To ensure safety and reliability, the Pipeline and Hazardous Materials Safety Administration (PHMSA) included section 195.591 In-Line Inspection (ILI) of pipelines in the Federal Pipeline Safety Regulations last year. This means that when conducting In-line Inspection of pipelines, each operator must comply with the requirements and recommendations of three documents incorporated by reference in §195.3.
One of these documents is API Std 1163, In-line Inspection Systems Qualification Standard.
API Std 1163 is not a new document; its first edition was published in 2005. Since then, some operators have been following this standard at some level but now, all hazardous liquid operators need to comply with its recommendations as required by 49 CFR §195.591. The In-line Inspection Systems Qualification Standard is an umbrella document to be used with companion standards: NACE Standard Practice SP0102–2010 ‘‘In-line Inspection of Pipelines’’ and ANSI/ASNT ILI–PQ–2010, ‘‘In-line Inspection Personnel Qualification and Certification.”
A Closer Look
Let’s see the different documents required by the new rule. First, NACE Standard Practice SP0102–2010 ‘‘In-line Inspection of Pipelines.’’ This standard provides tables to improve tool selection. PHMSA provides hazardous liquid pipeline operators choices of tools to assess their pipelines, but operators need to choose wisely. The argument is that there is not a best ILI tool or silver bullet for all possible threats. However, there is a best ILI tool for specific inspection requirements and operators need to choose the appropriate tool considering several factors, including:
- Operating conditions
- History of their pipeline
- Threats affecting their asset
- Clear understanding of limitations and advantages of each ILI technology available
Selecting the proper ILI tool is not an easy task, as many operators have painfully experienced when they have suffered an incident relatively shortly after running an ILI tool that did not detect the actionable anomaly that caused the leak, or rupture.
Providing Quantitative Results
Let’s review now ANSI/ASNT ILI–PQ–2010, ‘‘In-line Inspection Personnel Qualification and Certification". PHMSA believes that the incorporation of this standard into the Federal pipeline safety regulations will promote a higher level of safety by establishing consistent standards to qualify the equipment, people, processes, and software utilized by the ILI industry. Operators need to verify the competence of the ILI personnel (education, training, experience and skills). Some operators have been requesting ILI vendors to provide data analyst certifications. However, there is much more to audit, i.e. written procedures, training programs, examinations (testing of personnel), personnel recertification, and performance evaluations.
Finally, API Std 1163, ‘‘In-Line Inspection Systems Qualification Standard.” Did I mention that it is an umbrella document? The standard covers all aspects of ILI, incorporating the requirements of the two previously discussed documents (NACE and ASNT). API Std 1163 begins covering ILI system selection, system and personnel qualification, and it ends with reporting and quality management system.
VeriFICATION AND RESULTS VALIDATION
Very well-known parts of API Std 1163 are verification and results validation. PHMSA requires operators to validate ILI results for each anomaly examined to verify the accuracy of the tool and, in this way, generate quantitative comparisons to determine if critical anomalies have been classified and characterized using an appropriate level of conservatism. This involves the acceptance of the survey and its inspection data. Is the ILI data complete? Is the data of good quality? Is the data plausible? Once the analysis has been completed, operators will need to answer some more questions. Are the results valid? Did the tool perform within the published tolerance and statistical confidence level (certainty)?
As many operators know, API Std 1163 is not just about generating unity plots. It also involves choosing a statistically significant number of digs so that the inferred results can be applied to the totality of the ILI survey. Operators need to compare the current ILI reports with previous ILI runs as well as searching the ILI report for known features. It requires close cooperation and interaction between the ILI vendor and the operator. The operator has the responsibility to ask the ILI vendor the necessary questions and to demand good answers. Doing all of this will not guarantee that you will discover and avoid all possible issues affecting a failed ILI run or an inaccurate ILI report, but not doing this correctly increases your chances to get in trouble.
Each pipeline system is unique and may contain a variety of threats related to operating conditions, pipeline vintage, and environment. G2 Integrated Solutions can help you comply with the law and ensure the safety and reliability of your pipeline. For more information, contact us today.