Oil and Gas Pipeline Archives

News & Views, Volume 49 | Digital Elevation Modeling: Support Pressure Tests Records and Reduce MAOP Reconfirmation Costs

April 20, 2021/in Bruce Paskett, Eric Elder, News and Views, Oil and Gas Pipeline, Scott Riccardella/by Structural Integrity

By: Scott Riccardella, Bruce Paskett, and Eric Elder

§ 192.624(a)(1) of the Mega-Rule 1 requires MAOP Reconfirmation for steel transmission pipe segments if records necessary to establish the MAOP in accordance with § 192.619(a)(2) (e.g. pressure test), including records required by § 192.517(a), are not traceable, verifiable, and complete and the pipeline is located in a high consequence area (HCA) or a Class 3 or Class 4 location.

Part 192, Section 192.517(a) requires that natural gas pipeline operators shall make and retain, for the useful life of the pipeline, a record of the following information for any Subpart J Pressure Test (PT):

The operator’s name, the name of the operator’s employee responsible for making the test, and the name of any test company used,
Test medium used,
Test pressur,
Test duration,Pressure recording charts, or other record of pressure readings.
Elevation variations, whenever significant for the particular test, and
Leaks and failures noted and their disposition.

News & Views, Volume 48 | Implementation of Material Verification – In Support of Mega-Rule Part 1 Requirements

September 30, 2020/in David Babbitt, Mega-Rule, News and Views, Oil and Gas Pipeline, Roger Royer, Scott Riccardella/by Structural Integrity

By: Roger Royer, Scott Riccardella, and David Babbitt

Operators are now required to define sampling programs and perform destructive (laboratory) or non-destructive testing to capture this information and take additional actions when inconsistent results are identified until a confidence level of 95% is achieved.

Various sections of Mega-Rule 1 require operators of natural gas transmission pipelines to ensure adequate Traceable, Verifiable, and Complete (TV&C) material records or implement a Material Verification (MV) Program to confirm specific pipeline attributes including diameter, wall thickness, seam type, and grade. Operators are now required to define sampling programs and perform destructive (laboratory) or non-destructive testing to capture this information and take additional actions when inconsistent results are identified until a confidence level of 95% is achieved. Opportunistic sampling per population is required until completion of testing of one excavation per mile (rounded up to the nearest whole number) up to 150 excavations (if the population exceeds 150 miles). Regulators have communicated an expectation that sampling locations or test sites are to be equally spaced throughout the population mileage.

News & Views, Volume 48 | Strategic Evaluation of MAOP – Reconfirmation Plans and Options

September 30, 2020/in Bruce Paskett, News and Views, Oil and Gas Pipeline, Scott Riccardella/by Structural Integrity

By: Scott Riccardella and Bruce Paskett

On October 1, 2019, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published amendments to 49 CFR Parts 191 and 192 in the Federal Register issuing the Pipeline Safety: Safety of Gas Transmission Pipelines: MAOP Reconfirmation, Expansion of Assessment Requirements, and Other Related Amendments Final Rule (Final Rule).

The Final Rule requires that for on-shore steel transmission pipelines in an High Consequence Area (HCA), Class 3 or 4 location without Traceable, Verifiable and Complete (TV&C) records for §192.619(a)(2) (pressure testing, including records required by §192.517(a)) ; or where the Maximum Allowable Operating Pressure (MAOP) was established based on the Grandfather Clause and the MAOP creates a stress ≥ 30% of the Specified Minimum Yield Strength (SMYS), an operator will need to reconfirm the MAOP in accordance with the provisions of §192.624.

News & View, Volume 47 | Material Verification Intelligence

March 3, 2020/in Material Verification Intelligence, News and Views, Oil and Gas Pipeline, Scott Riccardella, Steven Biles/by Structural Integrity

By: StevenBiles and Scott Riccardella

A new program to help pipeline operators implement the Material Verification requirements in recently released pipeline regulation (Mega Rule)

On October 1, 2019, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published the long-awaited Mega-Rule (Part 1). One of the major new requirements identified in these amendments is when missing traceable, verifiable, and complete records, operators must implement a Material Verification (MV) (§192.607) program. MV requires operators of natural gas transmission pipelines, to develop and implement procedures to verify the material properties and attributes of their pipeline system. Included in the new regulation for MV are:

Develop procedures for conducting destructive and non-destructive testing
Define population groupings and implement sampling programs
Implement and document laboratory testing
Complete in situ and non-destructive evaluations (NDE)
Expand sampling if inconsistent results based on NDE and laboratory testing
Document program results and preserve for the life of the pipeline asset

News & Views, Volume 47 | Release of the First Safety of Gas Transmission Pipeline Regulation Mega-Rule

March 3, 2020/in Andy Jensen, Bruce Paskett, Mega-Rule, News and Views, Oil and Gas Pipeline, Scott Riccardella/by Structural Integrity

By: Scott Riccardella, Bruce Paskett, and Andy Jensen

On October 1, 2019 the Pipeline and Hazardous Materials Safety Administration (PHMSA) published amendments to 49 CFR Parts 191 and 192 in the Federal Register issuing Part 1 of the Gas Transmission Mega-Rule¹. This new regulation is commonly referred to as the Mega-Rule, as it represents the most significant regulatory impact on gas transmission pipelines since the original Gas Transmission Integrity Management Program (TIMP) Regulation was issued in 2003.

General Overview
As a result of numerous transmission pipeline accidents in the late 1990’s, the congressional Pipeline Safety Improvement Act of 2002 required operators of natural gas transmission lines to create TIMP Plans to identify transmission lines in High Consequence Areas (HCAs), conduct risk assessments and manage the integrity of covered segments in HCAs by conducting periodic integrity assessments. In 2010 through 2012, multiple incidents (Deep Water Horizon, San Bruno, California, Marshall, Michigan, Sissonville, WV) created a renewed focus on pipeline safety in Congress.

News & Views, Volume 46 | In-line Inspection Performance Validation Pipe Experiment

July 1, 2019/in News and Views, Oil and Gas Pipeline/by Structural Integrity

By: Jacob Arroyo

You’ve just completed the first in-line inspection (ILI) of a new pipeline asset. The ILI tool results are in, and there are no required repairs! However, how sure are we of the accuracy of the results? Could the tool have under-called some of the reported anomalies? Are there any regulatory requirements beyond the “response criteria” mentioned in CFR 192 and 195 for operators of hazardous transmission pipelines? These are the problems that ILI verification is trying to solve.

Traditionally, validations can be done using costly excavations of anomalies found by the tool. In cases where those anomalies need to be repaired, this approach is effective, and the validation does not require any further excavations. For some ILI inspections, the tool does not call any anomalies that need to be repaired. The traditional approach, in this case, has been to excavate sub-critical anomalies just for validation. In such cases, an ILI validation spool can be a valuable asset. ILI validation spools can be designed to quantify the uncertainty of the full spectrum of anomaly types without additional excavations, thus freeing up valuable resources to be allocated elsewhere to improve safety, minimizing the exposure risk of excavating pipeline assets while under full operating pressure.

News & Views, Volume 46 | Strategies, Projects and Technologies to Help Improve NDE Reliability in the Pipeline Industry

July 1, 2019/in Jason Van Velsor, News and Views, Non-Destructive Evaluation, Oil and Gas Pipeline, Roger Royer, Scott Riccardella/by Structural Integrity

By: Scott Riccardella, Jason Van Velsor, and Roger Royer

Pipeline operators face a multitude of threats, including service, environmental, or operational induced degradation to pipelines and related facilities. Non-Destructive Examination (NDE) is often used to characterize the nature and extent of this degradation. Thus, there is a critical need for reliable NDE as pipeline operators rely extensively on NDE as the basis for validating In-Line Inspection (ILI) results, determining fitness for service, and making repair and other operational decisions. Erroneous or inaccurate characterization of these defects can lead to unexpected leaks or failures, unnecessary and costly repairs, the establishment of an incorrect remaining life or re-assessment interval, and inaccurate (in)validation of ILI results.

News & Views, Volume 45 | Gas Pipeline Safety Regulation Update

January 1, 2019/in Bruce Paskett, Eric Fisette, Mega-Rule, News and Views, Oil and Gas Pipeline, Scott Riccardella/by Structural Integrity

By: Scott Riccardella. Erica Fisette, and Bruce Paskett

Update on the Safety of Gas Transmission and Gathering Pipelines Rulemaking (known as the Mega-Rule)
Structural Integrity (SI) personnel have had significant involvement in the Gas Pipeline Advisory Group (GPAC) meetings focused on consideration of the proposed pipeline safety rule titled “Safety of Gas Transmission and Gathering Pipelines” (Notice of Proposed Rule Making April 8, 2016). The meetings produced several recommendations to the Pipeline and Hazardous Materials Safety Administration (PHMSA) that are likely to be included in the Final Rule. A key outcome of these meetings was that PHMSA has decided the Final Rule will be split into three sub-rule packages that will all be final rules to facilitate the rulemaking process:

Maximum Allowable Operating Pressure (MAOP) reconfirmation, Material Verification, Expansion of Integrity Management Assessments Outside of High Consequence Areas (HCAs) and other related issues,
Repair Criteria, Inspections Following Extreme Weather Events, Corrosion Control improvements, Management of Change; and
Expansion of Part 192 regulations to include additional Gas Gathering Lines.

News & Views, Volume 44 | Update on Proposed Safety of Gas Transmission and Gathering Pipeline Regulation

April 27, 2018/in Bruce Paskett, Eric Fisette, News and Views, Oil and Gas Pipeline, Scott Riccardella/by Structural Integrity

By: Scott Riccardella, Erica Fisette, and Bruce Paskett

Structural Integrity (SI) has significant depth and expertise in current pipeline safety regulations and dedicates substantial resources to ensure a comprehensive understanding of proposed pipeline safety regulations. Using the most current insights relative to upcoming regulations, Structural Integrity guides our clients with strategic direction to best position their pipeline safety programs to comply with the new regulations. Structural Integrity takes a proactive role in attending key Pipeline and Hazardous Materials Safety Administration (PHMSA) meetings such as the Gas Pipeline Advisory Committee (GPAC) meetings as well as supporting the rulemaking efforts of the American Gas Association (AGA), Interstate Natural Gas Association of America (INGAA), Pipeline Research Council International (PRCI) and other key associations.

The GPAC is a statutorily mandated Committee that advises PHMSA on proposed gas pipeline safety standards and regulations. The Committee consist of members from Federal and State governments (PHMSA and National Association of Pipeline Safety Representatives or NAPSR), the regulated industry, and the general public. The Committee is responsible for reviewing the technical feasibility, reasonableness, cost-effectiveness, and practicability of proposed standards and regulations relative to pipeline safety. The goal of the Committee is to provide recommended revisions and/or actions in response to standards and/or regulations proposed by the Federal Department of Transportation (DOT)/ PHMSA.

News & Views, Volume 44 | Strategic Internal Corrosion Monitoring for Gas Pipelines

April 27, 2018/in Corrosion, Lance Barton, Monitoring, News and Views, Oil and Gas Pipeline/by Structural Integrity

By: Lance Barton and Tom Pickthall (EnhanceCo)

REGULATORY OVERVIEW
A March 16, 2017, advisory bulletin (Docket No. PHMSA-2016-0131 – “Pipeline Safety: Deactivation of Threats”) gave guidance on the deactivation of pipeline threats, including the threat of internal corrosion. On April 8, 2016, PHMSA issued a Notice of Proposed Rulemaking (NPRM) entitled “Safety of Gas Transmission and Gathering Pipelines”. Section §192.478 “Internal Corrosion Control: Onshore transmission monitoring and mitigation” of the NPRM would increase the scrutiny and requirements for monitoring and mitigating the threat of internal corrosion for the gas industry.

This bulletin and NPRM reinforce the requirements of CFR part 192-subpart O, Section 192.937, requiring gas pipeline operators to continuously assess their pipelines for the threat of internal corrosion as part of their overall integrity management program. One of the requirements is to determine if the gas entering the system is corrosive or not corrosive. The optimal way to prove that the gas is not corrosive is to build a thorough continuous monitoring program that considers guidance from the NPRM and the advisory bulletin.