TQ Presentation Intro Slide

Transcription

1 TQ Presentation Intro Slide

2 2014 Oklahoma Seminar Tulsa, Oklahoma November 2014

3 Contact Information Wayne St. Germain Pipeline Safety Specialist U.S. Department of Transportation PHMSA Inspector Training and Qualifications Ph:

4 Oklahoma Seminar 2014 Regulatory Review

5 Contact Information Wayne St. Germain Transportation Specialist U.S. Department of Transportation PHMSA Inspector Training and Qualifications

6 Rulemaking Process ANPRM Advance Notice of Proposed Rulemaking Used to gather information (non-mandatory) NPRM Notice of Proposed Rulemaking Defines intent and scope, something required from operator SNPRM Supplemental Notice of Proposed Rulemaking

7 Rulemaking Process FR Final Rule Implementation date, days depending on significance of regulation DFR Direct Final Rule Used for non-controversial issues

8 Alert Notices & Advisory Bulletins Alert Notices - a notice of a situation of immediate safety concern Advisory Bulletins - an advisory not of immediate safety concern matters that have potential to become safety or environmental risks

9 Final Rule September 25, 2013 Changes to 49 CFR 190 Pipeline Safety Programs Increases in both civil and criminal penalties ($200,000) Investigations, response options, hearings, addresses and contact information, Other administrative procedures

10 Notice November 27, 2013 Random drug rate to remain at 25% for calendar year positive drug test rate was <1% Reminder to submit information through PHMSA portal

11 Information Collection Notices April 1, Revision to Operator Registry April 28, Revision to Gas Distribution Annual Report May 6, 2014 Safety Related Conditions, Abandoned Underwater Pipelines, Periodic Underwater Inspections and Pipeline Safety Program Certification

12 Information Collection Notices June 26, 2014 Public Awareness July 1, 2014 Revisions to Operator Identification (OPID) August 14, 2014 Revision to Gas Distribution Annual Report

13 Information Collection Notices July 30, 2014 Revision to National Pipeline Mapping System Program Additional information will include spatial mapping accuracy, MAOP, class location, pipe information, construction data, commodity, throughput and compressor locations

14 ADB May 6, 2014 Lessons Learned from Marshall, Michigan Accident NTSB identified deficiencies in the integrity management (IM) program, control room management and public awareness that contributed to the release of hazardous liquid

15 Lessons Learned from Marshall, Michigan Accident ADB May 6, 2014 Operators should evaluate safety programs and implement any changes to eliminate deficiencies similar to the ones identified by the NTSB Encouraged to review past and future NTSB recommendations and proactively implement improvements

16 ADB May 6, 2014 Lessons Learned from Marshall, Michigan Accident IM Programs More conservative approach to defects Better data integration, including re-analyzing results because of new data Continuous reassessment process Performance measures and program evaluations using ADB (Meaningful Metrics)

17 ADB May 6, 2014 Lessons Learned from Marshall, Michigan Accident Control Room Periodic evaluations of leak detection capabilities Regularly train control room teams, including training on recognition of and response to emergencies and unexpected conditions on SCADA or leak detection software Scheduling policies and practices against ADB (Prevention of Human Fatigue in Control Rooms)

18 ADB May 6, 2014 Lessons Learned from Marshall, Michigan Accident Public Awareness Analyze & evaluate the effectiveness of programs Strong program shorten response Local emergency response agencies prepared to identify and respond to early indications of accident Evaluate against API RP 1162, ADB (Emergency Communications) and ADB (Communication during Emergency Situations)

19 ADB September 18, 2014 This advisory bulletin describes specific notification requirements and general O&M and integrity management requirements as well as additional actions operators should consider taking before, during and after flow reversals, product changes, and conversion to service..

20 ADB September 18, 2014 PHMSA refers operators to detailed guidance published in the document, Guidance to Operators Regarding Flow Reversals, Product Changes and Conversion to Service, which provides operators with PHMSA's expectations with respect to complying with existing regulations and also contains recommendations that operators should consider prior to implementing these changes..

21 ADB September 18, 2014 The document addresses flow reversals, product changes and conversion to service individually. The document is located at: /Pipeline/Regulations/GORRPCCS.pdf.

22 The Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 Signed January 3, 2012 Funds programs of the Pipeline and Hazardous Materials Safety Administration (PHMSA) through fiscal year Addresses National Transportation Safety Board recommendations resulting from recent pipeline incidents

23 Reauthorization Fines Maximums increased to $200,000 and $2,000,000. (Amdt , Oct 25, 2013) HCA Emergency Response Time Comptroller General report due in 2013.

24 Reauthorization Automatic / Remote Shut Off Valve Regulations to require for new (or replaced) transmission lines by Study completed October, 2012 Available at: efiles/files/press%20release%20files/final%20val ve_study.pdf or primis.phmsa.dot.gov/meetings/dochome.mtg?mtg= 80

25 Reauthorization Integrity Management (ANPRM and NPRM) Expanding IMP requirements outside HCA s Report due 2014 to include evaluation of public safety enhancement, risk reduction and incremental cost factors.

26 Reauthorization Leak Detection (Liquids) Study Completed 7A89CAA18E E3DB9C /filename/Le ak%20detection%20study.pdf Evaluation of limitations of current technology. Establish standards for capabilities of leak detection systems? Findings / future rulemaking?

27 Accident and Incident Notification Reauthorization Post discovery, one hour maximum time to notify NRC. (ADB ) Note: NRC is currently not allowing on-line filings Changes to system may lead to long wait time for telephonic reports

28 Pending Rulemaking Eight (8) of the nine (9) rulemakings are expected to be designated significant Significant rules require review by PHMSA, OST, OMB before publication

29 Rule Process Significant vs Non-Significant Rulemakings Annual effect on the economy of $100 million Create serious inconsistency, or with another agency Materially alter the budgetary impact of entitlements, grants, user fees, or loan programs or the rights and obligations of recipients thereof; or Raise novel legal or policy issues arising out of legal mandates, the President s priorities, or the principles set forth in this Executive order

30 Pending Rulemaking Safety of on-shore hazardous liquid pipelines (NPRM stage) Excavation Damage Prevention (Final rule stage) Excess flow valves (EFVs) beyond single family residences (NPRM stage) Changes to forms, including gas distribution incident and annual reports

31 Miscellaneous Gas Rule Several amendments based on petitions, NAPSR recommendations and other initiatives Post construction inspections, plastic pipe joiner qualification, welding definitions, Type B line leak surveys Published November, 2011 Final Rule stage

32 Plastic Pipe Covers materials and fittings, design factors and tracking and traceability Notice of Proposed Ruling (NPRM) stage

33 OQ, Cost Recovery and Other Changes Cover OQ for new construction, incident reporting, cost recovery and special permit renewal NPRM stage

34 Gas Transmission and Gathering Lines Expansion of IM requirements outside of HCAs, repair criteria, assessments, corrosion control, integrity verification process (IVP) Based on NTSB recommendations NPRM stage

35 Rupture Detection and Valves Establish and define rupture detection and response times, use of automatic shutoff and remote controlled valves Based on NTSB recommendations NPRM stage

36 Standards Update Incorporated by reference (IBR) standards Impact 22 of IBR standards Final Rule stage

37 IBR Documents Incorporated by Reference (IBR) Section 24 of Reauthorization addresses issue of incorporated by reference documents Public Meeting Incorporating by reference consensus standards unless available free of charge to the public on the Internet Modified to available for free

38 Access to safety standards PHMSA negotiated agreements with: American Petroleum Institute (API) American Gas Association (AGA) American society for Testing and Materials (ASTM) Gas Technology Institute (GTI) Manufacturers Standardization Society of Valves and Fittings Industry, Inc. (MSS) NACE National Fire Protection Association (NFPA)

39 Should or May Shall or Must Incorporated by Reference documents, should is must unless written justification why not practicable/necessary for safety

40 Enforcement Guidance Various enforcement guidance is available at: foia/e-reading-room Includes O&M, OQ, Corrosion, IM, Public Awareness

41 Enforcement Guidance Enforcement Guidance O&M Part 192 Revision Date Code Section Section Title Existing Code Language General (a) No person may operate a segment of pipeline, unless it is maintained in accordance with this subpart. (b) Each segment of pipeline that becomes unsafe must be replaced, repaired, or removed from service. (c) Hazardous leaks must be repaired promptly. Origin of Code Original Code Document, 35 FR 13248, Last Amendment Interpretation Summaries Interpretation: PI-ZZ-065 Date: The only safety standard in Part 192 that governs the maintenance of service line valves is (b). This section requires the repair, replacement, or removal from service of any segment of pipeline, including a valve that is unsafe. Although the inability to operate a service line valve may be reason to apply (b), Part 192 does not require inspection of service line valves to see if they are operable. Interpretation: PI Date: The letter requested clarification of our August 31, 1989, letter regarding protection for offshore pipelines. The requirements of 49 CFR (a) applies to conditions known or that can be foreseen at the time of construction. Thereafter, an operator does not have a continuing obligation under this rule to provide protection against hazards from changed or new conditions. However, if the operator learns the pipeline has become unsafe due to these changed or new conditions, the operator would Advisory Bulletin/Alert Notice Summaries Other Reference Material & Source Guidance Information Examples of a Probable Violation GPTC Guide Material is available. 1. Operators need to repair of conditions that are "unsafe" or "could adversely affect the safe operation of [the] pipeline system," but do not specify a time period in which the required repairs must be made. 2. Operator needs to define hazardous leak. Part 192 Subpart P defines hazardous leaks. While this definition is only applicable to distribution systems, it may provide guidance for defining hazardous leaks. See for additional guidance material. 3. Operator needs to have a leak classification system if all leaks are not repaired promptly. 4. Operator needs to have written procedures for leak classification and defining required repairs including time frames for performing repairs. 5. Operator must have a process for documenting leaks. 1. The lack of a procedure is a violation of The lack of records is a violation of The operator did not follow written procedures. 4. Operator does not have a leak classification process. 5. Pipelines known to be unsafe are not repaired. 6. Operator did not perform repairs in a timely manner or in accordance with their procedures.

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43 Includes terms defined in code and interpretations Technical documents and other IBR sources

44 PHMSA Information Websites PHMSA Training and Qualification PHMSA Pipeline Safety Regulations PHMSA Rulemaking rulemaking

45 Outstanding Issues

46 Construction Issues

47 Cured In Place Liners - FAQ

48 Construction Issues

49 Coatings

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52 Patch Stick Issues Heating the patch stick and dripping the product on the coating holiday is not acceptable.

53 Fingernail scratched off applied patch stick repair

54 Good patch stick application - notice heated/discolored area around patch, this indicates that the pipe was heated before and during patch stick application

55 Patch Sticks are only for pinhole or abrasion repair. 2 part epoxy should have been used.

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58 2 part epoxy Follow manufacturers instructions Preparation required (Sanding = anchor pattern) Thoroughly mix product Use promptly If products starts to cure before application the repair presents the appearance of the next slide

59 2 Part Epoxy

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61 DCVG Dig on First Phase Disbonded girth weld coating poor surface preparation

62 DCVG Dig on First Phase Girth Weld Coating Mixed with Backfill Wet Epoxy Mixed with Backfill

63 Electronic Holiday Detection (Jeeping) Visual inspection must supplement jeeping Problems identified - Bent defective spring. - Not identifying and repairing all jeeps - Passing over visible holiday without the jeep sounding - Based on experience, jeep voltage may need to be set as high as 3500v to detect coating defects

64 Are the workmen finding coating holidays? Do the workmen operating the jeep have time to find and repair coating holidays?

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66 Manipulating the jeep spring over building fiberboard stuck to the pipe is poor practice 66

67 Just jeeping at skids only on lowering in is not usually per construction procedures 67

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69 A bent jeep spring can miss coating holidays 69

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71 Duct tape can shield coating holidays 71

72 Manipulating the jeep spring over building fiberboard stuck to the pipe is poor practice 72

73 Just jeeping at skids only on lowering in is not usually per construction procedures 73

74 Look for coating holidays in the ditch. Observing these indicates a problem. 74

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76 Thin Film Epoxy Issues Insufficient heating (3M procedure specify degrees F - lower temperatures could mean improper curing) Over heating during application can be a problem (the coating looks burnt and is unacceptable) Poor sandblasting 76

77 425 F to 488 F

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79 Girth Weld Coating

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81 Is there water in the pipe? = no coating coverage 81

82 Rock Padding Rock Shield Record area where RS applied 82

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87 Gouges and Bending Gouges consult procedures Acceptable wall thickness? < 1% diameter? 87

88 Proper burial depth on bores? 88

89 Is the pipeline buried deep enough and protected from erosion? 89

90 High Mechanized Defect Rate Causes Pipe sizing issues Inexperienced welders Start up issues X-ray or AUT falling behind eliminates timely feed back. Feed back is a valuable tool to improve weld quality. 90

91 The welding procedure allows how much high-low? 91

92 High Mechanized Defect Rate PHMSA Concerns: Having defects not an issue. Defect repair, NDT and tracking is an issue. Industry experience usually shows % defect rate on mechanized welding - 2 7% for semi-automatic welding - 2 5% on manual welding 92

93 Laminations can be an issue especially associated with an 80% waiver 93

94 AUT easily shows laminations 94

95 Preheat Heating the weld joint before welding Temperature of the weld joint immediately before the arc is struck. Procedures state Contact Pyrometer, or Temperature Indicating Crayon Range of preheat values found in the welding procedure 95

96 Use of Temperature Indicating Crayon Temperature indicating crayons (Tempilstik) are specially formulated to melt at a specific temperature. On a cold pipe surface upon heating the mark changes color and melts at the specific temperature Used on a hot surface the crayon only indicates the temperature is greater than the specified temperature on the crayon if the crayon melts Applying the crayon on an area adjacent to a weld joint and then heating with a propane torch directed on the mark will give a false temperature indication. In this case the flame heats the crayon mark faster than the pipe. The pipe will not be up to the required temperature. The crayon should be used after heating and two different temperature crayons may be necessary to determine the preheat is within the welding procedure. 96

97 Temperature Indicating Crayons The crayon holder specifies the melt temperature. 97

98 Interpass Temperature The temperature at a location near the start position of the welding arc(s) recorded immediately before initiating consecutive pass or passes. (from Appendix A) Minimum Interpass Temperature generally preheat temperature Maximum Interpass Temperature highest temperature allowed to start welding. 99

99 Must follow welding procedure Some items to check Bevel configuration Electrodes rods filler metals Electrical parameters Speed of travel Weld dimensions 101

100 Welding Procedures The procedure states cfh shielding gas flow rate. Does the photo show an acceptable value? (No) 102

101 Electrical Characteristics Values displayed on welding machines should be within the range of the WPS. Machine is not calibrated but usually close. If outside procedure use calibrated clamp-on. 103

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103 Welding procedure required 250 F preheat

104 Band Damage 106

105 Welding Band Damage to Coating

106 Inspection Requirements Large variation in inspector competency What are the inspectors responsibilities? Welding inspector must be knowledgeable and competent Verify welding procedure is followed Observe Document Report Correct Work stoppage Not fall asleep in the pickup truck 108

107 Image Quality Indicators 109

108 Image Quality Indicators (Penetrameters) PHMSA (OPS) recognizes the 20 th editions of API The 20 th edition only allows the use of Wire Type Image Quality Indicators. 110

109 Refer to Table 5 API th Edition Weld Thickness Essential Wire Diameter ASTM Set Inches Inches Letter A > A or B > B > B > B > B 111

110 ASTM E 747 IQI Wire Sizes for A B Packets SET A SET B

111 ASTM Type B Packet The complete outline of the essential wire must be visible and not obscured by number belt. 113

112 Is the radiographic density per API 1104 or operator s procedures? 114

113 Radiographic Requirement Both Parts 192 and 195 require a certain percentage (based on location or class location) of welds be nondestructively tested and that a percentage of a welders daily work product must be nondestructively tested. If the radiographs image quality indicators are not acceptable, or the radiograph is unacceptable, then there may be insufficient numbers of radiographs to meet the percentage and/or daily requirements of the applicable code. 115

114 Radiographic Problems Identified Poor radiograph technique - so bad minimum % could not be achieved Poor radiograph developing practices Fogged Film and/or artifacts Radiographs too dark or light Density (H&D) out of operator s specification or API specification Improper or poor radiographic interpretation Missing one or more segments of the weld radiograph Segments of radiographs do not overlap Missing radiographs when compared to weld maps

115 Radiographic Problems Identified continued No repair radiograph Radiographed wrong defect area (multiple repairs) should be able to match up unrepaired areas of repair radiograph to original radiograph Numbering irregularities (Changed numbers with magic marker) Radiographing same weld twice or multiple times and changed weld identification numbers IQI issues essential wire not visible Poor radiographic technique used on transition welds especially if there is a large difference in thickness

116 Facility Locations Welds >6 # films poor quality # require repair # duplicated. Location Location Location Location Location Location Location Location Location Location Location Location Location Location Location Location Location

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129 Pipe on Solid Rock Anomaly Dig

130 DCVG Dig on First Phase Disbonded girth weld coating poor surface preparation

131 15 Holidays DCVG Dig

132 DCVG Dig

133 DCVG Dig on First Phase Girth Weld Coating Mixed with Backfill Wet Epoxy Mixed with Backfill

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135 Specificity and details for written procedures

136 Would you order Strawberry? Cherry? Raspberry? Cinnamon? Red Velvet Cake? Or... Would you Just order RED?

137 Mosquito? Flea? Or... Spider? Hyppopotamus?

138 Details Who What When Where Why How Other information to provide clarity

139 the plans should be an outline for compliance. They should either say what you do or, You should do what they say Either way you will be in compliance with your own procedures

140 Example:

141 Only the right combination of specificity and detail will provide what we essentials to achieve these goals and give us the compliance we want and need.

142 Other things that add specificity, detail and clarity Flowcharts, Drawings and photos Tables Definitions References to DOT codes

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149 Other things that add specificity, detail and clarity References to other Company Manuals or Plans that contain more details and specificity Corrosion Safety Measurement Design

150 Example: The incident needs to reported to the pipeline controller. Rewritten. The first employee having knowledge of the emergency and/or arriving on the emergency scene will report incident information within 15 min. of notification and/or arriving at the site, to the pipeline control center by telephone or company radio.

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152 KEY WORDS Be Is Are A Was Were Has been Have been Will be Being

153 Example: Extensive training on the new safety procedures is required to be attended by the maintenance staff. Rewritten. The entire maintenance staff is required to attend extensive training on the new safety procedures from 8-11 a.m. next Monday in the Welding Shop.

154 Correct the following five sentences to practice changing passive to active voice. 1. Hunger was what Bill felt. 2. Reading is enjoyed by Mary. 3. The town was destroyed by fire. 4. Funny is what clowns are. 5. Cheese was liked by Sara.

155 Hunger was what Bill felt. Bill felt hungry. (Bill is the subject, felt is the action)

156 Reading is enjoyed by Mary. Mary enjoys reading (Mary is the subject, enjoys is the action) 1. Reading is enjoyed by Mary.

157 The town was destroyed by fire. Fire destroyed the town (Fire is the subject, destroyed is the action) 1. Reading is enjoyed by Mary.

158 Funny is what clowns are. Clowns are funny (Clowns is the subject, funny is the action) 1. Reading is enjoyed by Mary.

159 Cheese was liked by Sara. Sara likes cheese (Sara is the subject, likes is the action) 1. Reading is enjoyed by Mary.

160 Problems can occur with operators who fall back on specifics in their OQ Plan to avoid the specifics in their O&M.

161 Although OQ Plans have specifics, they are not usually available onsite for verification by inspection personnel during O&M activity inspections or emergencies; hence the need for a certain level of specificity and detail in the O&M and Emergency plan procedures

162 Remember in the end, The plans should either say what you do or, You should do what they say Either way you will be in compliance with your own procedures