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I'm just going to briefly tell you who's on the panel today and I'm going to run through some slides to try to generate a couple of questions but we really want to open this up to the audience as much as possible we have a bunch of experts from a variety of different pipelines up here and they're willing to answer any questions at all we kind of want to keep it focused on Integrity management and operations and why things go bad and why they don't but we really uh want you to ask the questions you want to ask of these people I'll try to set it up a little bit I mean Andy Drake I've worked with Andy for years now he's the vice president of asset Integrity in Technical Services for Enbridge Ben kochman is the director of pipeline safety policy for Inga tend to be the big natural gas pipelines um uh Stephanie Wilson is the VP of logistics and Engineering for Phillips 66 and actually she was in Bellingham not too long ago she's because she's also the chair of the uh performance Excellence team for the liquid side of the industry and uh Rick line is the director of compliance in pipeline risk management for The Southern Company gas which includes Atlantic Gas and light and others and he's gonna we're gonna give each of these people just a second to talk introduce themselves a little more but first I'm going to try to run through some stuff and start setting up the conversation what we really want to talk about is things associated with the integrity and the safety of pipelines Integrity management people wonder what Integrity management is you know it certainly varies depending whether you're a big gas pipeline a liquid pipeline or a Distribution Company and I think they'll they'll parse what those differences are you know how often you have to assess and what your emphasis is but this kind of gives the plan do check act that's built into all kinds of different industry things now um that you really what Integrity management is you have to know what type of pipe you have in the ground you have to understand that you have to understand the risks to that pipe you have to assess the pipe and those risks and then you continually do that and as things improve you know and and mitigate those risk either by you know checking the pipe when you run a smart Pig through it and then fixing things or it's a continual process and certainly they'll talk more about that you know one of the things there's some good news and there's some bad news when you look at the data this is uh um you know we always say we're trying to get to zero incidents and we haven't got quite there now and we could have a whole session on in a discussion of whether we ever can but uh this is a serious incidents these are ones that put somebody in the hospital or kill somebody and you can see that's pretty good news for the gas pipelines it's really low I mean for the for the big pipelines it's really low and for Gas Distribution it's on a downward curve Gas Distribution tends to have more of those incidents because Gas Distribution pipes are where we live everywhere and there's way more miles of them significance incidence is a little bit different story because significant incidents are ones that cause you know deaths injuries major property damage or big leaks and you know for the gas side of the industry those two bottom lines they've been kind of stable it kind of goes up and down depending on what part of the graph you look at for the liquid industry it's tending to go up although if you look at the last five years it's trended down so maybe that's a good information too the the problem when you look at graphs like this Integrity management only applies to certain portions of your pipeline and Those portions are supposed to be getting a whole lot more attention than the other parts of your pipeline and if you're given Those portions of your pipeline so much more attention why are these some of these graphs going up or not moving very much at all it would seem like Integrity management ought to be driving these in the other direction this is the significant incident rate of the pipelines of the um that are in high consequence areas so these are really the ones that are under Integrity management this is for gas transmission pipelines the black line is a line that shows the pipelines that aren't under Integrity management they don't get all that special Extra Care although you can talk about that too because some companies treat everything about the same I mean the green line are the ones that are and you can see that the ones that are getting this extra special attention having to progressed much more and then depending on the year it could even be worse than the ones that are getting the attention here's the same thing for hazardous liquid pipelines and this one's even more Divergent because the trend line is going down for the pipelines that supposedly aren't getting special attention but it's tended up for the ones that are getting the attention I mean you the public could look at this graph and think oh God Integrity Management's making things worse and finally this is just the causes when you rope all the different type pipelines together because it really varies and Rick's going to talk about this a little bit about the difference between distribution and transmission of how this how this works so this just shows that you know for certain types of pipeline materials and Equipment corrosion those types of things are really high and things like that especially corrosion is one of those things in Integrity management it's really supposed to be focused at so if you look at that green line if you can parse it out for corrosion it's actually trending up slightly versus some of the other ones and that's really the one that's a Time dependent thing that Integrity management focuses on along with a lot of these other things I think that was yeah that was all I was going to do I was going to give each person like two or three minutes just to tell us a little bit about who you are how you fit into Integrity management and uh what questions you feel comfortable answering this morning so you want to start off Andy uh my name's Andy Gray I'm vice president NASA Integrity for Enbridge we have about 20 000 miles of large diameter gas transmission pipe in the US and Canada uh I have been Integrity management most of my career I'm a professional engineer in the state of Texas I'm an asme fellow and I've been chair of the asme Committees that founded some of the documents that were basically the framework for the Integrity management standards um I think it was a great place to come together we were laughing about tough questions I think throw any questions you've got at us I really mean that I think there really is a test of the relationship that we have with one another if we're not going to talk about the tough things and why are we here Ben thanks Carl my name is Ben kochman I'm inga's director of pipeline safety policy I have a little bit atypical background for this position as I am not an engineer prior to serving uh with Inga I ran the office of governmental International and public affairs at finza so it's nice to see some some friendly faces here and my replacement um uh prior to being at finza I did Congressional Affairs for former Secretary of Transportation Elaine Chao and then prior to that I worked on Capitol Hill for about eight years in both the House and Senate and a variety of different policy positions as far as my connection to this Inga represents about 26 member companies um Andy being one of them and ironically also Rick but on on the transmission side um and I'm in charge with doing the safety advocacy with themsa for the trade Association so I really appreciate the opportunity to be here with all of you I've found the panel is immensely helpful in learning more of your issues and I appreciate the collaboration that Inca has had with pipeline safety trust for many many years Stephanie Wilson um I don't push it and see if it turns green check s maybe I'll just bring it a little closer better okay Stephanie Wilson um the manager of engineering and logistics for Phillips 66 vice president of Philips 66 pipelines and So within my periphery I have asset Integrity I've been involved with asset Integrity for about four years as well as the control center so I know that um we've been prompted on possibly getting some Leak Detection questions as well so I so I do have the control room and the leak detection area I'm also as noted the lead of the performance Excellence team for a joint Lipa and API committee on the liquid side so Phillips 66 does operate about 13 000 miles of pipelines liquids and we own and have owned an inter ownership interest in about twenty thousand miles of pipeline but a little bit about the performance Excellence team is that it is a joint team between Lipa and API of the owner companies that participate in those organizations and we come together and we put out a three-year strategic plan which are the industry's priorities on how to advance safety evaluate where we are so certainly the slide scene or our slides that we review quite frequently within those committees and how we can get better and we are coming up on the end of a three-year cycle which will end in this year in 2022 and are actively working to get our plan out for the 2023 through 2025 cycle as well and you can see the results in progress that we communicate and we make every year in an annual report available through the API and the Lipa organizations right okay uh uh my name is Rick long I am the director of compliance and pipeline risk management for Southern Company gas if you wonder what Southern Company gas is there you see it on the screen it's four local distribution companies spread around the nation in Atlanta Georgia Nicor Gas in Illinois Virginia Natural and the Tidewater area of Virginia and Chattanooga gas in Tennessee put all together the corporation has 4.2 million customers so we're right there at the top is one of the largest operators in the nation on the LDC side 74 000 miles of distribution Maine about 74 000 miles of service footage to go with it and 2400 miles of transmission tucked within those Distribution Systems for the most part um my career is 37 years over 37 years with the company started as an engineer out of Georgia Tech and have done through operations engineering compliance ran dispatch corrosion a little bit of everything uh now I deal with the Regulatory Compliance side so uh that's the corporation that's kind of my background I'm here as your dimp representative today I figured this slide would have value because it attempt are really two different animals Carl and that the transmission Integrity is focus on the big pipelines at the higher pressures distribution Integrity is completely uh everything else it's so out of our 107 160 000 miles of pipe all but 2400 miles of it lives in this dimp bucket so it's different it doesn't have high consequence areas and moderate consequence areas all of our pipe that's in the DIP program is all of our pipe if that makes sense since it runs through our neighborhoods it is I mean everything's High consequence because you know they run right up to everybody's house uh the play and do check act that that was on the previous slide this is the dimp version of that uh it's a it's a simpler version but key of it is know your system all right and I got to give a lot of credit to finsa uh for this this regulation is completely different from transmission Integrity for a lot of good reasons but um that's what it is if you're gonna call it dimp it's now your system and and learn from it so uh we'll obviously get more into questions um why is it different I think this this slide when I first saw it uh pulled together by one of my folks tell us exactly why we have two different regulatory approaches to this if you look the blue is a breakout of of incidents for distribution and green for transmission for the nation and so different threats to different systems right transmission pipelines tend to be undedicated right away so you see different things that impact it like corrosion and Equipment failure those are the highest ones for them for the distribution pipelines the ones that are in the city streets guess what excavation damage is right at the top how they're outside force that's cars and trucks hitting meter sets things like that different threats and so different approaches for different threats uh and then this is the last slide uh kind of to align with what I think Carl showed earlier the distribution Integrity incidents had been going have been going down this is the national data on damage excavation damages and that trend line is very similar to what you saw in the dimp incidents going down and aligns with the previous slide excavation damage is by is certainly the biggest biggest threat we see on a distribution Integrity side people digging around the pipes great thanks let me back up to one of my slides and see if I can put anybody on the spot um in 2015 the national Transportation safety board actually did a study of Integrity management and one of the findings of their study stated that there is no evidence that the overall occurrence of gas transmission pipeline incidents in hcas has declined and they went on to say that it looks like for hazardous liquids the incident rates actually going up in high consequence areas there's a there's the gas transmission fairly stable but it hasn't been going down liquids seems to be doing something else other than maybe the last five years is good news so so when you see these how do you how do you explain this stuff Andy you want to take a crack at it sure uh first of all I don't think Integrity management is causing an increase in the incident rate but but I think it's really uh we're down in a very a good place where the frequency of instance significant instance is low and the causes are varied it's not like we're having a corrosion problem you saw the statistics spread out I think the key here is drill into the data and ask the five lies why why why why why why is this happening I think that's so fundamentally tied to the plan do check act cycle and I know that might sound sort of esoteric but when you look at it it's really about take the data drill into the data break it down and really ask hard questions about why is this happening what is it that's causing it what are the biggest causes and then develop a plan to do something about it then check your performance is what we're doing right now okay it doesn't seem to make sense What's Happening Here adjust your plan and go again and I think that iteration is intended to create a virtuous cycle not an infinite not a Insanity do Loop you know or keep doing something and nothing's happening it's a virtuous cycle to continue to escalate you know even and improve our performance and I think that um we started off if you remember third party damage the first set of data that we had was the leading cause of incidents was third party damage we set this infrastructure and these processes and systems around digesting that data and looking at it we put a lot of energy into 8-1-1 we put a lot of energy into you know the the the damage prevention programs and we've seen those numbers come down awareness has gone up the numbers are coming down next next biggest block of of effort was corrosion we put a lot of energy into making pipes pickable developing MF technology is getting more consistent in how we've validated the logs and dug up the anomalies and repaired and remediated okay we're not seeing that number drop down but I think that's telling us something that's important that where would the number be if we weren't doing these things would be I think frightening and it did just an ongoing never-ending challenge I think is really the quest here so you know we talked a little bit ago you know okay what was after corrosion well it was cracking what was after cracking well now you're starting to hear things like uh land movement issues okay well when you look at the data those are now starting to become the next big deal um and I think it's just a constant effort to continually Drive energy into those things and continue to look for the opportunities to advance the State of the State whether that's tool development Technologies or just straight up programs I mean quite frankly on Geo hazards the geohazard issue that's in the Eastern side of the United States in particular is a very different mechanic than what's in the western side of the mechanic it's creep the pipe moves an inch or two a year over a long period of time you can't see it with your eyes so if you bring your eyes you're bringing a hammer to a screw it's not you're not going to pick that up there also is not a definitive industry standard on how to manage and Geo hazards that creep okay well we just sponsored a geohazard jip among all the industry trying to figure out what is the best standard of care to address that threat then that will be put forth to fimza as a recommendation for a potential regulation which helps improve the standard of care and I think it's just that iterative cycle so I try not to get too distracted with not moving it down I think we're in a good part of the curve but we got to keep that focus and that effort going thanks how about you Stephanie the performance Excellence teams looks at something like this what does that make you think we want to be and that we are going to continue to improve and get better through the plan do you check I act um and process that Andy described through continuous learning we have come a long way in our continuous learning as Andy had mentioned in terms of the development of first thing corrosion and then cracks and we continually improve and push those things I would like to offer a few other data points and insight into this graph and that we do track the three primary data points that films are also tracks in terms of the serious and the significant incidents and one of the data points that is missing from this slide set are the incidents impacting the public in an environment so um another point of view and another piece of data on the significant incidence raised is significant incidents can be on property or off property and there is a dollar threshold that will trigger it to be a significant incident a dollar threshold to the operator later but it doesn't necessarily accurately as accurately reflect the consequence as maybe an incidence impacting the public and the environment do aware and things criteria like a contamination of soil and items like that go into that calculation so if you break those down and you look at the significant incidence because you always ask why why why why why what is the root cause because you've got to know the root cause we want to move this we have moved it we want to continue to move it so what's the uh towards zero what's what's the root cause and so we look at this in terms of Tanks facilities and pipeline right away because the significant incident category will capture all three of those very different environments for the regulated assets there is a trend upwards um you know especially until the last five years on tanks and Facilities uh things that are on the operators property and um you know that's disappointing and we need to continue to push those down to zero if you look at the significant incidents on the pipeline right away that is actually showing a downward Trend over the same time period so the most serious um incidents that are on there right away as well as the incidents impacting the public and environment um have shown shown a downward Trend and of course you know we're both at the same time proud and humbled by the continual fact that we've got to we've got to get better and you know reach reach zero great Rick just a quick question for you because dimp is so much a distribution Integrity management is so much different um because basically your everything's a high consequence area yes one of the things that seems to have kind of shifted in the last few years is there was a lot of emphasis on pipe replacement not very many years ago and now the emphasis is more on finding leaks and mitigating or fixing leaks and I've heard some operators say well you have to choose what you want us to replace pipes or do you want us to fix all these little leaks we can't do both talk about that a little bit well sure uh um all right you're right Carl I mean there was a tremendous emphasis on infrastructure replacement still is and I think one of the key reasons why the distribution Integrity rule was written the way it was is a performance a flexible Performance Based one is because Distribution Systems are so disparate I mean you can have one operator whose entire system is plastic you can have another one who's all cast irons or mostly cast iron and so I think what I've where I'd go with this Carl is I don't think we're past the period of infrastructure replacement still very important for a lot of operators to get their legacy materials out somehow some have it uh and I I think that's your first priority but as you get your infrastructure up to date now getting leaks repaired is much easier for that operator I'll I'll use us as an example in the last 20 years we uh have replaced over 5400 miles of vintage pipeline we're down to 416. so that has allowed us to really focus on our reduction of leaks and we've reduced our leak backlog by 75 in the last three years so you can get there you can it just it's going to take a lot of effort and some people are starting in different places because they have all their infrastructures all right my last question are how many people I want to just see your hands are itching to add to grill these guys okay my last question is I just want to look at this slide for a second because one of the things that Stephanie just said um you know there's different definitions for significant incidents in incidents affecting people in the environment which is a category that I like and we help help come up with that but one of the things people need to understand is that not all pipelines report things the same to some degree the incident reporting favors natural gas versus hazardous liquids because like hazardous liquid have to import any incident that includes a fire or an explosion natural gas doesn't it's not considered significant I mean it's not reported there's different thresholds for spills you know it's five gallons is reported for hazardous liquids but it's 3 million cubic feet is that right three million for hazardous liquid so that's not even close to the same so hazardous liquids report way more incidents than Natural Gas why is that why why does a fire or an explosion on a natural gas pipeline not an incident and it is on a hazardous liquid okay I could start with this so I appreciate the question I think I I would disagree that the gas transmission lines don't get caught up in the incident reporting data my understanding is that there's a hundred and twenty two thousand dollar threshold that needs to be reported so when that happens if a pipe has an incident that ruptures and you're gonna go fix that it's kind of hard to dig up that pipe or place it and have that not meet the 122 000 threshold so by that metric I would say most of the incidents are actually reportable under the Sims regulations so a different metric catches them versus The Spill quantity or something here correct damage correct I think that there's a duality and it's probably a growing event for us here in the gas side frankly I mean part of the issue I think on liquids is is that primary consequence is environmental and that can be caused by leaks and in so you've got a very tight threshold to try to catch leaks in the gas side you're you're I think managing in two different buckets if you will you've got safety issues the traditional pipeline safety issues incidents failures ruptures any incident rupture is going to trigger that threshold I mean you can see that around you're clearly going to go over that criteria in a rupture gas transmission pipes typically don't leak that's that's a different different and the way that the industry historically and I mean historically Back 40 years 50 years ago methane was thought to be more benign so if it if there was a question between safety in the environment it was okay the easiest thing to do is blow the pipe down discharge the gas as long as it's you know it's lighter than air it's going to dissipate into the atmosphere that's not the problem now we're starting to track leaks but who's tracking them EPA we report leaks to a very different threshold to the EPA and I say you've kind of got safety triggers you know whether which is a set of thresholds and then you've got leak discharges which is a very different animal in the gas and I think you're starting to get a sense of collecting that data now and but I think you're going to converge those thoughts and manage it yeah and I think you know you heard Tristan talk about that you know we're going to put more emphasis on the gas side about the environmental impact methane which I think is a whole paradigm shift into thinking too so the data is there it's just in different buckets I'm glad you brought that up because I was kind of wondering about that I mean hazardous liquids have to report five gallons spilled because people understand that five gallons of crude oil into a creek that was a problem and natural gas has been treated more as a safety thing three million cubic feet up into the air didn't seem like a big problem but in the last 10 years as we understand methane better that's a lot of gas going into the atmosphere should the atmosphere be treated as a high consequence area should instead of seven percent of your pipelines being in high consequence areas should the whole system be because it's going up into the atmosphere that's a that's a that's an interesting question you know um I'm gonna answer it yes I think not in the context of a high consequence area but I think it should be a focus area an intentional Focus area and I think it is growing to be just that um I think the environmental issue is becoming its own Focus area for natural gas and it's a huge growth opportunity and I think that's why I want to point out you know as mentioned the safety issues okay we've got this three million threshold that reports incidents now you're wrestling with a new social value you know a new constraint we want to try to track the environmental effects on gas it's not benign and we need to change the way we think so blowing down the pipe every time anything happens isn't a free move on the board we've got to think about that you know it's safe but that's not zero sum how do we try to pick that up so I think it is becoming a focus area whether you want to call a high consequence area or not it is becoming a focus area and I think we're now just starting to gather the data about what are the causes which is back to your plan to check Act fuel that plan with thoughtfulness well what does the cause of these releases and we're starting to see things you know that are managed by EPA like slipstream Emissions on turbines okay that's not a traditional safety thing that's an admissions thing for units that are regulated by a different agency okay it's not that it's not being managed being managed by somebody else so how do we fit the puzzle together and use all this information I think is really where we are right now yeah can I can I just add here I think there needs to be a recognition of planned releases and unplanned releases so on the plan release side Inga members are working very very hard to try and minimize that that methane vent to the atmosphere there's newer technologies that are being invented we're looking forward to those being further expanded upon another area that were I think we definitely need is regulatory updates from fimza you know one of the best examples is actually the class location rule so uh just for for situational awareness for the folks that aren't familiar with it when a lot of the pipes were built many many years ago the populations that were around them were a much smaller number and then as growth has happened more people have moved closer and then that necessitates a regulatory uh shift where operators need to treat the the areas where populations are nearby much more seriously and based off of the existing films or regulations operators are required to do hydrostatic testing or you need to cut out and replace the pipe so it's to a higher standard in both of those instances you could have gas that's theoretically vented to the atmosphere so we have been advocating very very strongly with fimza there's uh there's a provision in the 2020 pipes act which would require fimza to hold a gpac meeting on on the rule which fins unfortunately is late on but we're hopeful that we can get this this rule moving because you'll add more Integrity management items for those uh for those lines and then that would actually result in fewer emissions to the atmosphere so it's a twofer in my opinion it's going to improve safety and then it's also going to improve the environment all right let's get some questions great um hi my name is Joe Von Fisher I'm a professor at Colorado State University our group published analysis um earlier this year that looked at the abundance of natural gas leak in Distribution Systems um and as a function of sort of social justice issues we found in the analysis of about 6 000 leaks in 16 cities that the best predictor of leak density was percent people of color in these uh census tract areas and um and I say this not as a finger wagging I say this as something that Linda Doherty talked about yesterday in her panel about something that we're like oh my God yeah Linda was talking about as an inspector which she had to choose among places to go to inspect that some of the most vulnerable communities also had very high crime rates and they needed police protection to enter some of these areas and there has been um when I talk about this with other utility people you know one-on-one they're like yeah this happens sometimes in some areas it's it's hard to manage some of our of our areas and so I say from a distribution perspective but also more broadly there's a recognition that some uh more vulnerable communities have also experienced this pattern of um of higher exposure or higher risk so turning this around and not as a finger pointing but as of what could we do to record to fix patterns going forward for example could we include uh um census tract as a scale in our dimp models and look at vulnerable communities as uh as areas that we that we target for early repair and replacement or could we do reporting of all of our inventory and our management at the census tract scale that would anonymize things from location of infrastructure so would utilities The Operators be interested in in Greater reporting greater transparency and greater explicit management of their infrastructure to include uh social vulnerability as one of the management targets so that's I say it and I know it's a challenge I know that we're all facing this thing can we be more transparent can we be more explicitly targeting social vulnerability in the way we manage pipeline systems great you want to take a crack at that record a few questions yeah how is your company has your company started to look at how to address vulnerable communities um and and I'll be honest I I was in there yesterday uh when we're testifying it was very powerful session and I appreciate uh the question matter of fact I've made a note I have not read your study yet and I'm going to uh finally we can talk yeah here's here's what I would say to you is that um we don't want to treat anybody preferentially in that regard a person is a person whether they're EJ or non-ej in my opinion a life is a life and so the right way for us as operators to approach this and and I can only speak for my own company but we approach it in a very in an agnostic approach right so if we are looking okay first off when when they call the call center somebody calls and says they have a lead we don't ask them where they live right we take the leak we go um if we have a scheduled leak and it's coming due because of the regulatory requirement we go regardless of where it is in the city uh you know we live in this world now we're trying to get it you find it you fix it so um to me that's our goal is agnostic agnosticism on this in this regard on our distribution Integrity assessments uh we are right now um at least at our company shifting away from relative risk models into a probabilistic this is a big step for us it puts us on a Leading Edge um we are making sure as we roll this out at our first LDC that the considerations for um human impact and property impact are in that same way agnostic right so let me just I'm going to push back a little bit and let's let's make sure we give other people some chance too so okay well well one in one if we say all lives matter which I I think no one disagrees with but we should be able to look at the data and say are we behaving in that way and so Southern Company should analyze its own data and I suspect like most distribution companies you haven't and ask do we see an absence of a pattern um with respect to people of color for example so let's we can take this offline more and I could talk about I'd love to have a conversation about it but I will say we actually have looked at each okay great and we feel very good about okay we are as an operator anybody else talk want to talk about how you're starting to look towards vulnerable communities I know that's been a big issue for some sighting of new pipelines particularly I think it's it's to me very similar to the issue about you know about methane you know I think it is is a social awareness issue it's a new consideration not going to say constrained a new consideration that we have to be very thoughtful and get the get the information the facts and data in to make better choices become more aware as designing pipelines routing pipelines operating pipelines to take that into consideration and I think it's something we need to be deliberate about I think it's emerging right now and I think it's absolutely appropriate just uh Echo what Andy was saying in that we are definitely you know um talking about it right step one let's talk about it we've got data now we've got ways to evaluate that and Philip 66 we've add a layer to our mapping system with the environmental um Justice type of communities and so although we haven't I you know self-admit we haven't figured out exactly where we're going with that information but we do to a certain extent also want to be agnostic and so balancing of that uh so more some more to come definitely looks like Mr cooperowitz Rick Cooper with Zach facts I don't want to put Rick on a on a cross plier but uh do you map your grade leaks for your system you map them by grade by type by cause we uh so we keep up with all of our leaks in that regard you're right I mean grade ones get repaired immediately upon Discovery continuous I was involved in the dimp regulation and it's you know the process is kind of a sausage making you know we talked about requiring mapping of great leaks but we backed off of that In fairness some of the operators there's a wide spectrum large groups small group operators the technology 10 or 12 years ago was just developing it's been existent now for a good 10 years so most responsible operators that are distribution will map their grade leaks by cause by type and so they see if there's a hot spot being developed so they can get ahead of it I think that'll help address the earlier concerns we didn't get it into regulation we compromised on that responsible operators have been doing this for years now and so the public needs to know that I don't know if it rises to the level of requiring and in regulation but uh just just the data point for you so that's good I I I absolutely I will tell you that as we as an operator and I know many of the operators in the LDC sector you know we are looking at you know we're using the data that's that's the know your system you got to use your data so you you got to use the leakage data and you got to talk to your subject matter experts because the people in the field will tell you what the data doesn't tell you and we use that data to prioritize where we're going to go do our replacement so to your point if you have a hot spot and it's it's going to go to the top of the list there's more leaks or a thousand feet good all right there there's one up front here Lois um so we've heard a lot about satarsha Mississippi and the CO2 Denbury pipeline explosion we've heard from people who said that they spent the night in the hospital and multiple nights in the hospital but those injuries were not recorded as injuries and I believe that that affects whether or not that particular event shows up on any of these charts as a serious or a significant pipeline incident and so it you know it makes me wonder whether we've even captured everything that's happened on these charts and I wonder you know is it because we have this goal of zero incidents are we are we not counting incidents when we should be because we just want the chart to eventually say zero um how do you reconcile that how do you make sure that everything that should be counted is counted and represented to the public so that we can manage it and make good decisions Joe said something yesterday that I thought was really resident which was you know when we when we have data and we're open and honest and transparent about it we can learn from it and we can manage better so what do you think about this phenomena of not counting things that probably should be counted I'll I'll take a shot at that because I think there it touches on a conversation that I think Lois had yesterday in the data conversation the data session and that is um first of all this is one set of data this is incident data but we also track precursory things before things happen significant safety related events are tracked also the reported condition states that we give to femza and those I think are also a huge learning vessel for us a vehicle for us to get information on the system before things actually became a failure or impacted society and I think what's really important in this is is let's get everything in front of us to make that decision about are we you know are we well informed is what I hear you saying are you well informed are we trying to kind of create a fate of complete of a pretty chart you know and I think the point the goal and and I'm going to come back to something you asked Carl in a minute because I think it's really important is our goal is zero none of these incidents are are acceptable so how do you get marshalling energy to move the needle the most the fastest the best I mean that's really what that continuous Improvement cycle is about so you want as much information coming in to ask those questions to shape that plan and and I think that it's a learning process so why are some of the statistics going up well to be very Frank if you went back a couple slides where you're showing the breakdown across different threats one of the increasing components is manufacturing and materials why what happened all of a sudden what that really is a lot of the ingredients in that component is blowdowns the ESD system went off it's like okay that's what the SD system does so for years those didn't count we didn't we didn't count them because they weren't a traditional failure but when you start entering into well now that's methane coming out of the gas coming out of the pipe shouldn't do that it's a different kind of failure the device is doing what it's supposed to do but what caused it to break down well no ring failure well that's a material flaw that's not a traditional but it's something we want to get in front of us and figure out so the numbers they bump around as we kind of learn and change and grow in our Paradigm of looking at methane or looking at EJ or looking at these other things we need to just keep asking why what why is it coming up so when you look at equipment failures you see that's 25 percent what happened all of a sudden the equipment that this equipment was breaking it's not really breaking it's just another dimension of how we're looking at safety when we add methane and blowdowns and esds okay well those aren't traditional failures if that makes sense but their environmental releases which is now something we're trying to track so it's just some of it's a growing pain while while the microphone comes up to Alan I'm gonna sneak a question in here that just to help inform you know there's different requirements in Integrity management for gas transmission they have to run smart pigs you know generally every seven years hazardous liquids it's every five years um one of the things we keep hearing I think one of your recent incidents I know Marathon had one shell had two that I can think of was that they ran smart pigs uh and and but there was an incident and what we heard was that the data hadn't been received or incorporated into the system before the failure occurred so they were doing the right things but there was too much time lag between when your vendor or whoever ran the smart pigs and you got the data to mitigate the problem and you had a failure um does that mean the the reinspection intervals are too far apart um I think we have two questions there I'm gonna try to break them down uh the incident that I think you're referring to as US with regard to a hard spot in Kentucky uh we ran the hard spot tool and the vendor came back and said there was nothing actionable there and I think that was really more of a technology limit than a uh than an egregious breakdown by the vendor or any sort of control problem I think some of the technologies that we have out there um are emerging and hard spot tools are not um something that's well used got a lot of track time in the history of the industry so there's not quite that level of performance like we do on mfls it wasn't that it was in the can it's that they didn't understand how to analyze it correctly and have the technology to break down the signals um back to the in so that's one question the other question I thought I heard was about the inspection frequencies um you know the thing that I uh I really appreciate as I get older and you know it's not trivial is uh you learn and I think that when we built an asme and we built the reinspection interval requirement for seven years so we're looking at it a hundred thousand miles pipe and you're trying to figure out okay what's a conservative growth rate for a hundred thousand mile pipe in the desert in the mountains and the city and the dirt and the water and we're like okay that could be like all over the board and it is so you look at a bell curve what's the data telling us and you pick a number we picked 11 actually as a conservative growth rate and then we took 30 percent of I came to seven that's not everything but it's most so and it's conservative it's factual based it's science okay and then we just keep getting more and more data but when we wrote the the standard and which became a rule it was and the operator should consider the specifics of the situation and determine whether they need a more conservative inspection frequency because we know if we tried to cover 100 it might be every other year because there could be some place in New York City where you've got it's all kind of interference currents and it's super aggressive and you need to be on that well that doesn't work and a rural environment where you got good CP so you're trying to make a decision so that compliment that second part of the operator has to consider is really important it's but it's not prescriptive and that that takes the onus of the operator and the regulator to sit down and go did you really consider this did you really dial this in so how often does your company or companies you're aware of actually do inspections more often than they're required to I would say we run about half our tools I'm looking at half our tools are less than seven years but some of that is probably counter-intuitive we may run it on seven years so that we don't have to predict out as far the growth rate so that we don't dig up a bunch of things that aren't growing that fast the other side of the bell curve or if we do that when we run a tool let's say run until this year we find 20 anomalies two of them are near-term and some of them we have to predict out how fast they'll grow so in seven years we come back at the right time well if we assume an aggressive growth rate we have to come back and most of them aren't doing anything like well that wasn't a good idea so it's easier actually shorten the interval up so I'm going to predict that as far if you if that makes sense the further out you predict the wider that Gap gets if it's growing at this rate but you're predicting out you know an aggressive grade by the time you go out a long way there's a lot of them didn't go anywhere so you're digging up things you don't have to dig so there's a counter-intuitive part of it too taking more frequency actually cuts down the number of anomalies that big most the time and it helps build your risk you know confidence in your risk conclusions so how about the liquid side Stephanie let me build on that so and the reassessment interval is um has a lot of pieces of information and parts to it right so five years on the liquid site compared to the seven but that five years is a not to exceed that's not a baseline reassessment interval your Baseline reassessment interval and comes through the procedure that the operator has written into their integrity Management program that takes into account um the data from your tool runs the current tool run your previous tool runs it takes into account risk it takes into account any other pieces of data that would go into that particular inspectable section of pipe to come up with that reassessment interval and and so while um there is you know obviously that five years of regulatory not to exceed your Baseline really comes from a calculated uh methodology um as well as you know our technical experts who have um really you know we've got technical experts and and phds I think were mentioned that work their careers in this space so that they can be the best educated to make those best decisions and I will note um that you know films that has a guy although you know the they do an actual regulation um it's the five years um or um earlier as needed they do have a guideline that would help operators set those reassessment intervals out there so what percent of your pipelines do you do more often than five years I don't have that number um offhand um but you know I do we do we do do um a fair amount because I can think of specific sections all right I'll quit bow guarding the uh microphone here Alan Alan Mabry it seems uh something Rick said piqued my interest on a topic related to risk modeling and um you know over the years we've seen issues with the relatives index modeling this that's been used quite a bit in fact we had a workshop way back in 2015 to really leverage the knowledge on and really guide the usage of risk modeling tools but I just wanted you to comment on where we need to go next because we're seeing issues with things are still being missed dealing with one of my favorite topics interactive threats which really is what's happening with some of these geotechnical events where you have land movement which where you combine like a lot of rain or or global warming for instance with you know vintage pipeline yeah varying thrusted or interacting and where do you think we need to go with that you mentioned probabilistic yeah uh no that's a great question Alan um the uh I'm gonna I'm gonna dance a little bit on you here because I don't think one size fits all with the answer and that's and in that sense I think as long as we and I'm going to stick to the distribution side I love Andy or somebody else speak for the transmission side on that but on the distribution side as you well know we have operators that vary from 5 million customers all the way down to operators have less than 100 meters in that regard so uh I don't think that's within the realm of EX possibility for those small operators to get into the field of interactive threats they just don't have the technical wherewithal in that regard so I don't think that a mandate of that would actually fix it I think the big operators will start to will go down that path but I think you got to have the right Tools in toolbox for the big operators and the small on that side but but moving towards I think the industry is doing a good job on its own of moving from relative risk to probabilistic and then interactive sits behind anybody else on that one yeah I'll take that you know I think when we look at what's the next big next iteration on The Virtuous cycle I think Mega world one and two are a big step forward I think they provide a lot of clarity but I think when we look out there I think that quantitative risk assessment qra probabilistic approach is logical we've moved in that direction because we wanted to improve the certainty of the conclusions that we're making and the actions that we're taking it's a model that comes out of the medical industry the aviation industry we talked about that yesterday the nuclear industry I think it just takes a mountain of data and a lot of energy to break that down the five away questions across all those threats but I do think that's the next opportunity and I think it's probably a 15 to 20 year Journey To be honest but I think the I think the The Climb is worth the view so I had something to add here as well while Annie's going way further in the future and I know we've already previewed this with with you Alan but inga's imci or Integrity management continuous Improvement program we did our second iteration of that uh and two of the items that I think would be worth mentioning are on emat tools we're trying to get more uh more operators to use the tool and then also uh as Amy alluded to earlier on Geo hazards you know that joint industry project the ingos has facilitated uh the goal is to get that through an eventual API standard but those are just two tools that are part of that imci program that inga's trying to move the ball forward to try and just keep the the State of the State increasing all right we're got about four or five minutes left so in the back good morning my name is Jade woods and I'm from Baton Rouge Louisiana West Baton Rouge Parish which is just about an hour up the road it's also the northernmost point of what's often called cancer alley or death alley and I have a responsor a comment to what was said earlier um there's been a lot of talk today about environmental justice and black and brown communities and in particular environmental justice or Frontline communities and I don't see very many of us in the room today so I will provide some perspective I want to make it clear that when analyzing why leaks insignificant and serious incidents have occurred in disproportionate rates in communities of color that deserves much more than a passive sort of agnosticism in your analysis that deserves a very clear very Equitable and intentional analysis about why communities of color have been experiencing the public health and environmental health impacts of this infrastructure for decades and so I call on all of you to do a lot more I'll keep this brief and the next panel in the breakout room will be about CO2 pipelines specifically in environmental justice communities and I really encourage all of you to attend to continue this conversation because it deserves a lot more time so thank you thank you for your comments All right we can probably squeeze one more in either he's giving me the one minute sign Mr lesniak this is a comment and a question the I heard Andy say this and I've heard several other uh folks in the industry say this over during the conference um is that the need for updated uh rules and regulations and so my comment is a challenge to the industry is make sure you're doing everything you can to make the rule making process move swiftly and um because uh to be honest my impression is that one of the reasons the rulemaking process goes slowly is because the industry doesn't want it to go fast and if and if you want it to go fast you can help with that and so I really hope that the associations are doing that because I think it's in everybody's best interests I'm not saying that fast bad rules but fast good rules and let's not slow them down make the bureaucracy worse than it already is yeah and that kind of relates to something you and I were talking about Andy that uh you know the last big tranches of the mega rule as they came out the industry challenged those and slowed it down more how do you explain that if you're in favor of safety well you want me to take that one sure so um so I appreciate that that Carlin and I appreciate the question Chuck so uh as you all know Inga filed a petition for reconsideration of the most recent gas transmission rule part two and this is where I think uh when you read it it seems like we're angry and we hate finza and the rule is garbage and and whatnot but we made very clear to put up front in our position that we support the rule what we wanted to do was get some more time to implement it it's a rule that took over 10 years to write it there was a four-year gap between when Finns are considered it through a gpac meeting and there were aspects that ended up getting Lost in Translation over that four-year window so in our view first of all we needed more than nine months to implement it because we were already under trying to implement the valve Rule and then also we for such a complicated rule it typically takes time you want your operators to have their procedures in place training to be there and that takes it takes time so we were pleased that that finza ended up granting an extension for the additional nine months that we had asked for but then also on the other items we were trying to improve the rule there are sometimes areas where the the rule didn't necessarily mesh up with other aspects of of the code so we pointed that out to ensure consistency and strength so it may seem that we're trying to slow down the process in actuality we're just trying to make sure that the rule is stronger more durable so that it will exist for many many years to come with that issue all right we are out of time we're going to take a break there's your choices for the next session help me thank these folks for taking a well semi-moderate grilling [Applause]