In the third and final portion of the series, Not Every HCA Analysis is Created Equal, we’ll explore the effect of the type of product being transported, and how to incorporate pipeline facilities into the analysis process. If you didn’t catch the first and second segments of the series be sure to check back before continuing on here to learn about ever changing HCA boundaries and realistic model inputs.
In our previous post in the series, Not Every HCA Analysis is Created Equal, we talked about the importance of verifying analyses provided through software or vendors, and the potential vulnerabilities to consider, as well as the basis of identifying HCAs and their boundaries. In this installment we’ll be deliberating how model settings and data can impact emergency response plans and generating release scenarios.
Performing High Consequence Area (HCA) analysis correctly is a critical initial step to Integrity Management Program (IMP) success, and if it is not done correctly, can be a substantial liability for companies. In this three part blog series, we will be discussing a set of key components and challenges involved in liquid HCA projects including:
- Meeting all regulatory requirements conservatively
- Performing HCA analyses to accomplish goals within IMP
- Obtaining realistic results that provide value
- Reducing potential impacts and costs
- Incorporating a variety of formats of data to prepare for analyses
- Providing accurate, realistic response times
- Obtaining accurate and updated HCA data
- Performing adequate QC/verification of results
While most operators routinely use commercially available software packages, or retain vendors to do their analyses, and appear to be satisfied with their results, Integrity Plus has noted a number of potential vulnerabilities that operators should carefully consider. The reality is that spill modeling software applications are incredibly sophisticated calculators that are used to simulate pipeline ruptures and determine could-affect status, and as with any calculator, the input of the wrong “numbers” will generate inaccurate results. In purchasing these applications or partnering with third party vendors who do little to no consulting prior to setting up model parameters, operators are opening themselves to substantial regulatory and business risks. Inaccurate could-affect analysis could certainly become exposed during a regulatory audit, and result in enforcement action. In addition, some operators are finding out that their analyses are incorrect at the absolute worst time, after a release. A segment that had previously been identified as non could-affect has a release, and the product migrates to an HCA. That being said, let’s dig in to exploring some of the most common pitfalls, associated Pipeline and Hazardous Materials Safety Administration (PHMSA) guidance, and potential solutions to HCA analysis.
…it is an operator's responsibility to ensure that it has identified all high consequence areas that could be affected by a pipeline segment. An operator is also responsible for periodically evaluating its pipeline segments to look for population or environmental changes that may have occurred around the pipeline and to keep its program current with this information. (Refer to §195.452(d)(3).)