Safety management & integrity services for pipelines, from Dynamic Risk
From gathering systems, midstream and transmission pipelines to distribution networks, Dynamic Risk is equipped with the in-house expertise to provide complete pipeline risk assessment, data management, and compliance reporting. Our clients benefit from improved safety and environmental protection, best-in-class engineering expertise, reduced capital spend through a risk-based approach and proven results for reduced risk and greater system reliability.
The Dynamic Risk network supports over 100 upstream gathering pipeline operators across North America and transmission/midstream clients globally.
Dynamic Risk’s team of industry regulatory experts have the credibility, knowledge and experience with industry best practices to work with our clients throughout a regulatory audit process for improved system compliance and integrity, reduced maintenance costs through program efficiencies and staff augmentation to support overloaded teams.
As pipelines continue to encroach on each other, operators need an effective solution to ensure safe operations that adhere to regulatory standards. Our pipeline integrity solutions enable users to conduct a comprehensive review of their organization’s adherence to safety measures, while efficiently and accurately determining Class Location, as well as identifying High Consequence Areas (HCA).
Gas Mega Rule by the Pipeline and Hazardous Materials Safety Administration (PHMSA)
On October 1, 2019, PHMSA finalized a rule for gas transmission pipelines, which was in development for over eight years. This highly anticipated rule, referred to by many as the “Gas Mega Rule,” is considered to be the most significant change to the existing gas pipeline regulations since 1970.
Purpose of the Gas Mega Rule
The idea of the Gas Mega Rule was initiated by the PHMSA through an Advance Notice of Proposed Rulemaking issued in August 2011, as a response to a pipeline incident from September 10, 2010 in San Bruno, California. Following investigations into the incident, as well as another incident that occurred in Sissonville, West Virginia on December 11, 2012, the National Transportation Safety Board (NTSB) issued specific recommendations to PHMSA to revise existing pipeline regulations.
Summary of the provisions of the regulatory action
The mandates from Congress required the PHMSA to:
- Expand integrity management regulations beyond pipelines located within a High Consequence Area (HCA), for regulations requiring the verification of Maximum Allowable Operating Pressure (MAOP)
- Elimination of the “grandfather clause” in existing regulations (§192.619) that allowed for selected pipe segments installed prior to 1970 to remain untested.
Costs and benefits
It is advised for gas transmission operators to review the changes to PHMSA’s Rulings for Parts 191 and 192 and adjust existing integrity programs as necessary to achieve continued regulatory compliance.
The value for pipeline operators to adhere to PHMSA’s Gas Mega Rule is to ensure they are regulatory compliant if they are audited. In addition, these regulations ensure that the pipeline assets operate efficiently for the safety of the public, protection of the environment and to reduce potential risks of any incidents occurring.
Newly defined ‘Moderate Consequence Areas’ to be included in the scope
To address the mandate from Congress to expand integrity management requirements beyond the currently defined HCAs, the PHMSA has introduced a new definition – Moderate Consequence Area (MCA). An MCA is generally defined as the area within a Potential Impact Circle (similar to that applied to establish HCAs) that either contains 5 or more buildings or a major roadway (e.g. interstate highway, freeway, expressway and other 4-lane roadways); and does not already meet the definition of an HCA.
Important Information on each of the New PHMSA Rules
PHMSA Final Rule: Gas Transmission Pipelines
The final rule, effective as of July 1, 2020, has been published. It is important that gas transmission operators assess final rule readiness and begin preparing for the potential impact on in-place integrity management programs and operating practices.
The ‘Mega Rule’ in practice
The PHMSA’s Mega Rule applies to over 500,000 miles of gas and hazardous liquid pipelines in the United States. The rule mandates pipeline operators to have an effective plan and program in place to adhere to more rigorous safety regulations and additional detailed reporting. It outlines the expansion of existing integrity management requirements to gathering lines and other previously unregulated pipelines.
What’s next for pipeline operators?
Gas Transmission pipeline operators must ensure the following has been actioned for regulatory compliance:
- Risk assessment methods that can perform sensitivity analysis, evaluate interacting threats, address uncertainties, and assess risk mitigation activities.
- Reporting and data management systems in place to integrate data to define and mitigate risks, and demonstrate compliance to regulations.
The future rulings for gas operators that are currently in development include:
- Repair criteria, IM improvements, cathodic protection, management of changes, and other related amendments
- Mega Rule for Gas Gathering (Upstream and Midstream gathering system pipeline operators) – final rule under development
What you need to consider to comply with the “Mega Rule”
At a minimum, an operator should develop a Mega Rule Response Plan that includes the following:
- Systems in place to calculate and identify both HCAs and MCAs on an on-going basis, along with the supporting processes to capture and align pipeline right-of-way adjacent structures along with other pipeline.
- Determining pipeline segments that meet the applicability requirements (§192.624) and develop processes and procedures to perform MAOP reconfirmation by July 1, 2021.
- Determining pipeline segments that require material verification (according to §192.607) and developing procedures for material verification that may potentially be required as early as July 1, 2020 in conjunction with analysis of predicted failure pressure during pipeline assessments (§192.712).
- Ensure reporting and data management systems are in place to integrate data and perform analysis as a basis to confirm reliability, define and mitigate potential risks, and demonstrate compliance to the regulations.
We can help with a pipeline assessment
Transmission and midstream operators are recognizing the need to have an improved understanding of their managed pipeline assets to protect capital investment, mitigate risk, ensure public safety, and adhere to new state/federal regulations, more specifically PHMSA’s Mega Rule.
Our scalable and flexible approach fully enables the establishment, maintenance and transfer of integrity for the full life cycle of your pipeline assets.
Our transmission and midstream software solution, IRAS ComplianceAuditor, is a robust application that can conduct a comprehensive review of your organization’s current safety measures and regulatory standards to ensure safe and compliant pipeline operations. It checks for data gaps, overlaps and out-of-range data values. Using a data management quality control review process, data is checked for completeness and accuracy and discrepancy reports are available to identify outstanding data issues. Users can also perform comparative analytics for year-to-year review and change management and have the ability to export these detailed reports for further review and integration with corporate GIS.
Key features and functionality to support operators include:
- Support for Class Location Analysis, HCA Analysis, calculation and verification
- In complete compliance with 49 CFR 192
- Class Location Analysis with configurable adjustment for clustering and 4-storey building prevalence
- HCA analysis support for Method 1 and/or Method 2 with MCA calculation support
- Canadian Class Location compliance with CSA Z662 requirements
- High-performance dense area processing
- Single or multi-line processing
- Dynamic integration, alignment and visualization
- Change management providing for legacy retention and comparative analytics for year to year review
About our pipeline integrity management program
For many of our clients, improved analytics is a key driver for choosing an integrity management solution. The need to extract value from data and perform analytics to support and drive decisions is no longer a desired state, but a necessity. In today’s environment, operators are charged with minimizing risk, meeting regulatory compliance standards, and operating efficiently.
Operators want to improve system performance, processes and procedures to increase the efficiency and accuracy of their reporting. The attributes of a rolling implementation play a key role in meeting these goals.
Regulatory Audits Support
A pipeline management system (the Management System) provides a framework to manage risk throughout the pipeline lifecycle and documents the objectives, the associated performance requirements, and identifies the proper sequence of processes and procedures to be managed, scheduled, tracked, documented, communicated and reported. Dynamic Risk applies a structured “Plan, Do, Check, Act” (PDCA) approach as an audit framework in application with selected appropriate industry standard best practice guidelines to assess if the Management System is compliant, adequate, implemented, effective and provides for continuous improvement.
Pipeline integrity management consulting services
Dynamic Risk brings a unique blend of superior engineering know-how and experience along with world-class software, data management, and engineering response projects. By building high performance teams in each of these areas, we are able to deliver high-value services and technical solutions to our clients that meet or exceed industry and discipline best practices for pipeline integrity management programs.
Our consulting services provide agile expertise at every stage of the pipeline operation lifecycle to help you safely deliver the energy North America counts on.
We have over 120 professionals dedicated to pipeline integrity management and work with over 100 operators in North America, and across the globe, which has enabled us to refine our services and solution offerings with a profound understanding of industry needs.
By building high performance teams in each of these areas, we are able to deliver high-value services and technical solutions to our clients, consistent with industry and discipline best practices for pipeline integrity management programs.
Canadian Standards Association (CSA) Regulations
Summary of the CSA regulations
In June 2019, the CSA released the 8th edition of CSA Standard Z662: Oil and Gas Pipeline Systems. This most recent edition, the first update since 2015, will have a wide range of impacts on the energy industry and includes a combination of new and updated requirements. The 2019 standard identifies 18 significant changes from the 2015 edition. These changes include, but are not limited to, updated requirements for reuse of materials, trenchless installations, and revised wording that ensures alignment between various clauses and annexes within the standard, as well as alignment with other standards such as CSA Z245: Steel Pipe.
Important Information on key areas of the CSA Regulation Mandates
The six key changes and their impact on pipeline systems are as follows:
- Class Location
- Designated Geographical Areas (DGA)
- Records retention
- Engineering assessments
- Leak detection
- Dent assessment criteria
- Annex N (Guidelines for Pipeline System Integrity Management Programs)
CSA regulations in practice
Class Location is defined as a geographical area that is classified according to its approximate population density as well as other characteristics that are considered when designing and pressure testing piping in a specific area. Essentially, it is a means of ensuring that the operating and design parameters of a pipeline are appropriate for the population density at every point along the pipeline route. In line with the 2015 edition of CSA Z662, Class Locations are divided into four different categories intended to reflect different levels of population density. The only change in the 2019 edition is the inclusion of the 120-person occupancy threshold for buildings in Class 2. Previously, buildings occupied by 20 or more people could be classified as Class 2. However, in 2019, criteria have been added where any building occupied by more than 120 people during normal use must now be classified as Class 3.
The 2019 standard also includes a change with respect to the applicable area covered by each Class Location. Previously, Class Locations for an area were calculated based on a measurement of 200m on either side of a pipeline (for a total width of 400m) and 1600m (or 1 mile) along the length of the pipeline.
As a result of these changes, there is now an opportunity for operators of sweet gas pipelines to decrease the assessment area width to as little as 60m. However, depending on the pipe diameter and operating pressure, operators could also see an increase beyond the 400m width defined in the 2015 edition.
For operators of liquid and CO2 pipelines, there is no change in the Class Location assessment area as previously defined and it remains 400m in total width and 1600m in length (with a few exceptions as noted in Section 220.127.116.11, including where it can be demonstrated that a smaller width will not increase the hazard to health and life beyond the assessment area).
It must be noted that location factors for non-sour High Vapour Pressure (HVP) liquid pipelines have been updated in 2019 to match those of non-sour gas pipelines. As a result of this change, the location factors for HVP Class 2 locations increases (from 0.800 to 0.900), whereas they decrease for both Class 3 and 4 locations (from 0.800 to 0.700 and 0.550, respectively).
The 2019 edition of CSA Z662 has added criteria for Low Vapour Pressure (LVP) to distinguish between liquids with low and high flammability, with the latter being defined as having a flashpoint less than 38°C. This distinction results in a major change to the standard, where the LVP high flammability location factors for Class 3 and 4 decrease from 1.000 to 0.800. This 20% drop for location factor could have serious implications for LVP pipelines and could necessitate substantial pressure reductions or even pipe replacements for existing pipelines.
The revised Class Location requirements outlined in CSA Z662-2019 represent significant changes regarding pipeline design, especially for LVP pipelines in Class 3 and 4 locations as noted above. However, the commentary associated with Section 10.7.1 clarifies that changes in Class Location are not intended to be prompted by this new version of CSA Z662, but rather as a result of a change in physical attributes around the pipeline (i.e. new dwellings). While new pipelines will be held to the updated design requirements, existing pipelines will only be held to these requirements once a Class Location change has been identified.
Designated Geographical Area (DGA)
A Designated Geographical Area (DGA), as introduced in 2019, is a new concept to CSA Z662 and will be of particular interest and importance to operators of LVP liquid pipelines (excluding fresh water). DGAs have similarities to HCAs and are defined in the standard as a surface water body that could be impacted by a pipeline uncontrolled release incident and by its location, use, or intrinsic value, is sensitive to an adverse effect from such an incident. DGAs are intended to be surface water bodies of special concern where heightened protection might be required.
At a high level, DGAs are water bodies where a pipeline release could have serious consequences. As such, CSA Z662-2019 requires that LVP pipeline operators determine what constitutes a DGA while taking into consideration the following:
- Disruption to commercial navigation activities
- Use as a major drinking water or food source
- Presence of and type of fish species
- Reliance of endangered or protected species on use of the water body
In tandem with the criteria noted above, LVP pipeline operators will be required to identify pipeline segments where a release could adversely affect a DGA, while weighing the impact of:
- Terrain and environment surrounding the pipeline
- Presence of waterways or ditches that could serve as pathways
- Flow characteristics of the release fluid over land or on water
- Potential release volume including consideration of likely failure modes
- Emergency response plans
Aside from establishing a process to identify and document DGAs, the standard state DGAs are to be considered separately from Class Location, with LVP pipeline segments identified as potentially impacting a DGA using a location factor not to exceed 0.9. This could present challenges for operators similar to those discussed pertaining to the reduced location factors associated with the updated Class Location requirements in CSA Z662-2019.
However, the standard does offer an exemption to the maximum 0.9 location factor for DGAs in the event it can be demonstrated that other measures can be used to achieve an equivalent level of environmental protection. These measures can include internal linings, advanced leak detection and in-line inspection capabilities.
While many operators will have existing data and information that will aid in determining DGAs along its pipeline(s), it is anticipated there will be a significant amount of effort involved in meeting this new requirement. Establishing a consistent and well-defined process for determining DGAs will be key, which could be mitigated by information-sharing amongst LVP pipeline operators.
Another potential challenge will be ensuring there is sufficient data available to meet the DGA criteria outlined by CSA Z662. For example, identifying ditches that could serve as pathways and impact DGAs in the event of a release requires a significant level of detail in terms of the area surrounding the pipeline including route, topography, soil conditions, etc. Leveraging any existing HCA information and overland spill modelling would prove helpful, as would the availability of detailed and up-to-date GIS information.
CSA Z662-2019 introduces a new requirement (Section 4.1.11), which states that all design documents and records must be maintained for the life of the pipeline system. The new clause lists a series of documents and records including:
- Engineering assessments
- Materials specifications
- Class Locations
- Basis for valve location and spacing
- Basis for stress and support calculations
- Basis for pipe cover and clearance
- Basis for compressor and pump station design
While most, if not all, operators already keep these documents and records as standard practice, it is now a requirement with CSA Z662-2019. The standard also notes that all existing records be maintained for the life of the pipeline system, even for pipeline systems designed prior to the release of this latest edition. However, records need not be created retroactively, which may be of particular interest in cases where operators acquire pipelines previously operated by others.
The recently released edition also includes some updates with respect to engineering assessments and the criteria they are required to consider, such as:
- Depth of cover
- Presence of crossings
- Presence of and proximity to other facilities
- Loads and interacting loads
- Potential presence and significance of undetected imperfections
As with the retention of records, these new requirements may already be factored in as part of existing operator specified engineering assessment criteria – notably relatively straightforward criteria such as depth of cover. The potential presence and significance of undetected imperfections could prove more challenging and the scope of work involved will likely be heavily dependent on in-line inspection tool tolerances (i.e. trying to quantify and qualify imperfections which are too small to be detected by ILI tools).
It should also be noted that there are updates regarding the engineering assessment process as outlined in Section 3 – Safety and Loss Management System. Specifically, Section 3.4.2 has added a requirement, which ties the engineering assessment process to a management of change process.
Section 10.3 of CSA Z662-2019 also includes updates on leak detection requirements and of particular note is Section 10.3.3 Leak Detection for Sales Quality Liquid Hydrocarbon Pipelines. Previous editions of the standard included a requirement for companies to periodically review their leak detection programs with a reference to Annex E as a recommended practice, but the 2019 edition now has the requirements outlined in Annex E as mandatory.
Section 10.3.5 Leak detection for other pipelines (excluding fresh water), has also been updated to require that operating companies develop a leak detection program including the specific criteria included in 10.3.5. This clause is specifically targeted at upstream liquid pipelines and essentially moves towards holding upstream operators to standards in line with midstream operators. This new set of expectations could be a big undertaking for upstream companies who do not operate many pipelines and as such, may not have very mature pipeline integrity programs.
Dent Assessment Criteria
There have been updates to the 2019 standard pertaining to dent assessment criteria as outlined in Clause 10.10.4.2. This clause includes three changes in the new edition which provide guidance on which dents shall be considered as defects unless determined by an engineering assessment to be acceptable.
For dents interacting with welds which are >6mm in depth for pipes with outside diameter 323.9mm or smaller, criteria have been added to exclude those dents with measured curvature strain <4% and which pass non-destructive inspection for the interacting portion of the weld. This addition will provide operators with some newfound flexibility when determining which dents qualify as defects.
On the flip side, criteria have been added to the clause to account for the effects of pressure cycle fatigue when identifying potential defects. This addition will require that operators include pressure cycling as part of any engineering assessments to determine whether a dent should be considered a defect.
The updated clause also includes revised wording to differentiate between internal and external corrosion as it pertains to dents, with the 40% of nominal wall thickness upper limit for internal corrosion having been deleted in the 2019 edition.
Annex N – Guidelines for pipeline system integrity management
Another update to CSA Z662-2019 is a restructuring of Annex N, primarily intended to be more relevant to facilities. While this annex continues to be informative as opposed to mandatory, it continues the trend of increasing regulatory focus on not just pipelines but their associated facilities as well. This trend coincides with increasing scrutiny on the pipeline industry in terms of public perception, especially since the previous edition of CSA Z662 was released in 2015.
Given Annex N specifically addresses management systems, the update also highlights the importance of establishing comprehensive integrity programs with clearly defined processes and procedures that have been implemented and documented. The work involved in establishing and implementing integrity programs will vary greatly between operators and be dependent on their pipeline-related infrastructure as well as the maturity of their integrity programs. Some companies with mature integrity programs may only require minor updates or modifications, however for many companies where these programs are still being developed, especially with respect to facilities, significant time and effort could be required to develop and implement programs. In these circumstances, Annex N, while informative, provides an excellent framework for all companies to work towards.
What do pipeline operators need to consider to comply with regulations
It is important for pipeline operators to ensure their existing assets adhere to the new regulatory mandates in each of the revised clauses, with dedicated programs in place to support accurate analysis and insightful reporting. Scrutiny on pipelines, both within industry and from the public, continues to grow, underscoring the importance for operators to ensure safe, efficient, and responsible operations of their pipelines. Some key areas of consideration to support efficient and reliable pipeline integrity programs which meet the requirements of CSA Z662-2019 include the following:
- Ensure current and accurate Class Location information, especially where a recent change in the area surrounding the pipeline may trigger a change in class location, and, as a result, new requirements in line with the new edition of CSA Z662. 2
- Establish a well-defined, clear process and criteria for identifying DGAs while following the guidelines outlined in CSA Z662. Leverage existing information where possible and expect a learning curve due to varying interpretations of what constitutes a DGA depending on the operator/company.
- Leverage existing pipeline integrity programs wherever possible, including information sharing between operators/companies, as a means of understanding and ensuring compliance with new and updated requirements of CSA Z662-2019.