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The Failure Files: What on Earth is Happening with Geohazards?

Nov 29, 2023 | Failure Files

On May 4th, 2020, a 30-inch natural gas line ruptured in Hillsboro, Kentucky due to a recognized geohazard threat that wasn’t mitigated in time. In this special season of Pipeline Things: The Failure Files, Chris and Rhett dive into the NTSB reports of significant pipeline failures and the impact they’ve had on modern-day integrity management programs. Understand the rising threat of geohazards and how to prevent them in this episode of Pipeline Things.

In the words of Dr. Dave, there are two kinds of operators – those that have recognized the threat of geohazards and those that haven’t.

To wrap up The Failure Files season, Rhett and Chris discuss a 2020 event in Hillsboro, Kentucky related to geohazard threat management. More operators are becoming aware of the threat of geohazards and working to implement proper management techniques. Rhett and Chris discuss what those proper management techniques look like, and what integrity managers should consider.

Highlights:

  • What makes geohazards different from other threats we’ve discussed in this arc?
  • How do we assess for geohazards?
  • What are common geohazard misconceptions?
  • What are the key takeaways from this incident in Hillsboro and the NTSB report that followed?

Connect:

Rhett Dotson

Christopher De Leon

D2 Integrity

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Rhett Dotson: Thanks for joining us on today’s episode of Pipeline Things. I think episode seven, in this final episode of the arc, really represents an opportunity to change the course of pipeline integrity. Will we learn from the failures of others? I think there’s no better place to do that than the area of geo hazards. Today we take you to Hillsborough, where we take a look at a failure due to geohazards, and a relatively recent one at that, in 2020.
We hope you enjoy this episode and we hope you’ve enjoyed this arc.
Rhett Dotson: All right. Welcome to today’s episode of Pipeline Things. I am your host, Rhett Dotson, my co-host Christopher De Leon. I was listening to a podcast this morning, The Rise and Fall of Mars Hill, and there’s one small segment in there, Chris – fantastic podcast, by the way – where they interview this lady, she says, you know, the great thing about being a host of a show is like, it’s your show. You are the host. No one can tell you what to do.
Christopher De Leon: Is that why you tried to take my little dance? On episode six.
Rhett Dotson: Because I am the host. You need to recognize that.
Christopher De Leon: Well, you know, just remember this, you know, there’s people who have ideas…
Rhett Dotson: This was your idea in full fairness.
Christopher De Leon: And there’s people that do ideas.
Rhett Dotson: So, you know, totally and totally.
Christopher De Leon: That teamwork makes the dream work.
Rhett Dotson: You’re right.
Christopher De Leon: Teamwork makes it.
Rhett Dotson: So, as we get into today’s episode. Today’s episode is a much more recent failure, right? So, we’ve been dealing going all the way back to Bellingham. Yeah, but now we’re in we’re going to be in 2020 and in Hillsboro. Yeah, that’s what we’re going. But what’s so interesting about this episode, Chris, and so interesting about this failure is I feel like it is if there is a who’s who or what’s going on in pipeline integrity, I feel like geohazards is the what’s going on in the pipeline integrity topic.
Christopher De Leon: Yeah.
Rhett Dotson: I feel like it’s been that way for several years. So, one of the most interesting, I would say humorous and interesting introductions was written by Dave Johnson, who we, I use to call Dr. Dave.
Christopher De Leon: So, it’s Dr. Dave.
Rhett Dotson: It’s Dr. Dave. Some of these people may or may not.
Christopher De Leon: If you know who Dr. Dave is, raise your hand.
Rhett Dotson: Yeah, there you go. And so, it’s some people know him, probably some, some may not. So, he originally started back whenever he was like Enron’s director of pipeline.
Christopher De Leon: VP at Enron.
Rhett Dotson: And then when that whole ship imploded, he ended up going in. He worked at Energy Transfer, well what became Energy Transfer. And most people knew I mean, he’s like beloved in the industry.
Christopher De Leon: If you were plugged into the industry, like legitimately plugged in, in some kind of organization or doing research or anything as an industry, you’ve probably met Dr. Dave. Great guy.
Rhett Dotson: So, Dr. Dave was like, beloved, great guy. Great guy. I hope he’s an avid listener of the show. You can hear his plug him.
Christopher De Leon: We’ll have to tag him.
Rhett Dotson: But he when he wrote the introduction to the INGA document on the management of geohazards and I loved the introduction, I’ve used it so many times repeated here on the show, he says it basically mirrors how, the threat of geohazards mirrors, how the threat of stress corrosion cracking was in the seventies.
He’s like, at first when it happened, it was like someone else’s problem. Yeah, right. Like, oh my goodness, I am so sorry that that operator has stress, corrosion, crack. He’s like, then it turned into a Canadian problem. It was like, if it’s like it was regionalized or it was like second stages, you realize that, oh, it’s the Canadians now, but thank God we’re south of the border because we don’t have this cracking problem that they have it.
He’s like, the third stage is you have to operators, operators who realize they have the threat and those who just haven’t realized that they have the threat yet. And I love that you said the fourth stage is finally where you get to like a holistic research and growth and maturity in the problem, right?
Christopher De Leon: We have a problem.
Rhett Dotson: Yes, where the industry as a whole begins to coalesce. Right. And so, I mean, it took what, God probably…
Christopher De Leon: That’s a really good pun to SCC dude, you’re on fire.
Rhett Dotson: I’m telling you…
Christopher De Leon: This guy is on fire.
Rhett Dotson: Because I feel like geohazards is the same path. Like if I had to say, I honestly think we’re somewhere between probably stage two and stage three, I feel like.
Christopher De Leon: Those guys have it and I think and I might have it as well.
Rhett Dotson: Thank God I don’t have pipelines in the Appalachian Mountains, you know.
Christopher De Leon: Hope you have data. I’ll say that.
Rhett Dotson: Or thank God I’m in Texas where I don’t have geohazards, which is a totally errant thought to have happen.
Christopher De Leon: Yeah.
Rhett Dotson: And so, I think a lot of operators have a growing awareness. So, you have this broad spectrum of, I’m going to say, geohazard integrity management programs and a growing awareness. But I think still a lot of operators that are, I’m going to say really either new or maybe even aren’t addressing the geohazard threat.
Christopher De Leon: Well, I can say this. I’m a little bit sad, right?
Rhett Dotson: Why?
Christopher De Leon: Because if you look at the previous six episodes that we’ve done, I think you’ve done a pretty good job of story time. And if we look at episode six, the one we just did on Centerville and this in the NTSB reports are not very long.
Rhett Dotson: I tell you what…
Christopher De Leon: The story time is coming to an end.
Rhett Dotson: It’s really interesting because…
Christopher De Leon: We only we’ve only got two pages!
Rhett Dotson: The failures themselves are significant in terms of what the operators can learn. But, you know, what are what we call them, It’s not Ms. Producer anymore. I don’t know what it is. Do we just call her Sarah?
Christopher De Leon: I feel like I want to call it.
Rhett Dotson: I was chastised for calling her second string. Sarah She’s got to come on stream and come up with a new name now, like.
Christopher De Leon: I like DC did. She’s. Oh, no, no, no. Not DC,
Rhett Dotson: DC Comics? Now she’s giving you eyes right now. I think when we have to abort this conversation and come up with something better, we will come up with a name. We know we should leave it up to the audience. AUDIENCE If you have suggestions for what we should call second string Sarah.
Christopher De Leon: No, Creative Director or…
Rhett Dotson: Creative Director
Christopher De Leon: Sarah …
Rhett Dotson: Not just Sarah.
Christopher De Leon: Yeah, the h. Don’t forget the h. I forget the h. Sarah Ha.
Rhett Dotson: We could sit, we could change. We could do like the old biblical thing, which she could go from being Sarah to Sarai.
Christopher De Leon: Or in Spanish. You see Sonia that’s even better.
Rhett Dotson: She’s like, move on, guys.
Okay, so going back, it is interesting because the NTSB failure reports did get very skimpy for these last two failures. And I don’t know the reasons why. I don’t know if it’s interesting. I don’t know if it’s because the NTSB got a hold of them. And it turned out that the.
Christopher De Leon: Calls, it was just really cut and dry. Yeah, maybe there wasn’t a lot to investigate.
Rhett Dotson: Yeah, but you don’t see any of the discussion around really like ASVs, RSVs, that conversation disappears. You don’t see any talk about consequence areas like a lot of hot button topic historically I think changed. I don’t know if that’s intentional because they wanted to make a more focused. Yeah, I have no idea. But I would tell the audience you can literally read the Hillsborough failure report in probably 10 minutes.
There’s not that much there. So, I’d encourage you to go take a look at it. Yeah. And yes, story time I don’t think is going to be that detailed. So, if you sat around the fire and you started wanting to listen to Rhett tell you a story, it’s going to be pretty short. You can have a lot of campfire left.
So let’s get into it. May 4th, 2020, 30-inch interstate natural gas pipeline that’s operated by Enbridge ruptures on a hillside location. What makes this story noteworthy is that it wasn’t a location that was previously unbeknownst to Enbridge. It wasn’t like this popped out of the blue and caught them unawares.
Christopher De Leon: And we got to give them credit, right? Because, I mean, I almost feel like this is the second time that’s happened to them. And we look at the hard spot failure, same thing, right? Like they knew there was stuff there, right? I mean, so you got to give them kudos in that, you know, they’re positioned right. You know, it’s just there just continues to be opportunities for lessons learned, but continuous.
Rhett Dotson: That’s one way to look at it. I wonder if they’d consider it that way. So, but basically the line ruptures in the total cost, no loss of life or fatalities, thank God, $11.7 million in damage. But where the story comes in is Enbridge knew this was a geohazard area. They actually had integrity programs in place to address it.
I think that is the surprising thing. And I think it speaks to why maybe I have my opinions are not formed on the basis of Hillsborough, but I have opinions on geo hazards based off of my experiences and my limited schooling. So, you know, most people don’t know this: I’m actually a civil engineer working in the field of mechanical.
You know, we my whole life now is structural. So, I was civil, structural and are very early on got into the field of solid mechanics, which is why I kind of work at the marriage of civil and mechanical. But in every job I’ve ever happened had whether it was a stress engineering or with rosin, people would be like, wow, that was a civil guy.
And I’d be like, yeah, no, you had a course in Geotechnical. I was like, I had one course. We call it Fear of Dirt, because that’s about all you learned, was that when you’re designing in dirt, the answer can be ten or 10,000, and we don’t actually know what it is. And it changes depending on what the water is in the soil.
And you would always be like, “Oh, you need a better job hazards guy.” I’m like, no, I’m not a geohazards guy because I don’t know anything about them. And I’m actually afraid and I feel like you really can’t quantify them. So, I’ve always had this healthy fear of dirt like because you just don’t know what’s going to happen.
And if you live in Texas long enough, you know that because you see your house cracking over time. Like God willing, this dry spell is probably making God knows how many people’s foundations cracked to pieces. But anyway…
Christopher De Leon: Tell us how you really feel.
Rhett Dotson: That’s how I really feel, Chris. I’m from afraid of dirt. I’m afraid of dirt.
Christopher De Leon: I mean, do you phone a friend when that situation happens?
Rhett Dotson: Yes, we get we get the dirt merchant, Alex Kinsey Johnson, and he counsels me when I lay on the couch. If you saw the clip for the Clarion conference. But no, they had detected in an ILI inspection in 2018, they had confirmed that they had an area of pipeline movement of around 4.2 feet. So, the story, in my opinion, really begins around that time, 2018, Enbridge identified it of beings a strained area.
They identified between repeat inspections that it’s movement and they identify that it intersects with a geohazard. Right there, you have all the information. You know, to be concerned because you have a bending strained area. You have an extreme area that’s changing and it coincides with a potential geohazard, like it’s like red flag, red flag, red flag.
2019, an aerial patrol determines that there is erosion at the right of way and the ILI indicates additional pipeline movement and they see ground scarp so they know things are continuing to change after 2018 moving into 2019. In 2020, they determine that it doesn’t require urgent action, but they’re going to continue to monitor the location and mitigate the identified threat.
So, what they have planned to do is and what we’re going to do is we’re going to go in there, we’re going to install strain gauges, we’re going to improve some drainage in the area, because, again, in most cases, when you’re dealing with your hazards, if you remove the water, some cases not most I really shouldn’t say that, if you change the water content, you change the direction of flow.
You can mitigate the activity of the geo hazards. So that’s their plan. Unfortunately, if it fails on May 4th, before they ever get the chance to implement any of those right. And the basis, I should say the basis for making that decision in 2020 was that they had estimated the strain capacity in the girth welds, it was very high.
And so, they said, “Hey, look, the strain capacity in this third world is really high. We’re nowhere near that limit. Therefore, we don’t have to take any action.”
Obviously, that turns out not to be true. So, post rupture, what they found was that the landslide feature was actually accelerating, right? So, if you had based your program on the movement observed between, let’s say, 2018 and 2019, that may have been misleading because the landslide was actually accelerating due to changing soil conditions.
Which is another important thing, landslides, just because they’re not moving or moving really slow don’t always stay at the same speed.
Christopher De Leon: Yeah.
Rhett Dotson: In addition to that, they found that there were two incomplete penetration and lack of root fusion defects in the girth weld. So, the girth weld that ultimately failed, turned out to have two defects. And when they accounted for those defects, they found that they had overestimated the strain capacity of the girth weld by a factor of three.
So, again, if we look at landslides as strain demand and strain capacity, the story here is that the strain capacity of the girth weld was wrong. So, their time to failure, what they were basing everything on was wrong. And they didn’t have as much time as they were much closer to the limit than they thought. And so, they had developed an entire integrity program around that that ended up, you know, obviously based on faulty information.
So, the NTSB didn’t you know, in this report, again, I would say it’s pretty bland. They didn’t put their normal list of here’s what we recommend and have everybody do. What Enbridge did in response was they decide they would use a reduced tensile strain capacity of 0.5%. But that’s just they just took a hard stop at 0.5%.
And had they had a 0.5%, which is I would say in most cases, some cases can be already pretty high, they would have triggered a response and this incident wouldn’t have happened. But the NTSB concluded that the pre-rupture analysis, which have already kind of delivered the baby for you, did not appropriately consider uncertainties such as, weld effects, changes in the slope and direction of the landslide that increase the susceptibility of the girth welds, acceleration of the landslide or the response of these pipelines two factors.
It stated basically you did an analysis to determine that you didn’t need to do anything and that analysis didn’t have sufficient safety margins and didn’t wasn’t I didn’t have an appropriate estimate of the actual capacity of the weld, which is how we get to the failure we get.
Christopher De Leon: I got a bunch of questions.
Rhett Dotson: Well, I think we’re going to take a break before you get to those questions, but I’ll say the audience will, too, because again, I think geohazards is an emerging field. So, this episode is going to be less about the failure and more about where are we at as an industry on geohazards and would do, what steps, what recommendations we have the operators to keep this from happening.
Hang on and join us again. We get back in the break.
Rhett Dotson: All right. Welcome back. So, we’re going to pick up we’re talking about the failure forum, geo hazards and the NTSB report for Hillsboro and Christopher has pretty much demanded to take over the episode at this point. I think he was offended at my comments earlier in the episode about the host having control now.
And so, you all are just going to witness firsthand the power struggles that go on between the two of us.
Christopher De Leon: Anybody that knows me, knows I have no interest in power.
Rhett Dotson: Chris soft or hard power because you’ve told me about this before and both of them…
Christopher De Leon: So, you do listen?
Rhett Dotson: I do, Chris. I listen to you when I want to.
Christopher De Leon: Well, you just remember this. Audience, look it up. Hard power, soft power. You got to have the right people in hard power. Otherwise, you’ll be in a tight spot. All right, so first question, geohazards. Are geohazards a threat to pipeline integrity?
Rhett Dotson: Neh.
Christopher De Leon: That’s when you phone a new friend.
Rhett Dotson: Absolutely. And I think you really have to divide them into two categories. So, I’m just going to briefly going to do it. There are hydrotechnical hazards, which I think all a lot of operators probably have more mature programs on – their water crossings, whatnot, even at the most recent the API cybernetics conference, Roberto Landazuri from ExxonMobil presented on ExxonMobil’s Hydro-Technical program and theirs is extremely developed over the last ten years.
But that was in response to, you know, the Wyoming Yellowstone fire. So, there’s hydro technical failures and river crossings. I feel like awareness has risen in the industry on those. And then there’s more traditional, we’d say, onshore geo hazard settlement related issues, landslides, those types of things are where I feel like operators are less, you know, I’d say less developed programs, and it’s because they always think landslides, because that’s the easiest one to convey across.
But the reality is it’s actually much broader than that. You can have sinkholes that develop, to be honest. You can have things like banks sloughing in water crossings that maybe are intermittent. You can have settlement related issues and things of that nature.
Christopher De Leon: So, it’s an integrity threat.
Rhett Dotson: It is absolutely an integrity threat. It should be in every operator’s plan.
Christopher De Leon: So typically, we think of an assessment, integrity, threats, you need to assess them. So, you have a plan for assessment. How do you assess for geohazards?
Rhett Dotson: Right. So, I think there’s two methods. You and Alex, Mackenzie Johnson, and I work together on this very well, and most people are aware now that we did the Clarion course that we did. The first iteration of the Clarion course was super well received shameless plug. There’ll be another version of it.
Christopher De Leon: That was that. That was a good idea. It was just.
Rhett Dotson: It was also your idea. So, you were responsible for the podcast in the clear on of course. Chris, Thank you for your good ideas. You’re like, Idea man.
Christopher De Leon: Is that hard power? Soft power.
Rhett Dotson: It’s, it’s slushy, middle, it’s slush power. So, we will be doing that course again in January.
Christopher De Leon: So, assessments.
Rhett Dotson: But assessments are really grouped into two types. There’s what I call surface-based assessments, which in most cases are based off of Lidar, foot patrols, let’s say “boots on the ground” type assessments, or Lidar. And those is in identifying known geohazards along your pipeline. So, it’s creating what we call a geohazard inventory. That’s one form of assessment.
The other form of the assessment is, is your assessments based on IMU and bending strain. Right. Which again, we’ve already done episodes on the middle child, which is, that was geometry. But the forgotten technology which is IMU.
Christopher De Leon: We’ve got a lot on the this already and so what to episode those at the top we had Nick Vonnegut talk about, you know, some of the new regs on extreme events, response to extreme events and lots of material out there.
Rhett Dotson: And so, which those are the two methods. Chris I would say the gold standard bar none is both of them together operators, usually because of budget, will do one or the other, but if you do one or the other, you’re very likely to capture your worst threats. But there have been a number of notable threats and Alex and I talk about them on the show where, doing only one or the other could lead you to not being able to identify.
Christopher De Leon: And you got right where I wanted to get, which is what I think we find here in this situation. Right. So, you said it earlier, right? They had performed a bending strain assessment, they had identified pipeline movement and movement, and they knew that everything and they knew and that you hazard. But I want to ask you something, because you said there’s two forms of assessments.
One is surface based. Is that, is that really an assessment?
Rhett Dotson: No, the surface based has more to do with the identification. Right. So, it’s there’s a component of assessment there that can be and whether or not you have an active geohazard and to what extent it might be active. So, like in this case, where the surface base fits in is they would have confirmed that what they were seeing in the pipeline was a result of external load.
So, there’s a proportion of assessment there and I would hope, I don’t know because the report doesn’t get into it, was that there was some indication of how fast or how quickly that landslide might have been moving. That probably influenced their decision, right? So, what I often look to get when I talk to Alex are when we send people outside, whenever I work with operators that have those surface-based assessments, I need to know the potential for episodic movement.
Remember I told you like I’m scared to death of dirt. And the reason I’m scared is because the situations can change instantly. Yeah, right. So, and that’s really the problem with geohazards is it’s not like any other threat for operators. So, when you talk about corrosion, we know corrosion grows and we can usually estimate the rate. And if the factors don’t change, you can usually assume that rate as long as you’re nothing else changes, will continue. And that’s a safe assumption.
It’s not so with geo hazards, right? Because your landslide might be moving at this rate today. Then you get one big rainfall or you get a serious season of rainfall events that change the conditions. The soil properties themselves suddenly change. The underlying clay layer may change. And the boom – you go from moving maybe an inch every three years to 36 inches in a day, right when the thing just goes.
And if you have that potential, it would be like corrosion. You got a 30% corrosion feature that’s growing at 5% per year and then all of a sudden, boom, it grows from 30 to 80%. Yeah, in two days, you know, like what? That that didn’t happen.
Christopher De Leon: Which is we’re leading right into this, right? So, this is great. So, you perform an assessment, but as integrity people we kind of have this this compliance mindset and this reference to standards. This is almost a sequence of events, right, that we stick to. Right. So, you gather information, you identify your risks, you prioritize, you perform assessments.
But when you perform assessment, what happens next? You have to understand your response.
Rhett Dotson: Yeah.
Christopher De Leon: Are there prescriptive responses? I mean, we always talk about 452 for liquids. We talk about 933 for gas or 714 for gas. What are we doing for geohazards?
Rhett Dotson: Nothing. And this is I’m going to tell you what this is about. The whole hot button topic, I think, is to ask you to punch a button. Do we ever I need a you know what? Ms. Producer/Ms. Aaron Rogers/Ms. Sarai, can you get us a like a red button that we can hit and we have a red button in the shows like .
Because this is a red button for me, for two reasons. First, I want to say that I think this actually ties in all the ways. I guarantee you Enbridge probably had some consultants that were helping with them. I doubt that they were purely managing this on their own. And if they were, they had internal consultants and their own internal SMEs, internal SMEs or XMEs always have biases, right?
And so, I think it is it is worth noting that that bias and things like that probably play a role here, even though the NTSB report doesn’t get into it.
Christopher De Leon: But we’ve talked about that. We go all the way from Bellingham where I use the whole point of data integration, right? I was like, data integration. Like, well, what kind of data integration? It was like we had previous ILI data that indicated there was something you need to integrate, but that would happen. So, the guy was like, we knew they made a bad call.
Rhett Dotson: When I’ve had a lot of calls like this. And these are some of the hardest questions I get is when I’m talking to an operator and they’ve got an activity and I know they don’t want to dig it or I know they don’t want to, and they’re like, Rhett, how much time do I have? And the answer is always like, I can’t confidently say, right, like, I know you want me to tell you that you might have a year…
And the truth is, if nothing changes, you have a year. Nothing changes, you might have ten years.
Christopher De Leon: So, before we get there, I want to get back to the question.
Rhett Dotson: I was getting around to it. There’s nothing in regulatory right now. And what I keep saying, and I feel like I’m shouting it out.
Christopher De Leon: You are always yelling at me.
Rhett Dotson: It’s going to come like as operators, if we don’t respond appropriately and we don’t respond to them, it’s a matter of time until this incident occurs in such a way that forces PHMSA’s hands. So, this incident, why? Because it happened in the middle of nowhere, nobody was impacted. It probably didn’t even make, it probably made the news, but it probably made the news in such a limited sense that nobody that…
Christopher De Leon: No, you said something. You said that this is a hot topic. Why is this a hot topic?
Rhett Dotson: Because I’ll say awareness of geohazards and the prevalence of incidents is increasing. Right? And then we could go on and on. I choose not to get into if you say, oh, it’s due to climate change, I don’t know.
I can’t tell you why they’re increasing. It could be the news cycle is more aware, like a 24-hour news cycle makes us more aware of when these incidents happen. The prevalence and ability to take out your cell phone and be like, look at this giant fireball in the middle of nowhere from an exploded pipeline that wouldn’t have been around 30 years ago, right Chris?
So, it could also be just that humanity continues to encroach on pipelines that were previously located nowhere.
Christopher De Leon: We’re changing the landscape.
Rhett Dotson: We could be changing the landscape. And then, you know, look, I don’t care what the causes of climate change want to get into that point is things are changing enough to actually impact pipelines. It could be that they’re aging as well. You know, eventually, if it’s moving slow enough in enough places or we’re a long enough time, something’s going to give.
Christopher De Leon: And these pipelines have been in the ground in a lot of cases for a very long time. Or when you install the pipeline, you’re moving the earth as well. Right. So, you’ve made change to something that may be more stable.
So, the point is, I think the takeaway is if you were to look at 933 or 714, you’re not going to find a response.
Rhett Dotson: And I think I’m going to say now and I get I want to put the plug out there, I’m going to tell you my opinion because I’ve thought a lot about this. If we don’t get our geohazard act together, all operators, right, not just the big guys like Enbridge now has made substantial changes. And I think they learn from this.
And I’m aware of a lot of the changes that they’ve made. You know, Enbridge, in my opinion, has a much more robust geohazards program in light of this, but a lot of operators still don’t. And I asked myself if this would have happened in a slightly different scenario, maybe with an oil pipeline where they didn’t find the leak or didn’t find the leak soon enough.
Christopher De Leon: We might have some rulemaking.
Rhett Dotson: And it flowed, I don’t know, maybe into a river where it damaged, I don’t know, maybe a couple hundred thousand acres worth of wetlands like, I don’t know, maybe in Louisiana. Then I think the public
Christopher De Leon: Do people do care about Louisiana?
Rhett Dotson: People do. When they want to go fishing or Alligator hunting. I think I think at that point, PHMSA’s hand will be forced.
And what I don’t like about that is that in the field of geohazards, it’s so difficult because the pipelines don’t look the same. Whether you have a vintage pipeline or a new pipeline, matters, right? What you know about your material properties matters. What you know about the threat itself matters. And if you have PHMSA that come down, they say, you know what?
And I’ll throw it out there again, because it maybe this is a firebrand PHMSA comes down to just says, you know what, every, every single bending string call above point 3%, you’re going to dig. Man, we’re going to be in a world of hurt, Chris. And that’s the type of thing that I think descriptively PHMSA would do in response to an egregious action.
Christopher De Leon: Have we seen that before?
Rhett Dotson: Yes!
Christopher De Leon: I guess that’s what the series is about. Be proactive.
Rhett Dotson: So maybe a…
Christopher De Leon: Chance to be proactive.
Rhett Dotson: This is a chance to be.
Christopher De Leon: This is a chance to show we have learned our lesson.
Rhett Dotson: We have the chance. Alex and I, we were saying to find geohazards before they find us right now.
Christopher De Leon: So, it’s a kind of like hind and go seek. Were you good at that as a kid?
Rhett Dotson: You know, we used to play Survivor. Were you the fighter? We would do it.
Christopher De Leon: If you’re the one that would go and hunt or you, the seeker or the hider?
Rhett Dotson: I think I like to be the hider more than the seeker I like, but I don’t think I was very good at.
Christopher De Leon: I like to chase people, watch and gradually get tired, and then you finally at the end, when they fully quit, that’s when you tag them. You’re like, all right, you’re it. You watch them suffer a little bit. But anyways, different story.
Okay, so liquid. So just again, checking the boxes. There’s no response criterion in 452.
Rhett Dotson: No, and this isn’t like how you separate it into liquid and gas regs you know but there’s a pipeline issue. Geohazards are the one threat that absolutely does not care what the contents are. Maybe next to the external corrosion, which also doesn’t care what the pipeline contents are.
Christopher De Leon: Or third-party damage. But then again, the time to delay. But point is, okay, so we’ve tackled that. You know, one of the things that comes to my mind when you were going through story time, which I needed more, so it’s time to bear me and not only I needed more story time with Brett, but I will say this. So, one of the things I took away from it was it’s, you know, you mentioned this component of acceleration.
So, you have information in 2018, then you get more information in 2019, you show movement from 4.2 to 5.2. You know, there’s a geohazard. So, the word that comes to me is, you know, use that. You said, hey, they had a response, right? Their response was they were going to mitigate, you know, by managing the water. They were going to put strain gauges.
But the word that came to me was conservatism. And so, you also mentioned the idea of like when you deal with the CGR, corrosion growth rate, you know, like we understand that there’s we normally have a handle on that because we have some conservatism to it, whether it’s an RPR or, you know, we use a different assessment methodology.
Rhett Dotson: Yeah.
Christopher De Leon: Talk to us a little bit about what is the standard for conservatism when it relates to responding to geohazards or what’s the risk of not of only doing a bending strain and not a surface assessment to understand what level of conservatism you need? What’s your reaction?
Rhett Dotson: I think it’s really hard to define what the level of conservatism is because it doesn’t come in, honestly, as much on the demand side as much as the capacity side. So, you view with the risk you have if you only have a surface-based assessment is you are prioritizing without knowing the pipes response. So, it means a lot of times something that looks really bad on the surface might not be impacting the pipe at all.
And I’ve got numerous examples. I had one time at like operator called me in sheer panic because the banks of a bayou had completely collapsed. And I mean, you look at the photographs saying like, whoa, that looks bad. It turns out the pipeline was buried 15 feet deep and it absolutely did not care that the banks were collapsing at all.
But you look at another location where, to be honest, it may not be visually evident that you have substantial movement. In fact, I’m working on one right now where the evidence wasn’t even actually on the right of way. You had to walk left or right to find the head scarps or the toe of the landslide in order to know there was something going on.
But you had fairly substantial impacts on the pipeline bending strains north of 0.3 or 0.4%. So, the risk is when you’re prioritizing based on a surface-based assessment, you don’t actually know what’s going on in the pipeline. And so, your action is driven without knowing anywhere where the pipeline itself is with respect to its limit.
Christopher De Leon: So, conservatism, are you saying that we need to rely on the pipeline assessment potentially through IMU?
Rhett Dotson: Well, the only thing if you don’t have IMU data, you don’t have an extreme assessment. The only thing you can do is just try and mitigate based on what you think your worst landslide is.
Christopher De Leon: Assuming you don’t have strong gauges on it. Right. So, if you have IMU data we’re running building strains conservatism what kind of conservatism we need to apply.
Rhett Dotson: Som when we talk about bending strains know I usually talk in terms of green, yellow, red. And so, your yellow lights typically start around 0.3% bending strain. That’s where you need to be. You need to be very careful. When you get above 0.4, you’re getting into red territories. Like I often tell operators, look, if you have been strains above 0.5, you’re dealing with like less than 3% of all total bending strain calls that are made like you’re way out on the spectrum.
When you say how much conservative are we, the truth is we usually don’t know because we don’t know what the quality of the girth welds is. If you’re dealing with a new pipeline, a new build pipeline where you didn’t have issues with the girth wells being under matched, you know, so you had the material properties are sorted out, okay Chris, then 25% may not matter to you at all.
You move along, you’re dealing with a 1940s pipeline where they wanted to get off early on Friday and forgot to make a route pass on the girth weld, you could be in a real warning sign.
Christopher De Leon: So, what happened here?
Rhett Dotson: This was a Monday/Friday girth weld. Clearly somebody wanted to get off of work early and so they just, you know, missed the route pass.
Christopher De Leon: Well, we don’t know what the situation was.
Rhett Dotson: What there’s two options, right? They either left early on Friday or came back hungover on Monday. That’s what we call a Monday/Friday girth weld.
Christopher De Leon: We don’t obviously we’re having fun. That is not you know that we and those that statement fully. The idea is we’re just joking around.
Rhett Dotson: My name is Rhett Dotson and I do not support the comments made by Rhett Dotson formally on this show.
Christopher De Leon: But I think the point here was it’s it is there is a component of conservatism that we need to address. And right now, the best way that we know to do that is, to some degree surface base assessment related to how often we gather data is what it sounds like, be conservative in how often you get data.
Rhett Dotson: And be conservative, what your limits are. If you don’t have information to support strains over 0.5%, you need to be very cautious.
Christopher De Leon: So, if you don’t know what’s going on in your world, which there may not be a great way to know that, the you need to be conservative.
Rhett Dotson: Again, I always speak in terms of cause and stability is my guideline to operators. If you don’t if you get a bending strain report and you don’t know the cause of the bending strain, your level of concern should go up. If you know the cause, but you don’t know whether or not it’s stable, your level of concern should go up.
Christopher De Leon: So, do I wait for deformation in the pipeline, you know, am I using caliper data with, or geometry data with IMU data?
Rhett Dotson: You have to have a certain amount of hubris to be willing to try and manage on the basis of deformations. And the reason why is, again, you’re implying that whatever threats acting on the pipeline will move at a rate that it will give you a deformation that you can then manage. In reality, it could go and just rip right through the defamation, tear the girth weld, or you can develop cracks in the deformation.
So, I’m not a fan. Deformations are useful for maybe confirming whether or not you have a problem, but if you have one, you’re already at a point…
Christopher De Leon: It might be too late.
Rhett Dotson: Yeah, you’re already at a point, but you’re not going to call me…
Christopher De Leon: You’re at the response.
Rhett Dotson: Yeah. You’re not going to call me and me tell you to manage that. I won’t do that.
Christopher De Leon: You’re going to go do something.
So, let’s say I identified, I have some movement, I have strain, I also believe I have movement. I’m co-located in a geohazard zone and I just can’t get out there immediately. Like, I just, I can’t. I can’t physically respond in time to mitigate. Do I reduce pressure? Like what would be a natural next step?
Rhett Dotson: To push back, since you’re asking questions, when I put the notes up. I’m going to push back pretty hard, right? So, unless we’re talking about fairly low strains, like if we were talking about bending strains of 0.2 or 0.3%, you’re going to have to get someone out there, I’m going to say qualified. So, I’m going to refer you to like a Geosyntec or an Alex McKinsey Johnson.
I’m going to tell you, you better get it. Yes, you better get somebody qualified out there that can write a qualified statement telling you whether or not they think the geohazard’s active and what the potential is for it to be episodic.
Christopher De Leon: So, at this point, you’re focused on the environment, not the pipeline.
Rhett Dotson: If you’re trying to ask me for a timeline, because you said you can’t get out there.
Christopher De Leon: I’m getting to it. I can’t get out there in order to mitigate it.
Rhett Dotson: Look, all I can say is if I want assessment that has evidence of change. Yes, I have no information to tell you how fast that rate might change. You’re going to get a qualified opinion on it before I tell you don’t do it.
Christopher De Leon: And that will likely be focused on, initially, on the environment, the geohazard stuff.
Rhett Dotson: Because you need to understand exact what’s driving the pipeline. You have to understand that.
Christopher De Leon: And then you would maybe turn to materials?
Rhett Dotson: That would be like, I want to use something that people might understand, that would be like you finding a known area of selective seam world corrosion and you asking me what? Rhett? I can’t get out there right now. Can I get out there in a year and I pick one up? Do you think that’s like to see more corrosion is going to grow?
Christopher De Leon: That’s a good one, right? And you be like, I don’t know, I go check the dirt.
Rhett Dotson: Well, know what I’m saying is just we actually do have some ability, more so than select a single corrosion to characterize the environment. And a qualified person may go out there and they may look they may see the trees, butted over, because the monitoring, the way it looks, this landslide to be moving for 40 years.
Christopher De Leon: Yeah.
Rhett Dotson: Absent any environmental changes, we expect it to continue moving slower.
Christopher De Leon: And then you go into damage control basically.
Rhett Dotson: Yeah. Then I could tell the operator you have some time if they go out there and like me and it looks like this whole thing has been active, you know, the rainfall has changed as has been the rainiest season we’ve had in early season. Yeah, I’d be like, man, look, all bets are off. Like I think you actually, you go out there right now and there’s not much I can do to help you.
Christopher De Leon: So, what role does FEA have in this at all?
Rhett Dotson: So FEAis useful. I’ve done a lot of level three assessments. We continue to do a lot of level three assessments. They’re useful for understanding the response of the pipeline in terms of future mitigations. Right. So, let’s say you go out there, you do excavate the pipeline, you do some stress relief, you install strain gauges, maybe you even install non-native backfill.
But what you still need to know is how do you know that installing a, you know, strain gauges and setting a 500 micro strain limit is appropriate? FEA can help you understand that, right? So, it can say, hey, if all things remain the same, we continue to push the pipeline further. And this way then here’s how we expect the strains to progress.
You shouldn’t hit any of your critical limits until X or Y, and that’s well beyond where a 500…
So, scenario planning, you can scenario plan basically.
Christopher De Leon: So, if I need to scenario plan to manage my decisions moving forward, we can clone a friend, leverage some FEA and help me scenario.
Rhett Dotson: And the other benefit that it can quantify the membrane strains for use of bending strain only gives you half the equation. The FEA will give you the total strain state in the pipeline. Now, there are tools out there that claim to be able to do the membrane strain, even tools that are claiming they can do the membrane applies to range.
Christopher De Leon: I was going to ask you, I was going to ask you. So, what ILI technology is can we leverage for this?
Rhett Dotson: Yeah. So, I am you or we and you’ve heard me say before, you should be running in on everything. That’s an easy, no brainer. There are some axial strain tools out there that I think merit operators looking into more.
Christopher De Leon: To ask questions.
Rhett Dotson: You can ask questions. I think the vendors are making claims that need to be substantiated in terms of their ability to quantify plastic strains in using those technologies for membrane. But again, I do think they potentially have their place and I think we need to begin evaluating where they fit in in terms of their ability, their accuracy, in their ability to be used, and things like fitness for service assessments.
Christopher De Leon: Yeah, so if, you know, you have an area of concern, maybe it’s an upgrade, maybe it’s a mode of escalation. All right. So, when we talked about this a lot, so if I want to read more, you know, we always say one of my big things is it’s a lot of the stuff has been documented. It’s either been presented, you can find it somewhere, but sometimes you don’t always know where to find stuff.
Rhett Dotson: Yes.
Christopher De Leon: What kind of reads would you recommend?
Rhett Dotson: You know, there’s lots of really good read. So obviously, again, shameless plug. Number two, the clarion course is going to be coming back in January. We did get really good reviews from the first round. We had a lot of participants in the first round of the Clarion course. So, I think Alex and I put a lot of time into that and we’re not going to do it in-person next year, but we are looking at doing in-person in 2025.
So that’s one source and other sources. You know, almost every major conference, whether it’s PPIM or GPIC has a geohazards track now. Yeah, you should definitely consider that. Third thing is that Ingo is going to be issuing the updated version of the landslide management document. So that’s a good resource and that’s also going to be incorporated into 1187 API.
RP 1187 is going to be taking the Inga users guide the new one and incorporating it into a standard. So hopefully as that becomes more mainstream, Chris, we’ll, again, we’ll hit that goal of finding the two hazards before they find us.
Christopher De Leon: That was awesome. We didn’t get story time, but I got them riled up for us.
Rhett Dotson: Oh man, it’s like the hair standing up on the back of my neck. Do you want to close this out? You never closed out. I don’t think you’ve ever closed out the show. Close us out, Chris.
Christopher De Leon: You’re the host. Take us home, buddy.
Rhett Dotson: You’re right. I take the host back. So, again, I want to thank you guys for joining us. Geohazards is something that’s very close to my heart. I am very passionate about it. We hope you enjoyed this series on our NTSB failure report. I would encourage the audience out there. Chris and I chose only seven reports. There’s a lot. If you got an incident that you’re really passionate about you think we should cover in future episodes, there’s been pretty good feedback that we’ve gotten on this series.
I definitely think we’re going to come back around and cover other incidents in the future. And if you have one that you think we should take a look at, even maybe not inside the United States, we’d love to hear back from you. Thanks again for joining us on this episode of Pipeline Things. And we hope you will join us on our next arc.
I’m your host, Rhett Dotson, my co-host, Christopher De Leon, signing off. Thanks.

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