direct assessment ecda program development

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Ted Christensen, PE Direct Assessment ECDA – Program Development

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Page 1: Direct Assessment ECDA Program Development

Ted Christensen, PE

Direct Assessment ECDA – Program Development

Page 2: Direct Assessment ECDA Program Development

Objective:

1. Why is there an ECDA plan ?2. What are acceptable methods of

an ECDA plan ?3. Does it make a difference ?

Page 3: Direct Assessment ECDA Program Development

Requirements

“Pipeline Safety Improvement Act of 2002”

Signed into law on December 17, 2002

The law has 25 sections

“RISK ANALYSIS AND INTEGRITY

MANAGEMENT PROGRAMS FOR GAS

PIPELINES”

Page 4: Direct Assessment ECDA Program Development

Requirements

Each operator who owns or operates a gas transmission line in a high consequence area must adopt an integrity management plan that -

• Identify the high consequence areas (HCA’s)

• Perform risk assessment to prioritize HCA’s

• Perform baseline assessment

• Has integrity management plan (14 required sections)

Page 5: Direct Assessment ECDA Program Development

Requirements • December 17, 2002 - Pipeline Safety Improvement Act of 2002

signed into Law• December 17, 2002 – Operators may begin base line assessment

(grandfather)• January 28, 2003 – DOT issues proposed rule• December 12, 2003 – DOT issues regulation • June 17, 2004 - Operators must start base line assessment• December 17, 2004 – Operators must complete risk analysis and

adopt an integrity management plan (24 months)• December 17, 2007 – Operators must complete baseline assessment

for 50% of facilities, must be the highest priority (5 years)• December 17, 2012 – Operators must complete base line

assessment for 100% of facilities (10 years)

Page 6: Direct Assessment ECDA Program Development

Requirements

There are 4 acceptable methods defined by the rule for the baseline assessment:

1. Internal inspection (ILI)2. Pressure testing3. Direct assessment4. Other methods

Page 7: Direct Assessment ECDA Program Development

Direct Assessment • Types of Direct Assessment

• External Corrosion Direct Assessment (ECDA)• Internal Corrosion Direct Assessment (ICDA)

• Stress Corrosion Direct Assessment (SCCDA)

Page 8: Direct Assessment ECDA Program Development

ECDA External Corrosion Direct Assessment

A four part process that combines pre-assessment, indirect inspections, direct examinations, and post assessment to evaluate the impact of external corrosion on the integrity of a pipeline

Page 9: Direct Assessment ECDA Program Development

Regulation DOT 192.925 - What are the requirements for using External Corrosion Direct Assessment (ECDA)?

Must follow the requirements in

ASME/ANSI B31.8S - section 6.4

NACE RP 0502-2010

Page 10: Direct Assessment ECDA Program Development

Regulation The operator must develop and implement a plan that

has procedures addressing:

(1) Preassessment(2) Indirect examinations(3) Direct examinations(4) Post assessment and continuing evaluation

Page 11: Direct Assessment ECDA Program Development

The 4 required steps

(1) Pre-assessment

(2) Indirect examinations(3) Direct examinations(4) Post assessment and continuing

evaluation

Page 12: Direct Assessment ECDA Program Development

Preassessment • NACE RP 0502-2010 section 3• ASME B31.8S section 6.4

Apply a more restrictive criteria for first time use of ECDA in HCA section

Use of two different, but complimentary tools (must be listed in NACE RP 0502-2010 appendix

A or the operator must prove technique)

Page 13: Direct Assessment ECDA Program Development

Preassessment (cont.)

NACE RP 0502-2010 Section 3Preassessment - • Data collection (3.2)• Assessment of ECDA feasible (3.3)• Selection of indirect inspection tools (3.4)• Identification of ECDA regions (3.5)Requires -

• Sufficient data collected, integrated, and analysis• Comprehensive and thorough fashion

Page 14: Direct Assessment ECDA Program Development

Preassessment (Data collection)

As a minimum, the pipeline operator shall include data from the following five categories, as shown in Table 1

1. Pipe-related (6)

2. Construction-related (11)

3. Soil/environment (5)

4. Corrosion Control (10)

5. Operational (11)

A Total of 43 Data Elements

Page 15: Direct Assessment ECDA Program Development

Preassessment (Data collection)

Table 1: ECDA Data Elements (PIPE-RELATED)

Data Elements Indirect Inspection ToolSelection

ECDA Region definition Use and Interpretation of Results

PIPE -RELATEDMaterial (steel, cast iron, etc.)and grade

ECDA not appropriate fornonferrous materials.

Special considerations should begiven to locations wheredissimilar metals are joined.

Can create local corrosion cells whenexposed to the environment.

Diameter May reduce detectioncapability of direct inspectiontools.

Influences CP current flow andinterpretation of results

Wall thickness Impacts critical defect size and remaininglife predictions

Year Manufactured Older pipe materials typically have lowertoughness levels, which reduces criticaldefect size and remaining life predictions.

Seam Type Locations with pre-1970 lowfrequency electric resistancewelded (ERW0 or flash weldedpipe with increased selectiveseam corrosion susceptibility mayrequire separate ECDA regions.

Older pipe typically has lower weld seamtoughness that reduces critical defect size.Pre-1970 ERW or flash-welded pipe seamsmay be subjected to higher corrosion ratesthan the base metal.

Bare pipe Limits ECDA application.Fewer available tools – SeeAppendix A.

Segments with bare pipe incoated pipelines should be inseparate ECDA regions.

See ECDA methods provided in AppendixA.

Page 16: Direct Assessment ECDA Program Development

Preassessment (Data collection)

• If there is insufficient data for a ECDA region, and you cannot support the preassessment step, ECDA shall not be used for that segment

• Much of the data needed for the ECDA preassessment step is also used in the risk assessment phase of a pipeline integrity management program

Page 17: Direct Assessment ECDA Program Development

Preassessment (Assessment of ECDA feasible)

The following conditions may make it difficult to apply ECDA• Coatings that cause electrical shielding• Backfill with significant rock content or rock ledges• Pavement, frozen ground and reinforced concrete• Adjacent buried metallic structures• Inaccessible areas

If indirect inspection methods are not practical, the ECDA process may not be applied.

Page 18: Direct Assessment ECDA Program Development

Preassessment (Selection of indirect inspection tools)

• DOT 192.925 (b) (1) (ii)“If an operator utilizes an indirect inspection method that is not discussed in appendix A of NACE RP0502-2010, the operator must demonstrate the applicability, validation basis, equipment used, application procedure, and utilization of the data for the inspection method”

Page 19: Direct Assessment ECDA Program Development

Preassessment (Selection of indirect inspection tools)

Selection of Indirect Inspection Tools

Minimum of two indirect inspection tools • Detect corrosion activity and/or coating holidays

• Endeavor to use complimentary tools• The strength of one tool compensates for the limitations of the

other tool

• Table 2: ECDA Tool Selection Matrix

• Appendix A: Indirect Inspection Methods

Page 20: Direct Assessment ECDA Program Development

Preassessment (Selection of indirect inspection tools)

NACE RP0502-2010 appendix AIndirect Inspection methods

• Close -interval surveys (CIS)• AC current attenuation surveys• DCVG and ACVG surveys• Pearson surveys• Cell-to-cell surveys

Page 21: Direct Assessment ECDA Program Development

Preassessment (Selection of indirect inspection tools)

• Table 2: ECDA Tool Selection Matrix (Partial)

Page 22: Direct Assessment ECDA Program Development

Preassessment (Identification of ECDA regions)

An ECDA region is a portion of a pipeline segment that has • Similar physical characteristics• Similar corrosion history• Expected corrosion conditions• Uses the same indirect inspection tools

Page 23: Direct Assessment ECDA Program Development

Preassessment (Identification of ECDA regions)

• Table 1 - ECDA Data Elements and Table 2 - ECDA Tool Selection Matrix may be used as guidance in establishing ECDA regions

• The definitions of ECDA regions may be modified based on the results of the indirect and direct inspection steps

• A single ECDA region does NOT have to be contiguous (either side of a river)

Page 24: Direct Assessment ECDA Program Development

Preassessment (Summary)

• Data is gathered and reviewed(More information may be needed)

• Establish if ECDA is appropriate(Could be used for some HCA segments but not for others)

• Indirect inspection tools are identified(Different tools for different HCA segments)

• Regions are identified (Regions may change after indirect and direct examination)

Document your data, data sources, assumptions and decision making process

Page 25: Direct Assessment ECDA Program Development

The 4 required steps

(1) Preassessment

(2) Indirect examinations

(3) Direct examinations(4) Post assessment and continuing

evaluation

Page 26: Direct Assessment ECDA Program Development

Indirect examinations

NACE RP0502-2010 Section 4 To define the severity of coating faults, other anomalies and areas at which corrosion activity may have occurred or may be occurring

1. Requires the use of at least two inspection tools over the entire length of the ECDA region

2. Align and compare the data from the two inspection tools3. May require more than two inspection tools in a ECDA

region

Page 27: Direct Assessment ECDA Program Development

Indirect examinations • The boundaries of the ECDA region should be clearly

marked• When ECDA is applied for the first time, consider spot

checking, repeating inspections or other means to ensure consistent data

• The distance selected must be such that the inspection tool can detect and locate corrosion activity

• The indirect inspections should be conducted as close together as in time as practical (Change of season, installation or abandonment of facilities)

• GPS shots should be taken on above ground locations (even if outside of region)

Page 28: Direct Assessment ECDA Program Development

Indirect examinations After the indirect inspection data is taken, indications shall be identified and aligned for comparison

• Must define criteria for identifying indications• Coated lines: Should be sufficient to locate coating

faults regardless of corrosion activity at the fault• Poorly coated or bare lines: Should be sufficient to

locate anodic regions• Must consider spatial errors

Page 29: Direct Assessment ECDA Program Development

Indirect examinations

Page 30: Direct Assessment ECDA Program Development

Indirect examinations

After identifying and aligning indications, a classification system must be defined and applied • Classification is the process of estimating the likelihood of corrosion activity at each indication under typical year-round conditions• Severe - highest likelihood of corrosion• Moderate - possible corrosion activity• Minor - inactive or lowest likelihood of corrosion

Page 31: Direct Assessment ECDA Program Development

Indirect examinations • The criteria for classifying the severity

• capabilities of the indirect inspection tool• unique conditions within the ECDA region

• When ECDA is used for the first time• Make the classification system as stringent as possible

• When it cannot be determined whether corrosions is active, an indication should be considered severe

Page 32: Direct Assessment ECDA Program Development

Indirect examinations • Table 3: Example Severity Classification

Tool/Environment Minor Moderate SevereCIS, aerated moist

soilSmall dips with onand off potentialsabove CP criteria

Medium dips or offpotentials below CP

criteria

Large dips or on andoff potentials bellow

CP criteriaDCVG survey,

similar conditionsLow voltage drop:

cathodic conditions atindications when CP

is on and off

Medium voltage dropand/or neutralconditions at

indications when CPis off

High voltage dropand/or anodic

conditions when CP ison or off

ACVG or Pearsonsurvey, similar

conditions

Low voltage drop Medium voltage drop High voltage drop

Electromagnetic Low signal loss Medium signal loss High signal lossAC current

attenuation surveySmall increase in

attenuation per unitlength

Medium increase inattenuation per unit

length

Large increase inattenuation per unit

length

Page 33: Direct Assessment ECDA Program Development

Indirect examinations If two or more indirect inspection tools indicate a significant different set of locations at which corrosion activity may exist-• Explained by the inherent capabilities of tools?• Specific and localized pipeline features?

or• Preliminary direct examinations• Additional indirect examinations

Page 34: Direct Assessment ECDA Program Development

Indirect examinations • If discrepancies cannot be resolved

• ECDA feasibility should be reassessed

• For initial ECDA applications, any location at which discrepancies cannot be resolved, the location shall be categorized as severe

Page 35: Direct Assessment ECDA Program Development

Indirect examinations • After discrepancies have been resolved, the results of the indirect examination shall be compared with the results of the preassessment and prior history of each ECDA region• If the results are not consistent

• Reassess ECDA feasibility• Reassess ECDA region definition

Page 36: Direct Assessment ECDA Program Development

Indirect examinations

•NOTE: 192.933 (b) states - ...to determine that the condition presents a potential threat to the integrity of the pipeline…..An operator must promptly, but no later than 180 days after conducting an integrity assessment, obtain sufficient information about the condition to make that determination.

Page 37: Direct Assessment ECDA Program Development

Indirect examinations (Summary)

• Mark regions and conduct surveys• Align and compare results• Define classification system

• Must be as stringent as practical if ECDA is used for the first time

• Compare results• May need to do a preliminary direct exam• ECDA may not be feasible• If using ECDA for first time, unresolved discrepancies

must be classified as severe• Must be consistent with pre-assessment and region

definitions

Page 38: Direct Assessment ECDA Program Development

The 4 required steps (1) Preassessment(2) Indirect examinations

(3) Direct examinations

(4) Post assessment and continuing evaluation

Page 39: Direct Assessment ECDA Program Development

Direct examinations

NACE RP0502-2010 Section 5

The objectives of the Direct Examination Step is to determine which indications from the indirect inspections are most severe and collect data to assess corrosion activity

Page 40: Direct Assessment ECDA Program Development

Direct examinations • The six phases involved

• Prioritization of indication found during the indirect inspections

• Excavation and data collection at areas where corrosion activity is most likely

• Measurements of coating damage and corrosion defects

• Evaluation of remaining strength• Root cause analysis• A process evaluation

Page 41: Direct Assessment ECDA Program Development

Direct examinations (Prioritization)

Table 4: Example Prioritization of Indirect Inspection Indications

Immediate Action Required Scheduled Action RequiredStable for

Monitoring Severe indications in close proximity

regardless of prior corrosion Individual severe indications or groups

of moderate indications in regions ofmoderate prior corrosion

Moderate indications in locations inregions of severe prior corrosion

All remaining severindications;

All remaining moderateindications in regions ofmoderate prior corrosion

Groups of minor indications inregions of severe priorcorrosion

Allremainingindications

Page 42: Direct Assessment ECDA Program Development

Direct examinations • DOT 192.993 (c) Schedule for evaluation and remediation

• Must follow schedule in ASME B31.8S Section 7 Figure 4• Based on MAOP Above 50%/ Above 30% but not exceeding 50% / Not

exceeding 30%• Table is Pf/MAOP vs Response Time (years)

Page 43: Direct Assessment ECDA Program Development

Direct examinations (Measurements)

• Excavations based on the priority categories• Define minimum requirements for consistent data collection• NACE RP 0502-2002 Appendix A/B/C contains typical

data measurements and related activities• Gather information on

• Environment soils/water/MIC

• Coating type/condition/thickness/adhesion• Corrosion product/defects/measurements

Page 44: Direct Assessment ECDA Program Development

Direct examinations (Remaining strength)

• Evaluate or calculate the remaining strength at locations where corrosion defects are found• ASME B31G• RSTRENG• DNV Standard RP-F101

Page 45: Direct Assessment ECDA Program Development

Direct examinations (Root cause analysis)

• Must identify any root cause of all significant corrosion

• If a root cause is uncovered for which ECDA is not well suited, an alternative method of assessing the integrity should be considered• Shielding by disbonded coatings• biological corrosion

Page 46: Direct Assessment ECDA Program Development

Direct examinations (Process evaluation)

The purpose is to evaluate the criteria used to categorize the repair criteria and severity criteria • If existing corrosion is less severe than prioritized, you may modify

the criteria and then reprioritize all indications

• If existing corrosion is more severe than prioritized, you must modify the criteria and reprioritize all indications

• Any indication for which a comparable direct examination measurement shows more serious conditions than the indirect inspection data, indications shall be moved to a more severe

category

Page 47: Direct Assessment ECDA Program Development

Direct examinations (Summary)

• Prioritization of indication

• Excavation and data collection

• Measurements of coating damage and corrosion

defects

• Evaluation of remaining strength

• Root cause analysis

• A process evaluation

Page 48: Direct Assessment ECDA Program Development

The 4 required Steps (1) Preassessment(2) Indirect examinations(3) Direct examinations

(4) Post assessment and continuing evaluation

Page 49: Direct Assessment ECDA Program Development

Post assessment and continuing evaluation

NACE RP0502-2010 Section 6

The objective of the Post-Assessment Step is to define reassessment intervals and assess the overall effectiveness of the ECDA process

Page 50: Direct Assessment ECDA Program Development

Post assessment and continuing evaluation

Reassessment intervals based on • All immediate indications have been addressed during

direct examination• All monitored indications are expected to experience

insignificant growth• Remaining life calculations• Must not exceed DOT 192.939

Page 51: Direct Assessment ECDA Program Development

Post assessment and continuing evaluation

DOT 192.939• Pipelines operating at or above 50% SMYS

• Direct Assessment every 10 years• Confirmatory Direct Assessment every 7 years

• Pipelines operating at or above 30% SMYS, up to 50% SMYS• Direct Assessment every 15 years• Confirmatory Direct Assessment every 7 years

• Pipelines operating below 30% SMYS• Direct Assessment every 25 years• Confirmatory Direct Assessment every 7 years

Page 52: Direct Assessment ECDA Program Development

Post assessment and continuing evaluation

Remaining life calculations• If no corrosion defects are found, no remaining life

calculations are needed, the remaining life can be taken as the same for a new pipeline

• The maximum remaining flaw size shall be taken as the same size as the most severe indication • Root cause shows most severe indication is unique, use next

most severe indication• Substitute based on more sophisticated method

• Use values and methods provided in Appendix D in the absence of measured corrosion rate data

Page 53: Direct Assessment ECDA Program Development

Post assessment and continuing evaluation

Remaining Life = C x SM x t/GR

• C = Calibration factor of 0.85• SM = Safety margin = Failure pressure ratio minus MAOP ratio,

• Failure pressure ratio = calculated failure pressure / yield pressure• MAOP ratio = MAOP / yield pressure

• t = nominal wall thickness (mm or in)• GR = Growth Rate 0.4 mm/y (16mpy)

Page 54: Direct Assessment ECDA Program Development

Post assessment and continuing evaluation

Remaining life example:• 20 inch OD / .375 wt / x-52 / fp = 1700 psig

• Yield = (2 x wt x SMYS)/OD = (2 x .375 x 52,000) / 20 = 1950 psig• MAOP = Yield x CF = 1950 x .50 = 975 psig• Failure pressure ratio = fp/yield = 1700/1950 = .872• MAOP ratio = MAOP/yield = 975/1950 = .500• Safety margin = .875 - .500 = .375• t/GR = .375/.016 = 23.44 years

RL = 0.85 x 0.375 x 23.44 years = 7.47 years

Page 55: Direct Assessment ECDA Program Development

Post assessment and continuing evaluation

• When corrosion defects are found during the direct examinations, the maximum reassessment interval for each ECDA region shall be taken as one-half the calculated remaining life

• Different ECDA regions may have different reassessment intervals based on variations in expected growth rates between ECDA regions

Page 56: Direct Assessment ECDA Program Development

Post assessment and continuing evaluation

Assessment of ECDA effectiveness• At least one additional direct assessment location at a randomly

selected location shall be conducted to provide additional conformation that the ECDA process is working

• For initial ECDA applications, at least two additional direct exams will be performed• One which is classified as scheduled (monitor)• One in location where no indication exist

Page 57: Direct Assessment ECDA Program Development

Post assessment and continuing evaluation

Activity for which feedback should be considered1. Identification and classification of indirect inspection results2. Data collected from direct examinations3. Remaining strength analysis4. Root cause analysis5. Remediation activities6. In-process evaluation7. Direct examinations used for process validation8. Criteria for monitoring long term ECDA effectiveness9. Scheduled monitoring and period reassessment

Page 58: Direct Assessment ECDA Program Development

Records NACE RP0502-2010 Section 7

The ECDA records that document in a clear, concise, workable manner all 4 steps in the ECDA process

Page 59: Direct Assessment ECDA Program Development

ECDA Process Summary • Pre-assessment

• Data / ECDA feasibility / Selection of tools / identification of regions

• Indirect examinations• Conduct surveys / align and compare results / define classification system /

compare results

• Direct examinations• Prioritization / data collection / remaining strength / root cause analysis /

process evaluation

• Post assessment and continuing evaluation• Remaining life / re-assessment / effectiveness / improvement

Page 60: Direct Assessment ECDA Program Development

Common Question Does ECDA really work?

YES, BUT…..

• It will not work in all HCA segments

• The results of the indirect inspections may lead you to utilize IIL or pressure testing

• All four steps in the ECDA process must be completed thoroughly and documented

Page 61: Direct Assessment ECDA Program Development

Areas of Concern • Coatings that shield

• Tapes / extruded poly• Field joints - cold and hot applied tapes / heat shrink sleeves

• Deep pipelines - HDD• Poorly coated pipelines - number of indications

• Casings• Remaining life calculations - 16 mils/year• Surface conditions - pavement• Sacrificial Anodes - On/Off CIS / Coating fault indications

Page 62: Direct Assessment ECDA Program Development

Summary Documentation, Documentation, Documentation

Detail procedures

Share information

Expect to revise your procedures

ECDA is only one part of your company’s Pipeline Integrity Management Program

Page 63: Direct Assessment ECDA Program Development

Resources • Federal Register December 15, 2003 Vol. 68, No. 240.

Docket No. RSPA-00-7666 DOT Subpart O Pipeline Integrity Management 192.901 - 192.947

• NACE Standard PR0502-2010 Pipeline External Corrosion Direct Assessment Methodology

• ASME/ANSI B31.8S Managing System Integrity Of Gas Pipelines

Page 64: Direct Assessment ECDA Program Development

Conclusion

•Why is the an ECDA plan ?•What are acceptable methods of

an ECDA plan ?•Does it make a difference ?

Page 65: Direct Assessment ECDA Program Development

Thank You!

QUESTIONS ?

Ted Christensen, PEMercer Technical Services

816-820-2898