Embed Size (px)
Citation preview
TQ Presentation
Intro Slide
Tulsa, Oklahoma November 2014
2014 Oklahoma
Seminar
Contact Information Wayne St. Germain
Pipeline Safety Specialist
U.S. Department of Transportation
PHMSA Inspector Training and Qualifications
Email: [email protected]
Ph: 405-686-2315
Regulatory
Review Oklahoma Seminar
2014
Contact Information
Wayne St. Germain
Transportation Specialist
U.S. Department of Transportation
PHMSA Inspector Training and Qualifications
Email: [email protected]
Rulemaking Process
ANPRM – Advance Notice of Proposed Rulemaking
– Used to gather information (non-mandatory)
NPRM – Notice of Proposed Rulemaking
– Defines intent and scope, something required from
operator
SNPRM – Supplemental Notice of Proposed
Rulemaking
Rulemaking Process
FR – Final Rule
– Implementation date, 30 – 90 days depending on
significance of regulation
DFR – Direct Final Rule
– Used for non-controversial issues
Alert Notices &
Advisory Bulletins
Alert Notices - a notice of a situation of
immediate safety concern
Advisory Bulletins - an advisory not of
immediate safety concern
– matters that have potential to become safety or
environmental risks
Final Rule
September 25, 2013
Changes to 49 CFR 190 – Pipeline
Safety Programs
Increases in both civil and criminal penalties
($200,000)
Investigations, response options, hearings,
addresses and contact information,
Other administrative procedures
Notice
November 27, 2013
Random drug rate to remain at 25%
for calendar year 2014
2012 positive drug test rate was <1%
Reminder to submit information through
PHMSA portal
Information Collection Notices
April 1, 2014 - Revision to Operator Registry
April 28, 2014 - Revision to Gas Distribution
Annual Report
May 6, 2014 – Safety Related Conditions,
Abandoned Underwater Pipelines, Periodic
Underwater Inspections and Pipeline Safety
Program Certification
Information Collection Notices
June 26, 2014 – Public Awareness
July 1, 2014 – Revisions to Operator
Identification (OPID)
August 14, 2014 – Revision to Gas
Distribution Annual Report
Information Collection Notices
July 30, 2014 – Revision to National Pipeline
Mapping System Program
– Additional information will include spatial
mapping accuracy, MAOP, class location, pipe
information, construction data, commodity,
throughput and compressor locations
ADB 2014-02
May 6, 2014
Lessons Learned from Marshall,
Michigan Accident
NTSB identified deficiencies in the integrity
management (IM) program, control room
management and public awareness that
contributed to the release of hazardous liquid
ADB 2014-02
May 6, 2014
Lessons Learned from Marshall,
Michigan Accident
Operators should evaluate safety programs and
implement any changes to eliminate deficiencies
similar to the ones identified by the NTSB
Encouraged to review past and future NTSB
recommendations and proactively implement
improvements
ADB 2014-02
May 6, 2014 Lessons Learned from Marshall, Michigan
Accident
IM Programs More conservative approach to defects Better data integration, including re-analyzing
results because of new data Continuous reassessment process Performance measures and program evaluations
using ADB-2012-10 (Meaningful Metrics)
ADB 2014-02
May 6, 2014
Lessons Learned from Marshall, Michigan
Accident
Control Room
Periodic evaluations of leak detection capabilities
Regularly train control room teams, including training on
recognition of and response to emergencies and
unexpected conditions on SCADA or leak detection
software
Scheduling policies and practices against ADB-05-06
(Prevention of Human Fatigue in Control Rooms)
ADB 2014-02
May 6, 2014
Lessons Learned from Marshall, Michigan
Accident
Public Awareness
Analyze & evaluate the effectiveness of programs
Strong program shorten response
Local emergency response agencies prepared to identify
and respond to early indications of accident
Evaluate against API RP 1162, ADB 10-08 (Emergency
Communications) and ADB 12-09 (Communication
during Emergency Situations)
ADB-2014-04
September 18, 2014
This advisory bulletin describes specific notification
requirements and general O&M and integrity management
requirements as well as additional actions operators
should consider taking before, during and after flow
reversals, product changes, and conversion to service..
ADB-2014-04
September 18, 2014
PHMSA refers operators to detailed guidance published in
the document, Guidance to Operators Regarding Flow
Reversals, Product Changes and Conversion to Service,
which provides operators with PHMSA's expectations with
respect to complying with existing regulations and also
contains recommendations that operators should consider
prior to implementing these changes..
ADB-2014-04
September 18, 2014
The document addresses flow reversals, product changes
and conversion to service individually. The document is
located at:
http://phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles
/Pipeline/Regulations/GORRPCCS.pdf.
The Pipeline Safety,
Regulatory Certainty, and
Job Creation Act of 2011
Signed January 3, 2012
Funds programs of the Pipeline and Hazardous Materials Safety Administration (PHMSA) through fiscal year 2015.
Addresses National Transportation Safety Board recommendations resulting from recent pipeline incidents
Reauthorization
Fines
Maximums increased to $200,000 and
$2,000,000. (Amdt 190-16, Oct 25, 2013)
HCA Emergency Response Time
Comptroller General report due in 2013.
Reauthorization
Automatic / Remote Shut Off Valve
Regulations to require for new (or replaced)
transmission lines by 2014.
Study completed October, 2012
Available at: www.phmsa.dot.gov/staticfiles/PHMSA/Downloadabl
eFiles/Files/Press%20Release%20Files/Final%20Val
ve_Study.pdf or
primis.phmsa.dot.gov/meetings/DocHome.mtg?Mtg=
80
Reauthorization
Integrity Management (ANPRM and NPRM)
Expanding IMP requirements outside
HCA’s
Report due 2014 to include evaluation of
public safety enhancement, risk reduction
and incremental cost factors.
Reauthorization
Leak Detection (Liquids) Study Completed http://www.phmsa.dot.gov/pv_obj_cache/pv_obj_id_4A77C7A89CAA18E285898295888E3DB9C5924400/filename/Leak%20Detection%20Study.pdf
Evaluation of limitations of current technology.
Establish standards for capabilities of leak detection systems?
Findings / future rulemaking?
Reauthorization
Accident and Incident Notification
Post discovery, one hour maximum time to
notify NRC. (ADB-2013-01)
Note:
NRC is currently not allowing on-line filings
Changes to system may lead to long wait time
for telephonic reports
Pending Rulemaking
Eight (8) of the nine (9) rulemakings are
expected to be designated significant
Significant rules require review by
PHMSA, OST, OMB before publication
Rule Process
Significant vs Non-Significant Rulemakings
– Annual effect on the economy of ≥$100 million
– Create serious inconsistency, or with another agency
– Materially alter the budgetary impact of entitlements,
grants, user fees, or loan programs or the rights and
obligations of recipients thereof; or
– Raise novel legal or policy issues arising out of legal
mandates, the President’s priorities, or the principles
set forth in this Executive order.
- 29
-
Pending Rulemaking
Safety of on-shore hazardous liquid pipelines
(NPRM stage)
Excavation Damage Prevention (Final rule
stage)
Excess flow valves (EFVs) beyond single family
residences (NPRM stage)
Changes to forms, including gas distribution
incident and annual reports
Miscellaneous Gas Rule
– Several amendments based
on petitions, NAPSR
recommendations and other
initiatives
– Post construction inspections, plastic pipe joiner
qualification, welding definitions, Type B line
leak surveys
– Published November, 2011
– Final Rule stage
Plastic Pipe
Covers materials and fittings, design
factors and tracking and traceability
Notice of Proposed Ruling (NPRM)
stage
OQ, Cost Recovery and Other
Changes
Cover OQ for new construction, incident
reporting, cost recovery and special
permit renewal
NPRM stage
Gas Transmission and Gathering
Lines
Expansion of IM requirements outside
of HCAs, repair criteria, assessments,
corrosion control, integrity verification
process (IVP)
Based on NTSB
recommendations
NPRM stage
Rupture Detection and
Valves
Establish and define rupture detection
and response times, use of automatic
shutoff and remote controlled valves
Based on NTSB recommendations
NPRM stage
Standards Update
Incorporated by reference (IBR)
standards
–Impact 22 of IBR standards
Final Rule stage
IBR Documents
Incorporated by Reference (IBR)
Section 24 of Reauthorization addresses issue of
incorporated by reference documents
Public Meeting – Incorporating by reference
consensus standards unless available free of charge
to the public on the Internet
Modified to available for free
Access to safety
standards
PHMSA negotiated agreements with: – American Petroleum Institute (API)
– American Gas Association (AGA)
– American society for Testing and Materials (ASTM)
– Gas Technology Institute (GTI)
– Manufacturers Standardization Society of Valves
and Fittings Industry, Inc. (MSS)
– NACE
– National Fire Protection Association (NFPA)
Should or May
Shall or Must
Incorporated by Reference documents,
“should” is “must” unless written
justification why not
practicable/necessary for safety
Enforcement Guidance
Various enforcement
guidance is available at:
http://phmsa.dot.gov/
foia/e-reading-room
Includes O&M, OQ,
Corrosion, IM, Public
Awareness
Enforcement Guidance Enforcement
Guidance
O&M Part 192
Revision Date
09-28-2011
Code Section
§192.703
Section Title
General
Existing Code
Language
(a) No person may operate a segment of
pipeline, unless it is maintained in
accordance with this subpart.
(b) Each segment of pipeline that becomes
unsafe must be replaced, repaired, or
removed from service.
(c) Hazardous leaks must be repaired
promptly. Origin of Code
Original Code Document, 35 FR 13248, 08-19-
70 Last
Amendment
Interpretation
Summaries
Interpretation: PI-ZZ-065 Date: 05-22-1998
The only safety standard in Part 192 that governs the
maintenance of service line valves is §192.703(b).
This section requires the repair, replacement, or
removal from service of any segment of pipeline,
including a valve that is unsafe. Although the
inability to operate a service line valve may be
reason to apply §192.703(b), Part 192 does not
require inspection of service line valves to see if they
are operable.
Interpretation: PI-89-021 Date: 09-27-1989
The letter requested clarification of our August
31, 1989, letter regarding protection for offshore
pipelines. The requirements of 49 CFR
192.317(a) applies to conditions known or that
can be foreseen at the time of construction.
Thereafter, an operator does not have a
continuing obligation under this rule to provide
protection against hazards from changed or new
conditions. However, if the operator learns the
pipeline has become unsafe due to these
changed or new conditions, the operator would
Advisory
Bulletin/Alert
Notice Summaries
Other Reference
Material
& Source
GPTC Guide Material is available.
Guidance
Information
1. Operators need to repair of conditions that are
"unsafe" or "could adversely affect the safe
operation of [the] pipeline system," but do not
specify a time period in which the required repairs
must be made.
2. Operator needs to define hazardous leak. Part 192
Subpart P defines hazardous leaks. While this
definition is only applicable to distribution
systems, it may provide guidance for defining
hazardous leaks. See §192.711 for additional
guidance material.
3. Operator needs to have a leak classification
system if all leaks are not repaired promptly.
4. Operator needs to have written procedures for
leak classification and defining required repairs
including time frames for performing repairs.
5. Operator must have a process for documenting
leaks.
Examples of a
Probable
Violation
1. The lack of a procedure is a violation of
§192.605.
2. The lack of records is a violation of §192.603.
3. The operator did not follow written procedures.
4. Operator does not have a leak classification
process.
5. Pipelines known to be unsafe are not repaired.
6. Operator did not perform repairs in a timely
manner or in accordance with their procedures.
http://phmsa.dot.gov/pipelin
e/tq
Includes terms
defined in code and
interpretations
Technical documents
and other IBR
sources
PHMSA Information
Websites PHMSA Training and Qualification
http://www.phmsa.dot.gov/pipeline/tq
PHMSA Pipeline Safety Regulations
http://www.phmsa.dot.gov/pipeline/tq/regs
PHMSA Rulemaking
http://www.phmsa.dot.gov/pipeline/regs/
rulemaking
Outstanding Issues
Construction
Issues
Cured In Place Liners - FAQ
Construction Issues
Coatings
51
Patch Stick Issues
Heating the patch stick and dripping
the product on the coating holiday is
not acceptable.
Fingernail scratched
off applied
patch stick
repair
Good patch stick application - notice
heated/discolored area around patch, this indicates
that the pipe was heated before and during patch
stick application
Patch Sticks are only
for pinhole or abrasion
repair. 2 part epoxy
should have been used.
56
57
2 part epoxy
Follow manufacturers instructions
Preparation required (Sanding = anchor pattern)
Thoroughly mix product
Use promptly
If products starts to cure before application
the repair presents the appearance of the
next slide
2 Part Epoxy
DCVG Dig on First Phase
Disbonded girth weld coating –
poor surface preparation
DCVG Dig on First Phase – Girth Weld
Coating Mixed with Backfill
Wet Epoxy Mixed with Backfill
Electronic Holiday Detection
(Jeeping) Visual inspection must supplement jeeping
Problems identified
- Bent defective spring.
- Not identifying and repairing all “jeeps”
- Passing over visible holiday without the jeep sounding
- Based on experience, jeep voltage may need to be set as high as 3500v to detect coating defects
Are the workmen finding coating holidays? Do the
workmen operating the jeep have time to find and repair
coating holidays?
66
Manipulating the jeep
spring over building
fiberboard stuck to the
pipe is poor practice
67
Just jeeping at skids only on lowering in is not usually per
construction procedures
69
A bent jeep spring can miss coating holidays
70
71
Duct tape can shield coating holidays
72
Manipulating
the jeep spring
over building
fiberboard
stuck to the
pipe is poor
practice
73
Just jeeping at skids only on lowering in is not usually per
construction procedures
74
Look for
coating
holidays in
the ditch.
Observing
these
indicates a
problem.
75
76
Thin Film Epoxy Issues
Insufficient heating (3M procedure specify 425 –
488 degrees F - lower temperatures could mean
improper curing)
Over heating during application can be a problem
(the coating looks burnt and is unacceptable)
Poor sandblasting
425°F to 488°F
Girth Weld Coating
81
Is there water in the pipe? = no coating
coverage
82
Rock – Padding – Rock Shield
Record area where RS applied
83
84
87
Gouges and Bending
Gouges – consult procedures
Acceptable wall thickness?
< 1% diameter?
88
Proper burial depth on bores?
89
Is the pipeline buried deep enough and
protected from erosion?
90
High Mechanized Defect Rate
Causes
Pipe sizing issues
Inexperienced welders
Start up issues
X-ray or AUT falling behind eliminates timely
feed back. Feed back is a valuable tool to
improve weld quality.
91
The welding procedure allows how much high-low?
92
High Mechanized Defect Rate
PHMSA Concerns:
Having defects not an issue.
Defect repair, NDT and tracking is an issue.
Industry experience usually shows
- 2 – 10% defect rate on mechanized welding
- 2 – 7% for semi-automatic welding
- 2 – 5% on manual welding
93
Laminations can be an issue especially associated with an
80% waiver
94
AUT easily shows laminations
95
Preheat
Heating the weld joint before welding
Temperature of the weld joint immediately before
the arc is struck.
Procedures state Contact Pyrometer, or
Temperature Indicating Crayon
Range of preheat values found in the welding
procedure
96
Use of Temperature Indicating Crayon
Temperature indicating crayons (Tempilstik) are specially formulated to melt at a specific temperature.
On a cold pipe surface upon heating the mark changes color and melts at the specific temperature
Used on a hot surface the crayon only indicates the temperature is greater than the specified temperature on the crayon if the crayon melts
Applying the crayon on an area adjacent to a weld joint and then heating with a propane torch directed on the mark will give a false temperature indication. In this case the flame heats the crayon mark faster than the pipe. The pipe will not be up to the required temperature.
The crayon should be used after heating and two different temperature crayons may be necessary to determine the preheat is within the welding procedure.
97
Temperature Indicating Crayons
The crayon holder
specifies the melt
temperature.
99
Interpass Temperature
The temperature at a location near the start position of the welding arc(s) recorded immediately before initiating consecutive pass or passes. (from Appendix A)
Minimum Interpass Temperature – generally preheat temperature
Maximum Interpass Temperature – highest temperature allowed to start welding.
101
Must follow welding procedure
Some items to check
– Bevel configuration
– Electrodes – rods – filler metals
– Electrical parameters
– Speed of travel
– Weld dimensions
102
Welding Procedures The procedure states 20 – 40 cfh shielding gas flow rate. Does
the photo show an acceptable value? (No)
103
Electrical Characteristics
Values displayed on welding machines should be within the range of the WPS.
Machine is not calibrated but usually close.
If outside procedure use calibrated clamp-on.
Welding
procedure
required
250°F
preheat
106
Band Damage
Welding Band Damage to Coating
Inspection Requirements
Large variation in inspector competency
What are the inspectors responsibilities?
– Welding inspector must be knowledgeable and
competent
– Verify welding procedure is followed
– Observe
– Document
– Report
– Correct
– Work stoppage
– Not fall asleep in the pickup truck
108
109
Image Quality Indicators
110
Image Quality Indicators (Penetrameters)
PHMSA (OPS) recognizes the 20th editions of API 1104. The
20th edition only allows the use of Wire Type Image Quality
Indicators.
111
Refer to Table 5 API 1104 20th Edition
Weld Thickness Essential Wire Diameter ASTM Set
Inches Inches Letter
0–0.250 0.008 A
> 0.250–0.375 0.010 A or B
> 0.375–0.500 0.013 B
> 0.500–0.750 0.016 B
> 0.750–1.000 0.020 B
> 1.000–2.000 0.025 B
112
ASTM E 747 IQI
Wire Sizes for A – B Packets
SET A SET B
0.0032 0.010
0.004 0.013
0.005 0.016
0.0063 0.020
0.008 0.025
0.010 0.032
113
ASTM Type B Packet
The complete outline of the essential wire must
be visible and not obscured by number belt.
114
Is the radiographic density per API 1104
or operator’s procedures?
115
Radiographic Requirement
Both Parts 192 and 195 require a certain percentage
(based on location or class location) of welds be
nondestructively tested and that a percentage of a welders
daily work product must be nondestructively tested.
If the radiographs’ image quality indicators are not
acceptable, or the radiograph is unacceptable, then there
may be insufficient numbers of radiographs to meet the
percentage and/or daily requirements of the applicable
code.
Radiographic Problems Identified
Poor radiograph technique - so bad minimum % could
not be achieved
Poor radiograph developing practices
Fogged Film and/or artifacts
Radiographs too dark or light – Density (H&D) out of
operator’s specification or API specification
Improper or poor radiographic interpretation
Missing one or more segments of the weld radiograph
Segments of radiographs do not overlap
Missing radiographs when compared to weld maps
Radiographic Problems Identified continued
No repair radiograph
Radiographed wrong defect area (multiple repairs)– should
be able to match up unrepaired areas of repair radiograph to
original radiograph
Numbering irregularities (Changed numbers with magic
marker)
Radiographing same weld twice or multiple times and
changed weld identification numbers
IQI issues – essential wire not visible
Poor radiographic technique used on transition welds –
especially if there is a large difference in thickness
.
Facility Locations Welds
>6”
# films poor
quality # require
repair
# duplicated
Location1 357 52 5 0
Location 2 1093 147 8 0
Location 3 333 55 4 0
Location 4 346 131 11 0
Location 5 310 20 9 0
Location 6 823 106 8 0
Location 7 895 26 4 0
Location 8 215 14 3 0
Location 9 716 16 0 0
Location 10 139 16 0 0
Location 11 139 54 0 53
Location 12 391 83 3 9
Location 13 150 43 3 0
Location 14 526 77 4 0
Location 15 913 144 29 21
Location 16 1400 187 9 141
Location 17 1126 486 17 89
Anomaly Dig
Pipe on Solid
Rock
DCVG Dig on First Phase
Disbonded girth weld
coating – poor surface
preparation
DCVG Dig
15 Holidays
DCVG Dig
DCVG Dig on First Phase – Girth Weld Coating Mixed with Backfill
Wet Epoxy
Mixed with
Backfill
Specificity and details
for
written procedures
Would you order
Strawberry?
Cherry?
Raspberry?
Cinnamon?
Red Velvet Cake?
Or . . .
Would you
Just order RED?
Mosquito?
Flea?
Or . . .
Spider?
Hyppopotamus?
Details
Who
What
When
Where
Why
How
Other information to provide clarity
the plans should be an outline for compliance.
They should either say what you do
or,
You should do what they say
Either way you will be in compliance with your own procedures
Example:
Only the right combination of specificity and detail will provide what we essentials to achieve these goals and give us the compliance we want and need.
Other things that add specificity, detail and clarity
Flowcharts, Drawings and photos
Tables
Definitions
References to DOT codes
Other things that add specificity, detail and clarity
References to other Company Manuals or Plans that contain more details and specificity
Corrosion
Safety
Measurement
Design
Example:
“The incident needs to reported to the pipeline controller.”
Rewritten.
The first employee having knowledge of the emergency and/or arriving on the emergency scene will report incident information within 15 min. of notification and/or arriving at the site, to the pipeline control center by telephone or company radio.
KEY WORDS
Be
Is
Are
A
Was
Were
Has been
Have been
Will be
Being
Example:
Extensive training on the new safety procedures is required to be attended by the maintenance staff.
Rewritten.
The entire maintenance staff is required to attend extensive training on the new safety procedures from 8 -11 a.m. next Monday in the Welding Shop.
Correct the following five sentences to practice changing passive to active voice.
1. Hunger was what Bill felt.
2. Reading is enjoyed by Mary.
3. The town was destroyed by fire.
4. Funny is what clowns are.
5. Cheese was liked by Sara.
Hunger was what Bill felt.
Bill felt hungry. (Bill is the subject, felt is the action)
Reading is enjoyed by Mary.
Mary enjoys reading (Mary is the subject, enjoys is the action)
1. Reading is enjoyed by Mary.
The town was destroyed by fire.
Fire destroyed the town (Fire is the subject, destroyed is the action)
1. Reading is enjoyed by Mary.
Funny is what clowns are.
Clowns are funny (Clowns is the subject, funny is the action)
1. Reading is enjoyed by Mary.
Cheese was liked by Sara.
Sara likes cheese (Sara is the subject, likes is the action)
1. Reading is enjoyed by Mary.
Problems can occur with operators who fall back on specifics in their OQ Plan to avoid the specifics in their O&M.
Although OQ Plans have specifics, they are not usually available onsite for verification by inspection personnel during O&M activity inspections or emergencies;
hence the need for a certain level of specificity and detail in the O&M and Emergency plan procedures
Remember in the end,
The plans should either say what you do
or,
You should do what they say
Either way you will be in compliance with your own procedures
