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Integrity Management Continuous Improvement
Fitness For Service and Management of Pre-Regulation Pipe
Chad ZamarinChief Operating Officer
NiSource Midstream Services
For:Gas Pipeline Advisory Committee
December 13, 2012
What Is Fitness For Service (FFS)?
The ability of a system or component to provide continued service, within established regulations and margins for safety•Well-accepted approach to evaluate condition of a system or component to determine acceptability for continued operation•Applied in petroleum refining, petrochemical, pulp and paper, nuclear, coal and gas-fired electric power industries•One of the first acknowledged threat specific applications was in the pipeline industry
B31G, a method for calculating the remaining strength of pipelines in areas with metal loss, first published in 1984
Fitness For Service (FFS) for pipelines
Disciplined approach to assessing the condition of a pipeline component or system to demonstrate safety and reliability•Not a bypass for strong regulations – in fact, a basis for strong regulations•Process focused•Based on sound engineering•Numerous examples within existing regulatory framework
Alternative MAOP (liquids and gas) ERW Seam Integrity Threat specific integrity assessment Defect specific engineering critical assessment (ECA)
4
“Traceable, verifiable and complete”
Significant Focus on Records and MAOP
• PHMSA Advisory Bulletins• NTSB Recommendations• California MAOP Order
MAOP impacts numerous key functions• Understanding MAOP and related properties are critical to operating a safe
pipeline system
Gas Control
Facility Planning FERC Compressor
Measurement & Regulation
Project Mgmt
Pipeline & Corrosion Operations
Integrity Mgmt
Technical Data /
Geographic Data
Systems
•SCADA set points and alarms•System
operation
•Capacity & through-put to meet market demand•Modeling
analysis
•FERC certificated MAOP for pipeline
•Shutdown set points for compressor units•Operation of
compressor units
•Set points for over-pressure protection•Type of over-
pressure protection selected
•Pipeline design, construction & qualification testing requirements for new or replacement pipes•Safety measures
taken during maintenance, construction or anomaly investigations
• Jurisdictional gathering line determinations•RSTRENG or
other remaining strength calculations•Load and other
calculations•May influence
defect repair methods•CIS frequency
based on risk•May impact
areas considered active corrosion zones
•Pipeline operations, type & frequency of maintenance activities•Recordkeeping
associated with pipeline•Safety measures
regarding defects, excavation, public safety, etc.•Emergency
measures & planning•Pipeline isolation
and valve design
•Determining HCA areas based on PIR calculations•May impact
ability to pig pipeline•Failure pressure
calculations for anomaly indications•Risk calculated
for the pipeline
•Outcome of Class Locations determinations•PIR calculations•MAOP data in
GIS
Recognized need to define and implement a “fitness for service” protocol for pipelines built prior to regulations •Develop and apply guidance, including a process for systematically validating records and the MAOP. •Process will address NTSB recommendations and PHMSA advisory to demonstrate traceable, verifiable and complete records•Where records do not meet this standard, a process will include MAOP validation protocol to be applied within a defined period of time
INGAA CommitmentsFitness For Service for Pre-Regulation Pipe and MAOP Validation
Fitness For Service for Pre-Regulation Pipe and MAOP Validation
• Augmenting risk assessment and threat management to address material threats more aggressively for previously untested pipe.
• Where traceable, verifiable and complete records exist to establish MAOP, and there is a pressure test to 1.25xMAOP, continue to operate under 49 CFR 192.
• Where records are incomplete, or if the pressure test does not meet above criteria or there is no historical pressure test, apply FFS Process For Managing Pre-Regulation Pipe.
• Where records do not exist or are incomplete for a segment containing short sections of pipe in a replacement project or tie in of a line or appurtenance prior to the Federal regulations coming into effect, assign the segment as a high priority for hydrostatic pressure testing, direct examination and testing or replacement (San Bruno Provision – High Priority Slide 13).
• Evaluate use of historical pressure tests and piggability
• INGAA is working with AGA, API, AOPL and research community to develop ILI technology to evaluate material and construction threats in lieu of hydrostatic pressure testing.
Process for Traceable, Verifiable and Complete Records
Locate RecordsLocate Records
Are ThereGaps In Data?
Are ThereGaps In Data?
Compile DataCompile Data
Verify DataVerify Data Document GapsDocument Gaps Are GapsResolved? Are Gaps
Resolved?
Link To Data Base and Retain
Link To Data Base and Retain
Apply MOC In Changing Records
Apply MOC In Changing Records
Define Means To Resolve Gaps
Define Means To Resolve Gaps
Lack of Pressure Test Meeting 1.25xMAOP -
Apply Process For Managing Pre-Regulation Pipe
Yes
No Yes
No
Valid DataValid Data
Traceable, Verifiable and Complete Record
Guidance
Process For Managing Pre-Regulation Pipe
• Legislation included an MAOP / records requirement, broad stakeholder need• INGAA commissioned workgroup focused on records and MAOP• Broad Industry
Involvement• Operators are already
aggressively researching their systems
Fitness For Service for Pre-Regulation Pipe and MAOP Validation
Process For Managing Pre-Regulation Pipe
• FFS Process based on prior precedent – hazardous liquids regulation• Highest risk pipelines likely
require pressure test if records are not available
• Medium risk pipelines will require test or equivalent measure on longer timeline
• Continue operating low risk pipelines under current regulations
Fitness For Service for Pre-Regulation Pipe and MAOP Validation
Process For Managing Pre-Regulation Pipe
Discussion Draft – Work In Progress
Fitness For Service for Pre-Regulation Pipe and MAOP Validation
Risk Based Alternative
Risk Based Alternative Draws From Approach Used for Hazardous Liquid Pipelines at 49 CFR 195.303
LF-ERW is low frequency electric resistance welded; EFW is electric fusion or flash welded; and JF is joint factor as defined at 49 CFR 192.113
Process For Managing Pre-Regulation Pipe
Discussion Draft – Work In Progress
Fitness For Service for Pre-Regulation Pipe and MAOP Validation
Technical LeadMark Hereth
Managing DirectorBlacksmith Group/P-PIC
Executive ChampionChad Zamarin
Chief Operating OfficerNiSource Midstream Services
FITNESS FOR SERVICE FOR PRE-REGULATION PIPE AND MAOP VALIDATION
