During the last 20 years, operators of oil and gas pipelines in the United States have been slowly but steadily improving their safety record. The average frequency of what the U.S. Pipeline and Hazardous Materials Administration (PHMSA) terms “serious incidents,” and the number of associated fatalities, have both gradually declined. During the last three years, the nation’s 2.7 million miles of oil and gas pipelines have experienced a PHMSA-defined serious incident only once every 11 days, and fewer than 15 deaths annually, a remarkable safety record compared with railroads and highways for the volume of product pipelines move (Source: www.phmsa.dot.gov/pipeline/library/data-stats/pipelineincidenttrends and www.phmsa.dot.gov/pipeline/library/data-stats/pipelinemileagefacilities).
This is great news, with just one exception: When it comes to the engineers who help operate, maintain, and inspect the pipeline network, fewer and fewer of them now have had the life-changing experience of seeing, and responding to, a serious pipeline incident.
As with many engineering-related fields, a major generational turnover is occurring in the pipeline business. Every month, dozens more veteran pipeline engineers in the U.S. retire, taking with them critically important institutional knowledge. Some of the most important knowledge we are losing is these engineers’ first-hand memories of accidents that drove new safety regulations — and the personal insight and hard-earned credibility about why those regulations are so critical for a new generation of engineers to understand and follow.
One leading example that helps dramatize this trend occurred on a Thursday in June 2011 when a bland-sounding summary of a new PHMSA regulation appeared in the Federal Register. “This rule expedites the program implementation deadlines in the Control Room Management/Human Factors regulations,’’ the summary read, “in order to realize the safety benefits sooner than established in the original rule.’’
If you were new to the oil and gas pipeline industry, what you very well might not know was that this was the government’s response to one of the worst inland oil spills in U.S. history — the July 2010 rupture of a pipeline that released more than 20,000 barrels of diluted bitumen into the Kalamazoo River in Michigan. The accident triggered $180 million in fines, penalties, and settlements for the pipeline operator. Total cleanup costs exceeded $1 billion.
Most of the cited violations involved decisions in the pipeline operator control room, where alarms were sounding for 18 hours before an employee on the ground in Michigan confirmed diluted bitumen was leaking. National Transportation Safety Board investigators found control room operators believed the alarms were being caused by a possible bubble in the pipeline, so they decided to increase flow pressure for several hours inside the pipeline to clear a suspected blockage. That, of course, only worsened the spill, the environmental damage, and the ultimate fines and penalties.
PHMSA’s conclusion was that regulations about control room operator training and emergency planning — regulations that had been published in 2009 — needed to be accelerated sharply. PHMSA took the dramatic step of ordering the rule implemented 16 to 18 months sooner than first planned.
For pipeline operators looking to ensure their staff are fully informed and trained to comply with safety violations and avoid massive fines, it’s critical to know the “why” behind the “what” of new pipeline safety regulations. In this case, it would be one thing for pipeline safety personnel to read that PHMSA was requiring operators to “amend their existing written operations and maintenance procedures, operator qualification programs, and emergency plans.” When it was made clear that this was an extraordinarily accelerated emergency order from the government, coming in direct response to a billion-dollar pipeline disaster, the importance of understanding and complying with the regulation becomes far clearer and more compelling. The regulations are written mostly in performance language, which makes it critical for engineers to translate the meaning and importance of those regulations into engineering language.
When it comes to keeping our nation’s vital energy pipeline network safe, the blunt reality is, accidents lead to regulations. Accidents rarely have just one cause, but there’s usually a primary factor and then a set of secondary, aggravating factors that can turn a minor incident into a serious incident. There’s nothing like spending time at an accident site to strengthen your commitment to never having to visit another in your lifetime, and to turn you into an evangelist for safety.
These days, with — thankfully — fewer and fewer engineers having experienced serious incidents in person, it’s up to those of us left from a rapidly dwindling generation of pipeline engineers to serve as educators and to tell those stories. When we do, we can deepen the understanding of our newest colleagues of where regulations are coming from, bring to life how severe the consequences for failing to comply can be, and strengthen their resolve to follow these regulations for the good and safety of all.
Jeff Wiese is vice president and national practice leader for Pipeline Integrity services at TRC Companies (www.trcsolutions.com), a provider of engineering, environmental consulting, and construction-management services. Dewitt Burdeaux and Lane Miller are TRC Pipeline Integrity Services market directors. As a team, they have trained more than 2,700 state and federal pipeline safety inspectors and more than 1,000 private-sector pipeline managers and staff. For more information, visit http://events.trcsolutions.com/pipelinesafetytraining.