News & Views, Volume 47 | Release of the First Safety of Gas Transmission Pipeline Regulation Mega-Rule
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.
There have been several industry initiatives to support optimization of examination requirements for various items/components (both Class 1 and Class 2 components) in lieu of the requirements in the ASME Code, Section XI.
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.
Longitudinal seam-welded hot-reheat steam piping operating in the creep regime is a continuing life-management challenge for many older fossil-fired power plants.
Recently, a client approached SI after finding a through-wall flaw in an autoclave at the head-to-shell weld as indicated by a visible dye liquid penetrant examination (Figure 1). The autoclave was one of eight similar vessels used for processing the client’s product. Three of the autoclaves are identical in construction to the flawed autoclave and operate with similar process conditions. Remote visual examination by the client indicated that all four autoclaves had similar observations at the inside of the head-to-shell weld, but only one was leaking. The remaining four autoclaves are smaller and are used infrequently. The initial call from the client was for SI to provide emergent support for inspection of the three autoclaves identical to the leaking one to meet production demands. SI responded quickly and examined all four autoclaves using a manual phased array ultra-sonic technique (PAUT) from the exterior of the vessel. The manual PAUT examination provided excellent coverage of the weld region and visualization of the through wall flaw (Figure 2).
Structural Integrity recently had the opportunity to support a client’s emergent needs when their Standby Service Water (SSW) piping system experienced a pinhole leak just downstream of a valve. Concerned about other locations in the piping system with similar configurations, the site asked SI to assist with the expedited development of assessment and disposition plans for these other components. In response, SI was able to lean on our core competencies in failure analysis, advanced NDE inspection, and flaw evaluation to develop and deploy a comprehensive solution that met our client’s expedited timeline and helped them to mitigate the threat of future unplanned outages. The following sections outline how SI utilized our in-depth knowledge, cutting-edge technology, and world-class engineering to meet our client’s needs.
Structural Integrity Associates is participating in a Department of Energy (DOE) Integrated Research Projects (IRP) program focused on storage and transportation of used nuclear fuel (UNF). The project, entitled Cask Mis-Loads Evaluation Techniques, was awarded to a university-based research team in 2016 under the DOE Nuclear Fuels Storage and Transportation (NFST) project. The team is led by the University of Houston (U of H) and includes representatives from the University