That is because the Pipeline Hazardous Materials Safety
Administration (PHMSA) has regulation pending that will
require operators to verify the records they use to establish
and support the maximum allowable operating pressure
(MAOP) of pipelines in high and moderate consequence areas.
1
In addition, PHMSA has announced its intention to eliminate a
grandfather clause that has allowed gas transmission operators
to rely on historical data for establishing the MAOP of pipe
installed before 1970.
As a result, operators will have to perform what is
essentially a comprehensive pipeline genealogy project in
order to meet the upcoming regulations. Included will be
validating and documenting the mechanical properties – such
as construction materials by grade and specification, yield
strength and tensile strength – of all pipelines located in high
and moderate consequence areas, regardless of when they
were built.
But how will they find out what they do not already
know? Unlike curious family members, pipeline operators
cannot just search the industrial equivalent of a genealogical
database. But to get to the information they need, there is
an alternative as unobtrusive as a DNA cheek swab: non-
destructive positive materials identification (PMI) technology
used as part of a complete integrity verification process (IVP).
A call for ‘traceable, verifiable, and complete’
records
Like any number of governmental regulations that arose
from a public safety concern, PHMSA’s pending rules were
motivated by an accident, and a catastrophic one at that:
a deadly explosion and fire caused by the rupture of a gas
pipeline in the state of California.
In the US, the National Transportation Safety Board
(NTSB) is among the first on the scene to investigate the
cause of significant pipeline incidents as well as aviation,
railroad, highway and marine disasters. During the course of
their inquiry into the California pipeline failure, the NTSB
found that a ruptured section of pipe had been identified
on the as-built drawings as seamless when it was actually
longitudinally seam-welded, which meant the pipeline was
being operated outside of its original design criteria. The
NTSB subsequently recommended that operators establish
pipeline records if none existed in order to verify that
operating conditions are within the specifications of the line
configuration – a recommendation that PHMSA is upgrading
to a regulation.
In its advisory bulletin (ADB-2012-06) regarding the
pending regulation, PHMSA states that operators “must assure
that the records are reliable” when calculating MAOP and that
“these records shall be traceable, verifiable, and complete.”
PHMSA defines verifiable records as those “in which
information is confirmed by complementary, but separate,
documentation.” The agency also said that operators may
need to conduct other activities such as in-situ examination,
measuring yield strength, and non-destructive evaluation
(NDE) or otherwise verify the characteristics of the pipeline
to support a MAOP or maximum operating pressure (MOP)
determination.
“Traceable, verifiable and accurate recordkeeping in the
pipeline world is crucial,” PHMSA Administrator Cynthia
Quarterman said when she announced the pipeline verification
advisory in 2012. “It enables us to respond more quickly in the
event of an emergency, as well as gives us a more accurate
snapshot of the overall infrastructure.”
Early adopters prepare ahead of the proposal
becoming a mandate
Response to the advisory has, naturally, been mixed. Some
operators and organisations have jumped immediately onto
the bandwagon, determined to have their records in place
before the proposed regulation becomes a mandate in 2015.
Others remain in wait-and-see mode.
The Interstate Natural Gas Association of America
(INGAA), a nonprofit trade association whose members
represent about two-thirds of the natural gas transmission
pipelines in the US, is encouraging early adoption.
In a statement, INGAA said that its members have
“committed to a systematic validation of records and
maximum allowable operating pressure for their pipelines
in highly populated areas that predate federal regulations.
INGAA members are developing a process to demonstrate
traceable, verifiable and complete records with examples of
the types of records.”
But beyond the essential importance of complying with
regulations, there is additional value to understanding pipeline
properties.
For example, in a response to PHMSA’s 2011 Pipeline Safety
Report to America, metallurgist Kenneth Kraska says that
Figure 1.
Understanding who and what is affected by PHMSA’s
IVP.
Figure 2.
Data samples identified by PMI techniques.
26
World Pipelines
/
JUNE 2015
