pipeline safety update - napca nanney workshop... · pipeline and hazardous materials safety...
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Pipeline Safety Update
NAPCA Workshop
August 16, 2012
Houston, Texas
Pipeline and Hazardous Materials Safety Administration (PHMSA)
Steve Nanney
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
PHMSA Safety Update - Topics
• PHMSA – Overview
• Perspective on Past Performance
• Agency Priorities for 2012
• Where are we now?
• Verification of Records
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Who is PHMSA - DOT/PHMSA?
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Pipeline and Hazardous Materials
Safety Administration
(PHMSA)
FAA
FRA
FHWA
FMCSA
MARAD
NHTSA
PHMSA
RITA
STB
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Office of Hazardous
Materials Safety
Chief Counsel
Public Affairs
Contracts/Procurement
Human Resources
Training Center
Civil Rights
PHMSA
Office of
Pipeline Safety
Office of
Pipeline Safety
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
PHMSA - OPS Regions
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
PHMSA Mission
• To ensure the operation of the Nation’s pipeline transportation system is:
– Safe
– Reliable
– Environmentally sound
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
U.S. Pipeline Transportation System
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Pipeline Mileage Total
(%) Operators
Total
(%)
Hazardous Liquid 182,135 7 359 12
Gas Transmission 304,580 11 899 32
Gas Gathering 20,242 1 310 11
Gas Distribution
(main)
(service)
2,113,511 81
1,284 45 1,232,173 47
881,338 34
Total 2,620,468 100 2,852 100
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Pipeline System Components - 2011
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Perspective on Past Performance
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Significant Accident Breakdown Total by Type (Fatalities)
Total for All Types1
Hazardous Liquid
Gas Transmission
Gas Distribution
2010 255 (19) 120 (1) 75 (10) 54 (8)
20112 222 (16) 99 (1) 62 (0) 57 (15)
3 Year Average
(2008-2010)
269 (14) 116 (2) 74 (3) 68 (8)
5 Year Average
(2006-2010)
266 (15) 112 (2) 75 (3) 68 (10)
10 Year Average
(2001-2010)
277 (14) 119 (2) 72 (2) 76 (10)
1 Does not include gathering lines - totals may not add – excludes “fire first” incidents; 2 data as of 12/13.2011
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
y = 89.103e-0.034x
(3.4% decline/yr.)
0
20
40
60
80
100
120
1986 1990 1994 1998 2002 2006 2010
Pipeline Incidents w/Death or Injury (1986-2011)
Data source: DOT-PHMSA Incident data (as of Jan. 18, 2012)- 11 -
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
y = 176.92e-0.048x
(4.8% decline/yr.)
0
20
40
60
80
100
120
140
160
180
1986 1990 1994 1998 2002 2006 2010
Pipeline Major Injuries (1986-2011)
↑1,971
in 1994
Data source: DOT-PHMSA Incident data (as of Jan. 18, 2012)- 12 -
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
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y = 23.102e-0.019x
(1.9% decline/yr.)
0
10
20
30
40
50
60
1986 1990 1994 1998 2002 2006 2010
Pipeline Fatalities (1986-2011)
Data source: DOT-PHMSA Incident data (as of Jan. 18, 2012)
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
y = 5E+07e0.0836x
(8.4% increase/yr.)
$-
$200
$400
$600
$800
$1,000
$1,200
$1,400
$1,600
1986 1990 1994 1998 2002 2006 2010
(Millions)
Mill
ion
s
Dollar Damage from Pipeline Incidents (1986-2011), in 2010 Dollars
Data source: DOT-PHMSA Incident data (as of Jan. 18, 2012)- 14 -
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
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0
5
10
15
20
25
30
35
40
45
50
All Incidents - Gas Transmission and
Liquid Pipelines - 2002 to 2012/08
All Other Causes
Corrosion
Excavation Damage
Incorrect Operations
Material/Weld/Equip. Failure
Natural Force Damage
Other Outside Forces
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Agency Priorities for 2012
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
A Busy Year for PHMSA
• PHMSA “reauthorized” with new mandates
• 14 new NTSB recommendations
• Inspector General recommendations for HL pipelines
– State programs and oil spill response planning
• GAO issued some recommendations
• Conducted workshops, studies, and regs.
• Construction Inspections
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Agency Priorities for 2012
• Major Priorities
– Federal enforcement on excavation damage NPRM
– Hazardous Liquid Rule – through final phase
– Pipeline Enforcement Rulemaking – through final phase
– Gas Rulemaking – through proposed rule phase
• Likely to pick up most Congressional/NTSB items
– MAOP verification in class 3 & 4 + HCA’s (and beyond?)
• Records inadequacies, reporting and material testing requirements
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Where are we now?
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Aging Infrastructure (% by Decade)
Decade Hazardous
Liquid
Gas Transmission Distribution
Main Service
UNK/Pre 20s
2% ---
1920s 2% 2% --- ---
1930s 3% 4% 6% 3%
1940s 8% 7% 2% 2%
1950s 20% 22% 10% 8%
1960s 21% 23% 17% 13%
1970s 16% 11% 12% 14%
1980s 9% 10% 14% 17%
1990s 11% 11% 21% 22%
2000s 8% 10% 18% 21%
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Vintage/Legacy Pipe
• Grandfathered Pipe (with no pressure test)
• Pipe seam issues (LF/HF-ERW, Lap Welded, etc.)
• Older manufacturing quality issues
• Hard spots
• Laminations
• Low toughness
• Legacy coatings (CP shielding)
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Managing Challenges with Pipeline Seam Welds
DSAW Pipe Lap Welded Pipe
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Spiral Weld – SAW Pipe LF and HF - ERW Pipe
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Pipe Seam - Failures
Pipe – ERW Seam
Submerged Arc Welded (SAW)
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Electric Resistance Welded Pipe (ERW)
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
What are the Issues?
• Seam weld integrity issues are:
– Not always being identified by operator’s integrity management and risk assessment approaches
• Inadequate actions taken:
– Pipe seam not identified for special or urgent preventive and mitigative actions in some cases
• Grandfather MAOP/MOP
– No Code pressure test to +125% MAOP/MOP
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Pipe Seams Failures (2002-2012/8)
Seam Type Gas Hazardous
Liquid TOTAL
% of Total
DSAW 9 5 14 18
Flash Welded 1 5 6 8
HF ERW 3 15 18 23
LF ERW 5 23 28 35
Lap Weld 1 2 3 4
SAW 2 3 5 6
Other 4 2 6 7
Total 25 55 80 100
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Remediation Uncertainties in Vintage Pipe
• ILI Tool Accuracy/Tolerance and Reliability
− Tool tolerance, excavations, usage of unity plots
• Hard-to-Detect Threats
– SCC, girth weld defects, long seam defects, equipment failure, manufacturing defects
• Hydrostatic Pressure Test
– Future growth of un-remediated defects
• Direct Assessment
– Conclusions based on minimal excavations
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
2011 – New Pipeline Quality Low Strength Fittings
• Coating is cracking due to expansion of fitting during testing
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
2011 – New Pipeline Quality
• 24-inch Fitting
– Hydrotest – 2160 psi
– Failed at – 1740 psig
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
2011 – New Pipeline Quality
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Right–of-Way • Backfill practices • Clean-up practices • Maintenance
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
2011 – New Pipeline Quality
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
2011 – New Pipeline Quality
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2011 – HF-ERW Pipe Seam
• Where is the pipe mill and
construction QA/QC?
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
2011 – New Pipeline Quality
• Mill applied repair removed by scratching
• No surface prep at coating plant
• 2-part repair over spiral seam with portion of repair lifting off coating
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Current Challenges 2010/11/12
• High Profile Accidents with Serious Consequences on Aging and New Infrastructure
• Incidents on Several New Pipelines in 1st Year of Service –
– Industry needs improved material, construction, and operational QA/QC
• Differing Levels of “Acceptable Risk” with Different Audiences
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Verification of Records
PIPE DOCUMENTATION – Based on Code, Special Permit, and Operating Conditions
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Material Records
• Why are pipeline material records needed?
– To establish design and maximum operating pressures (MOP or MAOP)
– For integrity management (IM) programs
– Anomaly evaluations for safe operating pressure
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Records Management
• Materials must be manufactured in accordance:
– DOT referenced standards
– Able to maintain structural integrity of the pipeline:
• Operating pressure, temperature, and environmental conditions including outside force loads
• Fracture arrest for 80% SMYS pipelines
• Pipe Design
– Withstand external pressures and anticipated loads
– Designed for service and class location
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Records Management
• What are the first items looked at if a pipeline has an incident? Records!
– Material Records – pipe, fittings & fabrications, etc.
• QA and QC
– Standards – API, ASME, ANSI, MSS, and ASTM
– Tests – mechanical & chemical properties, welding, NDE, and hydrostatic test
– Design and Construction Records – Hydrostatic Test
– Operations and Maintenance Records
– Integrity Management Records
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Records Management
• What type pipe records are needed?
– For Design Formula and Maximum Operating Pressure
• Outside diameter
• Pipe wall thickness
• Yield Strength
• Weld Joint/Seam Type
– API 5L – pipe mill test report for new pipe also has….
• Chemical properties
• Tensile properties – yield and ultimate
• Hydrostatic test pressure
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
What pipe records are needed?
• Needs to be based upon Code, Special Permit and Service/Operating Conditions:
– 72% MAOP/MOP
• 192.105 or 195.106
– 80% MAOP/MOP
• 192.105 and 192.112 or Special Permit
• CE, Charpy, DWTT, Seam Hardness, Steel/Pipe UT, Marco Etch Tests, mill hydrotest pressure, seam weld tensile strength, etc.
– Fracture Arrest – Charpy, DWTT, etc.
– Strain Based Design – possible all of above
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
API 5L – 44th Edition Requirements Section 13 – Retention of Records
• hydrostatic-tester recorder charts or electronic;
• radiographic images for pipe inspection;
• non-destructive inspection by other methods where applicable;
• qualifications of non-destructive inspection personnel;
• radiographic images for jointer welds;
• repair welding procedure tests;
• heat and product analyses;
• tensile tests;
• guided-bend tests;
• CVN tests;
• DWT tests;
• records of any other test as specified in the annexes or the purchase order
• all welding procedure specifications (WPS) and welding-procedure qualification test records (WPQT/PQR) (see Annex A).
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Metallurgical & Pipe Test Report
• Needs to be based upon:
– API 5L
– Operator
– Code
– Permit, if any
– Operating Conditions
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Retention of Pipe Records
• Pipeline Operator for new pipelines:
– needs pipe records for Design, MAOP/MOP Determination, Operations and Integrity Management for the;
• “Life of the Pipeline”
• Based upon Code, Special Permit, and/or Operating Conditions/Parameters
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Why are material records needed?
• NTSB recommendation (San Bruno)
– delete the grandfather clause and require all pre-70 gas transmission pipelines be subjected to a hydrostatic pressure test incorporating a spike test.
• Act requires PHMSA to:
– direct gas transmission operators to provide verification that their records accurately reflect MAOP of Class 3/4 location and Class 1/2 HCAs
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
NTSB San Bruno Investigation
• Where were the pipe material records?
• NTSB Board Meeting August 30, 2011
• http://www.ntsb.gov/investigations/2010/sanbruno_ca.html
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Record Management Issues That PHMSA Has Seen!
• Unknown or unverifiable pipe specifications/mill test reports
• “Known” (but really unknown) information
• Project files not properly indexed or recallable – poor housekeeping.
• Incomplete or missing hydrostatic test records
• Lost records – acquisitions, mishaps
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Keep in Mind
• We all want safe operations
– Operators must know their systems, including risks and potential weaknesses.
• In San Bruno, we didn’t know??
• Suspect pipe, not meeting any standard.
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
PHMSA – Advisory Bulletin
• Advisory Bulletin (ADB) - ADB-11-01 – 01-10-11
– Titled: Establishing MAOP or MOP using record evidence, and integrity management risk identification, assessment, prevention, and mitigation. Docket No. PHMSA-2010-0381
– Reminded operators that records used to support MAOP and MOP determinations must be reliable, traceable, verifiable and complete.
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Adversary Bulletin (ADB)
• Directed to ALL pipeline operators – gas transmission, gas distribution and liquid
• Does NOT create any new records requirements
• Reminds operators of expectation that operational decisions are based on documented information
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
What does the ADB Require?
• The ADB information clarifies that adequate records should be:
– Traceable
– Verifiable
– Complete
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Traceable
• Traceable records are:
– clearly linked to original information about a pipeline segment or facility
Examples might include:
– Pipe mill records, purchase requisition or as-built documentation indicating minimum pipe yield strength, seam type, wall thickness and diameter.
• Records transcribed from original documents must have careful attention:
– Information from a transcribed record should be verified with complementary or supporting documents.
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Verifiable
• Verifiable records –
– information confirmed by other complementary, but separate, documentation.
• Two or more complementary records -
– positively linked can be used together as a verifiable record.
• A single record which has all needed information does not need a separate, complementary, document.
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Complete
• Complete records must include:
– a signature, date or other appropriate marking.
• Incomplete or partial records:
– not an adequate basis for establishing MAOP or MOP.
• If records are unknown, a more conservative approach is indicated.
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
PHMSA – Links
• PHMSA – Pipeline Technical Resources
– http://primis.phmsa.dot.gov/ptr.htm
• Advisory Bulletins
• Alternative MAOP (80% SMYS)
• Pipeline Construction Issues
• Low Strength Pipe
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
ERW Pipe Needed for PHMSA R&D Program at Battelle
Pipe with seam defects will be used in many tasks of the project including:
• Hydrotest Protocols to for ERW/FW Seams
– improve hydrotesting protocols and validate their practical utility.
• Defect Characterization: Types, Sizes, and Shapes
– bridge gaps in defect characterization in regard to types, sizes, and shapes
– improvements in the tools - ILI and hydrotesting
• Enhanced Detection and Sizing via Inspection
– work with vendors to improve the sensors, interpretive algorithms, and tool platforms in regard to ILI and ITDM to better ensure integrity
• Develop and Refine Essential Predictive Models and Quantify Growth Mechanism
– validate existing models and where gaps preclude validation refine or develop models needed to assess / quantify defect severity.
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
For R&D ERW Pipe Donations
• The source of the pipe will be blind to DOT PHMSA
• Please contact Battelle directly:
– Bruce Nestleroth
– 614-424-3181
• Battelle will pay freight charges
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U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Thank You
Steve Nanney [email protected]
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