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

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

By:  Scott Riccardella and Bruce PaskettNews & View, Volume 48 | Strategic Evaluation of MAOP Reconfirmation Plans and Options

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

News & View, Volume 47 | Material Verification Intelligence

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:

  • News & View, Volume 47 | Material Verification IntelligenceDevelop 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

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

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

By:  Scott Riccardella, Bruce Paskett, and Andy Jensen

News & View, Volume 47 | Release of the First Safety of Gas Transmission Pipeline Regulation Mega-RuleOn 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.

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

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

By:  Jacob Arroyo

News & View, Volume 46 | In-line Inspection Performance Validation Pipe ExperimentYou’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.

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

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

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

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

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.

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

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

By:  Scott Riccardella. Erica Fisette, and Bruce Paskett

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

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:

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

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

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

By:  Scott Riccardella, Erica Fisette, and Bruce Paskett

News & View, Volume 44 | Update on Proposed Safety of Gas Transmission and Gathering Pipeline RegulationStructural 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.

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

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

By:  Lance Barton and Tom Pickthall (EnhanceCo)

REGULATORY OVERVIEW
News & View, Volume 44 | Strategic Internal Corrosion Monitoring for Gas PipelinesA 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.

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News & View, Volume 43 | In-Line Inspection An Improvement Over Pressure Testing for Pipeline Integrity Management

News & Views, Volume 43 | In-Line Inspection – An Improvement Over Pressure Testing for Pipeline Integrity Management

By:  Scott Riccardella, Dilip Dedhia, and Peter Riccardella 

News & View, Volume 43 | In-Line Inspection An Improvement Over Pressure Testing for Pipeline Integrity ManagementStructural Integrity recently performed probabilistic fracture mechanics (PFM) analysis of a gas transmission pipeline for a major U.S. operator.  The analysis yielded interesting insights in several areas:

Pressure Testing versus In-Line Inspection
Pressure testing has long been considered the gold standard for assuring pipeline integrity.  By testing at a factor (e.g., 1.25x or 1.5x) above the Maximum Allowable Operating Pressure (MAOP), any size critical flaws in the line would fail at this pressure level and are thus removed prior to future service.  Subcritical flaws that remain after the test will be smaller than the critical flaw sizes during operation, and thus can be assumed to have some margin for growth before they become critical in service.  Flaw growth rates can be calculated based on operational and environmental factors to establish a reassessment interval for future testing or inspections.

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News & View, Volume 43 | A Strategic Approach for Completing Engineering Critical Assessments of Oil and Gas Transmission Pipelines

News & Views, Volume 43 | A Strategic Approach for Completing Engineering Critical Assessments of Oil and Gas Transmission Pipelines

By:  Scott Riccardella and Steven Biles

Regulatory Overview
News & View, Volume 43 | A Strategic Approach for Completing Engineering Critical Assessments of Oil and Gas Transmission PipelinesIn January 2012, the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 was signed into law directing PHMSA to take steps to further assure the safety of pipeline infrastructure.  PHMSA issued the related Notice of Proposed Rulemaking (NPRM) for Safety of Gas Transmission and Gathering Pipelines on April 8, 2016.  Included in the NPRM were significant mandates regarding:

  • Verification of Pipeline Material (§192.607); and
  • Maximum Allowable Operating Pressure (MAOP) Verification or “Determination” (§192.624)

The NPRM proposes requirements for operators to verify the MAOP of a gas transmission pipeline when:

  1. The pipeline has experienced an in-service incident (as defined by §191.3) due to select causes1 in a High Consequence Area (HCA), “piggable” Moderate Consequence Area (MCA), or Class 3 or 4 location since its last successful pressure test
  2. The pipeline lacks Traceable, Verifiable, and Complete pressure test records for HCAs or Class 3 or 4 locations
  3. The pipeline MAOP was established by the grandfather clause (§192.619 (a)(3)) for HCAs, “piggable” MCAs, or Class 3 or 4 locations.

To verify the MAOP of a pipeline, the NPRM provides the following options:

  • Method 1: Pressure Test
  • Method 2: Pressure Reduction
  • Method 3: Engineering Critical Assessment (ECA)
  • Method 4: Pipe Replacement
  • Method 5: Pressure Reduction for segments with small potential impact radius (PIR) & diameter
  • Method 6: Use Alternative Technology

The ECA Approach
Per the NPRM, Method 3 (ECA) is defined as an analysis, based on fracture mechanics principles, material properties, operating history, operational environment, in-service degradation, possible failure mechanisms, initial and final defect sizes, and usage of future operating and maintenance procedures to determine maximum tolerable sizes for imperfections. 

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