Scott Riccardella Archives

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 | 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 43 | A Strategic Approach for Completing Engineering Critical Assessments of Oil and Gas Transmission Pipelines

October 5, 2017/in News and Views, Oil and Gas Pipeline, Scott Riccardella, Steven Biles/by Structural Integrity

By: Scott Riccardella and Steven Biles

Regulatory Overview
In 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:

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
The pipeline lacks Traceable, Verifiable, and Complete pressure test records for HCAs or Class 3 or 4 locations
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.