PHMSA Update: Aging Infrastructure and Integrity Verification Process
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1 PHMSA Update: Aging Infrastructure and Integrity Verification Process NAPCA Workshop August 15, 2013 Houston, Texas Safety Administration (PHMSA) Steve Nanney 1
2 PHMSA Safety Update - Topics Performance Incidents from Overview PHMSA s 2013 Agenda Integrity Verification Process 2
3 Performance 3
4 Serious Incidents Downward Trend Continues in 2012 Serious Incident fatality or injury requiring in-patient hospitalization 4
5 Significant Incidents Downward Turn in 2012 Significant incidents include any of the following: 1. Fatality or injury requiring in-patient hospitalization; 2. $50,000 or more in total costs, measured in 1984 dollars 3. Highly volatile liquid (HVL) releases of 5 barrels or more; 4. Non-HVL liquid releases of 50 barrels or more; and 5. Liquid releases resulting in an unintentional fire or explosion 5
6 2012 Hazardous Liquid Incidents Top Causes for All Reported & Significant Categories Material/ Weld/Equip Failure Corrosion Incorrect Operation 6
7 2012 Gas Transmission Incidents Top Causes for All Reported & Significant categories Material/Weld/ Equip Failure Corrosion 7
8 2012 Gas Distribution Incidents Top Causes for all incident categories: Other Outside Force Damage Excavation Damage Other 8
9 Significant Accident Breakdown Total by Type (Fatalities) Total for All Types 1 Hazardous Liquid Gas Transmission Gas Distribution (19) 121 (1) 79 (10) 54 (8) (12) 139 (1) 83 (0) 60(11) (10) 129 (3) 62 (0) 49 (7) 3 Year Average ( ) 262 (14) 130 (2) 75 (3) 54 (9) 5 Year Average ( ) 10 Year Average ( ) 268 (12) 124 (2) 74 (2) 62 (8) 281 (15) 122 (2) 77 (2) 73 (11) 1 includes gas gathering (zero fatality) - excludes fire first incidents; data as of 03/29/2013 9
10 Incidents from 2012 Overview 10
11 High Profile Incidents Chevron; Salt Lake City, Utah (Interstate) Crude oil and refined products Multiple accidents: 6/10, 12/10, 3/13 Sissonville, West Virginia (Interstate) Impact to major interstate highway; questions on HCA determination Led to Congressional oversight hearing NTSB investigation Mayflower, Arkansas (Interstate) Canadian heavy crude Investigation underway 11
12 Sissonville Pipeline Incident Dec 11, 2012: Rupture of a 20 X-60, gas transmission pipeline (1967 vintage)
13 Sissonville Pipeline Incident No injuries or fatalities (thankfully) 3 homes destroyed, others damaged Interstate 77 damaged and temporarily closed 3 pipelines in vicinity 20, 26 and 30 PHMSA issued Corrective Action Order NTSB investigated cause 13
14 14 Mayflower, AR Pipeline Accident March 29, 2012: 20 crude oil pipeline ruptured in Mayflower, Arkansas ~ 5,000 bbls of crude spilled Pipeline carrying Canadian crude oil (Wabusca) from Patoka, Illinois to Nederland, Texas Pipeline installed /1948.
15 Mayflower Pipeline Incident Pipeline flow reversal project was completed in 2006 Line from Patoka, IL to Nederland, TX has been shut in pending the results of the investigation Considerable media attention 15
16 Incidents like these and others in past years helped to form the focus of PHMSA s 2013 Agenda 16
17 PSA of Mandates 42 Mandates in Pipeline Safety, Regulatory Certainty, and Job Creation Act (PSA) of 2011 Includes 9 required studies (Leak Detection, Cover over Buried Pipelines, R&D, Diluted Bitumen, Cast Iron, Damage Prevention, Expansion of IMP, Gathering Lines, ) Other topics include: MAOP Records Verification, Tests to Confirm Material Strength of Previously Untested GT in HCAs 1 hour Notification of Incidents, Automatic/Remote Shut-off Valves
18 NTSB Recommendations 27 NTSB recommendations: ERW Pipe Seam Study/Implementation Emergency Response Information Sharing Operator Sharing Plan Information 911 Notification (Operator and 911 info exchange) ASVs/RCVs Removal of Grandfather Clause for Gas Transmission ILI Piggable Gas Transmission Pipelines Pressure testing of Gas Transmission (w/ spike test) 18
19 Nominal Pipe Size data as of from Part H 19
20 Decade Installed data as of from Part J 20
21 Specified Minimum Yield Strength data as of from Part K 21
22 PSA of 2011, 23 MAOP Mandate Verify records for Class Locations 3 & 4 and HCAs Reconfirm MAOP for pipe with incomplete records 5,401 miles with Incomplete Records in Class 3 & 4 and HCAs Strength test all untested pipe in HCAs operating at > 30% SMYS 3,220 HCA miles with Pressure Test < 1.1 MAOP Gas Transmission 2012 Annual Report data as-of
23 23 Specified Minimum Yield Strength data as of from Part K
24 NTSB Recommendation P Eliminate Grandfather clause and require hydrotest with a spike test for all pre-1970 pipe 55,120 miles Grandfathered miles reported (c) (22,717) and (a)(3) (32,403) 93,817 miles with Pressure Test < 1.1 times MAOP 20,272 miles with Stress Level > 72% SMYS or Unknown. Except for Special Permit/Alt MAOP pipelines, PHMSA expects this mileage is Grandfathered. PHMSA expects that Grandfather miles and Pressure Test < 1.1 MAOP are actually close to same # Somewhere between 55 and 94 thousand miles Gas Transmission 2012 Annual Report data as-of
25 Pressure Test Range Pressure Test Range Total Miles % Total PT 1.1 MAOP or no PT 93,817 31% 1.25 MAOP > PT 1.1 MAOP 19,131 6% 187,628 62% PT 1.25 MAOP Gas Transmission 2012 Annual Report data, Part R, as-of
26 Pressure Test < 1.1 MAOP data as of from Part R 26
27 Operating Stress Levels over 72% SMYS & Unknown % SMYS Interstate Intrastate Total > 72 to 80 11, ,895 > ,299 Unknown 973 6,074 7,038 Miles operating between 72 and 80% SMYS are either Grandfathered, Special Permit, or Alternative MAOP under 619(d) Miles with Unknown SMYS are Grandfathered Gas Transmission 2012 Annual Report data, Part K, as-of
28 Data Summary by HCA and Class Location data as of from Part Q Location Total GT Miles % in HCA GT HCA Miles Non-HCA Miles Class 1 237, , ,096 Class 2 30, ,412 28,798 Class 3 32, ,854 16,759 Class Total 301,540 19, ,862 HCA high consequence area
29 NTSB Recommendation P Manufacturing & Construction Defects Considered Stable Only for Pipe with Pressure Test 1.25 times MAOP 3,220 GT HCA Miles with Pressure Test < 1.25 MAOP 1,483 miles ILI Able 1,737 miles ILI Not Able Gas Transmission 2012 Annual Report data as-of
30 Pressure Test < 1.25 MAOP data as of from Part R
31 NTSB Recommendation P Configure all lines to accommodate smart pigs, with priority given to older lines ILI Piggable 60% of Total 118,947 miles ILI Not Able 40% of Total 69,579 miles Diameter 8-inch 23% of Total 44,600 miles Diameter 6-inch 15% of Total???? miles ILI Not Able due to system configuration Gas Transmission 2012 Annual Report data as-of
32 ILI Able vs Not Able Part R Class 1 - HCA - non-hca Class 2 - HCA - non-hca Class 3- HCA - non-hca Class 4 - HCA - non-hca TOTAL Total Miles 1, ,851 1,409 28,978 15,850 16, ,458 Gas Transmission 2012 Annual Report data as-of ILI Able 1, ,035 1,152 15,073 10,469 6, ,511 ILI Not Able , ,905 5,381 9, ,
33 Integrity Verification Process
34 Integrity Verification Process GOAL: Establish a comprehensive program to effectively address Congressional Mandates and NTSB Recommendations. 34
35 Overview Held IVP Workshop on August 7 Link to Workshop and Presentations g=91 Speakers NTSB Vice Chairman Chris Hart PHMSA Pipeline Safety Trust NAPSR Operators Gas and Liquids Intrastate (2) PG&E and Northwest Natural Gas Interstate INGAA Liquids API/AOPL Explorer Pipeline
36 Integrity Verification Process (IVP) Chart Based upon Congressional Mandates and NTSB Recommendations 36
37 Basic Principles of IVP Approach IVP is based on 4 principles 1. Apply to higher risk locations High Consequence Areas (HCAs) and Moderate Consequence Areas (MCAs) 2. Screen segments for categories of concern (e.g., Grandfathered segments) 3. Assure adequate material and documentation 4. Perform assessments to establish MAOP 37
38 Principle #1 Apply to Higher Risk Locations High Consequence Areas (HCAs) Moderate Consequence Area (MCA): Non-HCA pipe in Class 2, 3, and 4 locations Non-HCA pipe Class 1 locations that are populated in PIR (proposed 1 house or occupied site) to align with INGAA commitment House count and occupied site definition same as HCA, except for 1 house or 1 person at a site (instead of 20) PHMSA Estimates 91,000 miles HCA/MCA (out of 300,000 miles) 38
39 HCAs and Est. MCA Mileage Scope of Proposed IVP Process Estimated to Apply to: Total Estimated HCA + MCA Mileage = 91,000 miles Total HCA Non-HCA MCA Class 1 237,756 1,660 Class 2 30,210 1,412 28,798 28,798 Class 3 32,613 15,854 16,759 16,759 Class ,540 19,678 Total 236,096 (est.) 25, ,862 (est.) 71,160 PHMSA estimates approximately 33,000 miles of GT pipe (approximately 11% of total GT mileage) would meet screening criteria & require IVP assessment to establish MAOP IVP Process Steps 1 12 based upon 2012 Annual Report Data. 39
40 Principle #2 Screen for Categories of Concern Apply process to pipeline segments with: Grandfathered Pipe Based upon 5-year highest actual operating pressure of segment prior to July1,1970 Operating pressures over 72% SMYS pre-code Grandfathered Pipe Lack of Records to Substantiate MAOP Lack of Adequate Pressure Test History of Failures Attributable to M&C Defects 40
41 Principle #3 Know & Document Pipe Material If Missing or Inadequate Validated Traceable Material Documentation, then Establish Material Properties by an approved process: Cut out and Test Pipe Samples (Code approved process) In Situ Non-Destructive Testing (if validated and Code approved) Field verification of code stamp for components such as valves, flanges, and fabrications Other verifications 41
42 Principle #4 Assessments to Establish MAOP Allow Operator to Select Best Option to Establish MAOP Candidate IVP Options for Establishing MAOP Subpart J Test with Spike Test Derate pressure Engineering Critical Assessment Replace Other options PHMSA should consider? 42
43 Draft - Process Steps 21 Step Process Grandfather Clause and MAOP Review Process Steps 1 4 Integrity Review Process Steps 5 8 Low Stress Review Process Steps 9 12 Material Documentation Review Process Steps Assessment and Analysis Review Process Steps Implementation Process Step 21 Deadlines for Implementation 43
44 Draft Process Step 1 Grandfather Clause Screen 1 Related Mileage (c) MAOP Est. by Grandfather 22,717 miles reported as Grandfathered MAOP ( (c)) 32,403 miles reported for MAOP ( (a)(3)) Estimated 14,000 HCA/MCA Miles for (a)(3) and (c) MAOP 44
45 Draft Process Step 9 HCA/MCA Screen 9 Segment in HCA or MCA? A major screening criterion is location risk (HCA or MCA) Even though listed on the draft flow chart as Step 9, the HCA/MCA screening step may be accomplished first. HCA/MCA screen should be done first to avoid exhaustive and expensive documentation review for segments that are screened out by virtue of low location risk 91,000 HCA/MCA miles (out of 300,000 mi.) 45
46 Assessment & Analysis - Steps Select Method to Establish MAOP Assessment and Analysis to Establish Material Condition of Pipeline and MAOP, commensurate with segment-specific issues and documentation shortcomings. Assessment could include, as appropriate, specific assessments such as: ILI Program CIS Coating Survey 18 Interference Survey Engineering Critical Assessment 19 Based on Results Take Appropriate Action to Est. MAOP Develop Specific Guidelines Develop Specific Guidelines 17 Derate Pipeline Commensurate with Class Location And Perform Remaining Life Fatigue Analysis. Future Uprating allowed per Subpart K OR Replace Pipe 16 Perform Subpart J Pressure Test Supplemented with Spike Pressure per NTSB P Develop Specific Guidelines 21 Develop Specific Guidelines Document Basis for MAOP and Perform Remaining Life Fatigue Analysis 20 Develop Specific Guidelines Continue to Operate and Maintain in Accordance with Part
47 Specific Guidelines & Criteria IVP Chart is high level concept Details and specifications under development Will use knowledge from workshop and comments on web site to develop details Details to Develop: Spike pressure test specs (pressure, hold time, etc.) De-rate criteria (amount of MAOP reduction) ILI program requirements and specifications Material verification specs (# of cutouts, etc.) 47
48 Target Completion Timeframes Implementation Timeframe Multi-Year Effort Graduated timeframes with priority to: Legacy (LF-ERW /Seam Issue) pipe segments HCAs High Stress segments Proposed deadlines under development 48
49 Thank you Steve Nanney US DOT / PHMSA (713) office steve.nanney@dot.gov 49
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