00:54:34.690
that they're either not
done within the timeframe,
00:54:34.690 --> 00:54:36.440
under the slot which is five years.
00:54:37.520 --> 00:54:39.480
Or you're just not documenting that,
00:54:39.480 --> 00:54:41.580
what specifically did
you actually review?
00:54:42.770 --> 00:54:46.950
And then in general, just a
general lack of documentation.
00:54:46.950 --> 00:54:49.700
That's kind of like, kind of
been like a recurring issue
00:54:49.700 --> 00:54:52.310
that we've kind of seen
over and over and over again,
00:54:52.310 --> 00:54:54.230
not just with your DIMP program,
00:54:54.230 --> 00:54:59.230
but also as it applies to
state code for the 8.209.
00:55:00.100 --> 00:55:04.080
So I just kinda want to
emphasize just a little bit,
00:55:04.080 --> 00:55:05.690
you can go to the next slide please.
00:55:05.690 --> 00:55:07.880
And please, please, please
document as much as you can,
00:55:07.880 --> 00:55:10.480
the DIMP program was
intended to be a live document.
00:55:12.170 --> 00:55:14.860
We want you to be
documenting legitimately
00:55:14.860 --> 00:55:17.430
every step, every action, every year.
00:55:17.430 --> 00:55:19.580
So then, also when we
come and do an inspection,
00:55:19.580 --> 00:55:21.680
it just goes a lot smoother.
00:55:21.680 --> 00:55:24.690
So the last thing that I'll just
want to put up on the slide
00:55:24.690 --> 00:55:25.828
is my contact information.
00:55:25.828 --> 00:55:29.420
If you have any questions,
comments, or social observations,
00:55:29.420 --> 00:55:31.377
DIMP or GIMP related,
feel free to reach out
00:55:31.377 --> 00:55:33.043
and I'll be more than happy to help out.
00:55:33.890 --> 00:55:35.090
Thank you for your time.
00:55:37.269 --> 00:55:38.940
All right.
Thank you, Isaac.
00:55:38.940 --> 00:55:39.773
All right.
00:55:41.600 --> 00:55:43.650
Up next, for
incidents and accidents,
00:55:43.650 --> 00:55:45.600
we have Mr. Godspower Oniovosa.
00:55:45.600 --> 00:55:47.910
So whenever you're ready, sir.
00:55:47.910 --> 00:55:49.040
Thank you, Michael.
00:55:49.040 --> 00:55:50.110
My name is Godspower Oniovosa,
00:55:50.110 --> 00:55:52.560
I'm the Accident/Incident
investigation lead
00:55:52.560 --> 00:55:53.970
for the state of Texas.
00:55:53.970 --> 00:55:56.210
As we all know, accident
and incident brings safety,
00:55:56.210 --> 00:55:59.260
kind of a shield into our
body when we have them.
00:55:59.260 --> 00:56:02.551
But with the operations
with your pipeline operators,
00:56:02.551 --> 00:56:03.850
there are safety requirements
00:56:03.850 --> 00:56:06.240
that whenever operator
has accident or an incident
00:56:06.240 --> 00:56:08.270
on their pipelines,
00:56:08.270 --> 00:56:10.657
they must report to the
Railroad Commission
00:56:10.657 --> 00:56:11.510
or the federal Commission.
00:56:11.510 --> 00:56:14.890
And there are safety
requirements that are required,
00:56:14.890 --> 00:56:17.129
whenever there's an accident or incident
00:56:17.129 --> 00:56:18.155
happens on the pipelines.
00:56:18.155 --> 00:56:21.470
So for federal regulation
that when an event
00:56:21.470 --> 00:56:25.095
involves the release
of a gas on a pipeline
00:56:25.095 --> 00:56:26.000
or from a another gas facility
00:56:27.620 --> 00:56:30.100
of petroleum gas or refrigerant gas,
00:56:30.100 --> 00:56:32.977
pipeline operators
are required to report
00:56:32.977 --> 00:56:36.970
under the federal regulation of 191.3,
00:56:36.970 --> 00:56:40.443
if that results into an event
of a death or personal injury
00:56:40.443 --> 00:56:44.837
or installation on an estimated
property damage of $122,000.
00:56:46.400 --> 00:56:49.510
Or if it involves only
tensional release of the gas
00:56:49.510 --> 00:56:52.800
that is above of 3
million cubic or more,
00:56:52.800 --> 00:56:54.610
operators are required to report.
00:56:54.610 --> 00:56:57.470
And also likewise,
if this event involves
00:56:57.470 --> 00:57:01.520
liquid or carbon dioxide
or hazardous liquid
00:57:01.520 --> 00:57:04.330
from any of the pipelines,
also (indistinct) storage,
00:57:05.466 --> 00:57:07.820
or involves the release of liquids,
00:57:07.820 --> 00:57:12.820
under the federal regulation
of 195.5 and 195.52,
00:57:13.530 --> 00:57:17.600
pipeline operators must
also report that accident
00:57:18.440 --> 00:57:21.990
to the federal, PHMSA, or to
the Texas Railroad Commission.
00:57:21.990 --> 00:57:26.060
And if the events that
involves the release of a liquid,
00:57:26.060 --> 00:57:29.913
if it involves the
release of five gallons or,
00:57:32.664 --> 00:57:33.990
less the five barrels
00:57:33.990 --> 00:57:36.990
or involves death of a
person or personal injury
00:57:36.990 --> 00:57:40.097
necessitating hospitalization,
00:57:40.097 --> 00:57:42.890
are also estimated property damage,
00:57:42.890 --> 00:57:44.520
involving cost of clean up
00:57:44.520 --> 00:57:47.120
and recovery of value of the product
00:57:47.120 --> 00:57:49.760
that is up to exceeding $50,000,
00:57:49.760 --> 00:57:53.980
they're also required
to report that incident.
00:57:53.980 --> 00:57:56.810
Also on gathering lines, gas and liquid,
00:57:56.810 --> 00:57:58.210
this is to be regulated by
00:57:58.210 --> 00:58:00.610
the Texas Administrative
Code (indistinct)
00:58:00.610 --> 00:58:02.610
under the regulated gathering lines.
00:58:02.610 --> 00:58:05.200
Whenever those releases are, you know,
00:58:05.200 --> 00:58:08.920
released from the gathering
lines, either gas or liquid,
00:58:08.920 --> 00:58:13.490
the safety requirements by
Texas Administrative Code 8.11,
00:58:13.490 --> 00:58:16.113
you're required to
report those incidents.
00:58:19.701 --> 00:58:20.760
I wanna make some changes,
00:58:20.760 --> 00:58:23.030
there are some little
changes that came up recently.
00:58:23.030 --> 00:58:25.537
On March 12th, I think this year, 2021,
00:58:25.537 --> 00:58:29.160
there was a change on
one of the consequences
00:58:29.160 --> 00:58:31.280
under the regulation 191.3.
00:58:32.749 --> 00:58:35.620
Actually before, it was when
the estimated property damage
00:58:35.620 --> 00:58:37.937
was like exceeding $50,000,
00:58:37.937 --> 00:58:40.793
but now, there are this
changes, start operating in March,
00:58:40.793 --> 00:58:42.190
that whenever it exceeds,
00:58:42.190 --> 00:58:45.880
estimated property damage is $122,000.
00:58:45.880 --> 00:58:49.200
And this was as a result of
adjustments before inflation,
00:58:49.200 --> 00:58:50.260
which was made to determine,
00:58:50.260 --> 00:58:55.240
and that determination is
made in appendix A in Part 191.
00:58:55.240 --> 00:58:58.000
And I also want to also remind us,
00:58:58.000 --> 00:59:00.960
for liquid, there was no changes.
00:59:00.960 --> 00:59:05.340
The estimated property
damage is still exceeding $50,000,
00:59:05.340 --> 00:59:10.010
but the difference is that it
is inclusive of your products.
00:59:10.010 --> 00:59:12.500
Then also, another reminder is that,
00:59:12.500 --> 00:59:15.297
operators have to have in their O&M,
00:59:15.297 --> 00:59:18.790
accident and incident
investigation procedure.
00:59:18.790 --> 00:59:21.410
This is for you to analyze the accident
00:59:21.410 --> 00:59:23.160
and also to determine the cause
00:59:23.160 --> 00:59:25.224
and to mitigate and minimize
00:59:25.224 --> 00:59:26.577
the possibility of the recurrence.
00:59:26.577 --> 00:59:29.180
And this are requirement
per the federal code
00:59:29.180 --> 00:59:32.550
of 192.617 and for gas,
00:59:32.550 --> 00:59:37.550
and 195.402 A5-6 for liquid.
00:59:40.170 --> 00:59:42.390
And for Class 1 and rural gathering
00:59:42.390 --> 00:59:43.570
which I had mentioned earlier,
00:59:43.570 --> 00:59:46.210
that this is being regulated
00:59:46.210 --> 00:59:48.820
by Texas Administrative Code of 8.11.
00:59:48.820 --> 00:59:51.492
The reporting criteria
we can find is about,
00:59:51.492 --> 00:59:52.343
for gas is 8.210A,
00:59:54.240 --> 00:59:56.050
and for liquid is 8.301A,
00:59:57.020 --> 00:59:59.110
which is stuff that you can find out
00:59:59.110 --> 01:00:02.002
on the release or
whenever there's a release
01:00:02.002 --> 01:00:03.311
from Class 1 or rural gathering
01:00:03.311 --> 01:00:06.280
and the consequences
that you must, as operator,
01:00:06.280 --> 01:00:08.440
must report to the Railroad Commission.
01:00:08.440 --> 01:00:10.413
And also about 8.110E,
01:00:11.354 --> 01:00:15.020
you're also required to perform
an investigation requirement
01:00:15.020 --> 01:00:18.010
to analyze the accident
to determine the cost
01:00:18.010 --> 01:00:20.393
and also to provide corrective action.
01:00:23.700 --> 01:00:25.950
So one of the (indistinct) expectations
01:00:25.950 --> 01:00:27.480
of the Railroad Commission is,
01:00:27.480 --> 01:00:29.510
one, whenever there's a release,
01:00:29.510 --> 01:00:31.910
whenever there's a
reportable incident or accident,
01:00:31.910 --> 01:00:33.390
you are required by a procedure
01:00:33.390 --> 01:00:36.000
to analyze the accident and incidents
01:00:36.000 --> 01:00:37.590
to the time and the cost.
01:00:37.590 --> 01:00:39.620
And not just only the time and the cost,
01:00:39.620 --> 01:00:42.730
and also the plan to
minimize reoccurence.
01:00:42.730 --> 01:00:44.290
These are also be determined
01:00:44.290 --> 01:00:45.900
that whenever with inspectors coming,
01:00:45.900 --> 01:00:48.070
when they're performing
the accident investigation,
01:00:48.070 --> 01:00:50.620
you should be able to show
documentation that this process,
01:00:50.620 --> 01:00:52.280
or these procedures are followed.
01:00:52.280 --> 01:00:53.860
And also, you also required to submit
01:00:53.860 --> 01:00:55.930
the 30-day report with applicable forms
01:00:55.930 --> 01:00:59.723
to the safety at Railroad
Commission of Texas, .Texas.gov.
01:01:00.750 --> 01:01:02.050
I think if you will,
01:01:02.050 --> 01:01:04.100
for now if you have any information,
01:01:04.100 --> 01:01:06.060
as I told you, I'm the incident lead,
01:01:06.060 --> 01:01:07.815
and as (indistinct) all
my contact information
01:01:07.815 --> 01:01:09.770
is (indistinct), Godspower Oniovosa,
01:01:09.770 --> 01:01:11.550
and my email and my phone contact.
01:01:11.550 --> 01:01:13.600
You can feel free to
reach me, thank you.
01:01:14.510 --> 01:01:16.620
All right.
Thank you Godspower.
01:01:16.620 --> 01:01:20.470
And that was all of our
presenters that we had.
01:01:20.470 --> 01:01:21.440
Here on this slide,
01:01:21.440 --> 01:01:23.810
we go through and have
the Commissioners listed out
01:01:23.810 --> 01:01:26.890
and a physical mail address,
01:01:26.890 --> 01:01:28.620
you can go through
and reach out to them at,
01:01:28.620 --> 01:01:31.630
or any inquiries to anyone
else in the Railroad Commission
01:01:31.630 --> 01:01:33.390
that you go through and have.
01:01:33.390 --> 01:01:35.580
We do want to go
through and remind y'all
01:01:35.580 --> 01:01:37.010
that there is an evaluation
01:01:37.010 --> 01:01:39.490
that y'all can go through
and take and complete
01:01:39.490 --> 01:01:40.840
at the following website.
01:01:40.840 --> 01:01:42.840
Again, if you download
the copy of this presentation,
01:01:42.840 --> 01:01:45.360
you will have that link
and be able to access it,
01:01:45.360 --> 01:01:47.770
go through and fill it
out if you so choose to.
01:01:47.770 --> 01:01:49.470
And again, somewhere to the beginning,
01:01:49.470 --> 01:01:51.630
we're gonna be going
through an archive in this video,
01:01:51.630 --> 01:01:54.220
and you can find it at
the link that was provided,
01:01:54.220 --> 01:01:56.190
first, at the beginning
of the presentation,
01:01:56.190 --> 01:01:59.710
and second, should be a link
somewhere in the Q&A section
01:01:59.710 --> 01:02:00.980
to go through and list that out.
01:02:00.980 --> 01:02:03.420
So, thank you very much for
going through and attending
01:02:03.420 --> 01:02:05.733
and I hope you have a
wonderful rest of your day.