Gas Transmission Integrity Management Inspection Lessons Learned

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Gas Transmission Integrity ManagementInspection
Lessons Learned

• Zach Barrett
• PHMSA Office of Pipeline Safety

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Gas Transmission Integrity ManagementInspection
Lessons Learned

• Identified Inspection Issues

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Inspection Results

• HCA Identification operator did not take into
  account mapping inaccuracies
• Mapping inaccuracies may be as much as plus or
  minus 500 ft. or as little as a few feet.
• Looking for operators to take a conservative
  approach to assure mapping tolerances will not
  result in HCAs not being identified.
• 192.905(a) (See FAQ 174)

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Inspection Results

• HCA Identification - Operator did not contact
  public officials for locating identified sites.
• Rule requires that public officials be contacted
  not optional
• Must Provide Public Officials with Appropriate
  Data to Provide Identified Site Information
• 192.905(b)(1)

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Inspection Results

• HCA Identification - Operator did not bound the
  HCA from the outside of the first circle to the
  outside of the last circle meeting the HCA
  definition.
• 192.903(3)
• HCA Identification Operator did not document
  their use of Method 1 or Method 2 for identifying
  HCAs along their pipeline system.
• 192.905(a)

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Inspection Results

• HCA Identification - Operator did not document
  their completion of identifying HCAs by December
  17, 2004.
• 192.907(a) FAQ 14
• Operator using method 1 (Class Location) did not
  look for identified sites in Class 12 locations
• 192.903(1)(iv)

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Inspection Results

• Terminology of New HCA is being inappropriately
  used for labeling recently found HCAs due to
  errors during initial HCA identification efforts.
• Characterization of these HCAs as New is
  inappropriate since these HCAs existed, and
  should have been identified, prior to 12/17/2004.
• 192.905(c)

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Inspection Results

• Threat Identification - A formalized technical
  justification was not available for the
  elimination of a potential threat
• A documented technical justification is necessary
  for a HCA not to be considered susceptible to a
  given threat.
• This should be based on factual data and not on
  assumptions (We Never Had a Failure Due to This
  So We Never Will)
• If data does not exist to exclude a threat it
  must be included for assessment
• 192.917(a-e) 192.947(d)

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Inspection Results

• Threat Identification Consideration was not
  given to the interactive nature of threats in
  Risk Assessment.
• 192.917(a) B31.8S Section 2
• This is the number 1 issue cited.

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Inspection Results

• Threat Identification - Operator did not
  integrate excavation damage indications with
  assessments to address the third party damage
  threat.
• Foreign Line Crossings
• Top Side Dents not on previous surveys
• Earth disturbed over pipeline identified during
  Direct Assessment Surveys
• 192.917(e)(1)

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Inspection Results

• Key decisions not well documented
• Changes to BAP, Risk Ranking and Risk Weightings
• 192.947 (d)

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Inspection Results

• Operator did not provide justification for not
  excavating and evaluating immediate repair
  conditions from ILI Indications within 5-days.
• Referenced from 192.933 - ASME B31.8S Section
  7.2.1 requires the evaluation to be completed in
  5-days additional time may be taken to affect
  repairs if a pressure reduction is in place.
• 192.933(c)

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Inspection Results

• Operator did not include immediate conditions in
  Section 7 of B31.8S referenced by 192.933
• Metal loss on a longitudinal seam (direct
  current, low frequency weld, or flash weld)
• 192.933(d)(1)

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Inspection Results

• Operator had not developed methodology to receive
  timely results of possible immediate conditions
  from ILI vendor
• Discovery is when adequate information about a
  condition is obtained to determine that the
  condition presents a potential threat to the
  integrity of the pipeline
• Preliminary reports from ILI Vendors can often
  provide adequate information without waiting for
  a Final Report
• 192.933(b)

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Inspection Results

• The calculation of safety factors and response
  times using ASME B31G or RSTRENG is not valid for
  conditions with greater than 80 wall loss. Such
  anomalies require response as immediate
  conditions
• 192.933(d)(iii)

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Inspection Results

• Failure to include ILI tool inaccuracies when
  determining immediate conditions under 192.933.
• See FAQ 68

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Inspection Results

• Operators did not address consequences in the
  risk analysis
• In order to organize integrity assessments for
  pipeline segments of concern, a risk priority
  shall be established. This risk value is
  comprised of a number reflecting the overall
  likelihood of failure and a number reflecting the
  consequences. (ASME B31.8S Section 5.5)
• 192.917(c) FAQs 22, 78, 81, 83, and 172

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Inspection Results

• Preventive and Mitigative Measures must be
  implemented promptly. An Operator may have
  enough information based from data gathering and
  integration. (Do not wait until all baseline
  assessments are complete.)
• 192.935(a) FAQ 90

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Inspection Results

• Failure to provide a notification if using Direct
  Assessment for Near-Neutral SCCDA or Wet Gas ICDA
  as there are no code sections or referenced
  standards covering these threat assessments (New
  technology)
• 192.921(a)(4) 192.923(b) FAQ 127

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Inspection Results

• Criteria of acceptance was not established for
  quality assurance program
• 192.911(l) B31.8S Section 12.2

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