What is the Future of Pipeline Integrity

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What is the Future of Pipeline Integrity

• SGA
• Integrity Management Workshop
• April 28, 2008
• John S. Zurcher
• Process Performance Improvement Consultants, LLC
• P-PIC

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2002 to 2006 Onshore Incidentswhich Resulted in
a Ruptures and Leaks
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Most Frequent IMP Violations

• 192.911 Elements of Program 73
• 192.917 Threat Identification 60
• 192.935 Prevention and Mitigation 32
• 192.933 Actions to Address Integrity 31
• 192.925 ECDA 28
• 192.905 HCA Identification 17
• 192.937 Continuous Improvement 17
• Based on approximately 350 NOA and NOPV Items

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192.911 Violations

• This paragraph is more general in its
  requirements. It seems that if the inspector was
  not sure what paragraph to cite, this paragraph
  was used.
• Common issues included
• Did not identify HCAs
• Did not have BAP or perform Risk Assessment
  Correctly
• Inadequate procedures or records
• Inadequate MOC and handling of changes to plan
• Inadequate QA and QC in the plan processes
• Did not follow the requirements of ASME
• One common issue is level of detail in the plan,
  Framework versus a fully developed IM Program

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192.917 Violations

• Integrating data was not sufficient
• Did not consider near neutral SCC
• Technical justification for not considering
  threats
• Data gathering a quality not addressed
• PM measures not driven by data
• Seam integrity not considered
• Did not employ look-back based on results

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192.935 Violations

• Prevention and mitigation measures not identified
• PM measures not evaluated for effectiveness
• No decision process for when to employ PM
  measures
• No process for how to select PM measures
• No documentation of PM measures
• PM measures did not include evaluation or
  determination for use of ACV or RCV

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192.933 Violations

• Did not provide for pressure reduction prior to
  and during examination
• Did not define Discovery of Condition time
  frame
• Did not have a work plan or schedule for
  remediation
• Immediate conditions not defined (SCC, etc.)
• Did not record dates of examination and repair
• Did not have plan for dealing with Monitored
  Conditions and future Risk Assessments

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192.925 Violations

• Documentation of all steps not complete
• Did not follow the NACE standard
• Did not examine pipe within reasonable time frame
• Did not include encroachment data in process
  steps
• Feasibility step not always done or not done
  first
• Documentation of tool selection
• Did not have more restrictive requirements for
  first time DA process use.

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192.905 Violations

• Public sources of information on identified sites
  not used
• Public officials not contacted
• No process to identify HCAs during routine OM
  activities such as patrolling
• HCA process was not adequate
• New HCAs not incorporated into BAP within one
  year

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192.937 Violations

• Reassessment intervals not determined
• Did not include near neutral SCC into plans
• Did not have provision for annual review of BAP
• Did not have process to select future assessment
  tools
• Periodic evaluations not based on risk assessment
• Inadequate documentation for periodic evaluation
• No provision to incorporate new information into
  risk assessment

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What are we not doing well ?

• Assessment results not consistent with what is
  found
• Vendor performance seems to vary significantly
• Tool performance seems to vary significantly
• Over digging the indications from assessments
• Spending too much money chasing indications that
  do not require mitigation
• Being very conservative in the performance of the
  program
• Still treating IMP as a pig-and-dig program
• Managing internal corrosion through gas quality
  criteria and enforcement

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What are doing badly ?

• Performing prevention and mitigation activities
  for the long term as part of the life-cycle of
  integrity management, taking credit for PM
  activities
• Keeping up with the year-to-year maintenance and
  capital replacement of facilities
• Looking at the three sides of integrity
  management
• ILI for determination of pipe condition
• Pressure test for determination of pipe strength
• Direct assessment to determine environment around
  the pipe
• Getting standards and regulations changed to
  reflect what we have learned over the past five
  years
• Changing the IMP program and plans to reflect
  what we have learned

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What is the Future of Pipeline Integrity ?

• Using IMP for Class Change Special Permits
• Using IMP for MAOP Special Permits
• Increasing the 7-year interval through Special
  Permits
• Guided Wave Technology Waivers
• Near-neutral SCC DA
• Dent with Metal Loss Criteria
• Cost Benefit information
• After the Baseline Assessments are more miles
  brought into the program?
• More tools and combined tools
• Determine the value of Risk Assessment after BAP