Curious about how to avoid fines for lack of compliance with 49 CFR §192, Transportation of Natural and Other Gas by Pipeline, and 49 CFR §195, Transportation of Hazardous Liquids by Pipeline? In this series of posts about pipeline integrity and compliance myths, we explain how to avoid some of the most common mistakes companies make when operating oil and gas pipelines.
The “Turkey Problem”: The Past Doesn’t Predict the Future
Are you ready for compliance myth #1?
“We can predict our future safety performance based on our history of safe operations.”
In other words, “A leak/spill/fire hasn’t happened in the past, so it’s not likely to happen in the future.”
You know what we’re talking about… the fill-in-the-blank catastrophe that’s never happened in the history of your pipelines. So it will never happen, right?
Oops, what you’ve got there is what Nasim Taleb, in his book, Antifragile, calls a “turkey problem.” The turkey is living the life on the farm. He gets fed well every day. He gets good medical care. He doesn’t see any evidence to the contrary, so he thinks his future is secure. But the turkey can’t possibly predict what will happen on Thanksgiving based on the history of his life thus far.
Don’t use history to predict the future, especially when it comes to time-dependent events. For example, pipeline corrosion, pipeline cracks, and some geohazards get worse over time, not better. The safest assumption is that corrosion or a crack is growing but just haven’t reached a critical threshold yet.
The Denbury Gulf Coast CO2 Release
Before the 2020 carbon dioxide (CO2) rupture and release in Satartia, Mississippi, the team at Denbury Gulf Coast Pipelines, LLC, assumed their Delhi Pipeline didn’t have unmanaged issues.
In 2020, heavy rains likely caused a land slide under which the Delhi Pipeline was buried. The weight put additional strain on the pipeline until it ruptured. The federal Department of Transportation fined them $3,866,734, and it cost them and additional $3,947,009 in clean-up, emergency response, and damages. Ultimately, that release cost Denbury $7,813,743.
What You Can Do to Avoid the “Turkey Problem” and Promote Oil and Gas Pipeline Safety
Oil and gas incidents have the potential to harm the environment, wildlife, employees, and the population at large. What can you do to avoid getting stuck in the “that can never happen to us” trap and promote oil and gas pipeline safety? Three things.
1. Make your procedures airtight.
A good procedure identifies industry best practices, risks associated with the applicable assets, and a clear way to train and communicate with employees, contractors and other people who could be affected by the asset. The procedure should also spell out how you will learn from near-misses and failures.
2. Assess for potential threats and act on the results.
Determine all potential threats. This is where most oil and gas operators get tripped up. Regardless of what the federal regulations allow, you need to ask yourself, “Is this assessment going to give me reasonable insight into all potential threats to this pipeline?” If not, you need to supplement that assessment with another one.
Whatever the gameplan ends up being, it must yield actionable results. If the results are inconclusive, you must conduct a different kind of assessment. Giving it the ol’ college try—or worse, assuming the problem doesn’t exist—leaves your fate to chance. When it’s compliance and integrity, do you want to roll the dice? Hint: After you’ve had a release, the answer is simple.
PRO TIP: There's an alternative. In some cases, you can analyze your existing data to book-end what the problem could be. You know you have the problem, but you can prove with data analysis that the risk is within acceptable parameters.
3. Test your assumptions and assertions.
How do you know you have only certain types or a certain number of threats on an asset? Test your assumptions and assertions by thinking up a cost-effective way to test them. If you have good procedures, test those procedures by having a qualified third party assess them and suggest ways to improve. (See our LinkedIn post about drinking your own Kool-Aid®.)
What are some of the ways you keep yourself from being complacent about potential threats to your pipeline? Add your comments below.
Links to our other compliance myth posts:
Schedule a free, 30-minute pipeline safety and compliance consultation.
Dan Prascher, Principal
(307) 488-0110 (O) | (303) 941-3773 (M)