Outside Review of Revised Pipeline Analysis

Late last week, I forwarded a copy of the draft Pipeline Safety Hazard Assessment to Richard Kuprewicz. He is a pipeline engineer who has worked with the City of Bellingham, WA and with the Pipeline Safety Trust. Mr. Kuprewicz is often quoted on pipeline matters in the press and has extensive experience in this field. You can gain appreciation of his background by simply entering his name in a search engine such as Google.

Mr. Kuprewicz’s comments are reproduced below. In reading this material, keep in mind that he has no first-hand knowledge of the the SJHHS site and his comments are based on his first reading of the July 16 draft. Also, he was not paid for his comments.

I have completed a quick review of the attached draft and have the following general comments which are by no means meant to be limited to all the problems or serious mischaracterization associated in this draft report.

I do not know if it is the pipeline inexperience of the “professional engineer” or the fact that she must follow a “goofed” guideline protocol defined by the CDE risk assessment method that creates a very poor risk assessment concerning transmission pipelines based on the many false technical assumptions or related misinformation that apparently biases the outcome. I’ll let you be the judge on this matter. Some quick general comments.

1) While this report is “stamped” by a professional engineer the fact remains that concerning pipelines there is no such animal as a profession engineering stamp for pipeline engineers. Risk assessment and pipeline design, operation, maintenance, failure dynamics, responses, and siting issues are highly specialized fields and not many companies or government agencies or individuals bring the unique system experience required to qualify to be true experts in this field. A review of the pipeline regulations and pipeline codes will clearly indicate that experience in this area takes precedence. The stamp Is an illusionary safety that the attorneys and insurance companies can neutralize if it had to come to that extreme.

2) The report fails to adequately present or properly discuss the much higher release rate dynamics associated with liquid transmission pipeline rupture of a highly compressed fluid. For a 16 inch pipeline operating at a pressure near 1425 psig you can bet that the release rate will be well beyond 10,000 Bbls/hr until the pump energy and line pack effect dissipate (this can take quite some time). Note that this rate increase release volume, depending on SCADA operation recognition and reaction time, can easily exceed the volume associated with pipeline drain down which brings to question why 5 minutes was chosen for rupture detection and pump shutdown. It is my extensive experience that 5 minutes is a very fast reaction time and no information is provided in the report to verify such an optimistic reaction will occur during a rupture on this pipeline segment. A plot of the amount of tonnage of fuel released over time taking into effect the transient hydraulic effects will make this rupture mass release point. I’ll let you take a guess as to how many microseconds a rupture release will take to blow to the surface and form a very large and turbulent vapor cloud. I am not here to scare folks just to be sure people are making informed decisions based on facts and sound science

3) I’d be real careful about overstating the safety associated with integrity management regulations as many pipeline companies are still on a learning curve. Note also that KM is under a CAO or settlement with PHMSA as a result of numerous pipeline failures that apparently their west coast integrity management program missed.

4) It is unclear whether all the girth welds in the KM pipeline in this area were inspected. Note that federal regulation at the time of this construction (1986?) did not require all girth welds to be inspected. KM could clear this important matter up quickly by stating that they did indeed radiograph all girth welds and ideally still have the records of such important construction inspections. Girth weld failures associated with land or earthquake tend to manifest themselves as rupture releases.

5) It is stated that “The CDE protocol relies on an annual frequency of pipeline failure based on historical data collected from the Office of Pipeline Safety (OPS) Hazardous Liquid Pipeline Accident Database.” There is insufficient evidence to verify that the assumed pipeline failure probability of 1.3 x 10-3 is appropriate for this segment of the KM pipeline. This value/determination is very leveraging to the risk assessment conclusion. There are many problems with the OPS database – one of them being that false or erroneous reports made to this database cannot be corrected by OPS. There are other serious problems with this protocol utilizing history to predict future pipeline operations. Know of any pipeline operator that is still running his pipeline like he was 1 year, 5 years ago, or ten years ago?

6) It is stated in page 7 under ‘Human Error” that “Past pipeline accidents that were caused by third party damage but compounded by human error (e.g., the Bellingham pipeline accident in 1999) resulted ...” This is an error of fact in the report related to Bellingham and underscores more of the problems probably associated with the OPS database. The primary failure initiator for the Bellingham rupture has never been publicly disclosed and I am not permitted to disclose that evidence. I can, however, speak up when others are not being truthful or have mischaracterized the cause of this terrible tragedy. The NTSB report wisely mentions that third party damage “contributed” to the Bellingham failure. Somewhere in this risk assessment report for this KM pipeline I read that they have some remote operated valves that close in one minute – now that gets my attention on a 16 inch liquid pipeline operating close to 6000 Bbls/hr! KM had better have very competent transient pressure hydraulic modeling engineers on this pipeline segment who know what they are doing!

7) One last comment on the assessment’s observation that hydrocarbon vapor mixtures in the open can’t explode. Such poor observations demonstrate very poor experience with hydrocarbon mixture releases and emergency response (such as gasoline) even in the open.

Anyway, I think I have made my point. California may be trying to make progress in school siting around pipelines, but let’s all try to avoid an illusion of safety that poor risk assessment approaches can create. The illusion of safety can cause groups of very smart people to do incredible stupid, even reckless decisions that can drive to serious failures.

In my opinion, comments such as these make it clear that our school Board should not rely on a single opinion regarding the risk of the pipeline. Other experts like Mr. Kuprewicz should be retained on behalf of the Board to raise the appropriate questions and extend Ms. Fitzgerald's analysis to consider practical steps that would mitigate risk to students and staff in the area of the school.