Christopher and Rhett are back! To kick off 2023, Pipeline Things break down RIN 2 and discuss how some pipeline traditions are now changing. They break down everything from their own family traditions to corrosion control. You’ll want to tune into this episode!
Highlights:
– Family traditions from the Dotson & De Leon households
– Given the tone of the rule change (originally high-level, now more prescriptive), could PHMSA get more prescriptive in 7 years?
– What’s different about corrosion control?
Have any questions about the episode? Submit them for Rhett & Christopher to answer in an upcoming Q&A!
Connect:
Be sure to subscribe and leave a comment or rating!
Pipeline Things is presented by D2 Integrity and produced by ADV Marketing.
Rhett Dotson
Welcome. Happy New Year to 2023 and pipeline things. Welcome back. You’re going to see more of Christopher and I this year. We’re bringing the show back to you on our standard every other week. This is the first episode we actually get into a rehash of traditions and some of them related back to maybe some of your holiday traditions as it relates to Ren 2 of the rule and Chris takes us through what are his high-level thoughts on the big changes. It’s kind of a precursor episode to some more that are upcoming. Again, welcome back this new year and we look forward to bringing you mini episodes and hope you enjoy this one. Thank you very much. All right. Hello and welcome to today’s edition of Pipeline Things. I’m your host, Rhett Dotson, and my co-host, Christopher De Leon. We’re here today where we talk about all things relevant to the pipeline industry, things that you might find interesting, things that a pipeline thing that an integrity engineer might find interesting. And the show where hopefully, maybe, I don’t know if we ever really were able to hit on moms understanding what we actually do. It was a noble attempt. It was a noble goal, to get our moms to understand what we do. Unfortunately, I can say that following the 18 episodes in our first season, I, I don’t think my parents know what I do,
Christopher de Leon
I think that’s okay. I think that’s like that’s kind of like just tradition.
Rhett Dotson
Everybody understands what my brother does. They’re like, he’s a doctor.
Christopher de Leon
But he’s also the first born. Well, I’m just saying that’s tradition, right. Like tradition is like mostly your parents follow the oldest and then they don’t maybe follow the other ones, or they don’t understand what you do. My parents don’t really know what I do either.
Rhett Dotson
Yeah, well, you know, speaking of traditions and following the holidays, that’s always a fun time. It is, because believe it or not, I actually think we have some we have some traditions in the pipeline industry, maybe regulated traditions, but traditions, nonetheless. All right. You go first. Tradition in the De Leon household on either side of the family.
Christopher de Leon
Oh, we changed it.
Rhett Dotson
Really?
Christopher de Leon
Oh, yeah. And that was fun. Actually, we didn’t get as much of this as we thought. So, Amanda and I, over the holiday seasons, always travel to four different homes, both for Christmas and Thanksgiving. That’s disastrous every year.
Rhett Dotson
Every year.
Christopher de Leon
It’s exhausting.
Rhett Dotson
Oh, that is exhausting.
Christopher de Leon
We’re not doing that anymore. We now had nobody come to our house.
Rhett Dotson
Oh, that is the way to go.
Christopher de Leon
We got the kids. You see, the kids come to the house, you eat good food, come to the house.
Rhett Dotson
That’s good stuff.
Christopher de Leon
Yeah.
Rhett Dotson
So how did they deal with that?
Christopher de Leon
Perfect.
Rhett Dotson
Oh, yeah.
Christopher de Leon
Oh, yeah. Not everybody came, but that’s okay. Cleanup was easier. We got more leftovers.
Rhett Dotson
You know, it’s funny, at ours, like, I grew up in a house, right? So, I grew up in southern Louisiana. Cooking’s a big deal down there, right? And my mom is a fabulous cook. She really is. But her meals were always like, Oh, that’s right, to Louisiana. They’re pretty. Mom. Mom’s Thanksgiving meal was a good spread. That’s also very rich, really good food. So much so that I mapped out the whole thing about 12 years ago, like down to the T of how to re cook it. But it takes a lot of time. Well, see, the last couple of years with just, you know, kids and everything being busy and I started going camping the week before thing, I was like, I don’t want to cook this. Mom doesn’t want to cook it. Let’s pick up food from somewhere. So, we’ve done Creekwood grill around the corner. This year we’re making stone cold meats, and it’s like a taboo topic in my family. Like it gets my sister kind of upset, but I’m like, you know what? I was like, so this year my wife’s like is great. The most important thing about Thanksgiving is just getting the family together. I could care less if we eat Popeye’s chicken. But no, seriously. So, this year, my wife’s like, what are you doing? And I was like, I’m just going to order it. So, I just ordered it. And, by the way, guys, I ordered the whole spread because no one wants to eat takeout. If you want to cook your own, you can. This is stone cold pizza, man. This is like a butcher I’m going to take you there after this episode, okay? We’re actually you’re going to go see.
Christopher de Leon
So, for me, mom, was always the first meal that we went to. We go to mom’s house, and mom makes everything from scratch. Obviously your mom. It’s just amazing, right? And for me, it was always the stuffing with all the yummy, gizzards and all the fixings. Right. And so, we started cooking Thanksgiving this year. And I have a tradition of because it’s Thanksgiving, I give thanks. So, I actually cook three hams, one for the family, two that we give away. Yeah. So, my stuffing isn’t on par with mom yet. The turkey is pretty good.
Rhett Dotson
Stone cold meat man. Family man. They have chorizo.
Christopher de Leon
All I can think of is Stone Cold Steve Austin. Like, that’s all I could think of.
Rhett Dotson
We’re going to Stone Cold Meats after this.
Christopher de Leon
And Stone cold, you know, Stone Cold Steve Austin is really.
Rhett Dotson
No. She wouldn’t. No. Miss producer would not know who Stone Cold Steve Austin is. Do you remember who you honestly think? Do you watch wrestling growing up? Does she look like she watched wrestling?
Christopher de Leon
So, I actually started with three, which is like the Mexican wrestling, which is where they would do all the action, just like with the massive stuff. Right? Yeah. And like, you like Nacho Libre and you’re like pulling off their hat and they’re like, no, don’t do it. And then we started watching, the American wrestling and that was just different.
You have Ric Flair, you know, he walks around doing this, you know, and then the rock dismounts the rock was cooking tradition man. The rock tradition. Now he’s going to do it if he’s black.
Rhett Dotson
Oh man. Look, we’re going to bring it round. So crazy thing is we’ve had traditions for a long time in the pipeline industry, like maybe regulated traditions, but traditions, nonetheless.
Christopher de Leon
And now we have changed those traditions.
Rhett Dotson
Now we have changed. And I think they’re kind of handling it like my family handles the change to Thanksgiving. They’ll have a tie in there. You can do it for less than leave. It’s like your kids. I don’t want to go.
So, we’re going to have a, a series here a little bit within the, within this first arc that we’re doing what we’re going to unbox. Ren 2 and so really, this is, your world more than it is mine.
So, I’m going to provide commentary, but try and lead us through this question just right. So yeah, just high level. Obviously, Ren 2 was the third one that came out in terms of numerical order. Right. So, there were three parts for those of you out there. Three parts. It is ordered as the second but came out as the third.
Yeah. Chris, is it fair to say that Ren 2 might have the most striking changes? Or is it just because we’ve adopted the 607 and material properties verification and TVC records already?
Christopher de Leon
I would say.
Rhett Dotson
Or would you say that this is more sweeping than the 6 or 7 stuff?
Christopher de Leon
Yeah, I have to use my own words here.
And I would say I think that Ren one, which was MLP reconfirmation until properties verification was like the highlights. Yeah, I think those were more impactful like programmatic changes. And I think that Ren two focuses more on augmenting processes that you already have, and it provides clarity on things that we always kind of uncertain to. So, for example, one of the topics is repair criteria.
So, you kind of already have a process for that. So, this just kind of expands it a little bit.
Rhett Dotson
So yeah, again and what I want to do is float high level on this and then we’ll start hitting on, on on dropping some of the, the bombs or the big topics that exist in Ren 2. I think it’s fair to say, as you were doing that, that Ren 1 was the first one hit on the big things that were new to the role.
Christopher de Leon
Yeah, right. I’ll say it this way. The probably the largest impacts because of San Bruno. Right. So, we have to go all the way back to San Bruno. Right. And it was that we initiated the mega rule. Yes. If we use that terminology. And then I would say that Ren 1 were kind of like those heavy hitters from San Bruno that were not likely already in, in regulated programs.
Rhett Dotson
I do think it’s fair to say that this one is taking existing things, things that you’re already doing like repair criteria. And you’re right, it is expounding ethics. Some cases being more explicit in what FEMSA wanted.
Christopher de Leon
And that goes, I mean that’s a big, big part that I think I won’t jump into too quickly. But I mean, with you, depending on which version of the Ren 2 document you read, one of the things that I like about it is it is a lot of pages.
It’s north of 200 pages. And you would say it’s probably not a fun read, but it’s very insightful. And what happens with it, if I was to give you an executive summary, is you had notice of proposed rulemaking already, kind of had the things that they were considering putting in the final rule.
And then you have the formation of the bringing together the G pack, which basically is industry leaders coming together to get feedback to FEMSA up and all that’s recorded. And then there’s comments issued by the public on that proposed rule and then FEMSA takes both the comments from feet, from the public and from G pack.
And they then potentially revise the proposed language. And so you kind of get to see that sequence of events, right? Like they’ll highlight a clause that they wanted to make changes to. Then you’ll say the g pax comments and then you’ll see industry comments, and then FEMSA will say, and now here’s the position you take. And I think that’s neat.
And that’s why it’s kind of worth reading the, the final rule. And it’s in its extended version because it kind of gives you the background for how they ended up coming to an end.
Rhett Dotson
It’s funny sometimes, you know, like, yeah, we just reject. It’s not like those rules are going to kick in like we appreciate it.
But no, this is our stance now. I kind of laugh. There’s a bit of that in there where they listen and there’s a bit of that too. But they’re like, no, we’re the FEMSA. So, we’re moms and this is what we’re cooking. And if you don’t like what we’re cooking, you can go.
Christopher de Leon
You don’t like gizzards in the stuffing.
Rhett Dotson
They’re more like, you don’t like what we’re cooking. You’re not welcome at Thanksgiving. It’s like. So you identified eight different areas, right? That the amendment and this rule clarifies that we’re going to take and, they were, you know, clarifying certain integrity management provisions.
Codifying management of change process updating and bolstering gas transmission, pipeline corrosion control requirements. Requiring operators to inspect pipelines following extreme weather events. Monitoring one. Strengthening integrity management assessment requirements. Adjusting repair criteria for our HCAs. Creating new repair criteria for HCA’s and revising or creating specific definitions related to the above amendments. So, we’re going to try and hit each one of these high levels.
At a high level we’re not. And again, there’s going to be follow up episodes. So, this is a good point for me to recommend. If you catch us on this episode, please leave a comment on LinkedIn. Direct message. Christopher. Or I. If you got a question out of this episode you want addressed in one of the follow up ones, it’d be a great idea to do that.
Christopher de Leon
So that way we can cater this to you guys. Like we have our ideas on where we think there’s emphasis, but obviously if you guys have questions where we can elaborate.
Rhett Dotson
So obviously let’s start with the I am clarifications. Right. And I know that you said a big one was related to data integration being included.
Christopher de Leon
Right. So, this is yeah, it’s a big one, I would say.
I think there were parts of that discussion that I thought was relevant just to share, not so much as a specific requirement kind of back to tradition and I think that was an important one.
Rhett Dotson
So, what do you mean elaborate on that?
Christopher de Leon
Yep. So, under item clarification they touched on at least four topics right. So, threat identification of data integration risk assessment threat assessments for plastic pipe and PNM measures.
And of those. The one that I wanted to highlight a bit was thread unification data collection and data integration. And so basically you would say traditionally, I think we do a good job of identifying the threats, going back to that list of 21 or whatever it is. Yeah, 3018 I think we do a good job is, you can see it traditionally, an operator would say, we’ve been doing this since early 2000.
So how does this change it? What? Yeah, we’ve inspected a couple times. We understand our pipeline. So, what’s their change for? And I think one of the things that I found interesting when I read it was that FEMSA reiterated the importance of your integrity program evolving. And so, what they basically said was it’s the expectation was at first was you had a framework that kind of set your initial processes.
But their expectation is that your program is continuously evolving. And so, it seems like they’re wanting you to be able to demonstrate how your program is changing based on the information, the data collection and the data integration that you’re using. And so, an example of that would be, they would say they’re very explicit. They say, hey, for, you know, as a minimum requirement and you need to satisfy appendix A of B 3018S.
And, and you would say, but I think I do that, and you would say, so the organic question that from someone like you as pragmatic is yours. You would say, well, I think I’m doing that.
Rhett Dotson
I’m looking through it, Chris. There’s, there’s a lot it’s a lot more prescriptive than just 30 18S. Right. There you have it. They give an explicit list of things that they want integrated from a data perspective.
that’s more I’d say exhaustive. Like if we were just saying looking at the threats and data integration 30 18S there’s more in here now.
Christopher de Leon
Yeah. And but again, it’s worth a read. And so, some of the highlights of all of that that I would probably bring forward is because as a listener you’re probably saying, hey, we look at this all the time.
So, I wanted to try to find something to maybe make you think a little bit. And what they say is it’s one, how are you demonstrating that your program is evolving? And I think the second thing that I thought was interesting and GPAC commented on was it’s how you are accounting for SME input into the data integration. Because think about it.
When you’re going to run risk, you have you must have data. And one of those inputs is for example, you have a facility and you’re not able to run an inspection. So, what do you do. You call your corrosion tech, and you get some input.
Rhett Dotson
So, I look Chris, my own person, my own opinion here is again that I feel like FEMSA is trying to push operators to integrate more and better data into their risk model.
I think if you look at the minimum requirements for data integration, an operator could say we integrate soil information and CP and that’s our data integration. And I think FEMSA are saying I want more. I want to understand how this feeds into your risk model. And they’re pushing for it. Right. Because what they’re trying to say is when we said we wanted a risk model, we wanted you to really have a robust risk model.
Christopher de Leon
But I would say is, is that, you know, our industry is I mean, it’s different right now.
Rhett Dotson
So, my question to you.
Do you. So, what we’ve seen again, I’m following the tone of the rule change. Originally given as a high level. Now giving more prescriptive. Is there a step forward that you see firms that could take another seven years where they could say, look, we wanted you all to do this with data integration.
And they could really get even more prescriptive on this threat identification data stuff than they do now, because they added a lot.
Christopher de Leon
Yeah. It’s hard to say what to do in seven years, because I think they really leverage the results of the inspections, IE audits and I would say one in the discussion. So, one of the things that I felt people were doing basically, and so one of the things that they really highlighted was SME bias and how your document in that, and they highlight two very specific components.
What control measures do you have on your SME inputs? You can’t just take their word for it. So, they want to see for some input. What are your controls. And the second thing they require now is we want their names and their qualifications. And so, if you think of the prior to REN 2, you would say this operator says they data integrate.
Well what data Walmart SME input. They’re now saying well what qualifies as SME. Who are they and what kind of control measures do you have? So, I would say in seven years or ten years or 15 years, they would probably see how functional this is.
Rhett Dotson
SME qualification I get. Can I get a little can I get a plaque “FEMSA Approved SME”.
All right. Some of the lesser ones. You mentioned management to change a high level. What’s going on there? And this is sections one 9213 and 192.
Christopher de Leon
Now what I think what I would highlight for our readers or our listeners here and watchers is, I think it’s 192, section 909 and I remember the title of it, but basically says if there are significant changes that are impactful to your plan and your program, you need to notify FEMSA.
So and so that’s just what I would give you as a takeaway. You have REN 1. You have REN 2 for your traditional you know I am programs. If any of these changes are fundamentally changing the way you do things. For example, now maybe the use of an SME as an example, right. You need to let FEMSA know.
And I think that’s something to think about.
Rhett Dotson
Okay. I want to hit one more before we take a break here. So, what’s up with corrosion control? So, in section 935, I mean, obviously there’s a whole bunch, but you mentioned some stuff related to measures on corrosion control. What’s hitting you different there.
Christopher de Leon
Yeah. So again, I like what you said that like what’s different there. What I would say is it’s I mean I followed the GPC meetings and, and all the commentary closely. And I think, something that I observed from this different than kind of maybe the converse of what you said earlier, where sometimes FEMSA is just like, no, I disagree with you.
This is what we’re going to do. I think this is a good example where FEMSA are really took to industry’s comments. And, they had proposed putting additional corrosion control measures, in subpart O and for us for you guys, again, support is specific to integrity management for ECAs. And what industry came back with was it’s we think that subpart I which is for corrosion control.
It has enough there. And you should stay within the confines of subpart I. And basically, we see FEMSA agreeing and saying you know what. We’re not going to put additional P specific for corrosion control in subpart O. We’re going to go on ahead and leave it where it is. So, if you were expecting to see changes in 935 related corrosion control and measures, you’re not going to find it.
They left it within the confines of, subpart I, which I think was neat. Right. That was a good example of industry saying hey FEMSA, let’s talk about this. And FEMSA was like, you know what? You got a point.
Rhett Dotson
Yeah. It’s good you can bring it, you know what? We’ll let the breadcrumb rusting come to Thanksgiving this year I like that.
All right. Hey, we are going to take a break as we continue our flyby on REN 2, where we’re going to hit a few more topics and we’ll be right back with us. Thank you.
Kara Turner
Hi, I’m Kara Turner. I am the managing director and co-founder of ADV marketing. We get the honor of working with Rhett and Christopher to produce this crazy podcast, and work with them on any other initiatives that they have when it comes to marketing. And if you know them or listening to this podcast, do you know that it gets crazy around here?
So, we have a lot of fun with them. ADV marketing is a full-service business to business marketing agency. We specialize in service companies and technology companies. So if you are enjoying listening to this podcast and the fun that they’re having, reach out to us and see how we can make your marketing fun.
Rhett Dotson
All right. Hey, welcome back to Pipeline Things. Your host here. And again, you know, the goal of these episodes to kind of, you know, just drop bombs and let you know where we’re going because we’re going to be talking about a lot of these in detail.
So, we feel like you got a high-level hit. There’s going to be more to come on each one of them. So, we left off as we finished talking about the PNM measures for corrosion control. And the next bullet point on your list. Chris was inspected following extreme weather events.
Christopher de Leon
Yeah. So that one quick background again the proposed rules said something of the effect of following extreme event.
You have 72 hours to go find out if there is an integrity threat, an active threat that you need to act on. And looking through the back and forth of the process that is, is described. What you’ll see is that what they what it seems like they’ve come to is this, this, this idea of cessation.
Right. So, after the extreme event has passed and you can safely access the site with equipment and personnel to perform an inspection, you then have 72 hours to respond to the integrity threat caused by an extreme weather event.
Rhett Dotson
Yeah. So, let’s run that down because that’s interesting in it sweeping. Right. So, I just want to give a again I want to give people some perspective on this now.
613 C yeah, following an extreme weather event or natural disaster that has the likelihood of damage to pipeline facilities. I’m curious how you would determine that by the scouring or movement of the soil surrounding the pipeline or movement of the pipeline. So, the definition is having a likelihood of damage by moving the pipeline. Then it gets a specific list such as a named tropical storm or hurricane or a flood that exceeds the river.
Shoreline or creek. High water banks in the pipeline, a landslide in the pipeline, or an earthquake in the pipeline and operator must inspect all potentially affected onshore transmission pipeline facilities to detect conditions that could adversely affect the safe operation of the pipeline. It’s sweeping, and it says an operator must commence the inspection required by that paragraph within 72 hours after the point in time when the operator reasonably determines that the affected area can be safely assessed, accessed. So that’s interesting. So, it says you must commence the inspection, which means start. But it also means you must understand where all your pipes that I’m sorry, like as I read it, I think that’s onerous, right.
Christopher de Leon
It depends on the maturity of your geo hazards program.
Rhett Dotson
So, let’s stop. Have you ever looked at a pipeline map from FEMSA? And have you seen how many pipelines are in South Louisiana on the south coast of Texas?
Christopher de Leon
So why is that relevant?
Rhett Dotson
Because, I mean, those are all regulated, covered pipelines.
And if a hurricane comes through a tropical storm or a tropical storm. Yes. I don’t see how you say it didn’t potentially adversely affect them. I don’t know how as an operator, you get to saying, hey, Tropical Storm Gustav did not impact my pipeline. Therefore, this isn’t applicable to me. I think it’s more likely it feels like it’s saying that if it if it came through, you almost must assume that it impacted your pipeline.
Unless you’re 60ft deep. I see this as yeah, the impact on this,
Christopher de Leon
you might be going a little bit overboard.
Rhett Dotson
I’m just saying the impact of this. We’ll look in Louisiana too. When you get down there, there’s a lot of things like that.
Christopher de Leon
I would say that’s parallel to you interacting with gators in south Louisiana. Operators have been operating pipelines in there for a long time. They understand their assets.
Rhett Dotson
A flood that exceeds the river. I’m just saying there’s a lot of pipelines.
Christopher de Leon
They also have personnel that go and rock the water.
I just I think of the day owners at the end of the day. I think it just depends on the maturity of your geo hazards program.
Rhett Dotson
We’re going to get into it later. Yeah. I think the takeaway is this is you an operator operate near rivers, operate near anywhere.
That could have potential geo hazards. You need to recognize at 613 could impact you, and it’s got to be built into your plan. All right. I think one of the more interesting ones comes out of section E, which is or I’m sorry, your F, which is the. Well, it’s e
Let’s do E because this is a big one. Stress corrosion cracking. Direct assessment. Why is that a big deal and why is Ren 2dropping that a big deal Christopher.
Christopher de Leon
There are different ways to think about it. So, this is where the consultant has an opinion. Right. So, I think my general position is that you have to be very careful about the decisions you make based on your, your threat susceptibility models that you have, especially if they’re SME based.
You normally want them to be data based because we’ve seen time and time again how imat tools for gas lines have proven susceptibility models. Wrong and that you’re not susceptible or you haven’t found it. Now I think we need to separate there a bit so that you may have some that you can buff out or sand out within, say 10, 15% of your pipe wall.
And that means they’re just not critical, right? And so, I would say keeping that in mind, I think what this does, it’s if you have a really good grasp on your threat of SEC, this gives you a tool. Let’s say you’re I’ve, I’ve already done two e mats, and you really got your SEC under control. This could be a good tool for you to alternate with Ili to serve as an integrity assessment.
So that’s one approach. We’re not saying that is the approach.
Rhett Dotson
Prior to this change in 923 C and 929 SEC, DEA permitted as an assessment method for stress corrosion cracking.
Christopher de Leon
I would have to say the answer is yes. But what I think also is it’s what we see here specifically is that it incorporates by reference SP 0204 right.
And so, I think that’s really where we have the biggest change in the next document, which is a standard. Right? So, it’s not an RPP. It’s a standard that’s been incorporated by reference.
Rhett Dotson
Do you think the changes here will lead to increased competition between DEA and Imat?
Christopher de Leon
I don’t know if competition is the word I would use.
I don’t think that’s competition. I think that is them assessing how much data they have, and which of those two tools best fits their program and their level of threat.
So, let’s be clear about this. So, let’s say you have a pipeline that’s right. At 30 years old and you haven’t found it yet. You might want to go do some SEC DEA and not take the investment in the journey where an EMAT will be. Right. So that’s one example of how it’s not that it’s competing, but rather it’s what’s the right tool for me right now.
Rhett Dotson
Hey, hey, here’s your chance. You can ask us questions. Or alternatively, you’re also going to see us interviewing a lot of guests. So, it’s like I say, welcome to the 2023 Arc for Pipeline Things. Thank you for joining us. And stick around. It’s going to be a great new year. Just want to say Happy New Year and welcome back.
Thank you. I am your host Dotson and my co-host Christopher De Leon. And we’ll see you again next time.
Welcome. Happy New Year to 2023 and pipeline things. Welcome back. You’re going to see more of Christopher and I this year. We’re bringing the show back to you on our standard every other week. This is the first episode we actually get into a rehash of traditions and some of them related back to maybe some of your holiday traditions as it relates to Ren 2 of the rule and Chris takes us through what are his high-level thoughts on the big changes. It’s kind of a precursor episode to some more that are upcoming. Again, welcome back this new year and we look forward to bringing you mini episodes and hope you enjoy this one. Thank you very much. All right. Hello and welcome to today’s edition of Pipeline Things. I’m your host, Rhett Dotson, and my co-host, Christopher De Leon. We’re here today where we talk about all things relevant to the pipeline industry, things that you might find interesting, things that a pipeline thing that an integrity engineer might find interesting. And the show where hopefully, maybe, I don’t know if we ever really were able to hit on moms understanding what we actually do. It was a noble attempt. It was a noble goal, to get our moms to understand what we do. Unfortunately, I can say that following the 18 episodes in our first season, I, I don’t think my parents know what I do,
Christopher de Leon
I think that’s okay. I think that’s like that’s kind of like just tradition.
Rhett Dotson
Everybody understands what my brother does. They’re like, he’s a doctor.
Christopher de Leon
But he’s also the first born. Well, I’m just saying that’s tradition, right. Like tradition is like mostly your parents follow the oldest and then they don’t maybe follow the other ones, or they don’t understand what you do. My parents don’t really know what I do either.
Rhett Dotson
Yeah, well, you know, speaking of traditions and following the holidays, that’s always a fun time. It is, because believe it or not, I actually think we have some we have some traditions in the pipeline industry, maybe regulated traditions, but traditions, nonetheless. All right. You go first. Tradition in the De Leon household on either side of the family.
Christopher de Leon
Oh, we changed it.
Rhett Dotson
Really?
Christopher de Leon
Oh, yeah. And that was fun. Actually, we didn’t get as much of this as we thought. So, Amanda and I, over the holiday seasons, always travel to four different homes, both for Christmas and Thanksgiving. That’s disastrous every year.
Rhett Dotson
Every year.
Christopher de Leon
It’s exhausting.
Rhett Dotson
Oh, that is exhausting.
Christopher de Leon
We’re not doing that anymore. We now had nobody come to our house.
Rhett Dotson
Oh, that is the way to go.
Christopher de Leon
We got the kids. You see, the kids come to the house, you eat good food, come to the house.
Rhett Dotson
That’s good stuff.
Christopher de Leon
Yeah.
Rhett Dotson
So how did they deal with that?
Christopher de Leon
Perfect.
Rhett Dotson
Oh, yeah.
Christopher de Leon
Oh, yeah. Not everybody came, but that’s okay. Cleanup was easier. We got more leftovers.
Rhett Dotson
You know, it’s funny, at ours, like, I grew up in a house, right? So, I grew up in southern Louisiana. Cooking’s a big deal down there, right? And my mom is a fabulous cook. She really is. But her meals were always like, Oh, that’s right, to Louisiana. They’re pretty. Mom. Mom’s Thanksgiving meal was a good spread. That’s also very rich, really good food. So much so that I mapped out the whole thing about 12 years ago, like down to the T of how to re cook it. But it takes a lot of time. Well, see, the last couple of years with just, you know, kids and everything being busy and I started going camping the week before thing, I was like, I don’t want to cook this. Mom doesn’t want to cook it. Let’s pick up food from somewhere. So, we’ve done Creekwood grill around the corner. This year we’re making stone cold meats, and it’s like a taboo topic in my family. Like it gets my sister kind of upset, but I’m like, you know what? I was like, so this year my wife’s like is great. The most important thing about Thanksgiving is just getting the family together. I could care less if we eat Popeye’s chicken. But no, seriously. So, this year, my wife’s like, what are you doing? And I was like, I’m just going to order it. So, I just ordered it. And, by the way, guys, I ordered the whole spread because no one wants to eat takeout. If you want to cook your own, you can. This is stone cold pizza, man. This is like a butcher I’m going to take you there after this episode, okay? We’re actually you’re going to go see.
Christopher de Leon
So, for me, mom, was always the first meal that we went to. We go to mom’s house, and mom makes everything from scratch. Obviously your mom. It’s just amazing, right? And for me, it was always the stuffing with all the yummy, gizzards and all the fixings. Right. And so, we started cooking Thanksgiving this year. And I have a tradition of because it’s Thanksgiving, I give thanks. So, I actually cook three hams, one for the family, two that we give away. Yeah. So, my stuffing isn’t on par with mom yet. The turkey is pretty good.
Rhett Dotson
Stone cold meat man. Family man. They have chorizo.
Christopher de Leon
All I can think of is Stone Cold Steve Austin. Like, that’s all I could think of.
Rhett Dotson
We’re going to Stone Cold Meats after this.
Christopher de Leon
And Stone cold, you know, Stone Cold Steve Austin is really.
Rhett Dotson
No. She wouldn’t. No. Miss producer would not know who Stone Cold Steve Austin is. Do you remember who you honestly think? Do you watch wrestling growing up? Does she look like she watched wrestling?
Christopher de Leon
So, I actually started with three, which is like the Mexican wrestling, which is where they would do all the action, just like with the massive stuff. Right? Yeah. And like, you like Nacho Libre and you’re like pulling off their hat and they’re like, no, don’t do it. And then we started watching, the American wrestling and that was just different.
You have Ric Flair, you know, he walks around doing this, you know, and then the rock dismounts the rock was cooking tradition man. The rock tradition. Now he’s going to do it if he’s black.
Rhett Dotson
Oh man. Look, we’re going to bring it round. So crazy thing is we’ve had traditions for a long time in the pipeline industry, like maybe regulated traditions, but traditions, nonetheless.
Christopher de Leon
And now we have changed those traditions.
Rhett Dotson
Now we have changed. And I think they’re kind of handling it like my family handles the change to Thanksgiving. They’ll have a tie in there. You can do it for less than leave. It’s like your kids. I don’t want to go.
So, we’re going to have a, a series here a little bit within the, within this first arc that we’re doing what we’re going to unbox. Ren 2 and so really, this is, your world more than it is mine.
So, I’m going to provide commentary, but try and lead us through this question just right. So yeah, just high level. Obviously, Ren 2 was the third one that came out in terms of numerical order. Right. So, there were three parts for those of you out there. Three parts. It is ordered as the second but came out as the third.
Yeah. Chris, is it fair to say that Ren 2 might have the most striking changes? Or is it just because we’ve adopted the 607 and material properties verification and TVC records already?
Christopher de Leon
I would say.
Rhett Dotson
Or would you say that this is more sweeping than the 6 or 7 stuff?
Christopher de Leon
Yeah, I have to use my own words here.
And I would say I think that Ren one, which was MLP reconfirmation until properties verification was like the highlights. Yeah, I think those were more impactful like programmatic changes. And I think that Ren two focuses more on augmenting processes that you already have, and it provides clarity on things that we always kind of uncertain to. So, for example, one of the topics is repair criteria.
So, you kind of already have a process for that. So, this just kind of expands it a little bit.
Rhett Dotson
So yeah, again and what I want to do is float high level on this and then we’ll start hitting on, on on dropping some of the, the bombs or the big topics that exist in Ren 2. I think it’s fair to say, as you were doing that, that Ren 1 was the first one hit on the big things that were new to the role.
Christopher de Leon
Yeah, right. I’ll say it this way. The probably the largest impacts because of San Bruno. Right. So, we have to go all the way back to San Bruno. Right. And it was that we initiated the mega rule. Yes. If we use that terminology. And then I would say that Ren 1 were kind of like those heavy hitters from San Bruno that were not likely already in, in regulated programs.
Rhett Dotson
I do think it’s fair to say that this one is taking existing things, things that you’re already doing like repair criteria. And you’re right, it is expounding ethics. Some cases being more explicit in what FEMSA wanted.
Christopher de Leon
And that goes, I mean that’s a big, big part that I think I won’t jump into too quickly. But I mean, with you, depending on which version of the Ren 2 document you read, one of the things that I like about it is it is a lot of pages.
It’s north of 200 pages. And you would say it’s probably not a fun read, but it’s very insightful. And what happens with it, if I was to give you an executive summary, is you had notice of proposed rulemaking already, kind of had the things that they were considering putting in the final rule.
And then you have the formation of the bringing together the G pack, which basically is industry leaders coming together to get feedback to FEMSA up and all that’s recorded. And then there’s comments issued by the public on that proposed rule and then FEMSA takes both the comments from feet, from the public and from G pack.
And they then potentially revise the proposed language. And so you kind of get to see that sequence of events, right? Like they’ll highlight a clause that they wanted to make changes to. Then you’ll say the g pax comments and then you’ll see industry comments, and then FEMSA will say, and now here’s the position you take. And I think that’s neat.
And that’s why it’s kind of worth reading the, the final rule. And it’s in its extended version because it kind of gives you the background for how they ended up coming to an end.
Rhett Dotson
It’s funny sometimes, you know, like, yeah, we just reject. It’s not like those rules are going to kick in like we appreciate it.
But no, this is our stance now. I kind of laugh. There’s a bit of that in there where they listen and there’s a bit of that too. But they’re like, no, we’re the FEMSA. So, we’re moms and this is what we’re cooking. And if you don’t like what we’re cooking, you can go.
Christopher de Leon
You don’t like gizzards in the stuffing.
Rhett Dotson
They’re more like, you don’t like what we’re cooking. You’re not welcome at Thanksgiving. It’s like. So you identified eight different areas, right? That the amendment and this rule clarifies that we’re going to take and, they were, you know, clarifying certain integrity management provisions.
Codifying management of change process updating and bolstering gas transmission, pipeline corrosion control requirements. Requiring operators to inspect pipelines following extreme weather events. Monitoring one. Strengthening integrity management assessment requirements. Adjusting repair criteria for our HCAs. Creating new repair criteria for HCA’s and revising or creating specific definitions related to the above amendments. So, we’re going to try and hit each one of these high levels.
At a high level we’re not. And again, there’s going to be follow up episodes. So, this is a good point for me to recommend. If you catch us on this episode, please leave a comment on LinkedIn. Direct message. Christopher. Or I. If you got a question out of this episode you want addressed in one of the follow up ones, it’d be a great idea to do that.
Christopher de Leon
So that way we can cater this to you guys. Like we have our ideas on where we think there’s emphasis, but obviously if you guys have questions where we can elaborate.
Rhett Dotson
So obviously let’s start with the I am clarifications. Right. And I know that you said a big one was related to data integration being included.
Christopher de Leon
Right. So, this is yeah, it’s a big one, I would say.
I think there were parts of that discussion that I thought was relevant just to share, not so much as a specific requirement kind of back to tradition and I think that was an important one.
Rhett Dotson
So, what do you mean elaborate on that?
Christopher de Leon
Yep. So, under item clarification they touched on at least four topics right. So, threat identification of data integration risk assessment threat assessments for plastic pipe and PNM measures.
And of those. The one that I wanted to highlight a bit was thread unification data collection and data integration. And so basically you would say traditionally, I think we do a good job of identifying the threats, going back to that list of 21 or whatever it is. Yeah, 3018 I think we do a good job is, you can see it traditionally, an operator would say, we’ve been doing this since early 2000.
So how does this change it? What? Yeah, we’ve inspected a couple times. We understand our pipeline. So, what’s their change for? And I think one of the things that I found interesting when I read it was that FEMSA reiterated the importance of your integrity program evolving. And so, what they basically said was it’s the expectation was at first was you had a framework that kind of set your initial processes.
But their expectation is that your program is continuously evolving. And so, it seems like they’re wanting you to be able to demonstrate how your program is changing based on the information, the data collection and the data integration that you’re using. And so, an example of that would be, they would say they’re very explicit. They say, hey, for, you know, as a minimum requirement and you need to satisfy appendix A of B 3018S.
And, and you would say, but I think I do that, and you would say, so the organic question that from someone like you as pragmatic is yours. You would say, well, I think I’m doing that.
Rhett Dotson
I’m looking through it, Chris. There’s, there’s a lot it’s a lot more prescriptive than just 30 18S. Right. There you have it. They give an explicit list of things that they want integrated from a data perspective.
that’s more I’d say exhaustive. Like if we were just saying looking at the threats and data integration 30 18S there’s more in here now.
Christopher de Leon
Yeah. And but again, it’s worth a read. And so, some of the highlights of all of that that I would probably bring forward is because as a listener you’re probably saying, hey, we look at this all the time.
So, I wanted to try to find something to maybe make you think a little bit. And what they say is it’s one, how are you demonstrating that your program is evolving? And I think the second thing that I thought was interesting and GPAC commented on was it’s how you are accounting for SME input into the data integration. Because think about it.
When you’re going to run risk, you have you must have data. And one of those inputs is for example, you have a facility and you’re not able to run an inspection. So, what do you do. You call your corrosion tech, and you get some input.
Rhett Dotson
So, I look Chris, my own person, my own opinion here is again that I feel like FEMSA is trying to push operators to integrate more and better data into their risk model.
I think if you look at the minimum requirements for data integration, an operator could say we integrate soil information and CP and that’s our data integration. And I think FEMSA are saying I want more. I want to understand how this feeds into your risk model. And they’re pushing for it. Right. Because what they’re trying to say is when we said we wanted a risk model, we wanted you to really have a robust risk model.
Christopher de Leon
But I would say is, is that, you know, our industry is I mean, it’s different right now.
Rhett Dotson
So, my question to you.
Do you. So, what we’ve seen again, I’m following the tone of the rule change. Originally given as a high level. Now giving more prescriptive. Is there a step forward that you see firms that could take another seven years where they could say, look, we wanted you all to do this with data integration.
And they could really get even more prescriptive on this threat identification data stuff than they do now, because they added a lot.
Christopher de Leon
Yeah. It’s hard to say what to do in seven years, because I think they really leverage the results of the inspections, IE audits and I would say one in the discussion. So, one of the things that I felt people were doing basically, and so one of the things that they really highlighted was SME bias and how your document in that, and they highlight two very specific components.
What control measures do you have on your SME inputs? You can’t just take their word for it. So, they want to see for some input. What are your controls. And the second thing they require now is we want their names and their qualifications. And so, if you think of the prior to REN 2, you would say this operator says they data integrate.
Well what data Walmart SME input. They’re now saying well what qualifies as SME. Who are they and what kind of control measures do you have? So, I would say in seven years or ten years or 15 years, they would probably see how functional this is.
Rhett Dotson
SME qualification I get. Can I get a little can I get a plaque “FEMSA Approved SME”.
All right. Some of the lesser ones. You mentioned management to change a high level. What’s going on there? And this is sections one 9213 and 192.
Christopher de Leon
Now what I think what I would highlight for our readers or our listeners here and watchers is, I think it’s 192, section 909 and I remember the title of it, but basically says if there are significant changes that are impactful to your plan and your program, you need to notify FEMSA.
So and so that’s just what I would give you as a takeaway. You have REN 1. You have REN 2 for your traditional you know I am programs. If any of these changes are fundamentally changing the way you do things. For example, now maybe the use of an SME as an example, right. You need to let FEMSA know.
And I think that’s something to think about.
Rhett Dotson
Okay. I want to hit one more before we take a break here. So, what’s up with corrosion control? So, in section 935, I mean, obviously there’s a whole bunch, but you mentioned some stuff related to measures on corrosion control. What’s hitting you different there.
Christopher de Leon
Yeah. So again, I like what you said that like what’s different there. What I would say is it’s I mean I followed the GPC meetings and, and all the commentary closely. And I think, something that I observed from this different than kind of maybe the converse of what you said earlier, where sometimes FEMSA is just like, no, I disagree with you.
This is what we’re going to do. I think this is a good example where FEMSA are really took to industry’s comments. And, they had proposed putting additional corrosion control measures, in subpart O and for us for you guys, again, support is specific to integrity management for ECAs. And what industry came back with was it’s we think that subpart I which is for corrosion control.
It has enough there. And you should stay within the confines of subpart I. And basically, we see FEMSA agreeing and saying you know what. We’re not going to put additional P specific for corrosion control in subpart O. We’re going to go on ahead and leave it where it is. So, if you were expecting to see changes in 935 related corrosion control and measures, you’re not going to find it.
They left it within the confines of, subpart I, which I think was neat. Right. That was a good example of industry saying hey FEMSA, let’s talk about this. And FEMSA was like, you know what? You got a point.
Rhett Dotson
Yeah. It’s good you can bring it, you know what? We’ll let the breadcrumb rusting come to Thanksgiving this year I like that.
All right. Hey, we are going to take a break as we continue our flyby on REN 2, where we’re going to hit a few more topics and we’ll be right back with us. Thank you.
Kara Turner
Hi, I’m Kara Turner. I am the managing director and co-founder of ADV marketing. We get the honor of working with Rhett and Christopher to produce this crazy podcast, and work with them on any other initiatives that they have when it comes to marketing. And if you know them or listening to this podcast, do you know that it gets crazy around here?
So, we have a lot of fun with them. ADV marketing is a full-service business to business marketing agency. We specialize in service companies and technology companies. So if you are enjoying listening to this podcast and the fun that they’re having, reach out to us and see how we can make your marketing fun.
Rhett Dotson
All right. Hey, welcome back to Pipeline Things. Your host here. And again, you know, the goal of these episodes to kind of, you know, just drop bombs and let you know where we’re going because we’re going to be talking about a lot of these in detail.
So, we feel like you got a high-level hit. There’s going to be more to come on each one of them. So, we left off as we finished talking about the PNM measures for corrosion control. And the next bullet point on your list. Chris was inspected following extreme weather events.
Christopher de Leon
Yeah. So that one quick background again the proposed rules said something of the effect of following extreme event.
You have 72 hours to go find out if there is an integrity threat, an active threat that you need to act on. And looking through the back and forth of the process that is, is described. What you’ll see is that what they what it seems like they’ve come to is this, this, this idea of cessation.
Right. So, after the extreme event has passed and you can safely access the site with equipment and personnel to perform an inspection, you then have 72 hours to respond to the integrity threat caused by an extreme weather event.
Rhett Dotson
Yeah. So, let’s run that down because that’s interesting in it sweeping. Right. So, I just want to give a again I want to give people some perspective on this now.
613 C yeah, following an extreme weather event or natural disaster that has the likelihood of damage to pipeline facilities. I’m curious how you would determine that by the scouring or movement of the soil surrounding the pipeline or movement of the pipeline. So, the definition is having a likelihood of damage by moving the pipeline. Then it gets a specific list such as a named tropical storm or hurricane or a flood that exceeds the river.
Shoreline or creek. High water banks in the pipeline, a landslide in the pipeline, or an earthquake in the pipeline and operator must inspect all potentially affected onshore transmission pipeline facilities to detect conditions that could adversely affect the safe operation of the pipeline. It’s sweeping, and it says an operator must commence the inspection required by that paragraph within 72 hours after the point in time when the operator reasonably determines that the affected area can be safely assessed, accessed. So that’s interesting. So, it says you must commence the inspection, which means start. But it also means you must understand where all your pipes that I’m sorry, like as I read it, I think that’s onerous, right.
Christopher de Leon
It depends on the maturity of your geo hazards program.
Rhett Dotson
So, let’s stop. Have you ever looked at a pipeline map from FEMSA? And have you seen how many pipelines are in South Louisiana on the south coast of Texas?
Christopher de Leon
So why is that relevant?
Rhett Dotson
Because, I mean, those are all regulated, covered pipelines.
And if a hurricane comes through a tropical storm or a tropical storm. Yes. I don’t see how you say it didn’t potentially adversely affect them. I don’t know how as an operator, you get to saying, hey, Tropical Storm Gustav did not impact my pipeline. Therefore, this isn’t applicable to me. I think it’s more likely it feels like it’s saying that if it if it came through, you almost must assume that it impacted your pipeline.
Unless you’re 60ft deep. I see this as yeah, the impact on this,
Christopher de Leon
you might be going a little bit overboard.
Rhett Dotson
I’m just saying the impact of this. We’ll look in Louisiana too. When you get down there, there’s a lot of things like that.
Christopher de Leon
I would say that’s parallel to you interacting with gators in south Louisiana. Operators have been operating pipelines in there for a long time. They understand their assets.
Rhett Dotson
A flood that exceeds the river. I’m just saying there’s a lot of pipelines.
Christopher de Leon
They also have personnel that go and rock the water.
I just I think of the day owners at the end of the day. I think it just depends on the maturity of your geo hazards program.
Rhett Dotson
We’re going to get into it later. Yeah. I think the takeaway is this is you an operator operate near rivers, operate near anywhere.
That could have potential geo hazards. You need to recognize at 613 could impact you, and it’s got to be built into your plan. All right. I think one of the more interesting ones comes out of section E, which is or I’m sorry, your F, which is the. Well, it’s e
Let’s do E because this is a big one. Stress corrosion cracking. Direct assessment. Why is that a big deal and why is Ren 2dropping that a big deal Christopher.
Christopher de Leon
There are different ways to think about it. So, this is where the consultant has an opinion. Right. So, I think my general position is that you have to be very careful about the decisions you make based on your, your threat susceptibility models that you have, especially if they’re SME based.
You normally want them to be data based because we’ve seen time and time again how imat tools for gas lines have proven susceptibility models. Wrong and that you’re not susceptible or you haven’t found it. Now I think we need to separate there a bit so that you may have some that you can buff out or sand out within, say 10, 15% of your pipe wall.
And that means they’re just not critical, right? And so, I would say keeping that in mind, I think what this does, it’s if you have a really good grasp on your threat of SEC, this gives you a tool. Let’s say you’re I’ve, I’ve already done two e mats, and you really got your SEC under control. This could be a good tool for you to alternate with Ili to serve as an integrity assessment.
So that’s one approach. We’re not saying that is the approach.
Rhett Dotson
Prior to this change in 923 C and 929 SEC, DEA permitted as an assessment method for stress corrosion cracking.
Christopher de Leon
I would have to say the answer is yes. But what I think also is it’s what we see here specifically is that it incorporates by reference SP 0204 right.
And so, I think that’s really where we have the biggest change in the next document, which is a standard. Right? So, it’s not an RPP. It’s a standard that’s been incorporated by reference.
Rhett Dotson
Do you think the changes here will lead to increased competition between DEA and Imat?
Christopher de Leon
I don’t know if competition is the word I would use.
I don’t think that’s competition. I think that is them assessing how much data they have, and which of those two tools best fits their program and their level of threat.
So, let’s be clear about this. So, let’s say you have a pipeline that’s right. At 30 years old and you haven’t found it yet. You might want to go do some SEC DEA and not take the investment in the journey where an EMAT will be. Right. So that’s one example of how it’s not that it’s competing, but rather it’s what’s the right tool for me right now.
Rhett Dotson
Hey, hey, here’s your chance. You can ask us questions. Or alternatively, you’re also going to see us interviewing a lot of guests. So, it’s like I say, welcome to the 2023 Arc for Pipeline Things. Thank you for joining us. And stick around. It’s going to be a great new year. Just want to say Happy New Year and welcome back.
Thank you. I am your host Dotson and my co-host Christopher De Leon. And we’ll see you again next time.