Integrity management has evolved since the standard of “avoiding loss of life” was set. On the newest episode of Pipeline Things, Christopher De Leon and Rhett Dotson are joined by Keith Leewis to discuss the evolution of integrity management and its future trajectory. Rhett, Chris, and Keith discuss the history of integrity management, how it has evolved within the last 25 years, and what new technology can mean for the future.
Highlights:
- What is PIR and what is the history of how it came to be?
- How has the standard goal of integrity management evolved from 25 years ago?
- Are integrity management and its standards evolving enough with the influx of resources available to operators now, in comparison to 25 years ago?
- As regulations have progressed, what is the need for prescriptive regulatory guidance?
Resources:
Consequence Related Background Papers
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Rhett Dotson
Welcome to today’s edition of Pipeline Things, Our guest. It’s quite possible to say that you began working in the industry before many of you who are listening were born. He is an esteemed member and contributed significant amounts to much of the, let’s say, documents, foundations that serve as guidance, and even some of the regulations that fit in our industry today. As he comes on to talk about risk PIR, where that came from, and maybe what we should be doing is operators and even looking forward to the impacts. And what does PIR look like for hydrogen and CO2, I think is a great episode. Thank you for joining us on today’s edition of Pipeline, Things. Hey, welcome to today’s edition of Pipeline Things. I am your host, Rhett Dotson. My co-host, Christopher de Leon. As you can see, if you are on the video, you can tell that things look a little bit different. We’re in headsets and that’s because we’re actually going to be doing a virtual guest today, really excited about that particular virtual guest and when he comes on. But before we do that, it’s probably good just to catch up a little bit. You know, we started this second arc or second arc. This is the second episode of The Arc of the Arc. Christopher what are we calling this ARC?
Christopher De Leon
Sage
Rhett Dotson
The sages, not like the spices you put in gumbo.
Christopher De Leon
No, no, not not little green stuff.
Rhett Dotson
No, but, but Sage in terms of.
Christopher De Leon
Wisdom, masters’ teachers
Rhett Dotson
Yeah. Because the sage you thought that was preferable to calling it the OG arc.
Christopher De Leon
Yeah. You know, because different people would have different interpretations of OG and people might not identify with that. So we figured Sage would be a little bit more
Rhett Dotson
Sage is more appropriate. That’s what you wanted to go with?
Christopher De Leon
Masters, teachers.
Rhett Dotson
Yeah, this might actually be the first time for the audience that Chris cared what somebody else thought it’s really, Oh Chris, I missed you.
Christopher De Leon
You know I’m a semi-private person. You keep revealing things about me on this show you need to stop.
Rhett Dotson
If people want to know who if you want to know the real Christopher, you have to listen to pipeline things in order
Christopher De Leon
to reveal stuff that people shouldn’t know.
Rhett Dotson
Yeah, so it’s really great. I’m actually excited about this, this particular guest. So, this guest, I guess he’s a fan of the show, I don’t know. But we bought him one because he offered us feedback. But many people may not know that this is actually his second appearance. We should offer, like, some type of a reward. Yeah. You know what? If you can I tell you what, if you’re listening to the show you can email me or email Miss Producer or email information at D2 integrity with where this particular guest appeared prior Well, we will send you one of the d2i branded Yeti cups.
Christopher De Leon
You know who does that, right?
Rhett Dotson
Yeah, I do. But you know, this is one of the nice ones. And I’m not saying there’s aren’t nice, but you’re right.
Christopher De Leon
You know our podcast has video and the other person’s podcast does not have video, so we give nice Yeti’s, this is on you when this airs.
Rhett Dotson
We’re going to have Yeti comparisons here. This is an excellent international guest, that we’re having on and I, I think is yeah, his reputation precedes him. Is that fair?
Christopher De Leon
For sure.
Rhett Dotson
Like everybody knows this because I get the pleasure of working with him on B 31 eight where he is famously known for voting down his own proposed changes to be 31 eight. So, every time that we joke, we joke like, he’s going to vote down his own change.
Christopher De Leon
Well, the cool thing is like brand matters. And this gentleman has a brand like definitely has, right? It’s like when you interact with this sage, you know exactly what you’re going to get, right? There’s the appearance, there’s the wittiness. You know, it’s just the experience. It’s a it’s a whole brand.
Rhett Dotson
So much fun. And you can also tell when people maybe haven’t met him because they usually mispronounce his name.
Christopher De Leon
Oh, that is very true.
Rhett Dotson
I definitely Rember the first time I tried to read his name. It’s sort of like totally mispronouncing, which is great because if my producer throws it up on YouTube, I’m wondering if people will wonder whether or not I’m doing right. You’re right. But without further ado, I think it’s I think we can go ahead and introduce our guests. Our guest today is Mr. Keith Lewis. And so if you want to bring him on, welcome Keith can you hear us?
Keith Leewis
Yes, I can. Very well, thank you.
Rhett Dotson
So, I want to say thanks for joining us today. And it’s not Keith Lewis. It is Keith Levis for all of our listeners out there. And Keith, I wanted to go ahead and if you don’t mind, give our listeners a little introduction and tell us who is Keith, What’s your background? Why are you a sage?
Christopher De Leon
And don’t water it down? People need to know why you’re a sage.
Rhett Dotson
This is the time to flex on them?
Christopher De Leon
All the listeners don’t know who you are.
Rhett Dotson
This is who you want to be your mentor.
Keith Leewis
So I can start with just the last 30 years which goes back to risk assessment.
Christopher De Leon
That’s your first flex bonus place. I’m only going to go back 30 years.
Rhett Dotson
I’ve been working longer than most of you have been alive.
Christopher De Leon
So, we’re going to start on just two times longer than you’ve been in the industry. So that’s where we’ll cut this off.
Keith Leewis
So, yeah, so back in the early nineties was when I started doing the risk assessment. And so, a number of us built the first one for what’s now t c energy and time. I also sat on the Pipe Safety Committee and also Pyramid, which was the C for the good part of a pipe safe is we got the blew it up a 36-inch pipeline up twice and take all kinds of readings and things because we needed to calibrate the thermal.
Rhett Dotson
Now I want to pause you there because I actually saw that slide. What I want the listeners to appreciate that is a true full-scale test. Like it looked like a small mushroom cloud in the picture. So, this was a full-scale test of a 36 inch. How much gas? Gas? Not, not. Airgas Natural gas. Like what was the scope of that test, if you don’t mind?
Keith Leewis
Well, one end of that line was plugged into Edmonton and the other end was plugged into Chicago. So just for some perspective, it’s not. But we did we did have to shut off valves five miles. So, it could terminate it. That was a big test. Two of them lit.
Rhett Dotson
Anyway, I’m sorry I interrupted you, Keith, because I wanted to ask you about that. On that slide. You said so. Okay, so we’re going back. Keep going. So, 30 years ago, you started with Risk and TC Energy, early nineties,
Keith Leewis
Early nineties. And then I defected to the United States and I started to work for GRI. And part of that was to begin to build the background for B 31 S, which is now called FEMSA and GTI. And the pipeline industry started to have meetings and things we needed to have to support. B 318 S And if you look in the back in 14, you’ll see a whole variety of GPI or a GRI or projects that we did to support B 318 S and that’s to do the technology end of it right. And so that all came together. I think we wrote the first one in 2001 and that was the green-covered one, and then 2002 was the first update. And then we had another update in 2004. by the time of 2004, I had added in all the DA stuff. One of the problems we needed to find a hole to put in direct assessment and it wasn’t quite ready yet. So, we stuck it in the background S in starting in 2004, we started to write the new standards. So, by 2010 often these standards were done and about 2012 I think they started to show up in 192.
Rhett Dotson
So, you have a rich background. Needless to say, on the standards and the development side with a focus on risk that is really awesome to appreciate you guys you’re describing a time period whenever I was actually in middle school.
Christopher De Leon
I was still watching X-Men at home.
Rhett Dotson
Well, wait, I saw I mean, maybe I was watching X-Men Middle School.
Christopher De Leon
He said early nineties I was in elementary.
Rhett Dotson
So anyway, but Keith, I do want to begin. Thank you for joining us and give a little context to why specifically or how we ended up with you here and bring a little focus. We did an episode on our failure file series related to this system fails and the advent of MCA’s is really kind of the expansion of regulatory consequence areas from just high consequence to moderate.
And some of the language in that report, the NTSB had noted specifically that the original intent of regulations was to protect against loss of life and that there was more that needed to be done beyond that. And in response to that episode, you sent me an email with a bunch of background and I said, this would make a fantastic episode, which is how we find ourselves here talking to you. So, if you don’t mind, I’d like you. I think most of our listeners are familiar with the concept of the PIR, but maybe not familiar with how and why it worked its way into code the way it did. Could you shed a little bit of light on that history there?
Keith Leewis
Yeah. So, there’s a variety of things. So, we had in B 31 we have the failure frequency and we have a consequence part B, so part of it was to set out a basis for the consequence. So, we, if we go back and look at the line breaks, we’ve had since 1970, for example, we can see the number of trees that they damaged, but we could also do a theoretical calculation later. So, the PIR has a number of assumptions and one is that every line break catches fire, which is not true. Second is the two outputs from the two ends interact with each other and get a single flame in the middle hand. And then we took that claim and we estimated mean point of that flame. And then we use calculations to get the thermal radiation as a function of distance from the rupture. So that made it a circle. But if you notice many of this burn areas looked more like dog bones. Sure. They’re sort of the they don’t interact and they tend to see each other and have two flames for a number of them. So sometimes the areas are really not a circle. It’s probably more like an oval. And if you take into account windy and other things, then that oval becomes spread over in a different area. But the first idea was, let’s keep it simple and we’ll have a circle. And that circle has a dosage at the end of it of about 1%, which was equal to piloted ignition in about 20 or 16 minutes, I think for wooden structures. So that meant you could hide in the wooden structure for the first 16 minutes and then bugger off.
Rhett Dotson
So, putting that into perspective, I want to make sure I recap. You developed the circle of which it had a 1% dose right? It’s a 1% dose, which means that only 1% of people.
Keith Leewis
1% lethality.
Rhett Dotson
Okay, so 1% mortality and would catch a normal wooden structure on fire in about 16 minutes, give or take.
Keith Leewis
Well, in 16 minutes, it would have to be piloted ignition. So, it meant something else had to be burning to set it on fire.
Rhett Dotson
Gotcha.
Keith Leewis
Okay, so that’s a wooden building because we wanted to have some shelter for people as well.
Rhett Dotson
But it doesn’t guarantee. I mean, I think an important thing you’re stating is that this isn’t guarantee you wouldn’t have damage outside of the PIR. It definitely doesn’t guarantee it. If the fire burned for longer than 16 minutes, most of the failures that we looked at have burned for longer than 16 minutes. Right.
Keith Leewis
So, in the 16 minutes in some cases is what it took to determine to shut the valve off in some cases. Yeah. And yeah, so in many cases takes we try to keep it an hour to close the block valves and isolate the section. But that means you have to close all the linkages to the parallel lines as well. So yeah, right. Because you are trying to keep the capacity up.
Rhett Dotson
Yes.
Keith Lewis
And so, with San Bruno, for example, it was a tie in to the line going by the airport that was shut last.
Rhett Dotson
Right.
Keith Leewis
And that turned the fire off. Yeah.
Rhett Dotson
So, one of the things I remember when we were discussing this episode and again, I think it’s useful because it is a I think you said it, it’s a very simplified way to do it. We take circles and we walk down the pipeline with a 660. So, we marked down 660 feet and it’s a fairly it’s a crude way to do it. But one of the things that you mentioned was, you know what, Rhett at the time we were doing this, we’re doing it with 486’s. And I was like, what the heck is a 486? Right?
Keith Leewis
So, for that it was our highest computer at the time, right?
Rhett Dotson
I think for most of our listeners, particularly our WPP, it’s important to recognize that at the time, something so central to our regulatory framework, it was brought into the picture was just simply due to resource limitations. We didn’t have the computational horsepower that we did today.
We don’t have computers everywhere. So, a very, a very simple means for addressing the consequence of failure was, was developed in, in the form of PIR or is it fair to say.
Keith Leewis
Yeah, so as a screening tool you have a circle running down the center of the pipeline and you’d stop every so many distances and count the houses inside the circle. And if they exceeded 20, then you went to the downstream know the upstream radius where it intersected the pipe and that was the beginning of your HCA. And then you kept going until you ran out. The houses drop below 20 and then you went to the downstream end. So, you got in. There are neither Earth and the center points. And so that was the simple way of doing it. And you’re right, we had only so much computing power. But if you notice, the HCA is a 192 invention. It’s not a B 31. So, B, 31 eight you’re supposed to do from the start to the finish. And we couldn’t do that at the time. So, when we were talking with the regulators, then we decided on using it for 20 House ‘sand that ended up to be somewhere between eight and 13% of most pipeline distances, and that means they could do that. So, but part of it, part that we had back in 2000 to 2001 with the HCA’s case was that they would eventually get longer. So, they invented MCA’s. But that took about ten years. Right. And eventually they’ll probably end up doing the entire pipeline length. Now, I think at the time decided that they would try and have all of the houses covered by about 2024 this year and have start to finish of the pipelines done by 2030.
Rhett Dotson
When you say start to finish, done, I’m sorry, what do you mean when you say start to finish done, start to finish as covered by integrity program. Start to finish with a baseline. Start to finish. What do you mean?
Keith Leewis
From pipeline milepost zero to whatever the end of it is. Right. So, 100% of your pipeline would be covered by 2030, according to what Ingo would like to have. Right by an integrity management program.
Rhett Dotson
Thank you. That’s what I was getting out, covered by an integrity measure because we decided.
Keith Leewis
No, no. Well, you’re talking s had an integrity monitor, minutes of a program for everything. The regulations had a limit to one. Yes. HCA And that was yes. Right. And then of course the states really like if you just passed three and four and had an integrity management program for all of that and eliminated all the calculations except for class one and two. So that’s how we got into the two different types of programs. So now everything is integrity management for three and four, class three and four, and the screening circle for class one and two, right? And now the screening circle for class one and two has MCA’s as well. All right. So, this is where we’re supposed to have people and we wanted to give them more protection.
Christopher De Leon
So, a couple of a couple of things to, to bring it around, Keith, if you can, for us, and this is where I want your opinion. So, you said a couple of things that I want to kind of paint a picture from for you to speak to your thoughts. You said originally it was the goal was loss of life. Right. So that’s where we want to go. But we can’t get there from the jump. And so, we put this as an industry. We put this plan in place. Right? And it started with PIR’s and then PIR’s drive or are part of how we’re understanding consequence, right? It’s part of risk management, right. So, failure, frequency and consequence, you address consequence by PIR and then regs come in and say, well, we’re only going to start IMPs on HCA cases and fast forward plus a decade now we’re bringing in MCAS. You having seen the original intent yet. You’ve seen the original intent, which is loss of life and kind of what your set up was based on the limitations of resources. We’ll do that more broadly, right? Whether it’s computers processing, people experience, we’re now fast forwarding from 2000 ish, right? Initial regs call it 02–04-time frame. Now we’re in 2023, go in 2024 for this podcast. Speak to that as to where you think the adoption and this continuous improvement component is from an industry perspective.
Rhett Dotson
Actually, you know what? I am going to give us a break on that question because I want to give Keith time. That’s a that’s a big question, which is I want to sum it up. It was a two-part question, and we’re going to address both parts, Keith, right after we take a quick break. Hang on and we’ll be right back with Pipeline. Things. Sorry, I needed to break my arteries. Then they had to redo the cameras. And Keith, my assistant from you can hear me, too. Yeah, I can hear you, too. And the audio’s back to minimal, so. Okay, I can barely hear Keith again. It’s like, great. I don’t care. We’ll see you. All right. Welcome back to Pipeline things. Thanks for taking our break where we have our guests, the esteemed Keith Lewis has been joining us as we talk about risk and where the pipeline industry was 30 years ago.
So, we left on a cliffhanger and I wanted to do it intentionally. I thought it was a good place to take a break. But, Chris, you asked the question. Yeah, and I’d like you to repeat that question again. Sure. Even though Mr. Lewis had plenty of time to think about it, give me more time to think about it.
Christopher De Leon
So, the question is, obviously, you’ve been doing this for a long time and there was a goal that was set at some point, right? Let’s call it early 2000’s. You guys put it all together. Right? Let’s fast forward. It’s at least 20 years and with the idea of it being the goal being, you know, preventing loss of life, you had an approach that was developed in resources, you had available time. But we all know that your resources are incredibly evolved and much more advanced, but we’re still using a lot of the same tools. And we’ve seen even regulation lag in a similar fashion. You being the sage that you are with all the world experience and you knew what the goal was originally to where we are now. I would like for you to just share some very authentic, potentially passionate and opinionated thoughts on kind of where we are as an industry as a whole and being able to achieve that goal of avoiding loss of life.
Rhett Dotson
Are we doing the right things or should we be doing more?
Keith Leewis
Well, we could. We’re doing really good things for the likelihood of failure. So, we’re working really hard on that part. But I think the consequence of failure has not moved an awful lot in the last 20 years for many companies. Some companies are quite a bit further ahead. So, we because we still use a screening tool and we just run it down the pipeline and that becomes HCA and now an MCA and that just turns the switch on or off. And whether you’re doing more integrity inspections, right, looking at things, inspecting things. But, you know, one of the real advantages with failure frequency is if you can granulate it that then you can zero in or where you need to spend the money. If we granularly the cut the consequences as well, then we could narrow down where we need to spend the money as well. So right now, it’s almost like a off and on switch. You either have a whole bunch of houses or you don’t. Right. And with HCA or MCA’s, it’s you have not quite as many houses, but a bunch of houses and so on either side of an HCA or in some of the smaller areas where you go through, you’ll find an MCA. So, if we take a circle, right. And so, we know that the circle is an ideal round thing and we could add things to it like the likelihood of failure, because the bigger the diameter, the more chances it will ignite. Right? And then we could add things to that, like what happens to the prevailing wind? Does the circle change? The other thing we could do is we could make it into a target symbol, you know, do you guys shop at Target? Right. For all kinds of. So, it’s like a red and white bullseye. Yeah, right.
Rhett Dotson
Substantially like I categorize our purchases every month, Keith like line by line. And the number of target purchases is astounding. And I’m thankful now that my wife does not listen to the podcast, that she will not hear me call that out.
Keith Leewis
Well, that’s a great example is the target symbol. So, the outside of the circle is the 1% lethality. Then you could use 25, 50% lethality, right? And when you run the smaller circles down, you capture different houses. Those houses would have a higher likelihood of consequence. So, you can start to get some granularity that way.
Rhett Dotson
Well, let me make an argument, Keith. What if an operator just said all you’re going to do is expand my integrity program, now?
Keith Leewis
You’re going to you’re going to separate your integrity program into more granularity and you’re only interested on the high-risk ones. Right.
Christopher De Leon
So, what are your thoughts, Keith, on why we haven’t moved that? We’ve seen that there is congressional mandate for using more data driven techniques like ILI. Why is it that we’re not seeing more on the consequence side, meaning whether it’s data integration or anything, that doesn’t mean you will dig this case because that’s the real consequence.
Keith Leewis
Yeah, there are two things. One is internally driven by the operator and the second one is regulatory driven. But regulatory driven depends on who’s holding the house. Right? And since 2002, we’ve had Republicans and Democrats switching back and forth a bunch, right? So, the MCA, I think was proposed back in the old times, back probably 06 or something like that, that by the time it worked its way through, different administrations have different emphasis on what they want done. It didn’t pop out till what, 2019 in something like that. So that’s one of the problems. The other one is the same question that Rhett asked about. Aren’t you just going to make things that I have to do more integrity that you’re still working with inside the HCA? So, but now you’re just adding a number on to your consequences. So, you’re going to sort them out into different groups with lower risk and higher risk. Don’t forget, HCAs are only doing 13% of the pipeline right? Plus, whatever is in your class three and four, which is probably less than 3% anyway for most big pipelines. So, most of the regular pipeline just gets the normal kinds of stuff, which is corrosion and leaks. Right?
Christopher De Leon
So, one of the things I remember Jerry telling me and I want to maybe shift focus, shift focus, but maybe I want to hear your thoughts on this. Right. So, Jerry, obviously he brought me into the pipeline. Well, he always had this idea of Chris, you would you have appreciated what should happen. His perspective is it’s finished. You should come together and develop a recommended sort of standard. And then that’s what we as an industry believe in and that’s how we should operate and regulators should follow in one way or another. Right. So, my question to you is, it’s obvious that you’ve been on a lot of standards committees, you’ve seen a lot of regulatory changes as it’s as an industry. Do you think that we have the right frameworks in place so that we continue to make the right decisions? Because again, we see a lot of actions and dollars being put towards assessments, but that doesn’t necessarily mean that the assessments are driving down the risk. What are your thoughts?
Keith Leewis
So that’s a two. One is you need volunteers on the standards in order to make sure that we’re working at the front end of the technology right. And that’s been harder and harder, and Rhett probably has its own opinions about how are we going to get people onto B318 and other standards. And the other one is to have the various companies, the operators have the passion to try and sharpen the pencil, to spend their money at the right spot and not over a big area. So, some companies are really doing that. So, I also sit on the CSA that 662. And so, there’ll be some new stuff coming out for risk assessment on that part. And so, they’re getting into more sophisticated analysis through that consequence end. In which way, if we’re waiting for the regulatory people to drive it, it’s taking time. So in in about 18 now 17 to 19, we had a risk assessment group that was put together by Stimson and I was on there. So, B 318 a rep for that. And so, their recommendations that came out of that and some of that will come through the regulatory since I have been involved in working with regulatory through Inga back probably before 2000 and in this century, it’s a we’ve always tried to get ahead of things, so we tried to do that with. Q But the regulatory people decided they wanted to write their own. And so there are a whole variety of different things. And when you think about the regulatory for 192, a lot of their part all has come from B 318 s, but they just maybe this is a bad word. Cherry-picked it, you know, it’s right.
Christopher De Leon
Yeah. We’re going to only incorporate the 2004 version we talked about, right. That has a variety of things, but it has the corporation used more lawyers, which was a topic on the packet when they were coming out with the latest regulation, but we didn’t see that change.
Keith Leewis
Well, they’ve been talking 2018 lately, but my personal opinion there’s 2004 was the last version we had. Both CDA and ICDA right and so they may have wanted to keep that, but both of those are now in 192. It was taken like 15 years to get them in there.
Rhett Dotson
But they’re there now, right?
Keith Leewis
So yeah, I see they didn’t actually do confirmatory direct assessment, which I think is can’t do anything. But anyway, I helped write that one too. So yeah.
Rhett Dotson
I think standards some challenges you know as we talk about trying to implement something that would be more granular in terms of consequence and the reality of there’s two sides, right? There is there’s limited resources. I’m going to say more in terms of people and maybe in terms of competency on the operator side as you get past the big operators there. And then I also think that from a regulatory perspective, I think Keith the regulators like the one off switch and tells them where they need to look and where they want me to look.
Keith Leewis
It’s good for audits.
Rhett Dotson
It’s it is good for audit. It’s right when you talk in terms of prescriptive regulation, I could see why it would be a challenge for regulators to do it. I think we should again, regulations set the minimum bar so I think operators should be encouraged to look beyond the minimum bar. But from a regulatory and an audit perspective, yeah, they’re going to favor an on off switch, not a targeted approach that has maybe a scaling zone that goes down. That’s a whole separate conversation. You know, again, I’ve been struggling in that whole prescriptive versus, well, non-prescriptive approach.
Keith Leewis
We’re not into performance based yet and we may never get there. It’s directive. So, we have the nine prescriptive threats. Right. And we know there’s a lot more than those and the granularity helps you out as well. Yeah. So yeah, so there’s a variety of things that we could talk about. Can I, can I make a plug? you talked about software. So, if you wanted to of software. It’s now DMV. Yeah, they can do consequences much better. And I work for dynamic risk as well. And they write software for these kinds of things too. So, There’s help out there. If you wanted to get more granularity and you don’t necessarily have the staff to do it yourself.
Rhett Dotson
Yeah. All right. I want to I want to let our audience know you actually a you glitched, too, there for a moment and the Internet got great We that was not an intentional you know he plugged both I was at Danica and did DMV now. Yeah, Keith I actually in as we move towards the close of the podcast, I want to hit on, I want to ask you what your thoughts are. PIR It’s been a great conversation as it pertains to natural gas, but we know a lot of the conversation in the industry is not around natural gas anymore. It’s around CO2 and hydrogen. What are your thoughts on this PR based non granular. If we’re trying to take the current methods we have and apply them to CO2 and hydrogen, what problems? What does this create? What do you think?
Keith Leewis
Well, for hydrogen, you can use the PIR. Recent work indicates that the thermal radiation from a hydrogen is both the same as methane. And if you go back to the earlier TAN 0 reports, it sounded like it was about half or 60%, but it turns out with the recent work that it’s not that it’s higher, so it’ll be about the same. So, you could use the PIR screening tool for hydrogen for CO2. It doesn’t combust and it is heavier than air. The other two are both lighter than air, so it goes straight up, right. Plus, if they’re burning, then you get thermal heat, which drags it up as well. The other one sits on the ground and runs downhill. So, it’s not going to be round. It’s going to depend on the terrain that you’re in. So, you need a whole different set of calculations to estimate what it’ll look like. So about 4% can get kind of toxic. And you so that means that it’s hard to drive, it’s hard to do those kinds of things. And when it starts getting up to 5%, then the engine and the car won’t work. And it’s even harder for yourself. And if you sit in a valley, then it may be like propane. So, it would be in a spot where the air gets pushed out of that. So, your consequences will change. But again, that too. I plugged our people to begin talking with. However, if you look at the EPA, you already have free software out there that you can grab. But again, you’ve got to have people that know how to use it or want to learn how to use it, right? So, there’s lots of free stuff to help. So, the first thing is you’ve got to figure out how much is coming out, at what rate over what time. So with thermal radiation, for example, if we close the valves and then we have a line break and we have 5 minutes to get out of the building, but the chances are there’s not a lot of help we can give for personal damage because it can take 25 minutes to an hour to get down to for thermal radiation, to get down to where the fire people can just begin to cross the EIR so they can’t even go in and do search or rescue. And so that was one of the things that I was trying to get across at that PPIM as well. And that work was done ten years ago and presented to FEMSA it as well. So, in many cases with thermal radiation, you can reduce the amount of property damage, possibly rescuing people is very difficult to find them shelter I haven’t found shelter and with CO2 you can asphyxiate people really quickly. If you don’t if you haven’t planned it out. And that’s why it’s really important to do your homework ahead of time and then to talk to your internal emergency response and also the fire and police, because they’re going to be in control. We have no control for over 20 years, so we just provide advice now.
Christopher De Leon
So, I want to I want to ask you this question, maybe look a little bit to the future. So, we at least I know we have a lot of focus on trying to do knowledge sharing, knowledge transfer, right. I mean, that’s how I learned a lot. So, I continue to try to learn to do the same for the industry and leverage experience because as we look at maybe some of the younger generation, I remember when I got hired, you spent some time on the podcast. The room’s always full of great people and it was just a few of us. And then fortunately, over the last five years or so, we put this big emphasis on hiring younger talent, WPP type organizations, bringing them in. Assuming we have some, we have some younger generation or some younger people who are in pipelines trying to do a good job. What’s the message you would give to them directly taking at least 30 years of your experience? Right. And seeing how standards developments happen, how they implemented, how operators are making decisions? What words do you give some of the younger generation that may be listening to those moments?
Keith Leewis
Yes. So the best thing is what you’ve been talking about all along is do the monitoring and get ahead of problems. Right. So that we don’t end up with ruptures If we want to talk about ruptures. And this is because now you’ve got a big problem, right, then you’re probably in need to invest some more time in figuring out the consequences and how you can stay ahead of that. All right.
Rhett Dotson
Integrity management is the best way to prevent failures.
Keith Leewis
Keep the product inside the pipeline. Right. If you can do that, because we didn’t, you know, 30 years ago, we didn’t have the same kind of ILI we have now. We also have magnetometers and things that can you can take over the line. You can find stress peaks, things of this nature as well. Plus, our CP is so much better these days, right, for corrosion and corrosion has been a major problem ever since the day one. So, the best idea to prevent problem is stay ahead of your maintenance and leak detection now. So, we have two types of leak detection. We have the B318, which is if it bubbles, you’re in troubles. And now we have yeah, that was bad. And we have EPA which is down to parts 4 million now kind of thing. Right. So, in most cases we’re interested in finding spots where the wall is thin enough that they the product is getting out. Right. And and now we can do it with aircraft stuff, with spectral looking at different wavelengths of light in order to pick up different kinds of oils and gases and things of that nature as well.
Christopher De Leon
So quick question for you, Keith. Are you being you going to be at PPIM 2024?
Keith Leewis
Well, unfortunate thing I can’t make it this year, though, so I have to be I have to be home for medical reasons this time, not mine.
Rhett Dotson
Way to go with that question, Christopher. What a terrible situation.
Keith Leewis
No, no, that’s okay. Looks like a really good program because I help put it together along with a whole variety of other people. So, you guys have lots of fun there.
Christopher De Leon
So yeah, here’s where I was going with it is it’s if you’re if you had an opportunity to listen to this podcast and if you have not met Mr. Keith Lewis, play this, next time you see him, go shake his hand and start a conversation. He might not appreciate that, but do yourself a favor.
Keith Leewis
I always appreciate it.
Rhett Dotson
Fantastic. I think that’s a great wrap up to the show. I want to say thanks for joining us. Keith and for all of the a rich history and you’ve given a lot to the pipeline industry. So yeah, thank you. Thanks for joining us and thanks for sharing. I don’t think this will be the last time we’ll talk to you because I think we’ll pick up this conversation in different forms.
Christopher De Leon
Have you had you noticed that some of the sage’s of the industry, they come on the podcast one or another uninvited and then we invite them? Yeah, I feel like there’s a trend and now he’s got his way on.
Rhett Dotson
I mean we’ll have to just having him on. It’s like there are other regulations I’m sure we need to talk about.
Keith Leewis
Well, I’m always happy, especially to talk to our young pipeliners, because that’s how information gets exchanged and TPIM is a really good one. IPC is another good one coming up as well. In September this year, though, we don’t get that many people coming up from down south. So, there are other opportunities as well. Yeah. Just buttonhole me and I’m always willing to talk right. I have opinions.
Rhett Dotson
Right. Well, fantastic. Well, I just want to say thank you and, you know, I think that’s going to wrap it up. So, thank you all for joining us on this episode of Pipeline Things. I’m your host, Rhett Dotson, and we will be back in two weeks with a different sage. Looking forward to it. Thanks. See you again in the future.
Keith Leewis
Be safe. Take care.
Welcome to today’s edition of Pipeline Things, Our guest. It’s quite possible to say that you began working in the industry before many of you who are listening were born. He is an esteemed member and contributed significant amounts to much of the, let’s say, documents, foundations that serve as guidance, and even some of the regulations that fit in our industry today. As he comes on to talk about risk PIR, where that came from, and maybe what we should be doing is operators and even looking forward to the impacts. And what does PIR look like for hydrogen and CO2, I think is a great episode. Thank you for joining us on today’s edition of Pipeline, Things. Hey, welcome to today’s edition of Pipeline Things. I am your host, Rhett Dotson. My co-host, Christopher de Leon. As you can see, if you are on the video, you can tell that things look a little bit different. We’re in headsets and that’s because we’re actually going to be doing a virtual guest today, really excited about that particular virtual guest and when he comes on. But before we do that, it’s probably good just to catch up a little bit. You know, we started this second arc or second arc. This is the second episode of The Arc of the Arc. Christopher what are we calling this ARC?
Christopher De Leon
Sage
Rhett Dotson
The sages, not like the spices you put in gumbo.
Christopher De Leon
No, no, not not little green stuff.
Rhett Dotson
No, but, but Sage in terms of.
Christopher De Leon
Wisdom, masters’ teachers
Rhett Dotson
Yeah. Because the sage you thought that was preferable to calling it the OG arc.
Christopher De Leon
Yeah. You know, because different people would have different interpretations of OG and people might not identify with that. So we figured Sage would be a little bit more
Rhett Dotson
Sage is more appropriate. That’s what you wanted to go with?
Christopher De Leon
Masters, teachers.
Rhett Dotson
Yeah, this might actually be the first time for the audience that Chris cared what somebody else thought it’s really, Oh Chris, I missed you.
Christopher De Leon
You know I’m a semi-private person. You keep revealing things about me on this show you need to stop.
Rhett Dotson
If people want to know who if you want to know the real Christopher, you have to listen to pipeline things in order
Christopher De Leon
to reveal stuff that people shouldn’t know.
Rhett Dotson
Yeah, so it’s really great. I’m actually excited about this, this particular guest. So, this guest, I guess he’s a fan of the show, I don’t know. But we bought him one because he offered us feedback. But many people may not know that this is actually his second appearance. We should offer, like, some type of a reward. Yeah. You know what? If you can I tell you what, if you’re listening to the show you can email me or email Miss Producer or email information at D2 integrity with where this particular guest appeared prior Well, we will send you one of the d2i branded Yeti cups.
Christopher De Leon
You know who does that, right?
Rhett Dotson
Yeah, I do. But you know, this is one of the nice ones. And I’m not saying there’s aren’t nice, but you’re right.
Christopher De Leon
You know our podcast has video and the other person’s podcast does not have video, so we give nice Yeti’s, this is on you when this airs.
Rhett Dotson
We’re going to have Yeti comparisons here. This is an excellent international guest, that we’re having on and I, I think is yeah, his reputation precedes him. Is that fair?
Christopher De Leon
For sure.
Rhett Dotson
Like everybody knows this because I get the pleasure of working with him on B 31 eight where he is famously known for voting down his own proposed changes to be 31 eight. So, every time that we joke, we joke like, he’s going to vote down his own change.
Christopher De Leon
Well, the cool thing is like brand matters. And this gentleman has a brand like definitely has, right? It’s like when you interact with this sage, you know exactly what you’re going to get, right? There’s the appearance, there’s the wittiness. You know, it’s just the experience. It’s a it’s a whole brand.
Rhett Dotson
So much fun. And you can also tell when people maybe haven’t met him because they usually mispronounce his name.
Christopher De Leon
Oh, that is very true.
Rhett Dotson
I definitely Rember the first time I tried to read his name. It’s sort of like totally mispronouncing, which is great because if my producer throws it up on YouTube, I’m wondering if people will wonder whether or not I’m doing right. You’re right. But without further ado, I think it’s I think we can go ahead and introduce our guests. Our guest today is Mr. Keith Lewis. And so if you want to bring him on, welcome Keith can you hear us?
Keith Leewis
Yes, I can. Very well, thank you.
Rhett Dotson
So, I want to say thanks for joining us today. And it’s not Keith Lewis. It is Keith Levis for all of our listeners out there. And Keith, I wanted to go ahead and if you don’t mind, give our listeners a little introduction and tell us who is Keith, What’s your background? Why are you a sage?
Christopher De Leon
And don’t water it down? People need to know why you’re a sage.
Rhett Dotson
This is the time to flex on them?
Christopher De Leon
All the listeners don’t know who you are.
Rhett Dotson
This is who you want to be your mentor.
Keith Leewis
So I can start with just the last 30 years which goes back to risk assessment.
Christopher De Leon
That’s your first flex bonus place. I’m only going to go back 30 years.
Rhett Dotson
I’ve been working longer than most of you have been alive.
Christopher De Leon
So, we’re going to start on just two times longer than you’ve been in the industry. So that’s where we’ll cut this off.
Keith Leewis
So, yeah, so back in the early nineties was when I started doing the risk assessment. And so, a number of us built the first one for what’s now t c energy and time. I also sat on the Pipe Safety Committee and also Pyramid, which was the C for the good part of a pipe safe is we got the blew it up a 36-inch pipeline up twice and take all kinds of readings and things because we needed to calibrate the thermal.
Rhett Dotson
Now I want to pause you there because I actually saw that slide. What I want the listeners to appreciate that is a true full-scale test. Like it looked like a small mushroom cloud in the picture. So, this was a full-scale test of a 36 inch. How much gas? Gas? Not, not. Airgas Natural gas. Like what was the scope of that test, if you don’t mind?
Keith Leewis
Well, one end of that line was plugged into Edmonton and the other end was plugged into Chicago. So just for some perspective, it’s not. But we did we did have to shut off valves five miles. So, it could terminate it. That was a big test. Two of them lit.
Rhett Dotson
Anyway, I’m sorry I interrupted you, Keith, because I wanted to ask you about that. On that slide. You said so. Okay, so we’re going back. Keep going. So, 30 years ago, you started with Risk and TC Energy, early nineties,
Keith Leewis
Early nineties. And then I defected to the United States and I started to work for GRI. And part of that was to begin to build the background for B 31 S, which is now called FEMSA and GTI. And the pipeline industry started to have meetings and things we needed to have to support. B 318 S And if you look in the back in 14, you’ll see a whole variety of GPI or a GRI or projects that we did to support B 318 S and that’s to do the technology end of it right. And so that all came together. I think we wrote the first one in 2001 and that was the green-covered one, and then 2002 was the first update. And then we had another update in 2004. by the time of 2004, I had added in all the DA stuff. One of the problems we needed to find a hole to put in direct assessment and it wasn’t quite ready yet. So, we stuck it in the background S in starting in 2004, we started to write the new standards. So, by 2010 often these standards were done and about 2012 I think they started to show up in 192.
Rhett Dotson
So, you have a rich background. Needless to say, on the standards and the development side with a focus on risk that is really awesome to appreciate you guys you’re describing a time period whenever I was actually in middle school.
Christopher De Leon
I was still watching X-Men at home.
Rhett Dotson
Well, wait, I saw I mean, maybe I was watching X-Men Middle School.
Christopher De Leon
He said early nineties I was in elementary.
Rhett Dotson
So anyway, but Keith, I do want to begin. Thank you for joining us and give a little context to why specifically or how we ended up with you here and bring a little focus. We did an episode on our failure file series related to this system fails and the advent of MCA’s is really kind of the expansion of regulatory consequence areas from just high consequence to moderate.
And some of the language in that report, the NTSB had noted specifically that the original intent of regulations was to protect against loss of life and that there was more that needed to be done beyond that. And in response to that episode, you sent me an email with a bunch of background and I said, this would make a fantastic episode, which is how we find ourselves here talking to you. So, if you don’t mind, I’d like you. I think most of our listeners are familiar with the concept of the PIR, but maybe not familiar with how and why it worked its way into code the way it did. Could you shed a little bit of light on that history there?
Keith Leewis
Yeah. So, there’s a variety of things. So, we had in B 31 we have the failure frequency and we have a consequence part B, so part of it was to set out a basis for the consequence. So, we, if we go back and look at the line breaks, we’ve had since 1970, for example, we can see the number of trees that they damaged, but we could also do a theoretical calculation later. So, the PIR has a number of assumptions and one is that every line break catches fire, which is not true. Second is the two outputs from the two ends interact with each other and get a single flame in the middle hand. And then we took that claim and we estimated mean point of that flame. And then we use calculations to get the thermal radiation as a function of distance from the rupture. So that made it a circle. But if you notice many of this burn areas looked more like dog bones. Sure. They’re sort of the they don’t interact and they tend to see each other and have two flames for a number of them. So sometimes the areas are really not a circle. It’s probably more like an oval. And if you take into account windy and other things, then that oval becomes spread over in a different area. But the first idea was, let’s keep it simple and we’ll have a circle. And that circle has a dosage at the end of it of about 1%, which was equal to piloted ignition in about 20 or 16 minutes, I think for wooden structures. So that meant you could hide in the wooden structure for the first 16 minutes and then bugger off.
Rhett Dotson
So, putting that into perspective, I want to make sure I recap. You developed the circle of which it had a 1% dose right? It’s a 1% dose, which means that only 1% of people.
Keith Leewis
1% lethality.
Rhett Dotson
Okay, so 1% mortality and would catch a normal wooden structure on fire in about 16 minutes, give or take.
Keith Leewis
Well, in 16 minutes, it would have to be piloted ignition. So, it meant something else had to be burning to set it on fire.
Rhett Dotson
Gotcha.
Keith Leewis
Okay, so that’s a wooden building because we wanted to have some shelter for people as well.
Rhett Dotson
But it doesn’t guarantee. I mean, I think an important thing you’re stating is that this isn’t guarantee you wouldn’t have damage outside of the PIR. It definitely doesn’t guarantee it. If the fire burned for longer than 16 minutes, most of the failures that we looked at have burned for longer than 16 minutes. Right.
Keith Leewis
So, in the 16 minutes in some cases is what it took to determine to shut the valve off in some cases. Yeah. And yeah, so in many cases takes we try to keep it an hour to close the block valves and isolate the section. But that means you have to close all the linkages to the parallel lines as well. So yeah, right. Because you are trying to keep the capacity up.
Rhett Dotson
Yes.
Keith Lewis
And so, with San Bruno, for example, it was a tie in to the line going by the airport that was shut last.
Rhett Dotson
Right.
Keith Leewis
And that turned the fire off. Yeah.
Rhett Dotson
So, one of the things I remember when we were discussing this episode and again, I think it’s useful because it is a I think you said it, it’s a very simplified way to do it. We take circles and we walk down the pipeline with a 660. So, we marked down 660 feet and it’s a fairly it’s a crude way to do it. But one of the things that you mentioned was, you know what, Rhett at the time we were doing this, we’re doing it with 486’s. And I was like, what the heck is a 486? Right?
Keith Leewis
So, for that it was our highest computer at the time, right?
Rhett Dotson
I think for most of our listeners, particularly our WPP, it’s important to recognize that at the time, something so central to our regulatory framework, it was brought into the picture was just simply due to resource limitations. We didn’t have the computational horsepower that we did today.
We don’t have computers everywhere. So, a very, a very simple means for addressing the consequence of failure was, was developed in, in the form of PIR or is it fair to say.
Keith Leewis
Yeah, so as a screening tool you have a circle running down the center of the pipeline and you’d stop every so many distances and count the houses inside the circle. And if they exceeded 20, then you went to the downstream know the upstream radius where it intersected the pipe and that was the beginning of your HCA. And then you kept going until you ran out. The houses drop below 20 and then you went to the downstream end. So, you got in. There are neither Earth and the center points. And so that was the simple way of doing it. And you’re right, we had only so much computing power. But if you notice, the HCA is a 192 invention. It’s not a B 31. So, B, 31 eight you’re supposed to do from the start to the finish. And we couldn’t do that at the time. So, when we were talking with the regulators, then we decided on using it for 20 House ‘sand that ended up to be somewhere between eight and 13% of most pipeline distances, and that means they could do that. So, but part of it, part that we had back in 2000 to 2001 with the HCA’s case was that they would eventually get longer. So, they invented MCA’s. But that took about ten years. Right. And eventually they’ll probably end up doing the entire pipeline length. Now, I think at the time decided that they would try and have all of the houses covered by about 2024 this year and have start to finish of the pipelines done by 2030.
Rhett Dotson
When you say start to finish, done, I’m sorry, what do you mean when you say start to finish done, start to finish as covered by integrity program. Start to finish with a baseline. Start to finish. What do you mean?
Keith Leewis
From pipeline milepost zero to whatever the end of it is. Right. So, 100% of your pipeline would be covered by 2030, according to what Ingo would like to have. Right by an integrity management program.
Rhett Dotson
Thank you. That’s what I was getting out, covered by an integrity measure because we decided.
Keith Leewis
No, no. Well, you’re talking s had an integrity monitor, minutes of a program for everything. The regulations had a limit to one. Yes. HCA And that was yes. Right. And then of course the states really like if you just passed three and four and had an integrity management program for all of that and eliminated all the calculations except for class one and two. So that’s how we got into the two different types of programs. So now everything is integrity management for three and four, class three and four, and the screening circle for class one and two, right? And now the screening circle for class one and two has MCA’s as well. All right. So, this is where we’re supposed to have people and we wanted to give them more protection.
Christopher De Leon
So, a couple of a couple of things to, to bring it around, Keith, if you can, for us, and this is where I want your opinion. So, you said a couple of things that I want to kind of paint a picture from for you to speak to your thoughts. You said originally it was the goal was loss of life. Right. So that’s where we want to go. But we can’t get there from the jump. And so, we put this as an industry. We put this plan in place. Right? And it started with PIR’s and then PIR’s drive or are part of how we’re understanding consequence, right? It’s part of risk management, right. So, failure, frequency and consequence, you address consequence by PIR and then regs come in and say, well, we’re only going to start IMPs on HCA cases and fast forward plus a decade now we’re bringing in MCAS. You having seen the original intent yet. You’ve seen the original intent, which is loss of life and kind of what your set up was based on the limitations of resources. We’ll do that more broadly, right? Whether it’s computers processing, people experience, we’re now fast forwarding from 2000 ish, right? Initial regs call it 02–04-time frame. Now we’re in 2023, go in 2024 for this podcast. Speak to that as to where you think the adoption and this continuous improvement component is from an industry perspective.
Rhett Dotson
Actually, you know what? I am going to give us a break on that question because I want to give Keith time. That’s a that’s a big question, which is I want to sum it up. It was a two-part question, and we’re going to address both parts, Keith, right after we take a quick break. Hang on and we’ll be right back with Pipeline. Things. Sorry, I needed to break my arteries. Then they had to redo the cameras. And Keith, my assistant from you can hear me, too. Yeah, I can hear you, too. And the audio’s back to minimal, so. Okay, I can barely hear Keith again. It’s like, great. I don’t care. We’ll see you. All right. Welcome back to Pipeline things. Thanks for taking our break where we have our guests, the esteemed Keith Lewis has been joining us as we talk about risk and where the pipeline industry was 30 years ago.
So, we left on a cliffhanger and I wanted to do it intentionally. I thought it was a good place to take a break. But, Chris, you asked the question. Yeah, and I’d like you to repeat that question again. Sure. Even though Mr. Lewis had plenty of time to think about it, give me more time to think about it.
Christopher De Leon
So, the question is, obviously, you’ve been doing this for a long time and there was a goal that was set at some point, right? Let’s call it early 2000’s. You guys put it all together. Right? Let’s fast forward. It’s at least 20 years and with the idea of it being the goal being, you know, preventing loss of life, you had an approach that was developed in resources, you had available time. But we all know that your resources are incredibly evolved and much more advanced, but we’re still using a lot of the same tools. And we’ve seen even regulation lag in a similar fashion. You being the sage that you are with all the world experience and you knew what the goal was originally to where we are now. I would like for you to just share some very authentic, potentially passionate and opinionated thoughts on kind of where we are as an industry as a whole and being able to achieve that goal of avoiding loss of life.
Rhett Dotson
Are we doing the right things or should we be doing more?
Keith Leewis
Well, we could. We’re doing really good things for the likelihood of failure. So, we’re working really hard on that part. But I think the consequence of failure has not moved an awful lot in the last 20 years for many companies. Some companies are quite a bit further ahead. So, we because we still use a screening tool and we just run it down the pipeline and that becomes HCA and now an MCA and that just turns the switch on or off. And whether you’re doing more integrity inspections, right, looking at things, inspecting things. But, you know, one of the real advantages with failure frequency is if you can granulate it that then you can zero in or where you need to spend the money. If we granularly the cut the consequences as well, then we could narrow down where we need to spend the money as well. So right now, it’s almost like a off and on switch. You either have a whole bunch of houses or you don’t. Right. And with HCA or MCA’s, it’s you have not quite as many houses, but a bunch of houses and so on either side of an HCA or in some of the smaller areas where you go through, you’ll find an MCA. So, if we take a circle, right. And so, we know that the circle is an ideal round thing and we could add things to it like the likelihood of failure, because the bigger the diameter, the more chances it will ignite. Right? And then we could add things to that, like what happens to the prevailing wind? Does the circle change? The other thing we could do is we could make it into a target symbol, you know, do you guys shop at Target? Right. For all kinds of. So, it’s like a red and white bullseye. Yeah, right.
Rhett Dotson
Substantially like I categorize our purchases every month, Keith like line by line. And the number of target purchases is astounding. And I’m thankful now that my wife does not listen to the podcast, that she will not hear me call that out.
Keith Leewis
Well, that’s a great example is the target symbol. So, the outside of the circle is the 1% lethality. Then you could use 25, 50% lethality, right? And when you run the smaller circles down, you capture different houses. Those houses would have a higher likelihood of consequence. So, you can start to get some granularity that way.
Rhett Dotson
Well, let me make an argument, Keith. What if an operator just said all you’re going to do is expand my integrity program, now?
Keith Leewis
You’re going to you’re going to separate your integrity program into more granularity and you’re only interested on the high-risk ones. Right.
Christopher De Leon
So, what are your thoughts, Keith, on why we haven’t moved that? We’ve seen that there is congressional mandate for using more data driven techniques like ILI. Why is it that we’re not seeing more on the consequence side, meaning whether it’s data integration or anything, that doesn’t mean you will dig this case because that’s the real consequence.
Keith Leewis
Yeah, there are two things. One is internally driven by the operator and the second one is regulatory driven. But regulatory driven depends on who’s holding the house. Right? And since 2002, we’ve had Republicans and Democrats switching back and forth a bunch, right? So, the MCA, I think was proposed back in the old times, back probably 06 or something like that, that by the time it worked its way through, different administrations have different emphasis on what they want done. It didn’t pop out till what, 2019 in something like that. So that’s one of the problems. The other one is the same question that Rhett asked about. Aren’t you just going to make things that I have to do more integrity that you’re still working with inside the HCA? So, but now you’re just adding a number on to your consequences. So, you’re going to sort them out into different groups with lower risk and higher risk. Don’t forget, HCAs are only doing 13% of the pipeline right? Plus, whatever is in your class three and four, which is probably less than 3% anyway for most big pipelines. So, most of the regular pipeline just gets the normal kinds of stuff, which is corrosion and leaks. Right?
Christopher De Leon
So, one of the things I remember Jerry telling me and I want to maybe shift focus, shift focus, but maybe I want to hear your thoughts on this. Right. So, Jerry, obviously he brought me into the pipeline. Well, he always had this idea of Chris, you would you have appreciated what should happen. His perspective is it’s finished. You should come together and develop a recommended sort of standard. And then that’s what we as an industry believe in and that’s how we should operate and regulators should follow in one way or another. Right. So, my question to you is, it’s obvious that you’ve been on a lot of standards committees, you’ve seen a lot of regulatory changes as it’s as an industry. Do you think that we have the right frameworks in place so that we continue to make the right decisions? Because again, we see a lot of actions and dollars being put towards assessments, but that doesn’t necessarily mean that the assessments are driving down the risk. What are your thoughts?
Keith Leewis
So that’s a two. One is you need volunteers on the standards in order to make sure that we’re working at the front end of the technology right. And that’s been harder and harder, and Rhett probably has its own opinions about how are we going to get people onto B318 and other standards. And the other one is to have the various companies, the operators have the passion to try and sharpen the pencil, to spend their money at the right spot and not over a big area. So, some companies are really doing that. So, I also sit on the CSA that 662. And so, there’ll be some new stuff coming out for risk assessment on that part. And so, they’re getting into more sophisticated analysis through that consequence end. In which way, if we’re waiting for the regulatory people to drive it, it’s taking time. So in in about 18 now 17 to 19, we had a risk assessment group that was put together by Stimson and I was on there. So, B 318 a rep for that. And so, their recommendations that came out of that and some of that will come through the regulatory since I have been involved in working with regulatory through Inga back probably before 2000 and in this century, it’s a we’ve always tried to get ahead of things, so we tried to do that with. Q But the regulatory people decided they wanted to write their own. And so there are a whole variety of different things. And when you think about the regulatory for 192, a lot of their part all has come from B 318 s, but they just maybe this is a bad word. Cherry-picked it, you know, it’s right.
Christopher De Leon
Yeah. We’re going to only incorporate the 2004 version we talked about, right. That has a variety of things, but it has the corporation used more lawyers, which was a topic on the packet when they were coming out with the latest regulation, but we didn’t see that change.
Keith Leewis
Well, they’ve been talking 2018 lately, but my personal opinion there’s 2004 was the last version we had. Both CDA and ICDA right and so they may have wanted to keep that, but both of those are now in 192. It was taken like 15 years to get them in there.
Rhett Dotson
But they’re there now, right?
Keith Leewis
So yeah, I see they didn’t actually do confirmatory direct assessment, which I think is can’t do anything. But anyway, I helped write that one too. So yeah.
Rhett Dotson
I think standards some challenges you know as we talk about trying to implement something that would be more granular in terms of consequence and the reality of there’s two sides, right? There is there’s limited resources. I’m going to say more in terms of people and maybe in terms of competency on the operator side as you get past the big operators there. And then I also think that from a regulatory perspective, I think Keith the regulators like the one off switch and tells them where they need to look and where they want me to look.
Keith Leewis
It’s good for audits.
Rhett Dotson
It’s it is good for audit. It’s right when you talk in terms of prescriptive regulation, I could see why it would be a challenge for regulators to do it. I think we should again, regulations set the minimum bar so I think operators should be encouraged to look beyond the minimum bar. But from a regulatory and an audit perspective, yeah, they’re going to favor an on off switch, not a targeted approach that has maybe a scaling zone that goes down. That’s a whole separate conversation. You know, again, I’ve been struggling in that whole prescriptive versus, well, non-prescriptive approach.
Keith Leewis
We’re not into performance based yet and we may never get there. It’s directive. So, we have the nine prescriptive threats. Right. And we know there’s a lot more than those and the granularity helps you out as well. Yeah. So yeah, so there’s a variety of things that we could talk about. Can I, can I make a plug? you talked about software. So, if you wanted to of software. It’s now DMV. Yeah, they can do consequences much better. And I work for dynamic risk as well. And they write software for these kinds of things too. So, There’s help out there. If you wanted to get more granularity and you don’t necessarily have the staff to do it yourself.
Rhett Dotson
Yeah. All right. I want to I want to let our audience know you actually a you glitched, too, there for a moment and the Internet got great We that was not an intentional you know he plugged both I was at Danica and did DMV now. Yeah, Keith I actually in as we move towards the close of the podcast, I want to hit on, I want to ask you what your thoughts are. PIR It’s been a great conversation as it pertains to natural gas, but we know a lot of the conversation in the industry is not around natural gas anymore. It’s around CO2 and hydrogen. What are your thoughts on this PR based non granular. If we’re trying to take the current methods we have and apply them to CO2 and hydrogen, what problems? What does this create? What do you think?
Keith Leewis
Well, for hydrogen, you can use the PIR. Recent work indicates that the thermal radiation from a hydrogen is both the same as methane. And if you go back to the earlier TAN 0 reports, it sounded like it was about half or 60%, but it turns out with the recent work that it’s not that it’s higher, so it’ll be about the same. So, you could use the PIR screening tool for hydrogen for CO2. It doesn’t combust and it is heavier than air. The other two are both lighter than air, so it goes straight up, right. Plus, if they’re burning, then you get thermal heat, which drags it up as well. The other one sits on the ground and runs downhill. So, it’s not going to be round. It’s going to depend on the terrain that you’re in. So, you need a whole different set of calculations to estimate what it’ll look like. So about 4% can get kind of toxic. And you so that means that it’s hard to drive, it’s hard to do those kinds of things. And when it starts getting up to 5%, then the engine and the car won’t work. And it’s even harder for yourself. And if you sit in a valley, then it may be like propane. So, it would be in a spot where the air gets pushed out of that. So, your consequences will change. But again, that too. I plugged our people to begin talking with. However, if you look at the EPA, you already have free software out there that you can grab. But again, you’ve got to have people that know how to use it or want to learn how to use it, right? So, there’s lots of free stuff to help. So, the first thing is you’ve got to figure out how much is coming out, at what rate over what time. So with thermal radiation, for example, if we close the valves and then we have a line break and we have 5 minutes to get out of the building, but the chances are there’s not a lot of help we can give for personal damage because it can take 25 minutes to an hour to get down to for thermal radiation, to get down to where the fire people can just begin to cross the EIR so they can’t even go in and do search or rescue. And so that was one of the things that I was trying to get across at that PPIM as well. And that work was done ten years ago and presented to FEMSA it as well. So, in many cases with thermal radiation, you can reduce the amount of property damage, possibly rescuing people is very difficult to find them shelter I haven’t found shelter and with CO2 you can asphyxiate people really quickly. If you don’t if you haven’t planned it out. And that’s why it’s really important to do your homework ahead of time and then to talk to your internal emergency response and also the fire and police, because they’re going to be in control. We have no control for over 20 years, so we just provide advice now.
Christopher De Leon
So, I want to I want to ask you this question, maybe look a little bit to the future. So, we at least I know we have a lot of focus on trying to do knowledge sharing, knowledge transfer, right. I mean, that’s how I learned a lot. So, I continue to try to learn to do the same for the industry and leverage experience because as we look at maybe some of the younger generation, I remember when I got hired, you spent some time on the podcast. The room’s always full of great people and it was just a few of us. And then fortunately, over the last five years or so, we put this big emphasis on hiring younger talent, WPP type organizations, bringing them in. Assuming we have some, we have some younger generation or some younger people who are in pipelines trying to do a good job. What’s the message you would give to them directly taking at least 30 years of your experience? Right. And seeing how standards developments happen, how they implemented, how operators are making decisions? What words do you give some of the younger generation that may be listening to those moments?
Keith Leewis
Yes. So the best thing is what you’ve been talking about all along is do the monitoring and get ahead of problems. Right. So that we don’t end up with ruptures If we want to talk about ruptures. And this is because now you’ve got a big problem, right, then you’re probably in need to invest some more time in figuring out the consequences and how you can stay ahead of that. All right.
Rhett Dotson
Integrity management is the best way to prevent failures.
Keith Leewis
Keep the product inside the pipeline. Right. If you can do that, because we didn’t, you know, 30 years ago, we didn’t have the same kind of ILI we have now. We also have magnetometers and things that can you can take over the line. You can find stress peaks, things of this nature as well. Plus, our CP is so much better these days, right, for corrosion and corrosion has been a major problem ever since the day one. So, the best idea to prevent problem is stay ahead of your maintenance and leak detection now. So, we have two types of leak detection. We have the B318, which is if it bubbles, you’re in troubles. And now we have yeah, that was bad. And we have EPA which is down to parts 4 million now kind of thing. Right. So, in most cases we’re interested in finding spots where the wall is thin enough that they the product is getting out. Right. And and now we can do it with aircraft stuff, with spectral looking at different wavelengths of light in order to pick up different kinds of oils and gases and things of that nature as well.
Christopher De Leon
So quick question for you, Keith. Are you being you going to be at PPIM 2024?
Keith Leewis
Well, unfortunate thing I can’t make it this year, though, so I have to be I have to be home for medical reasons this time, not mine.
Rhett Dotson
Way to go with that question, Christopher. What a terrible situation.
Keith Leewis
No, no, that’s okay. Looks like a really good program because I help put it together along with a whole variety of other people. So, you guys have lots of fun there.
Christopher De Leon
So yeah, here’s where I was going with it is it’s if you’re if you had an opportunity to listen to this podcast and if you have not met Mr. Keith Lewis, play this, next time you see him, go shake his hand and start a conversation. He might not appreciate that, but do yourself a favor.
Keith Leewis
I always appreciate it.
Rhett Dotson
Fantastic. I think that’s a great wrap up to the show. I want to say thanks for joining us. Keith and for all of the a rich history and you’ve given a lot to the pipeline industry. So yeah, thank you. Thanks for joining us and thanks for sharing. I don’t think this will be the last time we’ll talk to you because I think we’ll pick up this conversation in different forms.
Christopher De Leon
Have you had you noticed that some of the sage’s of the industry, they come on the podcast one or another uninvited and then we invite them? Yeah, I feel like there’s a trend and now he’s got his way on.
Rhett Dotson
I mean we’ll have to just having him on. It’s like there are other regulations I’m sure we need to talk about.
Keith Leewis
Well, I’m always happy, especially to talk to our young pipeliners, because that’s how information gets exchanged and TPIM is a really good one. IPC is another good one coming up as well. In September this year, though, we don’t get that many people coming up from down south. So, there are other opportunities as well. Yeah. Just buttonhole me and I’m always willing to talk right. I have opinions.
Rhett Dotson
Right. Well, fantastic. Well, I just want to say thank you and, you know, I think that’s going to wrap it up. So, thank you all for joining us on this episode of Pipeline Things. I’m your host, Rhett Dotson, and we will be back in two weeks with a different sage. Looking forward to it. Thanks. See you again in the future.
Keith Leewis
Be safe. Take care.