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In Wake of San Bruno, PHMSA Calls Oversight of IM Programs "Lacking"
The bulletin ominously warned: "However, some operators are not sufficiently aware of their pipeline attributes nor are they adequately or consistently assessing threats and risks as a part of their IM programs." Operator oversight of IM programs was deemed "lacking." The bulletin went on to list "deficiencies" PHMSA has found in its inspections and investigations.
"Inspections and investigations have revealed examples where assessment methods, specific tools and schedules were not based on a rigorous assessment of the type of threats posed by the pipeline segment, including consideration of the age, design, pipe material (including seam type), coating, welding technique, cathodic protection, soil type, surrounding environment, operational history or other relevant factors."
Richard B. Kuprewicz, president, Accufacts Inc., who is a member of the PHMSA technical advisory committee for liquid pipelines and who had a hand in fashioning the gas transmission IM program, says the advisory bulletin is "carefully and clearly worded in a matter that could be read as 'terse.' "
Boss takes issue with the implication in the advisory bulletin that there are systemic shortcomings in gas transmission compliance with aspects of the IM program. "If they are alluding to systemic problems with integrity management programs, those problems should be documented on their website," he responds.
In fact, the PHMSA website says nothing particular about integrity management violations. It does list civil penalties proposed in 2010, of which there were 34. Only three of those cases have been closed, with penalties paid amounting to less than $80,000 per case. Those cases had nothing to do with IM program violations, much less faulty risk assessments. Dixie Pipelines paid the biggest fine, $78,000, because it had not sent public awareness program brochures to homeowners whose properties were damaged in a previous accident. The biggest proposed fine was on Chevron Pipe Line Co. That case is still open.
PHMSA did site one integrity management violation, inadequate leak protection, among a number of other non-integrity problems in assessing a fine of $435,000. Moreover, across gas transmission, liquid, gas gathering and gas distribution lines in 2010, penalties proposed totaled $4.5 million. That is substantially less than the totals in 2008, the last year of the Bush administration, and 2009: $8.7 million and $6.4 million respectively.