construction inspection
the voice and choice of public gas
PHMSA’s Construction Inspection Rule John Erickson, P.E.
American Public Gas Association
Construction Inspection the voice and choice of public gas
• Prior to this rulemaking, paragraph 192.305 read as follows: • “Each transmission line or main must be inspected to ensure that it is constructed in accordance with this part.” • Does not apply to service line construction • “This part” means 49 CFR Part 192, e.g. the entire natural gas pipeline safety regulations
NAPSR Petition
the voice and choice of public gas
• In 2002 NAPSR filed a petition with PHMSA due to concern that some pipeline operators were allowing contractors to self inspect their own construction • NAPSR was concerned that this practice represented a conflict of interest and could result in less than thorough inspection • NAPSR’s petition stated that self inspection by operators did not offer the same risks
NAPSR Petition
the voice and choice of public gas
• “Therefore be it resolved , that 192.305 be amended to prohibit a contractor that is hired to do construction work for an operator from inspecting its own work.”
NAPSR Petition
the voice and choice of public gas
• NAPSR suggested the following language: • “Each transmission line and main must be inspected to ensure that it is constructed in accordance with this part. No operator shall use a person to perform these required inspections if that person is performing any construction activities subject to inspection. Nothing in this section shall prohibit the operator from inspecting construction activities with operator personnel who are involved in the construction activities.”
PHMSA Proposal
the voice and choice of public gas
• On November 29, 2011 PHMSA proposed: “Each transmission line and main must be inspected to ensure that it is constructed in accordance with this subpart. An inspection may not be performed by a person who participated in the construction of that transmission line or main.” • “Subpart” means Subpart G of Part 192 • NAPSR’s language allowing operators to self inspect has been dropped
TPSSC Recommendation the voice and choice of public gas
• On July 12, 2012 the TPSSC approved: “Each transmission line and main must be inspected to ensure that it is constructed in accordance with this part. No operator shall use an individual to perform a required inspection if that individual performed the construction task requiring inspection. Nothing in this section prohibits the operator from inspecting construction activities with operator personnel who are involved in the construction activities.”
PHMSA’s Final Rule
the voice and choice of public gas
• Final rule published March 11, 2015, to take effect October 1, 2015: “Each transmission line and main must be inspected to ensure that it is constructed in accordance with this subpart. An operator must not use operator personnel to perform a required inspection if the operator personnel performed the construction task requiring inspection. Nothing in this section prohibits the operator from inspecting construction tasks with operator personnel who are involved in other construction tasks.
PHMSA’s Final Rule
the voice and choice of public gas
• PHMSA certified the rule had no impact on small entities • Unclear if a two person crew can inspect each other’s work • APGA and AGA petitioned PHMSA to clarify • PHMSA has indefinitely stayed the effective date of the final rule • PHMSA formed a working group to advise it • Working group dies not include hazardous liquid or natural gas transmission operators
Issues To Resolve
the voice and choice of public gas
• Part or Subpart? • May a contractor use other contractor personnel to inspect their work? • May a 2 person utility crew inspect their own work? • Is it 100% inspection or risk based methodology? • Is it inspection of the craft or the final product? • What records are required to verify inspection? • What is the retention policy for inspection records? • What qualifications must inspectors have? • What inspections are included?
What Inspection Are Included? the voice and choice of public gas
• Part 192 includes the following inspections: • Visually inspect each length of pipe or component: – For damage that could impair serviceability (192.144)* – Plastic pipe and components were manufactured in accordance with a listed specification (e.g. ASTM D2513) (192.59)* – Steel pipe and components were manufactured in accordance with a listed specification (192.55)* * Not in Subpart G
What Inspection Are Included? the voice and choice of public gas
• Visually inspect welds to verify: – The welding is performed in accordance with the welding procedure (192.241)* – The weld is acceptable according to the standards in Section 9 of API Std 1104 (192.241)* – Welds that are repaired are acceptable (192.245)*
• Inspect joints made by other than welding for compliance with standards (192.273)* * Not in Subpart G
What Inspection Are Included? the voice and choice of public gas
• Pipe with imperfections or damage has been repaired or removed (192.309 & 311) • The pipe is protected against abnormal loads and vehicular traffic (192.317) • Pipe installed in a ditch is installed to minimize stresses and protect the pipe from damage (192.319) • Plastic pipe is installed to minimize shear or tensile stresses (192.321)
What Inspection Are Included? the voice and choice of public gas
• If casings are installed, casings: (192.323) – Can withstand superimposed loads – Have proper end seals and vents – Vents are protected from weather
• Pipe has proper clearance (192.325) • Plastic pipe has sufficient clearance, or is insulated, from any source of heat (192.325) • Pipe is installed at proper depth. (192.327) • Coating is undamaged (192.461)* • Pressure test (Subpart J)* * Not in Subpart G
Who Can Perform Each? the voice and choice of public gas
Inspections at the job site prior to construction:
Visually inspect each length of pipe or component: For damage that could impair serviceability (192.144) Plastic pipe and components were manufactured in accordance with ASTM D2513 (192.59) Steel pipe and components were manufactured in accordance with a listed specification (192.55) Marked as prescribed in the specification or standard to which it was manufactured (192.63) Visually inspect for proper locate marks (192.614)
2 person crew can self inspect?
1 person crew can self inspect?
Can inspect via technology?
YES – Not inspecting own handiwork
YES – Not inspecting own handiwork
NA
YES – Not inspecting own handiwork
YES – Not inspecting own handiwork
NA
YES – Not inspecting own handiwork
YES – Not inspecting own handiwork
NA
YES – Not inspecting own handiwork
YES – Not inspecting own handiwork
NA
YES – Not inspecting own handiwork
YES – Not inspecting own handiwork
NA
Who Can Perform Each? the voice and choice of public gas
Inspections during construction:
Visually inspect welds to verify: The welding is performed in accordance with the welding procedure (192.241) The weld is acceptable according to the standards in Section 9 of API Std 1104 (192.241) Welds that are repaired are acceptable (192.245 & 192.2419 (c)) Inspect joints made by other than welding for compliance with standards (192.273) Inspection of field bends (192.313) Inspection of wrinkle bends (192.315) Inspection of tapping coupons for internal corrosion (192.475) Inspection of buried pipeline when exposed (192.459) Just prior to lowering the pipe into the ditch and backfilling the external protective coating is inspected, and any damage detrimental to effective corrosion control repaired. (192.461)
2 person crew can self inspect?
1 person crew can self inspect?
Can inspect via technology?
?
?
?
YES
NO, unless using acceptable technology
YES – Photograph or other
YES
NO, unless using acceptable technology
YES – Photograph or other
NA NA YES – Not inspecting own handiwork YES – Not inspecting own handiwork
NA NA YES – Not inspecting own handiwork YES – Not inspecting own handiwork
NA NA NA NA
Who Can Perform Each? the voice and choice of public gas
Inspections after construction
Pipe with imperfections or damage has been repaired or removed (192.309 & 311) The pipe is protected against hazards that may cause the pipeline to move or sustain abnormal loads and vehicular traffic (192.317) Pipe installed in a ditch is installed to minimize stresses and protect the pipe from damage (192.319) Plastic pipe is installed to minimize shear or tensile stresses and encased where required (192.321) Casings: If casings are installed, casings: (192.323) Can withstand superimposed loads Have proper end seals and vents Vents are protected from weather Pipe is installed with enough clearance from any other underground structure to allow proper maintenance and to protect against damage that might result from proximity to other structures. For transmission pipe this is at least 12 inches. (192.325) Plastic pipe has sufficient clearance, or is insulated, from any source of heat so as to prevent the heat from impairing the serviceability of the pipe. (192.325) Pipe is installed at proper depth. (192.327) The finished piping system is pressure tested (192.503 (d), 192.505 (c),
2 person crew can self inspect?
1 person crew can self inspect?
YES
?
YES
YES YES
YES YES YES
YES
YES
YES YES
Can inspect via technology? ?
PHMSA Construction Issues the voice and choice of public gas
• DESIGN: – Incorrect pipe wall thickness for class location – Inadequate testing documentation for pipeline components – Scour depths at river crossings accounted for with depth of cover design – Buoyancy calculations and mitigation method – Abrasion resistant coatings for HDD and road bores – Hydrotest section design for elevation and minimum / max test pressure and correct stress levels / wall thickness, etc. – Routing to minimize stability issues and geologic hazards
PHMSA Construction Issues the voice and choice of public gas
• EXCAVATION – – – – – – – – – – –
Insufficient burial depth. Proper use of local one call system Use of spotters in proximity to marked infrastructure Inadequate use of rock shield, padding machines or selective backfill Insufficient burial depth( to code or waiver) Ditch profile not matching pipeline causing inadequate support Dents caused by placing pipe on rocks Erosion of cover at streams Insufficient pipeline weights Excavating over the pipe without adequate protection from rocks, etc. Not reviewing as-built drawings for parallel pipelines
PHMSA Construction Issues the voice and choice of public gas
• PIPE:
– Pit defects in the pipe body – Laminations – Pipe sizing issues and variability/damage to pipe ends – Low tensile strength and/or thin wall in some pipe – Process for identifying damage from transportation during stringing – Pipe properly stored to avoid coating deterioration (FBE chalks 1 mil / year from UV)
PHMSA Construction Issues the voice and choice of public gas
• Bending: – Correct bending shoes utilized – Use of padded shoes – Correct number of pulls for a given length – Ripples out of tolerance – Pipe seam not in neutral axis – Inadequate construction specification – Not using internal mandrel when required by procedures – Not following procedures
PHMSA Construction Issues the voice and choice of public gas
• MECHANICAL JOINTS – Not following proper torque requirements in installation of bolts – Procedure for bolt tightening sequence – Gasket material in good condition – Proper gasket for the type of flange used – Pipe with scratches on OD with stab type fittings – Correct gasket utilized with flange type
PHMSA Construction Issues the voice and choice of public gas
• WELDING - GENERAL – – – – – – – – – – – – – – – –
Welding procedures not on site where work is occuring System for monitoring defect rates including what limits are unacceptable Use of correct welding rod Proper storage of rod Line up clamps not always used. Line up clamps removed prior to 50% root bead Method/ equipment/ procedures to monitor and verify pre heat Improper cleaning of root pass Weld area not shielded from weather conditions and procedures for use of wind boards Time between root pass and hot pass not verified Pipe moved to change weld gap tolerance Welder is visually inspecting his work Post welding cool down process to minimize Hydrogen cracking in high strength pipe Arc Burn procedure Methods for checking voltage and amperage Longitudinal seams are aligned in accordance with procedures
PHMSA Construction Issues the voice and choice of public gas
• MECHANIZED WELDING – – – – – – – – – – – – – – – –
Coating damage caused by welding band Incomplete weld procedure qualification Pre-heat crew not using Tempilstiks Pipe size - Hi-Lo alignment issues NDT falling behind main gang Lack of padding between pipe and skids Incorrect or inadequate placement of skid cribbing Lack of inspector oversight Not following procedures Incorrect pre-heat or interpass temp Improper use of Tempilstik - too near weld Amps and Volts measured at machine not weld (only long leads) Moving pipe during root bead welding Initial high defect rates Inadequate defect repair tracking Inadequate quality and documentation of MUT
PHMSA Construction Issues the voice and choice of public gas
• MANUAL WELDING – Not following procedures (direction, speed, current, voltage, rod type by pass) – Lack of inspector oversight – Early clamp release – Arc burns due to poor welding practices – Incorrect pre-heat or interpass temp – Inadequate visual weld inspection – Improper storage of low hydrogen rods – Welding inspectors not in possession of welding procedures – Use of 'hinging' technique to aid with pipe line-up – Pipe size - Hi-Lo alignment issues – Improper gas flow rate for gas shielded processes – Inadequate defect repair tracking – Incomplete qualification documents for welders – Amps and Volts measured at machine not weld (for long leads) – Inadequate defect removal on repair welds
PHMSA Construction Issues the voice and choice of public gas
• NONDESTRUCTIVE TESTING – Essential wire or hole (used to verify the ability to identify and size defects) not visible on radiograph – NDT records not adequate or up to date – Poor radiographic technique - not meeting API 1104 requirements – Film density is not within specification – Incomplete qualification documents for technicians – Inadequate interpretation of radiographic results – Not meeting the minimum 10% NDT requirements – Incomplete qualification documents for technicians – Inadequate interpretation of radiographic results – Film density not in spec – QC program for auditing level II’s – Procedure qualification shot – System for correlating reader sheet to weld location – Failure to notice other anomalies in weld vicinity (thin pipe wall, etc.)
PHMSA Construction Issues the voice and choice of public gas
• COATING GENERAL – Proper instruments to measure anchor pattern and coating thickness
• FUSION BONDED EPOXY ISSUES – – – – – – – – –
Coating over mud or rust Application temperature too hot or cold Heat damage to the factory FBE coating Failing to follow manufacturer's instructions Sand blast technique - no correct bevel / no overlap at factory coating Coating in high wind with blowing dirt Water in the pipe during heating – does allow for uniform heating Coating specifications not available to inspectors Girth weld coating not fully bonded to pipe
PHMSA Construction Issues the voice and choice of public gas
• ELECTRONIC DEFECT DETECTORS (HOLIDAY DETECTORS / JEEPING) – – – – – – – – – – – – – – – – –
Failing to follow manufacturer's instructions Procedures for selecting correct voltage setting for coating type and thickness Process for monitoring frequency of defects to determine when unacceptable levels are encountered Low voltage setting on holiday detector Inadequate training of inspectors and contractors Jeeping over tape and fiberboard stuck to the pipe Failing to adequately clean the pipe before jeeping Failing to visually inspect pipe for coating defects Using damaged (bent) detector springs High resistance in electrical circuit / Too much resistance in circuit when using the dry ground Jeeping at too fast a speed per the spec or manufacturer Jeeping over coating repairs before they are dry Detector failing to identify defects Detector not calibrated per manufacturer Paint/coating on spring Documenting the regular (daily?) calibration of the jeep Use of wet sponge to check the coating on irregular fittings and valves
PHMSA Construction Issues the voice and choice of public gas
• LOWERING – Inadequate boom spacing per the ECA requirements – Unrepaired coating defects at lowering – Use of padded slings and rollers in good condition so coating is not damaged – Pipe fitting PI’s of trench adequately such that coating is not damaged by trench wall – Pipe fits ditch such that additional stresses are not introduced and pipe is not “jacked” away from trench wall – Pipe does not rest on rocks or other hard ledges on trench bottom creating stress risers – Trench breakers are properly installed to prevent stress risers near bends or fittings – Construction crews damaging pipe and coating during installation in ditch and backfill and when installing river weights – Installation with enough clearance from other substructures
PHMSA Construction Issues the voice and choice of public gas
• BACKFILL – Shade material contacting pipe is of sufficient gradation that coating is not damaged – Use of rockshield to avoid coating damage shade material is large or angular. – Max Backfill particle size is controlled such that compaction is achieved – Backfill does not contain organic material – Backfill material has optimal moisture content so it compacts and is not soupy or overly runny – Backfill does not contain trash
PHMSA Construction Issues the voice and choice of public gas
• HDD – Bend radii do not exceed design tolerances – Final hole is deeper than projected scour depth – Coating is not damaged during the pull – Pipe is not yielded during the pull – Procedure for monitoring pulling tension • GEOMETRIC INSPECTION – Caliper pig to verify the final product is free from detrimental dents – Quantification of dents (by size and location) to be repaired
PHMSA Construction Issues the voice and choice of public gas
• HYDROSTATIC TESTING – Poor test in winter due to freezing of pressure equipment – Cracks discovered in girth welds during hydro test – Improper pressure maintenance during hydro test – Long seam failure – Use of properly calibrated gauges and equipment – All piping, fittings and equipment utilized for filling and pressurizing is properly rated for max test pressures
One Idea
the voice and choice of public gas
• • • •
Accept changing part to subpart Include service line construction under 192.305 Change 192.305 to read: Each transmission line, main or service line must be inspected to ensure that it is constructed in accordance with this part. On installations of pipe over 2 inches diameter an individual may not perform a required inspection if that individual performed the construction task requiring inspection • Will also need language to address contractor self inspection
Where Are We Now?
the voice and choice of public gas
• NAPSR changed position urging PHMSA to prohibit both contractors and operators from selfinspecting • PHMSA staff managing working group left PHMSA • Working group has not met in nearly 6 months • Rule is still indefinitely stayed
the voice and choice of public gas
Questions
PHMSA’s Construction Inspection Rule John Erickson, P.E.
American Public Gas Association
Construction Inspection the voice and choice of public gas
• Prior to this rulemaking, paragraph 192.305 read as follows: • “Each transmission line or main must be inspected to ensure that it is constructed in accordance with this part.” • Does not apply to service line construction • “This part” means 49 CFR Part 192, e.g. the entire natural gas pipeline safety regulations
NAPSR Petition
the voice and choice of public gas
• In 2002 NAPSR filed a petition with PHMSA due to concern that some pipeline operators were allowing contractors to self inspect their own construction • NAPSR was concerned that this practice represented a conflict of interest and could result in less than thorough inspection • NAPSR’s petition stated that self inspection by operators did not offer the same risks
NAPSR Petition
the voice and choice of public gas
• “Therefore be it resolved , that 192.305 be amended to prohibit a contractor that is hired to do construction work for an operator from inspecting its own work.”
NAPSR Petition
the voice and choice of public gas
• NAPSR suggested the following language: • “Each transmission line and main must be inspected to ensure that it is constructed in accordance with this part. No operator shall use a person to perform these required inspections if that person is performing any construction activities subject to inspection. Nothing in this section shall prohibit the operator from inspecting construction activities with operator personnel who are involved in the construction activities.”
PHMSA Proposal
the voice and choice of public gas
• On November 29, 2011 PHMSA proposed: “Each transmission line and main must be inspected to ensure that it is constructed in accordance with this subpart. An inspection may not be performed by a person who participated in the construction of that transmission line or main.” • “Subpart” means Subpart G of Part 192 • NAPSR’s language allowing operators to self inspect has been dropped
TPSSC Recommendation the voice and choice of public gas
• On July 12, 2012 the TPSSC approved: “Each transmission line and main must be inspected to ensure that it is constructed in accordance with this part. No operator shall use an individual to perform a required inspection if that individual performed the construction task requiring inspection. Nothing in this section prohibits the operator from inspecting construction activities with operator personnel who are involved in the construction activities.”
PHMSA’s Final Rule
the voice and choice of public gas
• Final rule published March 11, 2015, to take effect October 1, 2015: “Each transmission line and main must be inspected to ensure that it is constructed in accordance with this subpart. An operator must not use operator personnel to perform a required inspection if the operator personnel performed the construction task requiring inspection. Nothing in this section prohibits the operator from inspecting construction tasks with operator personnel who are involved in other construction tasks.
PHMSA’s Final Rule
the voice and choice of public gas
• PHMSA certified the rule had no impact on small entities • Unclear if a two person crew can inspect each other’s work • APGA and AGA petitioned PHMSA to clarify • PHMSA has indefinitely stayed the effective date of the final rule • PHMSA formed a working group to advise it • Working group dies not include hazardous liquid or natural gas transmission operators
Issues To Resolve
the voice and choice of public gas
• Part or Subpart? • May a contractor use other contractor personnel to inspect their work? • May a 2 person utility crew inspect their own work? • Is it 100% inspection or risk based methodology? • Is it inspection of the craft or the final product? • What records are required to verify inspection? • What is the retention policy for inspection records? • What qualifications must inspectors have? • What inspections are included?
What Inspection Are Included? the voice and choice of public gas
• Part 192 includes the following inspections: • Visually inspect each length of pipe or component: – For damage that could impair serviceability (192.144)* – Plastic pipe and components were manufactured in accordance with a listed specification (e.g. ASTM D2513) (192.59)* – Steel pipe and components were manufactured in accordance with a listed specification (192.55)* * Not in Subpart G
What Inspection Are Included? the voice and choice of public gas
• Visually inspect welds to verify: – The welding is performed in accordance with the welding procedure (192.241)* – The weld is acceptable according to the standards in Section 9 of API Std 1104 (192.241)* – Welds that are repaired are acceptable (192.245)*
• Inspect joints made by other than welding for compliance with standards (192.273)* * Not in Subpart G
What Inspection Are Included? the voice and choice of public gas
• Pipe with imperfections or damage has been repaired or removed (192.309 & 311) • The pipe is protected against abnormal loads and vehicular traffic (192.317) • Pipe installed in a ditch is installed to minimize stresses and protect the pipe from damage (192.319) • Plastic pipe is installed to minimize shear or tensile stresses (192.321)
What Inspection Are Included? the voice and choice of public gas
• If casings are installed, casings: (192.323) – Can withstand superimposed loads – Have proper end seals and vents – Vents are protected from weather
• Pipe has proper clearance (192.325) • Plastic pipe has sufficient clearance, or is insulated, from any source of heat (192.325) • Pipe is installed at proper depth. (192.327) • Coating is undamaged (192.461)* • Pressure test (Subpart J)* * Not in Subpart G
Who Can Perform Each? the voice and choice of public gas
Inspections at the job site prior to construction:
Visually inspect each length of pipe or component: For damage that could impair serviceability (192.144) Plastic pipe and components were manufactured in accordance with ASTM D2513 (192.59) Steel pipe and components were manufactured in accordance with a listed specification (192.55) Marked as prescribed in the specification or standard to which it was manufactured (192.63) Visually inspect for proper locate marks (192.614)
2 person crew can self inspect?
1 person crew can self inspect?
Can inspect via technology?
YES – Not inspecting own handiwork
YES – Not inspecting own handiwork
NA
YES – Not inspecting own handiwork
YES – Not inspecting own handiwork
NA
YES – Not inspecting own handiwork
YES – Not inspecting own handiwork
NA
YES – Not inspecting own handiwork
YES – Not inspecting own handiwork
NA
YES – Not inspecting own handiwork
YES – Not inspecting own handiwork
NA
Who Can Perform Each? the voice and choice of public gas
Inspections during construction:
Visually inspect welds to verify: The welding is performed in accordance with the welding procedure (192.241) The weld is acceptable according to the standards in Section 9 of API Std 1104 (192.241) Welds that are repaired are acceptable (192.245 & 192.2419 (c)) Inspect joints made by other than welding for compliance with standards (192.273) Inspection of field bends (192.313) Inspection of wrinkle bends (192.315) Inspection of tapping coupons for internal corrosion (192.475) Inspection of buried pipeline when exposed (192.459) Just prior to lowering the pipe into the ditch and backfilling the external protective coating is inspected, and any damage detrimental to effective corrosion control repaired. (192.461)
2 person crew can self inspect?
1 person crew can self inspect?
Can inspect via technology?
?
?
?
YES
NO, unless using acceptable technology
YES – Photograph or other
YES
NO, unless using acceptable technology
YES – Photograph or other
NA NA YES – Not inspecting own handiwork YES – Not inspecting own handiwork
NA NA YES – Not inspecting own handiwork YES – Not inspecting own handiwork
NA NA NA NA
Who Can Perform Each? the voice and choice of public gas
Inspections after construction
Pipe with imperfections or damage has been repaired or removed (192.309 & 311) The pipe is protected against hazards that may cause the pipeline to move or sustain abnormal loads and vehicular traffic (192.317) Pipe installed in a ditch is installed to minimize stresses and protect the pipe from damage (192.319) Plastic pipe is installed to minimize shear or tensile stresses and encased where required (192.321) Casings: If casings are installed, casings: (192.323) Can withstand superimposed loads Have proper end seals and vents Vents are protected from weather Pipe is installed with enough clearance from any other underground structure to allow proper maintenance and to protect against damage that might result from proximity to other structures. For transmission pipe this is at least 12 inches. (192.325) Plastic pipe has sufficient clearance, or is insulated, from any source of heat so as to prevent the heat from impairing the serviceability of the pipe. (192.325) Pipe is installed at proper depth. (192.327) The finished piping system is pressure tested (192.503 (d), 192.505 (c),
2 person crew can self inspect?
1 person crew can self inspect?
YES
?
YES
YES YES
YES YES YES
YES
YES
YES YES
Can inspect via technology? ?
PHMSA Construction Issues the voice and choice of public gas
• DESIGN: – Incorrect pipe wall thickness for class location – Inadequate testing documentation for pipeline components – Scour depths at river crossings accounted for with depth of cover design – Buoyancy calculations and mitigation method – Abrasion resistant coatings for HDD and road bores – Hydrotest section design for elevation and minimum / max test pressure and correct stress levels / wall thickness, etc. – Routing to minimize stability issues and geologic hazards
PHMSA Construction Issues the voice and choice of public gas
• EXCAVATION – – – – – – – – – – –
Insufficient burial depth. Proper use of local one call system Use of spotters in proximity to marked infrastructure Inadequate use of rock shield, padding machines or selective backfill Insufficient burial depth( to code or waiver) Ditch profile not matching pipeline causing inadequate support Dents caused by placing pipe on rocks Erosion of cover at streams Insufficient pipeline weights Excavating over the pipe without adequate protection from rocks, etc. Not reviewing as-built drawings for parallel pipelines
PHMSA Construction Issues the voice and choice of public gas
• PIPE:
– Pit defects in the pipe body – Laminations – Pipe sizing issues and variability/damage to pipe ends – Low tensile strength and/or thin wall in some pipe – Process for identifying damage from transportation during stringing – Pipe properly stored to avoid coating deterioration (FBE chalks 1 mil / year from UV)
PHMSA Construction Issues the voice and choice of public gas
• Bending: – Correct bending shoes utilized – Use of padded shoes – Correct number of pulls for a given length – Ripples out of tolerance – Pipe seam not in neutral axis – Inadequate construction specification – Not using internal mandrel when required by procedures – Not following procedures
PHMSA Construction Issues the voice and choice of public gas
• MECHANICAL JOINTS – Not following proper torque requirements in installation of bolts – Procedure for bolt tightening sequence – Gasket material in good condition – Proper gasket for the type of flange used – Pipe with scratches on OD with stab type fittings – Correct gasket utilized with flange type
PHMSA Construction Issues the voice and choice of public gas
• WELDING - GENERAL – – – – – – – – – – – – – – – –
Welding procedures not on site where work is occuring System for monitoring defect rates including what limits are unacceptable Use of correct welding rod Proper storage of rod Line up clamps not always used. Line up clamps removed prior to 50% root bead Method/ equipment/ procedures to monitor and verify pre heat Improper cleaning of root pass Weld area not shielded from weather conditions and procedures for use of wind boards Time between root pass and hot pass not verified Pipe moved to change weld gap tolerance Welder is visually inspecting his work Post welding cool down process to minimize Hydrogen cracking in high strength pipe Arc Burn procedure Methods for checking voltage and amperage Longitudinal seams are aligned in accordance with procedures
PHMSA Construction Issues the voice and choice of public gas
• MECHANIZED WELDING – – – – – – – – – – – – – – – –
Coating damage caused by welding band Incomplete weld procedure qualification Pre-heat crew not using Tempilstiks Pipe size - Hi-Lo alignment issues NDT falling behind main gang Lack of padding between pipe and skids Incorrect or inadequate placement of skid cribbing Lack of inspector oversight Not following procedures Incorrect pre-heat or interpass temp Improper use of Tempilstik - too near weld Amps and Volts measured at machine not weld (only long leads) Moving pipe during root bead welding Initial high defect rates Inadequate defect repair tracking Inadequate quality and documentation of MUT
PHMSA Construction Issues the voice and choice of public gas
• MANUAL WELDING – Not following procedures (direction, speed, current, voltage, rod type by pass) – Lack of inspector oversight – Early clamp release – Arc burns due to poor welding practices – Incorrect pre-heat or interpass temp – Inadequate visual weld inspection – Improper storage of low hydrogen rods – Welding inspectors not in possession of welding procedures – Use of 'hinging' technique to aid with pipe line-up – Pipe size - Hi-Lo alignment issues – Improper gas flow rate for gas shielded processes – Inadequate defect repair tracking – Incomplete qualification documents for welders – Amps and Volts measured at machine not weld (for long leads) – Inadequate defect removal on repair welds
PHMSA Construction Issues the voice and choice of public gas
• NONDESTRUCTIVE TESTING – Essential wire or hole (used to verify the ability to identify and size defects) not visible on radiograph – NDT records not adequate or up to date – Poor radiographic technique - not meeting API 1104 requirements – Film density is not within specification – Incomplete qualification documents for technicians – Inadequate interpretation of radiographic results – Not meeting the minimum 10% NDT requirements – Incomplete qualification documents for technicians – Inadequate interpretation of radiographic results – Film density not in spec – QC program for auditing level II’s – Procedure qualification shot – System for correlating reader sheet to weld location – Failure to notice other anomalies in weld vicinity (thin pipe wall, etc.)
PHMSA Construction Issues the voice and choice of public gas
• COATING GENERAL – Proper instruments to measure anchor pattern and coating thickness
• FUSION BONDED EPOXY ISSUES – – – – – – – – –
Coating over mud or rust Application temperature too hot or cold Heat damage to the factory FBE coating Failing to follow manufacturer's instructions Sand blast technique - no correct bevel / no overlap at factory coating Coating in high wind with blowing dirt Water in the pipe during heating – does allow for uniform heating Coating specifications not available to inspectors Girth weld coating not fully bonded to pipe
PHMSA Construction Issues the voice and choice of public gas
• ELECTRONIC DEFECT DETECTORS (HOLIDAY DETECTORS / JEEPING) – – – – – – – – – – – – – – – – –
Failing to follow manufacturer's instructions Procedures for selecting correct voltage setting for coating type and thickness Process for monitoring frequency of defects to determine when unacceptable levels are encountered Low voltage setting on holiday detector Inadequate training of inspectors and contractors Jeeping over tape and fiberboard stuck to the pipe Failing to adequately clean the pipe before jeeping Failing to visually inspect pipe for coating defects Using damaged (bent) detector springs High resistance in electrical circuit / Too much resistance in circuit when using the dry ground Jeeping at too fast a speed per the spec or manufacturer Jeeping over coating repairs before they are dry Detector failing to identify defects Detector not calibrated per manufacturer Paint/coating on spring Documenting the regular (daily?) calibration of the jeep Use of wet sponge to check the coating on irregular fittings and valves
PHMSA Construction Issues the voice and choice of public gas
• LOWERING – Inadequate boom spacing per the ECA requirements – Unrepaired coating defects at lowering – Use of padded slings and rollers in good condition so coating is not damaged – Pipe fitting PI’s of trench adequately such that coating is not damaged by trench wall – Pipe fits ditch such that additional stresses are not introduced and pipe is not “jacked” away from trench wall – Pipe does not rest on rocks or other hard ledges on trench bottom creating stress risers – Trench breakers are properly installed to prevent stress risers near bends or fittings – Construction crews damaging pipe and coating during installation in ditch and backfill and when installing river weights – Installation with enough clearance from other substructures
PHMSA Construction Issues the voice and choice of public gas
• BACKFILL – Shade material contacting pipe is of sufficient gradation that coating is not damaged – Use of rockshield to avoid coating damage shade material is large or angular. – Max Backfill particle size is controlled such that compaction is achieved – Backfill does not contain organic material – Backfill material has optimal moisture content so it compacts and is not soupy or overly runny – Backfill does not contain trash
PHMSA Construction Issues the voice and choice of public gas
• HDD – Bend radii do not exceed design tolerances – Final hole is deeper than projected scour depth – Coating is not damaged during the pull – Pipe is not yielded during the pull – Procedure for monitoring pulling tension • GEOMETRIC INSPECTION – Caliper pig to verify the final product is free from detrimental dents – Quantification of dents (by size and location) to be repaired
PHMSA Construction Issues the voice and choice of public gas
• HYDROSTATIC TESTING – Poor test in winter due to freezing of pressure equipment – Cracks discovered in girth welds during hydro test – Improper pressure maintenance during hydro test – Long seam failure – Use of properly calibrated gauges and equipment – All piping, fittings and equipment utilized for filling and pressurizing is properly rated for max test pressures
One Idea
the voice and choice of public gas
• • • •
Accept changing part to subpart Include service line construction under 192.305 Change 192.305 to read: Each transmission line, main or service line must be inspected to ensure that it is constructed in accordance with this part. On installations of pipe over 2 inches diameter an individual may not perform a required inspection if that individual performed the construction task requiring inspection • Will also need language to address contractor self inspection
Where Are We Now?
the voice and choice of public gas
• NAPSR changed position urging PHMSA to prohibit both contractors and operators from selfinspecting • PHMSA staff managing working group left PHMSA • Working group has not met in nearly 6 months • Rule is still indefinitely stayed
the voice and choice of public gas
Questions
