This week’s Pipeliners Podcast episode features Byron Coy discussing the importance of keeping proper records, how the use of records has changed over the years, and the different values records hold. 

In this episode, you will learn about the different types of records, how to correctly store and update them, and how proper record keeping can benefit the industry.

Purpose and Uses of Records in Pipeline Safety Show Notes, Links, and Insider Terms

• Byron Coy is a highly accomplished pipeline safety professional with over 30 years of experience in the industry. He has dedicated his career to managing and mitigating pipeline safety risks, specializing in the application of pipeline safety regulations. Byron is currently working as a member of the regulatory advisory team at EnerSys Corporation. Connect with Byron on LinkedIn.
  • EnerSys Corporation, an EnerACT company, provides pipeline control room software tools and related subject matter expertise to the oil and gas pipeline industry. EnerSys is focused on control room operations, including SCADA, scheduling, control room management, leak detection, and interaction with field operations.
• PHMSA (Pipeline and Hazardous Materials Safety Administration) is responsible for providing pipeline safety oversight through regulatory rule-making, NTSB recommendations, and other important functions to protect people and the environment through the safe transportation of energy and other hazardous materials.
• Pigging refers to using devices known as “pigs” to perform maintenance operations. This tool associated with inline pipeline inspection has now become known as a Pipeline Inspection Gauge (PIG)
• Pipeline Right-of-Way is a strip of land encompassing buried pipelines and other natural gas equipment allowing them to be permanently located on public and/or private land to provide natural gas service.
• ILI (In-line Inspection) is a method to assess the integrity and condition of a pipeline by determining the existence of corrosion, cracks, deformations, or other structural issues that could cause a leak.
• PIR (Potential Impact Radius) is defined by PHMSA (49 CFR subpart 192.903) as the radius of a circle within which the potential failure of a pipeline could have significant impact on people or property.
  • PIR Calculation: PIR is determined by the formula r = 0.69* (square root of (p*d 2)), where ‘r’ is the radius of a circular area in feet surrounding the point of failure, ‘p’ is the maximum allowable operating pressure (MAOP) in the pipeline segment in pounds per square inch, ‘d’ is the nominal diameter of the pipeline in inches, and 0.69 is the number for natural gas (the number will vary for other gases depending upon their heat of combustion).
    • The formula that an operator must use in calculating the potential impact radius and potential impact circle for a pipeline is explained in the definitions provided in 49 CFR 192.903.
      • A diagram displaying how a potential impact circle looks can be found in Appendix E to Part 192, Title 49 (Guidance on Determining High Consequence Areas and on Carrying out Requirements in the Integrity Management Rule). This guidance is for the integrity management rules for gas transmission lines, but the diagram displays the same basic concept as the potential impact circle for a regulated gathering line.
• ASTM International (f/k/a as American Society for Testing and Materials) is an international standards organization that develops and publishes voluntary consensus technical standards for a wide range of materials, products, systems, and services.

Purpose and Uses of Records in Pipeline Safety Full Episode Transcript

Russel Treat: Welcome to the “Pipeliners Podcast”, Episode 299, sponsored by EnerSys Corporation, providers of POEMS, the Pipeline Operations Excellence Management System, compliance and operations software for the Pipeline Control Center, to address control room management SCADA, and audit readiness. Find out more about POEMS at EnerSysCorp.com.

Announcer: The Pipeliners Podcast, where professionals, bubba geeks, and industry insiders share their knowledge and experience about technology, projects, and pipeline operations. Now your host, Russel Treat.

Russel: Thanks for listening to the Pipeliners Podcast. I appreciate you taking the time, and to show that appreciation, we give away a YETI tumbler to one listener each episode.

This week, our winner is Sarah McGlon with Flint Hills Resources. Congratulations, Sarah. Your YETI is on its way. To learn how you can win this signature prize, stick around until the end of the episode.

This week, we’re going to speak to Byron Coy about the purpose and uses of records in pipeline safety.

Byron Coy, welcome to the Pipeliners Podcast.

Byron Coy: Good afternoon.

Russel: Very glad to have you. I think probably a lot of our listeners know who you are, but before we dive in, maybe you can give us a little bit about your background and tell us what you’re doing these days.

Byron: After school, I was actually in the pipeline industry for a number of years before joining PHMSA. All that time at PHMSA, I started out as an inspector for a while. I ended up being the Northeast Region Director.

Towards the end, I was developing programs like controller management, underground natural gas storage, and the newly released methane reduction program. Now I’m back in the industry working with EnerSys.

Russel: I’ll just say that we are very glad to have you. You add a lot of value to the team already, and we’re learning a lot. I thought I’d bring you on the podcast here and give some other people the opportunity to learn as well. How long did you actually work at PHMSA? How many years were you there, Byron?

Byron: 27 and change.

Russel: 27 and change. You’ve been around that organization for a long time. You’ve seen it go through a lot of growth and change and everything else. That’s awesome.

Byron: Mostly everything else.

Russel: Yeah. Mostly everything else. I asked you to come on, because I think the first thing I’d like to talk to you about is pipeline records and their importance. Maybe a good place to start is just ask. What is your general idea about what are records and why are they important?

Byron: Every pipeline operator makes and stores records probably on a daily basis, for design considerations, operating and maintenance, testing, and maybe on occasion, for instance, in accidents. On any given day, records are created, they’re retrieved, reviewed, archived, and some purged.

Yeah, there’s a regulatory requirement for records, but there’s a much broader value that pipeline operators can get out of these records.

Russel: What do you think has changed during your time with PHMSA? What do you think’s changed with operators about how the operators view records?

Byron: I think a lot of folks are getting more value out of their records than just collecting them because the regulator said you had to. I suspect that most of that is because of the application of the integrity programs, which requires a lot of deep dive data analysis with in line inspection, etc.

There’s an expectation that operators will look at data across multiple pig runs, and different kinds of line assets to get that deeper value out of information perhaps than was done before.

Russel: Yeah, I have a premise about what’s going to be required for our industry to get another order of magnitude of improvement and safety performance. Part of that involves what kind of records we gather, and what we do with those records once we gather them.

To your point, Byron, you talked a little bit about there’s a regulatory need or a regulatory requirement for records, but more broadly than that, and probably more important than that is there’s an operations and safety effectiveness opportunity with well structured records.

Byron: You bet. From a regulatory perspective, I just did a little poking around here in advance of our session here and the word record shows up over 450 times across all of the DOT pipeline safety regulations. That gives you a sort of an idea of how important records are to the regulatory world. That the highest count of any of those is within the gas code 192.

Russel: I’ll tell you, it makes me wonder if there are 450 different types of records. I don’t know if that’s a one for one, but it’s a large number for sure.

Byron: You bet.

Russel: From a regulatory perspective what kind of things beyond just the integrity management stuff, what other kinds of things are called for in the pipeline safety regulations? What kinds of records are there?

Byron: A lot of the records that are required to be kept are used to, I’ll say, validate or keep honest that operators are doing the kind of things that the code requires. The inspectors, they don’t live with the operators, god forbid.

The regulators are dependent on the quality and the depth of the records to help the operator demonstrate that they’ve been engaged in doing what’s required of the code. It’s a rare time that PHMSA chases someone because they’ve got funny records.

That would be serious trouble if someone were to get involved in that. You got records to demonstrate that you’ve been performing work to remain in compliance. Then often, there are records that are there to bring information to the attention of the operator that maybe they wouldn’t be looking at otherwise if the code didn’t ask them to do that.

Russel: When I think of programs, I think about policy, you have the code, you have your policy, you have your procedures, and then you have your records. From an operator standpoint, I often think the most important thing is the procedures. You’re really getting clear about what you’re asking people to do.

I would be interested in your perspective. What are more important or more valuable to the inspector – procedures or records?

Byron: Oh, let’s talk about both of them here for a minute. Procedures, the operator creates the procedures. The regulations are a set of objectives and the operators have to take those objectives and translate those into workable products, things that they have to do to accommodate what those objectives ask.

The record then is the vehicle to demonstrate a scorecard of how well did the operator translate those objectives. Did they yield the records as a way to validate that the procedures are realistic and the operators have been accommodating what they call out for?

Russel: Yeah. There’s a very tight correlation between procedures and records. I would think, and I’m just making this up, but I’m looking for your opinion on this preposition or supposition. That is well written procedures but poor records creates concern, more so than poorly written procedures but excellent records.

What I mean by that is at records that reflect you’re doing the things that need to be done and you’re capturing the data you need to be looking at.

Byron: Yeah. Maybe you don’t want to be in either one of those camps. You want to have good procedures and good records, either of the two is probably not so well. If the records are poor, that can raise a little doubt about the quality or thoroughness of the procedures.

Are the records poor because they’re just structured poorly or didn’t the procedures adequately orchestrate what the records are supposed to represent and how often they’re applied? Who reviews the records? How long are they going to be stored?

A lot of that relates to how well the operator maintains the data quality and the integrity of those records.

Russel: When we do reviews, so we’re working with an operator to prepare for an audit, there’s always focus on the policy, the procedures, and the records. Often the deficiency is in the records. When you start peeling the covers back, there’s all kinds of reasons why there can be deficiencies in the records.

In those situations where we’ve gone in and found really good records, but the procedures maybe aren’t that good, that’s just a need to modernize the procedures because the records reflect you’re doing the right thing.

You probably just need to modify your procedures to reflect what you’re actually doing versus poor records. Often there’s a lot more digging you have to do to get to the root cause.

Byron: Yeah, there’s a factor to that in the inspection process. An inspector may be looking at the procedures and they’re at odds of whether or not they think they’re adequate or not, on the fence as it were.

If they look at the correlating records and they seem to be thorough and account for all that’s necessary, that may cause the inspector to say, “Well, maybe the procedures aren’t that bad.” Because, the records as an outcome, are fairly good. In that case, the records can help color the procedures maybe a little bit better than they are.

Russel: I should probably make the remark that, these kinds of things we’re talking about here there’s a lot of judgment and gray. It’s not a black and white thing. I think sometimes, I know from my perspective, working with operators to help them get programs in place often is a lot of focus on the policy and the procedures and the records. It’s often difficult.

Particularly for a new operator. Somebody just bought assets or just built assets, they’re so focused on just getting competencies built up. For the guys that are more mature, the focus tends to become more about can I analyze these records and can I do analysis that tells me something about where I’m trending? That requires a mature program.

Byron: Yeah, you’re right about that. But inspectors are looking for procedures that they think the operators could actually fulfill. Procedures have things in them that are practical and they make sense. If they yield reasonable or good records, that’s the best of both worlds from an inspector’s view.

Russel: What is your perspective about, once those records are completed, what’s the aftercare and what’s the value of that aftercare in a good program?

Byron: A lot of operators, they’ll have someone who is the data keeper. Although they might not call them that. They’re responsible for maintaining the records. Now they’re not collecting the records. They didn’t write the procedures that dictated what the records consisted of, but he or she’s got all of them and they’re looking after them.

Once you’ve got them, now there’s an ownership issue there. How frequently do they need to be collected? Is this a monthly process, semiannual, quarterly, annual? If you have records in hand, someone should be assigned to review them.

I can recall a long time ago, I was looking at pressure discharge records off of a paper chart recorder with the red ink pen. You could always tell who was responsible to change out those paper rolls, because that was the guy that had the blue or red fingers, right?

Russel: Right.

Byron: The chart I happened to pull out, every month they put a new roll of paper in there and pulled out the chart. By halfway through the month, the discharge pen just went up to the top of the chart and just rode there for the rest of the month. I asked I don’t think the pressure actually did this, it looks like something went wrong here.

The station chief called in the technician that’s responsible for that recorder. “What happened here on the 16th? The pen just went off the chart.” He said, “I don’t know.” He said, “My job is to change that paper every month and I did.” There’s a record that kind of went south.

There was a conversation we had about who’s recording the data and who’s looking at it?

Russel: Yeah. Oh man. I will just say I’ve had similar kinds of conversations, with something that was put in place for a good reason, but the diligence and care changed over time because people felt, we’re looking at it anymore for a lot of reasons.

What that does indicate is just because you have the record doesn’t mean you’re getting to the results you’re looking for. In your example, you would think that somebody would be looking at that tape and determining if things were working the way they ought to be working.

Byron: Yeah you’re right. Say the origin source that the data itself from that recorder, in this case was a piece of information that the operator could be using for demonstration records, but also maybe operational purposes.

There may be, in a lot of cases, data that carries some additional value that is not obvious from the data itself, saying you can’t see the forest for the trees.

Russel: Exactly. Your story, Byron points specifically to the human factors or sometimes what we call the organizational bits around the data, the forms, the process, and all that is how the human beings that are doing this work, interacting with this data, relating to it.

Byron: I think the information beyond the visible piece up front, I call that the collective analysis concept.

Russel: Explain what you mean by a collective analysis, please.

Byron: Collective analysis, maybe on an individual piece of data, you’re looking at it over time. What was the reading last month or last year? Or a collective analysis maybe looking at, I’ve got three units that are identical. Why is the power efficiency drifting on this one and it’s holding steady on the other two?

If you’re looking at discharge pressure at a given time on one unit you’ll never see those kinds of things, but you could have some things going south. Unless you really look at the forest the trees will just be in the way.

Russel: I get it. What you’re calling a collective analysis is what I would call getting elevation on the problem.

Byron: Yes. That’s another way to look at it.

Russel: Yeah. It’s just another way to say the same thing, but it’s getting a holistic picture, and then seeing where that takes you versus just looking at the details.

Byron: Yeah, let me give you another example. Being in the department for so long people used to come to me and say, “Byron, that could never happen.” It has happened and I’ve seen a lot of them. Operator has a gas transmission line. It’s got three of them in common right-of-way.

For integrity purposes, they’re looking at the potential impact radius for consideration of inline inspection. The two 36 inch lines get your inline inspections, and they both show up some external corrosion at this particular location by a creek.

The 24 inch line, it’s PIR didn’t reach the people, so no inline inspection was necessary. They didn’t perform one. They had to do remediation work on the 236s because of the corrosion issues, but they never uncovered the 24, which was, I don’t know, 15 feet away. You know what happened about a year later, that line failed, root cause determined to be external corrosion.

I don’t know, I like to think maybe it was overlooked because I wouldn’t want to think that someone would say, “Hey, let’s not dig it up because we don’t want to have to make a repair.” That’s the kind of information you glean out of a collective analysis.

Russel: That’s actually an interesting conversation on its own part, because depending on the way my program is written, and depending on what my responsibilities are, what I’m doing might not cover that other pipe. You could have a situation too, similar situation, where that third pipe is owned by somebody else.

Byron: That would be tougher to reveal, right?

Russel: Exactly. You would think that if you’re dealing with a corrosion issue on your pipes and you’ve got another pipe in the same right-of-way, you might want to share that information. Now I realize there’s all kinds of issues with that. Again, that’s a whole nother conversation on its own.

What it does point to is we have a fiduciary responsibility to keep all products in all pipes, right? Beyond just the thing we’re working on.

Byron: Yeah, and that’s for sure. I just want to comment that what I described was not a shortfall in regulatory requirements. There was no requirement to do inline inspection because of the parameters in the GIP program. There were issues afoot, disappointments afoot, but not necessarily a regulatory shortfall.

Russel: This is where you use terms like due care or that sort of thing, but regulatory compliance is an aspect of pipeline safety. It is not in and of itself pipeline safety. Pipeline safety is compliance plus other things.

Byron: You’re right. The code is made up of a lot of old ASTM standards and the like, and there’s a lot of extra material in the code now that it’s come about over the years as a result of accidents, like I just described, and other events over time.

Yeah, it’s a minimum standard, but the pieces that are in there, they’re in there for a purpose. Shame on the operator if they’re just doing things to remain compliant because the code requires them. There’s a reason for it to be there, so there’s probably a good reason to get those things done.

Russel: Coming back to what we were talking about with records, right? There’s all kinds of challenges often when you have records, and the situation you’re talking about is three pipes running parallel – two 36 and one 24.

Correlating records you’re finding on regulated 36 inch pipe with records on unregulated 24 inch pipe or different compliance standards in a different program for a different pipe. That’s non-trivial in a lot of cases.

Byron: Yeah. There’s a lot of a mix of assets and it can be a little daunting. The offers, they have to sort out what’s required to do on what, where. Everybody understands that there’s budgets and fundings to do things.

Everyone’s trying to do the right thing to keep safe. Often, there’s limited resources to work with.

Russel: True. That’s true. It’s not a trivial thing to…One of the things we’re doing a lot more of, and I think this is probably true, particularly in construction, is we’re creating a whole lot more records. On new construction, all of that information is digitized and in structured databases and available for analysis.

That’s all great, but you still have to have the resources to do the analysis to get the value out of it. Records can add value, but they do have a cost associated with having them and squeezing that value at.

Byron: If you’re right, then you can spend a lot of time and not find anything, right?

Russel: Exactly. There’s a little bit of elevation, but there’s also a little bit of art to this. I don’t know how you would accomplish this in a program, but I know engineers particularly in gas plant operations and such that can walk out, stand in the plant, close their eyes, cock their head and listen and tell you what is working right and what is not working right in the plant.

Yeah, that comes from experience, and a lot of hands-on experience, like actually doing it kind of experience. That is something that good records management will tell you the same kind of thing, but there’s a little bit of art to it that comes out of a lot of experience.

Byron: In the recent years I’ve seen a lot of places where individual departments were responsible to do their own analysis on the records of their department. Of late there are some analytics departments cropping up that are not associated with one particular topic area, but they’re looking at the data at large to gain information.

Because that’s what they’ve possibly studied for and been doing for years, and where the people in the department were focused on corrosion control.

Russel: I think the whole pipeline safety thing is driving some of that. Because if you’re doing a good job with pipeline safety, and you’re looking at some of the programs, in my world, alarm management is a good example. Alarm management typically cuts over multiple departments.

We’re starting to have programs that cut across multiple departments and we’re starting to build some competency and capability around doing analysis across multiple disciplines. Really I think that’s the future for us in pipelining is to start getting to the point where we have an understanding of the entire system and how to analyze the system and not just the function.

Byron: Yeah, I see more of that happen.

Russel: Yeah, it is. It’s accelerating and there’s certainly people looking at different kinds of artificial intelligence and other things for doing it. I agree with you. I think that’s where we’re going. I think again, that supports why records are so important and why having them constituted and built up in a particular way is really important.

Because they have a lot of value beyond just demonstrating what you are doing, they have other value in terms of increasing your safety and operations performance.

Byron: Yeah, that’s for sure. You have records for drug and alcohol testing that demonstrates that you’ve performed those tests, maybe annual reviews for operations and maintenance programs. The records are there to demonstrate that you’ve done that work, but the greater value is what you suggested.

You got to get away from the trees so you can get a good look at the forest.

Russel: Exactly. I think that’s the right summary of this conversation is, build your forest and then figure out how to look at the forest. That’s non-trivial, man. I say that like it’s easy and I know it’s not. It’s a very challenging thing to do in these pipeline operations companies, because they have so many kinds of data of so many different types.

It’s not unlike, you go to the doctor and get a full physical and they do an MRI, an X-ray, blood work, and a CAT scan, and they run this whole barrage of different kinds of tests. All of these tests create different kinds of data, and then somebody has to look at all that and determine if you’re healthy or not, and if you’re not healthy, what to do about it.

We are very much like that as pipeline operators.

Byron: I’m clearly not a doctor, but I’m not so sure that anybody’s looking across the different kinds of tests as a whole. That’s what we’re asking the pipeline folks to do.

Russel: That is the value of the old general practitioner, and they’re harder to find in this day and age. That’s also true, probably in the pipeline world, it’s harder to find the general practitioner.

Byron: A world of specialists. Hey let me say, Russel, that the records clearly have multiple values. They provide an easy way for an operator to demonstrate that they’re in compliance with different aspects of the code.

The record can sometimes be a form that’s been filled out because of some regulatory requirement. The form now becomes a record. The records can help demonstrate the thoroughness of their procedures. We talked about a couple of minutes ago. There is always that squeeze to get that additional value out of that collective analysis we talked about.

Russel: Yeah, absolutely. I think that’s very well summarized. Byron, so very glad to have you on the team. Great to have this first podcast conversation with you. For the listeners, Byron and I are working on putting together a series of episodes and we’re trying to do that thoughtfully and in a way that provides some really good educational value for pipeliners.

Maybe we’ll come up with something about what do you need to do to be a good pipeline general practitioner? I hope you enjoyed this week’s episode of the Pipeliners Podcast and our conversation with Byron. 

Just a reminder, before you go, you should register to win our customized Pipeliners Podcast YETI Tumblr. Simply visit PipelinePodcastNetwork.com/Win and enter yourself in the drawing. If you’d like to support the podcast, the best way to do that is to leave a review. You can do that on Apple Podcast, Google Play, Spotify, wherever you happen to listen. You can find instructions at PipelinePodcastNetwork.com.

If you have ideas, questions, or topics you’d be interested in, please let me know either on the Contact Us page at PipelinePodcastNetwork.com, or reach out to me on LinkedIn. Thanks for listening. I’ll talk to you next week.

Transcription by CastingWords