U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Briefing on Kiefner & Associates, Inc./Applus RTD (KAI) Leak Detection Study Liquid and Gas Pipeline Advisory Committees December 11 and 13, 2012 Max Kieba Engineer, PHMSA Pipeline Engineering and Research Division

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Outline Background/Drivers of the study –Congressional Mandate –NTSB Recommendation Other PHMSA initiatives –March Workshop –July R&D Forum Scope of KAI’s Study Summary of Comments Received on Draft Report and Changes by KAI Observations from KAI’s Study - 2 -

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration KAI Leak Study Team David Shaw – Lead Author LDS SME, 30+ years experience in oil & gas Pipeline engineering and automation systems Numerical simulation and modeling Martin Phillips - Project Manager 30+ years experience, including Fitness for Service and ILI Other co-authors/team members: –Ron Baker and Christine Mayernik (incident review) –Eduardo Munoz, Hamood Rehman, Carol Gibson - 3 -

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Congressional Mandate Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011, Section 8 Leak Detection (hazardous liquid pipeline facilities and transportation related flow lines) (A) an analysis of the technical limitations of current leak detection systems, including the ability of the systems to detect ruptures and small leaks that are ongoing or intermittent, and what can be done to foster development of better technologies; and (B) an analysis of the practicability of establishing technically, operationally, and economically feasible standards for the capability of such systems to detect leaks, and the safety benefits and adverse consequences of requiring operators to use leak detection systems

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration NTSB Recommendation NTSB Recommendation P Require that all operators of natural gas transmission and distribution pipelines equip their supervisory control and data acquisition systems with tools to assist in recognizing and pinpointing the location of leaks, including line breaks; such tools could include a real-time leak detection system and appropriately spaced flow and pressure transmitters along covered transmission lines

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration March Workshop March 27, 2012 PHMSA Workshop: Improving Pipeline Leak Detection System Effectiveness –Designed to provide an open forum amongst all stakeholders to exchange information about the capabilities of and challenges associated with and LDS –Meeting Website, including Summary Report: ?mtg=75 ?mtg=75 –Information obtained through the workshop was used to develop the scope of the study - 6 -

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration July R&D Forum July 18 and 19, 2012: Government/Industry Pipeline Research and Development (R&D) Forum –Gaps identified by Leak Detection Working Group included reducing false alarms, leak detection system improvements for new and existing systems for both HL and Gas, and smart system development –Contractor personnel were present and provided status of study –Forum Summary Report and Presentations:

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration R&D Solicitation Technology/Knowledge - Reducing Alarms of Leak Detection Systems (cost-share) Technology/Knowledge/Standards - Leak Detection for New and Existing Systems (cost-share) Technology - Smart Leak Detection System Developments (cost-share) General Knowledge/Standards - Improving Leak Detection System Design Redundancy & Accuracy (no cost-share) Research Announcement: Solicitation closed, white papers currently being reviewed - 8 -

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Putting LDS into context Leak Detection Systems include technology, people, operating environment, and process and procedures involved Multiple layers of defense in pipeline systems in general, and LDS specifically, intended to prevent incidents from occurring and reduce the impact of an incident if one does occur - 9 -

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Scope of KAI study Review of pipeline incidents that had leak detection aspects (KAI chose between January 1, 2010 and July 7, 2012) Technical Feasibility: A review of installed and currently available LDS technologies along with benefits, drawbacks and retrofit applicability to existing pipelines. Operational Feasibility: A review of current LDS being used by the pipeline industry Economic Feasibility: A cost benefit analysis of deploying LDS on existing and new pipelines Standards Review: A study of existing LDS Standards Interviews with Operators and Technology Suppliers

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Summary of Comments and Responses by KAI Comments received via the website or from nine commenters (many had multiple comments within them, and/or on behalf of others such as trades associations, etc.) –Over 100 individual comments deemed technical in nature, directly related to the report, and appropriate for a response (many are similar to one another) Next slides are a summary of some of the comments that resulted in a change to the draft report All comments received by the comment deadline are available in their entirety at the following website:

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Summary of Changes: Draft Study CommentKAIs response Executive Summary should briefly recap some observations, such as inserting a summary table of the PHMSA database for the incident reports (January 2010 to July 2012) Contractors agreed with the comment, and a summary table has been added to the executive summary A number of commenters raised issue with certain specific statements such as in the summary “…many of the leak detection regulations in 49 CFR 195 – especially expressions of principles and procedures – apply in large part equally well to gas” and other language that might cause confusion with direct comparisons Authors removed specific statements like this to avoid confusion and modified other language in attempt to avoid any direct comparisons. However, language elsewhere in the report that talks about some similar concepts with CPM, SCADA, metering, etc. remain

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Summary of Changes: Draft Study CommentKAIs response Suggestions to modify absolute language such as “immediate” detection to detect “quickly”, “refined products are liquids inside the pipeline and remain liquids when released” to “usually”, or otherwise make absolute “fact” statements more clear they are in the opinion of the contractors (such as cost benefit) Contractors agreed and wording revised in a number of places such as page 3-17 and 3-19 to modify the absolute wording. Other wording modified to make it more clear it is in the opinion of the contractors, and language added in disclaimer acknowledging there are a variety of opinions on LDS Disagreement or errors found on some of the data provided in the case studies (such Liquid 6 and 8, Gas 2, 7, and 8) Changes made where it was clear an error was made in the draft report based on information submitted within date range of review. Changes were not made in other cases, such as if changes made in supplemental report submitted after the date range

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Summary of Changes: Draft Study CommentKAIs response Comments on missing references from bibliography or other references for basis of sensitivity levels provided References added where appropriate, for instance PRCI/Batelle report on Human Factors listed in bibliography. In general any references to volume sensitivity were from an EPA study EPA-510-S (May 1988) which is now added in a few sections for clarity Comments that report implies in certain sections it reviewed all aspects of gas systems, including distribution, but report does not cover certain aspects like lower pressure distribution systems not on SCADA, but may otherwise be on networked, interconnected distribution systems The contractors agree and acknowledge low-pressure distribution systems as explained by the commenter are not covered in detail in this report. Text was revised to state it is not covered by the report

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Observations from KAI Study From incident review based on operator reports submitted, exact percentages differed by system type, but in general for all types (HL, Gas Trans and Gas Distribution) –An emergency responder or a member of the public was more likely to identify a release than air patrols (if applicable), operator ground crew and contractors. –Air patrols, operator ground crew and contractors were more likely to identify a release than the pipeline controller/control room. –The pipeline controller/control room least likely to detect and identify release

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Observations from KAI Study Recommended best practices for leak detection for gas pipelines are lacking, as are best practices for external sensor- based leak detection. Unlike most other subsystems used on a pipeline, LDS do not have nameplate or rated performance measures that can be used universally across all pipelines. This is particularly true of CPM where computer software, program configuration and parameter selection all contribute, in unpredictable ways, to overall performance. There is no technical reason why several different leak detection methods cannot be implemented at the same time. In fact, a basic engineering robustness principle calls for at least two methods that rely on entirely separate physical principles

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Observations from KAI Study Many performance measures present conflicting objectives. For example, leak detection systems that are highly sensitive to small amounts of lost hydrocarbons are naturally also prone to generating more false alarms. Objectively, the largest cost element in any LDS is the investment in personnel who understand, manage, plan and improve leak detection within the pipeline company. Any leak detection beyond the simplest of technologies soon requires these experts

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Observations from KAI Most recommended practices for internal LDS contain principles that are valuable for external systems as well. Equivalent standards for external systems would be very useful to the industry Certain standards and regulations reviews expand in several useful ways, including by setting measurable performance standards for leak detection

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Draft Final Report and Comments The draft final report and all comments received by the comment deadline are available in their entirety at the following website:

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration Thank you! Questions? 20 Max Kieba Engineer, PHMSA Pipeline Engineering and Research Division