19 / 32
P H M S A C O M P L I A N C E
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 organizations 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 United
States, 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’s 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 developing necessary
pipeline documentation keeps operators in
compliance with American National Standard
Institute (ANSI) codes. Documentation is
necessary not only for records review, but whenever
welding is performed, replacement pipe materials
are obtained, or a pipeline is being reviewed for
re-rating, Kraska explains. Welding on a pipeline
without thorough knowledge of the materials
involved, the correct welding procedure, or the
composition of welding filler metal is also an ANSI
violation, he adds.
But there’s also a positive financial case to be
made in support of the regulation, and it goes like
this: Operators who’ve had to downgrade pipeline
pressure for lack of the records that would justify
higher pressure are losing money. By performing
PMI, they may find out that their pipelines
can actually accommodate higher pressure and,
therefore, increased capacity.
Operators who’ve had to downgrade
pipeline pressure for lack of the records
that would justify higher pressure are
losing money. By performing PMI, they
may find out that
their pipelines
can actually accommodate
higher pressure and, therefore,
increased capacity.
I N N O V AT I O N S • V O L . V I I , N O. 1 • 2 0 1 5
17