Gas TransmissionNPRM

David JohnsonNovember 10, 2016

Friday the 13th

came 5 days early !

2

A few statistical facts• As published in the FR:• 136 pages – like this →• 103 pages of intro &

preamble• 33 pages of proposed

rules• 52 enumerated

changes or additions to Parts 191, 192 and Appendices – many are multi-part

3

Definitions“When I use a word,” Humpty Dumpty said, in rather a scornful tone, “it means just what I choose it to mean—neither more nor less.” “The question is,” said Alice, “whether you can make words mean so many different things.” “The question is,” said Humpty Dumpty, “which is to be master—that's all.”

---Lewis Carroll, Through the Looking Glass• RTVC – used extensively but not defined• Farm tap – erroneously associated with gathering lines only• Moderate Consequence Area – like HCA with 5 houses,

Occupied Site or (tbd) highway• Occupied Site – like “Identified Site” with fewer people (5/50)• Legacy Pipe and Construction• Significant SCC

4

192.67 Records: Materials• Acquire and retain original pipe manufacturing

records• Life of pipeline retention• Specs in effect at time of manufacture• May require time travel capability

5

192.705 Records: Pipeline Components

• Manufacturing standard and pressure rating for• Valves • Flanges, fittings branch connections, extruded

outlets, anchor forgings and other components with YS ≥ 42,000 psi

6

192.319 Installation of pipe in a ditch &

192.461 Protective Coating• For new pipeline or replacements > 1,000 ft.• DCVG or ACVG survey within 3 months• Repair coating damage within 6 months of survey• > 35% for DCVG• > 50 dBμv for ACVG• Life of pipeline records

7

Other Corrosion Control• 192.465 – Determine extent of LPA by CIS and

confirm remediation by another CIS• 192.478 – Extensive gas quality measurement and

coupon monitoring for IC if gas may be potentially corrosive

• 192.485 – take remedial actions per B31G or RSTRENG if < 80% wall loss, based on PFP including class location factors. If pipe properties are not RTVC, go to 192.607

8

192.506 Spike Hydrostatic Testing

• Required if integrity threats cannot be addressed by ILI or DA

• Must use water• Spike must be at least the lesser of

o 1.50 x MAOP oro 105% of SMYS

• Must be in first two hours of 8-hour test• Determine retest interval if time dependent

9

192.607 Verification of Pipeline Material

• Must have documented material properties for pipe, valves, fittings and components ino HCA, Class 3 and 4

• OD, WT, YS, UTS, chem, seam, coating, mfgr spec• One set of properties per mile• Tests in 4 quadrants at each location• Charpy testing also if needed for failure P, cracking• Lots of details and specifics

10

192.613 Continuing Surveillance

• Adds inspection requirements following extreme weather events

• Inspection must start within 72 hrs of event cessation• Extreme weather events not defined• Type of inspection not specified

11

192.619(e) MAOP

For PL meeting 192.624 (coming next!), establish and document MAOP by:1. Pressure test (possible spike requirement also)2. Pressure reduction3. ECA4. Pipe replacement5. Pressure reduction – small PIR and OD6. Alternative technology

12

192.624(a) & (b) MAOPMust use one or more of Methods 1-6 for PL • Experienced reportable incident after most recent

Subpart J test due to M&C defect, cracking, SSWCo In an HCA, Class 3 or 4 location, or piggable MCA

• Subpart J records are not RTVC ino HCA, Class 3 or 4 location, or MAOP by 192.619(c)

in HCA, Class 3 or 4 or piggable MCA• Any of these criteria are triggers• Plan complete within 1 year• 50% of mileage complete in 8 years, all in 15 years

13

192.624(c) MAOP Determination

1. Pressure test – to class location factor, at least 1.25o Spike test likely required

2. Pressure reduction – highest operating pressure/1.25o Other factors for class locations and changes

3. ECA – fracture mechanics principles4. Replacement5. Pressure reduction – small PIR and OD

o Patrols and instrumented leakage surveyso Monthly in Class 1 & 2, weekly in Class 3 + Odorize

6. Alternate technologyo 192.607 may be required

14

192.624(d) Fracture Mechanics Analysis

• If any reason to believe susceptible to cracks or crack-like defects –

• Must perform fracture mechanics modeling for failure pressure and crack growth – remaining life

• If estimating size of defects that could survive hydro, must assume high CVN (larger surviving defects)

• If using ILI, must assume minimal properties – smaller surviving defects

• Must reevaluate before 50% of remaining life reached• If < 5 years, must perform hydrostatic test or reduce

MAOP

15

192.710 Assessments • Applies to non-HCA Class 3 & 4 and piggable MCA• Can use for MAOP verification if 192.624(c) is met• Initial assessment – identify anomalies and defects

for each susceptible threat• ILI – corrosion, deformation and mechanical

damage, cracking and any other threats• Subpart J pressure test – maybe spike test• Guided wave UT• EC, IC & SCC DA as last resort• Other technology• EC and IC requirements for < 30% SMYS

16

192.710 Assessments • Analysis by demonstrably qualified person to identify

condition that “could adversely affect” pipeline• Consider all uncertainties• Remediate per 713 if “could adversely affect”• Must consider ALL available information

17

192.711 Repair Procedures• Non – Integrity Management repairs• Correct conditions as prescribed in 192.713• If an immediate hazard –• Reduce operating pressure to safe level

o < 80% of pressure at time of discovery• Additional measures to protect persons & property

18

192.713 Permanent Repair• Applies to all transmission – additive to Subpart O (?)• Immediate

o Predicted Pf < 1.1 x MAOPo Dent with metal loss, cracking or stress risero Metal loss > 80% of wallo Metal loss on ERW or EFW seamo Significant SCC or SSWCo Reduce pressure until repairs complete

19

192.713 Permanent Repair• 2 – Year Conditions

o Smooth dent >6% of OD on upper 2/3o Dent >2% of OD affecting girth or seam weldo Predicted Pf ≤ 1.25 in Class 1, 1.39 in Class 2, 1.67 in

Class 3 and 2.00 in Class 4 – with uncertaintieso Corrosion > 50% of wallo Gouge or groove > 12.5% of wall

• Monitoredo Bottom 1/3 dent < 6% of ODo Upper 2/3 dent > 6% of OD but < critical strain level

20

192.750 Pig Trap Safety• Device for safely relieving pressure in barrel before

opening• And• Use suitable device to indicate pressure relief or• Provide means to prevent opening if pressure not

relieved

21

192.917 Identify & Use Threats

• Must identify and evaluate ALL potential threats• To do this, must gather, verify, validate and

integrate data on entire pipeline that could be relevant on covered segment

• Data must include list of 36 enumerated items –some multi-part

• Must correct for SME bias• Identify and analyze spatial relationships• Analyze data for interrelationships among threats

22

192.917(c) Risk Assessment

• “If you’re using one model, you’re probably going down the wrong path” Steve Nanney, 9-10-2015

• Analyze identified threats and potential consequences, including interactions

• Ensure validity in light of operator & industry history• Sensitivity analysis – probability & consequences• Determine additional P&M measures and their

relative impacts and values

23

192.917(c) Risk Assessment

• Help decisions to reduce risk, not just find highest risk• Data, threat evaluation, interactions, predictive• Lots of heartburn over this because:• Belief that enough good data and good models will

prevent failures – is wrong. • Very poor at predicting the large consequence, low

frequency (not probability) events• This subject needs creative thinking, but not getting it

24

192.917(c) Risk Assessment

The risk assessment must:1. Analyze how failure could affect HCA, including

worst case analysis2. Analyze impact of each threat or risk factor and

each combination that interact or contribute3. Better understanding of threats, failure

mechanisms, mitigation effectiveness and how to reduce

4. Account and compensate for uncertainties5. Evaluate risk reduction associated with activities

such as P&M measures and reduced intervals

25

192.917(e) Risk Assessment

• Must include cyclic fatigue analyses• Must include M&C defects – may require MAOP

reconfirmation• If low-f ERW, lap weld, or any pipe with seam factor

< 1.0 AND has experienced a seam failure or a pressure increase –

• Must assess with technology for seam integrity and seam corrosion anomalies

• Prioritize as a “high risk” segment for baseline and subsequent assessments

26

192.933 Address Integrity Issues

• Immediateo Predicted Pf < 1.1 x MAOPo Dent with metal loss, cracking or stress risero Metal loss > 80% of wallo Metal loss on ERW or EFW seamo Significant SCC or SSWCo Reduce pressure until repairs complete

27

192.933 Address Integrity Issues

• 1 – Year Conditionso Smooth dent >6% of OD on upper 2/3o Dent >2% of OD affecting girth or seam weldo Predicted Pf ≤ 1.25 in Class 1, 1.39 in Class 2, 1.67 in

Class 3 and 2.00 in Class 4 – with uncertaintieso Corrosion > 50% of wallo Gouge or groove > 12.5% of wallo Non-immediate crack-like defect

28

192.935 Additional P&M Measures

• Must take measures beyond those already in 192• Must be based on the risk analysis in 192.917 & include• Correction of past deficiencies, ASV/RCV, LD systems,

patrols, hydrotests, properties, coating, depth, etc.• Address outside force• IC – monitoring, inhibiting and removal• EC – interference, CP & test stations, coatings

29

Web Locations• Advisory Bulletins

http://phmsa.dot.gov/pipeline/regs/advisory-bulletin• Rulemakings

http://phmsa.dot.gov/pipeline/regs• Notices

http://phmsa.dot.gov/pipeline/regs/notices• Final Rules

http://phmsa.dot.gov/pipeline/regs/rulemaking/final

• Regulatory Agendahttp://www.reginfo.gov/public/do/eAgendaMain

30

I saved this for last again because at this point, we’re pretty much done.

31

Questions

32