Pipeline Integrity and the PHMSA Mega Rule – What You Need to Know

January 31, 2023

A vital part of a pipeline operator’s job is to ensure the integrity of pipelines always remain impenetrable and intact. The Pipeline and Hazardous Materials Safety Administration (PHMSA), in charge of regulating the pipeline industry, has recently developed new requirements concerning pipeline safety of gas transmission lines, adding layers of complexity and stringent new standards for operators.

The new rule Repair Criteria, Integrity Management Improvements, Cathodic Protection, Management of Change, and Other Related Amendments (also known as RIN2) goes into effect on May 24, 2023, and operators are required to have their integrity management program updated and implemented by February 2024. Because there are so many new complexities and factors involved, operators need to act now to update their program and ensure they adhere to all new guidelines and regulations.

What You Need to Know.

The latest rule specifies that pipeline operators of transmission lines in a regulated Integrity Management Plan update their requirements for repair criteria, assessment repair timelines, management of change procedures, expanded identification of potential threats to pipeline integrity (like a severe weather event), and more.

Where to Place Your Focus and Resources.

As operators review and update their integrity management programs, what are the best practices and things you need to review?

Start by focusing on data integration. PHSMA is requiring operators to incorporate more than forty specific pipeline potential threats into their risk assessments. Updating your integrity program to incorporate these changes is time intensive. New items like geohazard review, external forces, land movement, and water movement are all items to plan for and consider. Operators must start this process by May 24, 2023, and have all required integration complete by February 26, 2024.

Next, it’s important to update corrosion assessment requirements. PHSMA incorporated a standard assessment program that is more prescriptive than before, and corrosion assessments must be built to meet those strict industry standards.

Finally, it’s important to conduct a geohazard review. Operators must now take into account external forces that may affect the integrity of the pipeline. WSB put together a more in-depth article on this topic, and you can find more information on geohazard reviews by clicking here.

Don’t Delay, Act Now.

With so much to do and less than one year to do it all, many operators will find it difficult to allocate the internal resources and time necessary to fulfill all the requirements. Updating the integrity management program takes time, and if you haven’t started, you may already find yourself falling behind.

We have worked in the pipeline industry for over a decade and are available to help update plans, implement procedures, make risk assessments, and meet all requirements to ensure your program is in full compliance with the new rule. We have the team and the know-how to help guide pipeline integrity teams, no matter where you are in the process.

PHMSA Mega Rule: How to Prepare for Severe Weather Disasters

January 16, 2023

Hurricanes, flash floods, landslides, or any other form of severe weather can affect the environment by causing things like cracks and leaks in existing pipeline infrastructure. These issues can impact owners, managers, and workers of midstream transmission pipelines if they aren’t proactive in dealing with issues that may arise.

As part of the Pipeline and Hazardous Materials Safety Administration’s (PHSMA) final rule Repair Criteria, Integrity Management Improvements, Cathodic Protection, Management of Change, and Other Related Amendments (RIN2), PHMSA amended section 192.613 Continuing Surveillance to align with requirements previously added to the liquids rule. The new language seeks to decrease environmental issues by incentivizing proactive planning to protect and fix infrastructure in a timely manner after weather disasters.

WSB has a team of experts in geohazard risk assessment who can help companies navigate the murky waters of regulation and policy surrounding RIN2.

Policy Change

Extreme weather has been a contributing factor to several pipeline failures. PHMSA has issued Advisory Bulletins in 2015, 2016, 2019, and 2022 to communicate the potential that severe weather has to negatively impact pipeline integrity. PHSMA has amended 192.613 to require pipeline operators to inspect their potentially damaged infrastructure within 72 hours of a severe weather occurrence. If an issue is found during inspection, the operator is required to take the steps necessary to address the problem area.

PHMSA has defined extreme weather or natural disaster as any event that has the likelihood of damaging pipeline facilities. This includes soil movement around the pipelines, landslides, floods, earthquakes, and named hurricanes and tropical storms. Because storms of differing magnitudes will cause different outcomes in every landscape (e.g., even a small precipitation event may cause a landslide if the slope is unstable), this introduces a fair degree of uncertainty for operators. This regulatory and operational uncertainty can be difficult for companies to navigate, which is why a proactive approach to extreme weather management is important.

The rule goes into effect on May 24, 2023. After petitions by several industry agencies (AGA, API, and INGAA), PHMSA has decided to refrain from taking enforcement action on the severe weather inspections and other requirements from the effective date until February 24, 2024, for pipelines installed or repaired prior to August 24, 2022. We do recommend that operators take advantage of this extension now, PHMSA has the right to revoke this discretion at any time.

Geohazard Risk Assessment and Severe Weather Monitoring

We recommend companies proactively incorporate severe weather planning into their current geohazard risk assessment plan. It is vital that operators know their system, have identified where potential issues could occur, and have a plan in place to act within 72 hours of a hazardous event.

Having a scientific rationale and process in place within your geohazard risk assessment plan will go a long way when severe weather events happen.

What WSB Can Do

This rule is important to protect the environment, people, and property within the natural gas industry. The best approach to ambiguity and unknowns surrounding this policy change is being proactive. While there are no easy or one-size-fits all answers, there are geohazard risk assessment experts at WSB that are available to provide geohazard management assistance for operators.

WSB can also provide coaching and planning when it comes to combining a company’s geohazard program with a severe weather monitoring system.

Integrity Management of Energy Pipelines

Natural Pipeline Rupture & Fire

October 17, 2022

In May of 2020, a natural gas transmission pipeline ruptured in Hillsboro, Kentucky, causing a fire and millions of dollars in damage. The rupture, which occurred on a hillside pipe segment, had previously been identified by the operator for geotechnical monitoring and mitigation due to the presence of an active landslide. Following the incident, the National Transportation Safety Board (NTSB) released a pipeline investigation report (PIR-22/01) on the incident. While thankfully there were no fatalities or injuries, the operator estimated the cost of property damage and emergency response was $11.7 million.

Between 2018 and 2020, the operator performed multiple integrity management studies, including in-line inspections (ILIs) and geohazard assessments at the site of active landsliding. Integrity studies indicated that the affected pipeline was exposed to external loads, or loads transmitted to a pipeline from an external source. Although the operator planned to mitigate the hazardous site in Summer 2020, hillslope failure and pipeline rupture occurred before mitigation was completed.

Tips for Proactive Pipeline Management and Risk Mitigation

For gas and hazardous liquid pipelines, proactive management of geohazard risks is critical. To ensure pipeline safety and integrity, here are some tips for operators:

Perform comprehensive geohazard risk assessments, including field surveys, to efficiently identify, document and prioritize the nature and extent of potential threats. Detailed investigations should reduce uncertainly and improve risk and financial-based decision-making.
Quantify external loading and load distributions for at-risk pipelines.
Monitor environmental conditions and changing weather patterns. Soil stability can be adversely impacted by changing weather patterns, so it’s important to check soil and surface materials regularly.
With the assistance of geotechnical engineers, design and implement site-specific monitoring and mitigation plans based on risk analyses and load calculations. Monitoring and mitigation plans should provide operators sufficient time and information to act in response to geohazard events.

How WSB Can Help

Due to the complexity and variability of geohazards, WSB’s Energy Sciences team recommends comprehensive geohazard risk assessments be performed for energy pipelines on five-year schedules. Our team of scientists and risk assessment specialists can help you identify, mitigate, and manage geohazard risks through services tailored to meet regulatory requirements and individual risk profiles.

PHMSA Advisory Bulletin Review

Pipeline Safety & Integrity, as Related to Geohazard Risk

On May 26, 2022, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued an updated advisory bulletin (Docket No. PHMSA-2022-0063) to remind owners and operators of gas and hazardous liquid pipelines about the potential for damage and safety-related issues caused by geologic hazards (geohazards), including earth movements and climate-related hazards. Geohazards are naturally occurring and dynamic processes, capable of causing widespread damage, loss of property and/or injury and loss of life.

Earth movement hazards include slope instability, subsidence, frost heave, soil settlement, erosion, scour, and earthquakes. The causative factors of earth movements are myriad and complex but rooted in the understanding of regional geology, environmental conditions, and human influence. Earth movements can be exacerbated by local surface conditions (variable, steep, and rugged terrain), changing subsurface conditions, and climate-related hazards (e.g. heavy rainfall, flooding, washouts, weakened or unstable soil). It is important to understand that natural geohazards rarely occur in isolation but instead as hazard cascades: events that precipitates another, increasing resultant risks and consequences. Thus, it is imperative to consider and examine all possible geohazard factors when determining risk.

As outlined in 49 CFE 192.103 and 49 CFR 195.110, gas and hazardous liquid pipelines must be designed to withstand external loads, including those imposed by geohazards. In addition, PHMSA requires operators to take preventative and mitigative measures to avoid pipeline failure and consequences, such as those caused by geohazards (49 CFR 192.935 and 49 CFR 195.452). Additionally, integrity requirements pursuant to geohazards can be found under 49 CFR 192.917 and 49 CFR 195.452.

To ensure pipeline safety and integrity against geohazards, operators should consider taking the following actions:

Identify areas surrounding the pipeline which may be prone to earth movement and other geohazards. For each identified location, plans should be developed, with the assistance of geotechnical engineers, outlining design, construction, and monitoring procedures, based on site-specific hazards.
Monitor environmental conditions and changing weather patterns. Note, soil stability can be adversely impacted by changing weather patterns; evaluate soil and surface materials regularly.
Mitigation measures should be designed and implemented, as need be, based on site-specific conditions.

Mitigating against catastrophe

EFFECTIVELY MANAGING GEOHAZARD RISK

Underground pipeline infrastructure is expansive and vulnerable to natural disasters, extreme weather conditions and impairment from human activities. When systems fail, they can trigger catastrophic damage and global headlines. In 2018, extreme weather incidents cost the United States nearly $91 billion. Earthquakes, landslides, tornadoes and hurricanes have a huge impact on our above-ground infrastructure but can also significantly affect our less visible underground infrastructure.

To prepare for the fallout caused by extreme weather events, many private and public organizations are taking a proactive approach to managing their geohazard risk.

PRIVATE REGULATIONS

Private utilities who operate interstate pipelines are held to requirements enforced by the Pipeline and Hazardous Materials Safety Administration (PHMSA). These requirements provide guidance on how to manage operations when faced with extreme weather or natural disasters. Beginning in July 2020, PHMSA’s updated requirements will mandate the consistent monitoring of all pipeline systems throughout the United States. While regulations existed previously, the integrity management systems associated with pipeline infrastructure have been evolving in response to extreme weather.

To comply with the PHMSA’s requirements, many private oil and gas companies are developing and updating integrity management systems, a risk-based approach to improving pipeline safety and operations.

PUBLIC REGULATIONS

Instead of creating integrity management systems, public organizations create resiliency plans. These plans improve public safety, allow for more precise project scoping and cost estimating and provide more accurate forecasting for maintenance budgets. Additionally, resiliency plans help communities plan their budgets proactively.

BUT HOW DO YOU MONITOR UNDERGROUND INFRASTRUCTURE THAT SPANS MILES?

Traditionally, many companies and organizations have resorted to walking the entire pipeline system to measure where risk may occur in the event of a natural disaster or extreme weather event. This process is time-consuming and often not fast enough in response to a crisis or when quick decisions must be made.

Our team of geohazard experts knew there had to be a better way to assess geohazard risk. Working closely with both public and private clients, we developed a predictive tool that allows organizations to monitor their pipeline infrastructure virtually. This GIS-based geohazard model informs risk-based decision-making tools, such as risk matrices, that can be referenced to ensure PHMSA compliance or inform resiliency planning. Using the model, areas that may have been impacted by an extreme weather event can be monitored with the click of a button and action steps can be taken immediately to continue safe operations of the pipeline network.

THE IMPORTANCE OF MANAGING GEOHAZARD RISK

With changing severe weather patterns around the country, proactive management is becoming an increasingly important part of pipeline operations. Since the 1950s, precipitation occurring during heavy downpours has increased by 37% in the Midwest. These events increase the probability of landslides, flooding, and a host of other geohazards that may negatively impact pipeline integrity.

Identifying locations vulnerable to these types of events allow mitigation activities that are less expensive than addressing them after an event has occurred, making geohazard assessments a sound risk and financial management tool.

WHAT IS A RISK MATRIX?

Since it’s easier to stop a potential leak or release before it happens, geohazard predictive modeling reduces the risk of events. The predictive modeling program uses a simple formula (Risk = Probability x Consequence) and applies it to geohazards.

For example, a successful geohazard program will predict locations susceptible to landslides after heavy downpours by determining the factors most likely to cause failures across each location. These risk factors can include slope angle, the shape of the slope and depth to bedrock. The output of this modeling process is a set of factors that rank slopes by degrees of failure.

Spring flooding expected, new model warns asset managers about potential risks

By Nick Rodgers, Coastal Geomorphologist, WSB

2019 marked the wettest spring on record in the U.S. and with it came extensive flooding, affecting millions of Americans. The National Weather Service just released its 2020 spring flood outlook, predicting that flooding will be above average again. Minor flooding is expected in the spring, but recent warm winters have increased flooding by saturating soils before spring rains arrive. Like 2019, this spring is forecasted to bring above normal precipitation.

Large scale flooding damages infrastructure and displaces people from their homes. The 2019 floods caused millions of acres of farmland to go unused and transported the farms’ fertilizer to the Gulf of Mexico, creating a massive “dead zone” where fish cannot survive. Flooding can cause a “natural hazard cascade” where one disaster leads to more including erosion, landslides, and chemical contamination. The total cost of 2019 flooding is estimated to be $6.2 billion.

Our team at WSB recently developed a flood model to predict flood extent and help asset managers reduce damage to infrastructure. In general, these models can be used to assess risk for specific pieces of infrastructure, individual cities, or entire states. With this new flood model, we help asset managers determine risk by first predicting where flooding is most likely to occur. This information allows us to work with stakeholders to decide which assets are most vital. The process informs asset managers which critical assets are most likely to experience flooding and where flood risk is highest. Asset managers use limited resources to fight a seemingly unlimited amount of water. A strong understanding of risk is vital when deciding how to use limited resources for the next historic flood event. Although we cannot control the warm winters and wet springs that face us, we can control how we respond and prepare.

Nick is an environmental consultant with one year of project experience specializing in geohazard risk assessments, geomorphology, and GIS analysis. His technical skills include developing GIS models for geohazards, client consultation on how geohazards affect public and private assets, data visualization, and expertise in coastal and fluvial geomorphology. His non-technical skills include public speaking, developing client relationships, and project scoping. Most recently, Nick designed a new GIS flood risk model that estimates risk for large areas with minimal data input.

[email protected] | 612.219.9470