A comprehensive approach to compliance

On 1 July, 2020, the Pipeline and Hazardous Materials Safety Administration (PHMSA) revisions to 49 CFR 192 Part 1 – popularly known as the ‘Mega Rule’ – went into effect. This includes pipeline material verification and maximum allowable operating pressure (MAOP) reconfirmation, and records required to reconfirm MAOP must be traceable, verifiable, and complete (TVC).

However, where records are not traceable, verifiable, and complete for the pipeline material of construction, the owner must perform material identification. Records required to be verified include:

• Diameter.
• Wall thickness.
• Seam type.
• Pipe material grade (yield strength (YS), ultimate tensile strength (UTS), pressure rating of valves and flanges, etc).
• Pipe material charpy V-notch toughness values.

There are multiple methods for gathering the data required to reconfirm MAOP, but the preferred method is to utilise in-situ non-destructive methods. This methodology can be performed at opportunity digs by qualified technicians utilising approved tools, or by a prescriptive approach (scheduled repairs, excavations, etc.). The prescriptive approach consists of 1 excavation per mile, or 150 excavations, if comparable population is more than 150 miles.

The scope of the new regulations, the lack of overall industry guidance, and often incomplete historical integrity records, have left many operators struggling with how to utilise their resources most effectively to achieve compliance. With so many different disciplines required to reach compliance – ranging from non-destructive examination (NDE) and inline inspection (ILI) material classification, to in-ditch material verification and engineering support services for establishing material verification programmes – operators typically require support to implement these programmes. Operators can benefit from working with a third-party service provider – like MISTRAS Group, a One Source provider of asset protection solutions – with the engineering expertise and complete solution toolbox required to achieve ‘Mega Rule’ compliance.

NDE methods and tools

It is critical that qualified companies train, test, and provide qualified and certified technicians to perform testing with PHMSA-approved tools for data collection. Experienced service providers typically invest considerable resources in training quality technicians and in purchasing tested and qualified tools to accurately collect data in-situ at opportunity and scheduled dig sites.

The tools required to accurately collect material of construction data must be validated by a subject matter expert (SME) as comparable to destructive testing results for material of comparable grade and vintage. The NDE method must conservatively account for measurement inaccuracies and uncertainties using engineering tests and analyses. The NDE method must also use test equipment that has been properly calibrated for comparable test materials prior to each usage.

In May 2018 the Pipeline Research Council International (PRCI) released a report titled ‘Validation of In-Situ Methods for Material Property Determination’. The report provided a summary of test protocols applied and the performance results from various techniques. The Massachusetts Materials Technologies (MMT) ‘Hardness, Strength, and Ductility (HSD)’ advanced non-destructive material verification solution was tested by PRCI, and they found that the HSD was marginally the best technique with the lowest mean absolute percentage error (MAPE), highest correlation coefficients, and…

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Read the article online at: https://www.worldpipelines.com/special-reports/07112023/a-comprehensive-approach-to-compliance/