National Academy of Sciences

Transcription

1 National Academy of Sciences Transportation Research Board Study of Pipeline Transportation of Diluted Bitumen PHMSA Regulatory Authority and Keystone XL Pipeline October 23,

2 Topics for Briefing PHMSA s Regulatory Authority Facts regarding the proposed conditions for the Keystone XL Pipeline - 2 -

3 PHMSA Regulatory Authority Key Regulatory Section CFR49, Part 190: Part 190 Pipeline Safety Programs and Rulemaking Procedures Notice of Probable Violation This could include: Warning Letter Civil Penalty Compliance Order Notice of Amendment Safety Order - 3 -

4 When does PHMSA s Authority Begin and End The Beginning: when material fabrication and construction activities begin for any transmission pipeline is when PHMSA s authority starts. The End: When a pipeline is decommissioned and retired from service

5 Back Ground on Conditions Lessons Learned from new construction and operational inspections Gas 80% SMYS MAOP Special Permits o Modified based upon construction issues such as coating quality, dents and interference currents Gas Alternative MAOP Rule Modified for uniqueness between gas versus liquid operations and regulations Address Public Concerns - 5 -

6 Keystone XL Project Department of State (State) Sole federal authority charged with approving the routing of cross-border liquid pipelines PHMSA Cooperating Agency under the National Environmental Policy Act (NEPA) for the purposes of providing input for consideration of State s Environmental Impact Statement - 6 -

7 Keystone XL Pipeline Capacity: Keystone XL 500,000 bbl/day Capacity: Keystone plus XL 700,000 bbl/day - initial 920,000 bbl/day max. design Keystone XL Keystone Keystone XL: 1,712 miles Total 1,384 miles in U.S psig MOP - 72% SMYS 36-inch diameter - 7 -

8 Location Keystone XL Pipeline - Facts Originates at Hardisty, Alberta, Canada Endpoints - Houston and Port Arthur, Texas (now Cushing, Oklahoma) Mileage 1384 (Approximately 900 now) miles in U.S., new construction Operating Pressure 1302 psig Diameter 36-inch Yield Strength 70,000 psi; Grade X-70 Wall thickness inches - 72% SMYS - Mainline inch 72% SMYS HCAs inch downstream of pump stations at lower elevations - 8 -

9 Keystone XL Pipe Wall Thickness River Crossings (HDD) inch Roads and Cased Railroad inch Railroad Crossings inch HCAs (including populated, other populated, ecologically sensitive & drinking water) inch Downstream of pump stations (at lower elevations, determined by steady state & transient hydraulic analysis) inch - 9 -

10 Proposed Technical Conditions Keystone XL Pipeline State Dept may require conditions in response to public concerns, if/when permit is issued

11 Keystone XL Pipeline Technical Conditions State Dept Permit Design, Construction & Operations 49 CFR Part 195 for hazardous liquid pipelines Design Factor 72% SMYS Pipe manufactured per API 5L, 44 th Edition Fracture Control Plan for pipe toughness Non-destructive Ultrasonic Test of steel Internal Quality Management Program at steel and pipe mills Pipe seam quality assurance program Pipe coating application quality control program Code does not require these pipe quality assurance items Note: Items in red are above Part 195 criteria & were sent to State Dept., may be included in Permit

12 Technical Conditions State Dept Permit Pipe Mill Inspection Pipe mill inspection program for pipe manufacturing Perform tests to detect low strength steel in pipe mill Code no detailed requirements Pipe Mill Hydrostatic Test Pipe mill test pressure of 95% SMYS Code references API 5L 90% SMYS mill test pressure Note: Items in red are above Part 195 criteria & were sent to State Dept., may be included in Permit

13 Technical Conditions State Dept Permit Hydrostatic Pressure Test Level for 72% SMYS Design Mainline Piping hydrotest to 100% SMYS for 8 hours Station Piping hydrotest to 1.39 x MOP for 8 hours Root cause analysis of any leak, rupture or failures Code 1.25 x MOP for 4 hours plus 1.1 x MOP for 4 hours total 8 hours, no root cause analysis required for hydrotest rupture or failure Field Construction Welding Procedures All girth welds shall be nondestructively tested Code 10% of each welders daily total of welds Note: Items in red are above Part 195 criteria & were sent to State Dept., may be included in Permit

14 Technical Conditions State Dept Permit Mainline Valves Locate valves to minimize consequences of release from pipeline Mainline valves no more than 20 miles apart Switches on valve actuators to prevent pressure surges Remotely controlled and actuated Code valves at locations to minimize damage or pollution and on each side of a water crossing more than 100 feet in width Note: Items in red are above Part 195 criteria & were sent to State Dept., may be included in Permit

15 Technical Conditions State Dept Permit Internal Corrosion Control Cleaning pig runs twice 1 st year of service & yearly thereafter; Sample, analyze, and develop internal mitigation plans based upon lab test results of cleaning pig liquids Basic Sediment & Water (BS&W) 0.5% maximum Review program quarterly based upon crude oil quality Code no detailed requirements Temperature Control pipe coating 120 F to 150 F max. Requires monitoring with coating surveys Code no detailed requirements Note: Items in red are above Part 195 criteria & were sent to State Dept., may be included in Permit

16 Technical Conditions State Dept Permit Corrosion Control Surveys Interference surveys within 6 months in-service date Coating Condition Survey after installation in ditch and backfill, use direct current voltage gradient (DCVG) or alternating current voltage gradient (ACVG) surveys to determine coating condition and remediate, as required Corrosion surveys to ensure CP system is adequate Initial Close Interval Survey (CIS) within 1-year of in-service date Code requires construction inspection program and CP system, does not require coating condition survey, CIS, or timing for interference surveys after initial construction Note: Items in red are above Part 195 criteria & were sent to State Dept., may be included in Permit

17 Technical Conditions State Dept Permit Soil Cover 48-inches in all areas except consolidated rock (36 ) Maintain at 42-inches in uncultivated areas Periodic monitoring of soil cover through-out life cycle, replace or remediate soil cover, as required Code soil cover 36-inches for normal areas and for rock areas (30-inches) Construction OQ Field construction personnel qualification Code must be trained on phase of construction inspecting, not as detailed on training and documentation Note: Items in red are above Part 195 criteria & were sent to State Dept., may be included in Permit

18 Technical Conditions State Dept Permit Integrity Management Program Construction baseline in-line inspection (ILI) for entire pipeline Run deformation tool and replace all expanded pipe Run CIS on pipeline in conjunction w/ ILI assessment Immediate anomaly repair ; Code <1.0 x MOP Corrosion anomaly evaluation & repair 50%/ 40% wall loss 2% construction dents removed in all areas Integrity Management ILI on 5-year basis after construction baseline ILI Code no requirements for construction baseline ILI, deformation ILI and CIS in conjunction with ILI assessment. Note: Items in red are above Part 195 criteria & were sent to State Dept., may be included in Permit

19 Technical Conditions State Dept Permit SCADA leak detection and CRM Rule Pipeline Markers At roads, railroads, and sufficient in number Line of sight & maintained Code at roads, railroads, and sufficient in number Pipeline Patrolling 26 times per year same as Code Records Demonstrate compliance with all conditions for life of pipeline Code has requirements, but not as detailed and with some time limits for records retainage Note: Items in red are above Part 195 criteria & were sent to State Dept., may be included in Permit

20 Technical Conditions State Dept Permit Annual Reporting - Changes and integrity threats to pipeline Code no annual reporting of integrity threats Public Education awareness program, same as Code Flaw Growth Assessment Study to determine flaw growth based upon pressure cycling conditions, 2-years after pipeline in-service date Code not required Fatigue Analysis For 1 st 5-years annual fatigue analysis on most severe historical pressure cycling segment Code not required Note: Items in red are above Part 195 criteria & were sent to State Dept., may be included in Permit

21 Technical Conditions State Dept Permit Certification Senior executive officer must certify that conditions have been implemented in design, construction, and maintenance plans Keystone XL meets all conditions Code not required Note: Items in red are above Part 195 criteria & were sent to State Dept., may be included in Permit

22 Conclusions Pipeline Keystone XL Pipeline Design, construction, and Operations & Maintenance In accordance with 49 CFR Part 195 Additional State Dept. Conditions from PHMSA Addresses public concerns