Pipeline Records - - Lessons Learned. The Changing Industry Landscape and Transmission Records Implications NGA Operations Conference April 3, 2012

Transcription

1 Pipeline Records - - Lessons Learned The Changing Industry Landscape and Transmission Records Implications NGA Operations Conference April 3, 2012

2 Who Are We? CHA Consulting, Inc. CHA is a highly diversified, full service engineering firm servicing public, private and institutional sector clients throughout the United States. Jim Howe, Senior VP, Gas Engineering and Asset Management

3 Today s Agenda Why is this going on? What new legislation is now in place, and what is the potential for new regulations? What are the likely outcomes, and when? A process for transmission records review and MAOP validation Conclusion, discussion, and questions

4 Why Is This Going On? San Bruno Allentown, PA Philadelphia, PA

5 New Federal Legislation signed into Law in January, 2012 The Pipeline Safety, Regulatory Certainty, and Jobs Creation Act of 2011.to provide for enhanced safety and environmental protection in pipeline transportation, to provide for enhanced reliability in the transportation of the Nation s energy products by pipeline, and for other purposes

6 What Does the New Federal Section 3 Damage Prevention Legislation Say? Section 4 Automatic and Remotely Operated Valves Section 5 Integrity Management Section 6 Public Awareness and Education Section 7 Cast Iron Gas Mains Section 22 Excess Flow Valves

7 ..And Section 23, MAOP Validation Within 18 months, operators must identify and submit pipeline segments with insufficient records to validate MAOP Within 18 months, new rules are to be issued for strength tests for pipelines without records of previous tests in HCAs and >30% SMYS, including alternate methods

8 What Is the Potential For New More prescriptive MAOP validation requirements Remove pre-1970 grandfathering New requirements for: ILI Valves HCA System operation modifications Regulations?

9 What Are the Likely Outcomes, More prescriptive rather than less and When? Aggressive implementation time frames Not just regulators Regulation Review Period Immediate Implementation

10 The First Step: MAOP Validation Identify true verifiable MAOPs based on readily available documentation for installation and testing Have a system in place for maintaining current records as well as addition of new records Have a plan for addressing any record gaps via inspection, testing, de-rating, or replacement

11 A Process for Transmission Records Review and MAOP Validation

12 49 CFR Part 192 Guidance Documents Determination of Maximum Allowable Operating Pressure in Natural Gas Pipelines, PHMSA, April 22, 1998 AGA White Paper on Verification of MAOPs for Existing Steel Transmission Pipelines, April 2011

13 Steps in the Process Team structure Understanding your goals Reviewing and validating records Cataloging and digitizing records Identifying gaps Calculating MAOP Documentation Quality check

14 Team Structure Core Personnel Gas Construction & engineering experts Support engineers Technology experts Assess team size based upon miles of pipe, amount of documentation and planned completion date

15 Understanding Your Goals Organize data Identify technology associated with data Prioritize which segments to assess in what order Identify gaps Plan for gap mitigation Identify field work associated with mitigating gaps

16 Reviewing and Validating Records List of types of records you re looking for Identify preferred documentation and associated alternates Build a numbering system and a process for tagging the records Be clear on what constitutes validation Document the process

17 Potential Validation Items Required Data Year of Installation Hydrostatic Testing Material Data Material (Pipe Metallurgy and Grade) Manufacturing Process Seam Type Wall Thickness (Pipe) Diameter (Pipe) Coating Type Internal Lining? Construction Coupling Identification Post-Construction Coupling Reinforcement Welding NDT Post-Construction Girth Weld Reinforcement Depth of Cover As-built construction Documents Hydrotest Chart Mill Reports (MTR s) Pipe Fittings Valves Etc Coating/Wrapping Reports Radiography (X-ray) Reports Radiography Films (No Scanning Required) Welding Procedures Progress Diagrams/Reports Construction As-Built Drawings Construction Reports Alignment sheets Certification Letter Pre Construction Letter (Optional)

18 Cataloging and Digitizing Records Choose a document management tool Build a structure for organizing and linking the records Decide on level of accessibility Tie to GIS Availability to field personnel Decide on timing for review and upload

19 Typical Gaps: Identifying Gaps Welds Numbers and locations don t match, x-ray reports missing Mill reports can t be linked to specific sections to document material strength Material test reports can t be linked to specific materials Missing hydro/mtr documentation for final tie-ins Missing or incomplete as-builts Hydro documentation not signed off Not unique to older pipelines!

20 Calculating MAOP Documenting assumptions, applying them consistently Create assumption table or matrix Ensure assumptions are within appropriate margin of safety Documenting methodology Consistency with industry practice

21 Recommended for Inclusion: Methodology Assumptions Documents Segment reports Documentation Goal To be able to produce appropriate documentation to answer questions (internal or external) easily

22 Quality Check Start early Decide on layers to ensure quality: During the process internal or external Upon completion internal or external Ongoing audit to ensure continued compliance

23 Other Challenges and Tips Finding all of the existing records up front Handling HCA/non-HCA on the same line Adopting a pro-active approach to avoid reactive response

24 Think about how this will impact your operation Conclusion Workload and gap mitigation Be ready to explain your company s plan Know your system Ensure a consistent process within the industry NGA can help to start the discussion early

25 Questions?