pipeline safety compliance - wyoming pipeline authority

Pipeline Safety ComplianceWyoming Pipeline Authority Public Meeting

Casper, WyomingFebruary 17, 2009

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Pipeline Gathering Seminar

Pipeline Safety Compliance

Presenter:• John Beets - Principle GIS Technologist, Kansas City Operations

Objectives:• Who is the regulator?• Brief review of gathering regulation and requirement to comply

Primary Take Aways:• Regulation is increasing and so is enforcement• Come to seminar on Wednesday!

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Willbros Business Segments

• Engineering– Engineering, procurement,

construction management services for pipeline systems. EPC offerings for single source solutions. Manage & Maintain Program offers full range of services to sustain regulatory compliance and to safely and efficiently operate and maintain assets.

• Upstream Oil & Gas– Construction, Maintenance, EPC and

specialty services for oil and gas field gathering, processing and transportation.

• Downstream Oil & Gas– Turnarounds, construction, API

storage tank construction and maintenance, heater services, field services for refinery and petrochemical industries. EPC offering for turnkey solutions.

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Regulators of Pipeline Safety

• Pipeline and Hazardous Materials Safety Administration (PHMSA)• One of 10 agencies in the Department of Transportation• PHMSA Administrator appointed by President and confirmed by

Senate• Office of Pipeline Safety – 49 CFR 190, 191, 192, 194, 195, 199• Responsible for regulating 2.3 million miles of pipe• Funded by user fees• Intrastate pipelines typically inspected by State inspectors

– Ex.: Wyoming Public Service Commission

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Pipeline Safety Regulations – Brief History

• Catastrophic Pipeline Failures:– 1965 - Natchitoches, LA – 24” Tennessee Gas pipeline explodes due to stress

corrosion cracking. 17 people died. Prompted enactment of the 1968 Natural Gas Pipeline Safety Act.

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Pipeline Safety Regulations – Brief HistoryHigh Profile Incidents Lead to Increased Regulation:Natural Gas Pipeline Safety Act of 1968Hazardous Liquid Safety Act of 1979 Pipeline Integrity Management in High Consequence Areas for Hazardous Liquid Operators – 2001 and Pipeline Safety Improvement Act of 2002 – Natural Gas Transmission:• Identification of High Consequence Areas (HCA)• Integrity Management Planning

Pipeline Inspection, Protection, Enforcement, and Safety Act of 2006• Current liquids gathering and rural low-stress regulation• Distribution integrity management• Emphasis on public education and damage prevention

Proposed Rule Making• Regulation of distribution is forthcoming• All gathering could become regulated

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Current Gas and Hazardous Liquids Regulation:Gas gathering - effective April 14, 2006. Determination of gas gathering can be confusing (RP 80)

Liquids gathering and rural low-stress - effective July of 2008. Determination of liquids gathering and rural low-stress is more straight forward (based on diameter and hoop stress).

All onshore gathering lines (including rural) must be evaluated for compliance.

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Regulatory Determination is a Two Step Process:• What portion of your pipeline system is considered gathering? • What portion of your gathering is regulated?

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PHMSA Gas Gathering Definition

• According to regulation (192.8), API RP 80 must be used to determine gathering

• RP 80 provides two primary designations:1. Starts at the furthermost downstream point in a production

operation2. Pipelines returning gas to a gathering field to support production

operations (for fuel, gas lift, etc.)• Natural gas processing facilities are not regulated as gathering but may

operate regulated liquid line

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Determined by MAOP, stress level, and class location (population density). Regulated onshore gathering lines fall into one of two types:• Type A – Metallic lines operating at >= 20% SMYS or non-metallic with MAOP > 125

psig and within a Class 2, 3, or 4 location.

• Type B – Metallic lines operating at < 20% SMYS or non-metallic with MAOP <= 125 psig and within:

1) A Class 3 or Class 4 location.2) Within a Class 2 location the following applies:

a) All Class 2 locationb) A continuous one-mile long section of line extending 150 feet either side of the pipe

centerline and including more than 10 but fewer than 46 dwellings.c) A continuous 1,000 foot long section of line extending 150 feet either side of the pipe

centerline and including 5 or more dwellings.

Once gas gathering is defined – how is regulated gas gathering determined per PHMSA?

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Liquids rural gathering is defined as:• A nominal diameter between 6 5/8 inches and 8 5⁄8 inches• Operating at a MOP greater than 20 percent of SMYS or, if the stress

level is unknown or the pipeline is not constructed with steel pipe, at a pressure greater than 125 psig

Liquids rural low-stress is defined as:• A nominal diameter of 8 5⁄8 inches or greater• Operating at a MOP less than or equal to 20 percent of SMYS or, if the

stress level is unknown or the pipeline is not constructed with steel pipe, at a pressure of less than or equal to 125 psig

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Based on proximity to Unusually Sensitive Areas (USAs). Data currently provided by PHMSA to operators of hazardous liquids pipelines. Includes threatened and endangered species, other ecological areas, and critical drinking water resources.

• Regulated rural liquid gathering is in or within ¼ mile of a USA

• Regulated rural liquid low-stress is in or within ½ mile of a USA

Once rural liquid gathering or rural low-stress liquid is defined –how is regulated pipe determined per PHMSA?

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• Once rural liquid gathering or rural low-stress liquid is defined – how is regulated pipe determined per PHMSA?– Based on proximity to Unusually Sensitive Areas (USAs). Data currently

provided by PHMSA to operators of hazardous liquids pipelines. Includes threatened and endangered species, other ecological areas, and critical drinking water resources.

• Regulated rural liquid gathering is in or within ¼ mile of a USA

• Regulated rural liquid low-stress is in or within ½ mile of a USA

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What is Required to Comply?In order to comply an operator must:• Be able to locate their lines in the real world

• Separate gathering lines from production and transmission

• Determine the number and type of structures surrounding their lines (gas gathering)

• Determine the proximity of these structures to their lines (gas gathering)

• Analyze the density of structures to determine class location and regulated pipe (gas gathering)

• Analyze proximity of pipelines to USAs (rural liquids gathering and low-stress)

• Collect and store minimal pipeline data to determine hoop stress

• Implement safety programs based on the type of regulated pipe

• Maintain proper records to document compliance

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Pipeline Safety Compliance – Gas Gathering Example

Acquire controlled base mapping/imagery

over project area

Identify gas gathering lines per RP 80 using available records –collect pipe characteristics and

pressure data

Map identified gas gathering lines to controlled base

Identify and map habitable structures

within 660' of gathering lines

Analyze density of surrounding habitable

structures to determine class

Regulated pipe?

Determine Type A or B based on hoop stress

Implement required safety programs

Apply Risk Based Operation and Maintenance

NO

YES

Gas Well

Treatment Facility

Processing Plant

Gas Gathering

Gas Transmission

Regulated Gathering

Habitable Structure

GIS Analysis

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Take Aways: • Regulation is increasing

– In future – all gathering will probably be regulated

– In future – distribution will be regulated

• Enforcement of regulation is increasing (actions and fines)

• A large % of (gas) gathering in Wyoming may not be regulated – BUT! You must be able to prove that it is not regulated

• Current technology makes it easier to comply

• Objective should be to focus on core business as you have to this point, but still maintain a high degree of asset integrity

• More details in tomorrow’s seminar

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pipeline safety compliance - wyoming pipeline authority

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