Mounting regulatory pressure and persistent resource constraints are escalating pipeline integrity challenges to new heights, prompting pipeline operators across the U.S. to rethink traditional approaches to integrity assessment and management.
More stringent federal pipeline safety regulations—promulgated by the U.S. Department of Transportation (DOT) to implement the Pipeline Safety Improvement Act of 2002 (PSIA)--have begun kicking in, requiring more U.S. natural gas, crude oil and hazardous liquids pipeline operators than ever before to perform baseline integrity assessments of their pipeline systems using prescribed and costly inspection and testing methods. The new rules also require owners and operators of regulated pipelines to verify the integrity of their system more frequently. Proof-of-integrity requirements are especially rigorous for pipeline systems in so-called high consequence areas (HCAs), where the potential danger to public safety and the environment are greatest.
Straining to Comply
Coming at a time when surging domestic oil and gas activity is spurring high rates of throughput and expansion of pipeline gathering, transportation and distribution capacity, many pipeline operators are straining to find the right tools and experienced people needed to comply with the new pipeline integrity paradigm within the mandated timeframes. Assuring that compliance measures implemented for any given pipeline are appropriate, effective, and auditable can be a challenge in its own right, because requirements and compliance deadlines vary depending upon the substances put through a given pipeline system, the system’s specific function, and its location.
Understandably, pipeline companies of all shapes and sizes--even large integrated energy companies that have carried out comprehensive pipeline integrity management (PIM) programs for many years--are questioning the adequacy of current integrity-testing methods for satisfying the new federal requirements.
Complex New Requirements
DOT rules require a pipeline operator to use the best-suited assessment methods to identify anomalies associated with specific integrity threats on each segment of his pipeline system. In addition, pipeline operators are required to evaluate the reliability of any in-line assessment method selected, including its detection sensitivity; anomaly classification, sizing, and location accuracy; requirements for direct examination; its ability to inspect full length and full circumference of the segments to be assessed; and ability to indicate the presence of multiple cause anomalies.
DOT in many cases specifies in-line inspections using smart pigs as the preferred method for assessing pipeline integrity. Certainly, smart pigs at the beginning of the 21st Century are much more capable than smart pigs of just a decade ago; they can be equipped with more capable tools and instruments and configured in more ways to achieve optimal results in many different circumstances. However, not all pipeline operators have experience determining which smart pig tools or configurations are best suited for their needs.
To speed compliance with increasingly demanding federal pipeline safety and environmental rules, more pipeline owners and operators are beginning to outsource pipeline integrity assessment, maintenance and reporting activities to full-service, integrated, turnkey pipeline operating and maintenance (O&M) companies, such as EMS USA, which literally can provide every service a pipeline operator needs to comply with DOT integrity requirements.
Conducting Smart Pig Surveys
An effective smart pig survey begins with proper pre-run planning. To determine the optimal smart pig configuration, it is crucially important to consider the characteristics of the entire pipeline system, including minimum and maximum internal dimensions, maximum distance the pig must travel, the system’s minimum bend radius and bend angles, and features such as valve types, branch connections, and the elevation profile. Also important are the:
• Purpose for which the pipeline is used
• Type, volume, and location of substances to be displaced prior to initiating the smart pig run
• Type of information to be gathered by the smart pig
• Operator’s goals and objectives for the smart pig run
Proper pre-run planning helps ensure that the in-line inspection data acquired are accurate, complete, and suitable for assessing integrity issues. Equally importantly, it improves the efficiency of crews sent to find, dig up, inspect and repair the anomalies that are detected.
Even companies with large staffs capable of planning and scheduling smart pig runs, tracking the pigs, retrieving and interpreting the data, and pinpointing the locations of anomalies in the field frequently ask integrated pipeline services providers to actually dig up the pipes, make repairs and document attainment of objectives.
Comprehensive PIM Programs
As important as it is to optimally configure a smart pig for its intended purpose, a pipeline operator should not lose sight of the fact that pipeline integrity neither starts nor ends with smart pigging. Rather, smart pigging is merely one of many elements in a comprehensive PIM program, which also should include, but not be limited to:
• Monitoring, modeling, and mitigation of alternating current and direct current interference
• Inspection of coatings and wrap materials, investigation of failures, and institution of rehabilitation programs
• Close-interval cathodic protection surveys
• Direct assessment of internal and external corrosion forces and development of a corrosion prevention and management program
• Threat assessment, risk assessment and identification of potential to affect high consequence areas
• Hydrostatic testing, leak detection, soil surveys, and tank inspections
• Anomaly investigation, pipeline repairs, and pipe replacements
Implementing a comprehensive PIM program can be very costly. But it makes economic sense for regulated and unregulated pipeline systems, alike, by providing security against catastrophic failures that can threaten the very existence of a pipeline company. So as onerous as DOT’s new requirements might seem in some cases, the public and the environment are not the only beneficiaries.
What makes Economic Sense?
In fact, outsourcing PIM activities to an integrated, full-service O&M pipeline company brings with it the added benefit of access to a wide range of valuable services and technical capabilities, including: experienced project management support; advanced drafting and surveying capabilities; plant and facility maintenance; data management and reporting; environmental services; instrumentation, electrical, and mechanical services; and professional engineering services.
Each owner or operator simply has to decide how to ensure that his company is secure and profitable. In some cases, it might make economic sense for a pipeline to exceed safety and environmental regulatory requirements; in other cases, the objective should be to comply with the letter of the law. Experienced professionals can help a pipeline owner or operator identify and understand all the forces and risks in play, then collaborate to create and implement a multi-dimensional O&M program that makes the most sense for his business.
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