Damage prevention

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

January 31, 2023

By Brandi Wolfe, Regulatory Compliance Manager, Oil and Gas, WSB

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. 

Oil and gas

Integrity Management of Energy Pipelines

Natural Pipeline Rupture & Fire

October 17, 2022
By Kirstyn Cataldo, Jen Holmstadt, WSB

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:

  1. 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. 
  2. Quantify external loading and load distributions for at-risk pipelines.
  3. 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.
  4. 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. 

For more information on how WSB can enhance your integrity management program, please contact Jen Holmstadt at 612.619.9215 or JHolmstadt@wsbeng.com.

Jen is a senior project manager in the oil and gas division and has over 15 years of experience. As project manager, Jen oversees the development of GIS-based geohazard models and multi-state field inspection programs. Jen also works with developing risk assessment programs that cities, states, and counties can use to mitigate environmental risks to assets and public safety.

JHolmstadt@wsbeng.com | 612.619.9215

Kirstyn serves as the Senior Geomorphologist for WSB’s energy sciences team. She has over 7 years of technical and professional experience in the state and federal government and private industry. Her technical expertise includes geospatial (GIS) modeling and data analysis, digital imagery processing and manipulation, geologic and geohazard site assessments, and surface mapping.

KCataldo@wsbeng.com | 612.849.4667

Pipeline image

PHMSA Advisory Bulletin Review

Pipeline Safety & Integrity, as Related to Geohazard Risk

By Kirstyn Cataldo, Jen Holmstadt

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:

  1. 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.
  2. Monitor environmental conditions and changing weather patterns.  Note, soil stability can be adversely impacted by changing weather patterns; evaluate soil and surface materials regularly.
  3. Mitigation measures should be designed and implemented, as need be, based on site-specific conditions.

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. 

Kirstyn Cataldo is a Geomorphologist and Geohazard Specialist at WSB with technical experience in both state and federal government. In her time with the federal government, Kirstyn was a seismic hazard geologist that performed comprehensive paleoseismic investigations. Her experience also extends to analyzing geohazard risks associated with dams and reservoirs, surface mapping, digital imagery processing and manipulation, soil and rock sample logging and technical report preparation.

kcataldo@wsbeng.com | 612.849.4667

Jen Holmstadt has been a project manager and geomorphologist in the oil/gas and transportation industries for over thirteen years. Her experience characterizing and remediating contaminated soils/sediments on large river projects, led Jen to focus on designing and implementing geohazard risk assessment programs.

jholmstadt@wsbeng.com | 612.619.9215