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192 vs. 195 Gap Analysis. July 14-15, 2009 Arlington, VA. 192 vs 195 – Why are we Here?. Regulations started at different times, developed separately There are differences & gaps Differences raise questions – usually ‘Why?’ Management needs to understand biggest differences/gaps and why.

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192 vs 195 gap analysis

192 vs. 195 Gap Analysis

July 14-15, 2009

Arlington, VA

192 vs 195 why are we here
192 vs 195 – Why are we Here?
  • Regulations started at different times, developed separately
  • There are differences & gaps
  • Differences raise questions – usually ‘Why?’
  • Management needs to understand biggest differences/gaps and why
example bp alaska spill
Example – BP Alaska Spill
  • March 2, 2006 – release on North Slope
  • Release of 4800 barrels affected 2 acres of tundra
  • Low pressure pipeline; not subject to regulation
  • At Congressional hearing – Why?
  • No good answer; subsequent rule change
192 vs 195 what management wants
192 vs 195 – What Management Wants
  • What are the major differences?
  • Why do they exist?
  • Are they still justified?
  • What differences should be eliminated?
  • What other “holes” exist in the regulations?
  • Which holes should be fixed?
  • Better answer for next Congressional question
192 vs 195 action plan
192 vs 195 – Action Plan
  • Three phase approach
  • Phase 1 – head-to-head comparison
    • Completed
    • Results presented in spreadsheet distributed to the team
    • Useful to focus/direct our work, but probably too complicated for outside use
  • Phase 2 – Why? Are the differences still appropriate?
  • Phase 3 – What should we fix and in what priority?
192 vs 195 phase 1 results
192 vs 195 – Phase 1 results
  • There are four worksheets
  • The “guts” are in the comparison worksheet
192 vs 195 phase 1 ground rules
192 vs 195 – Phase 1 “Ground Rules”
  • No judgments
    • Different is different
    • No “but this isn’t needed here”
  • Purely editorial differences ignored
    • Violates “no judgments” but …
  • Deals only with what is there
    • No treatment of “holes” (e.g., low-stress HL pipe in March 2006)
192 vs 195 phase 1 major gaps
192 vs 195 – Phase 1: Major Gaps
  • Class locations: gas yes (192.5, 609, 611), liquids no
  • Minimum setback: gas no, liquids yes (195.210)
  • Pressure relief design: gas yes (192.199), limited requirements for liquids (195.406(b))
  • Alternative MAOP: gas yes (192.112, 620), liquids no
  • Repair: gas yes for transmission only (192.711-717), liquids no
  • Component design requirements: gas yes (192.143), liquids no
192 vs 195 phase 1 major gaps9
192 vs 195 – Phase 1: Major Gaps
  • Station design requirements: gas yes (192.163), liquids no
  • Wrinkle bends: gas precluded (192.315), liquids not
  • Casings: gas yes (192.623), liquid no
  • Corrosion control for converted pipe: gas, yes if can (192.452), liquids more limited treatment (195.557(b), 563(b))
  • Remediating corrosion: gas yes (192.483), liquids no
192 vs 195 less major gaps
192 vs 195 – Less Major Gaps
  • Uprating: gas yes (192.553, 555, 557), liquids no
  • Protection from hazards: gas yes (192.317), liquids no
  • Pressure testing for low stress: gas yes (192.507 – 513) liquids no
  • Assist in investigation: liquid yes (195.60), gas no
  • Plastic pipe: no provisions for liquid (but non-steel requires approval of Administrator)