This week’s Pipeliners Podcast episode features first-time guest Mark Wright of ROSEN discussing how to use Engineering Critical Assessment (ECA) for MAOP re-confirmation of pipeline assets.
In this episode, you will learn about this risk management approach to MAOP re-confirmation, the key differences between ECA and other tests such as hydro tests, the need for better data to support an ECA assessment and similar types of assessments, how ECA can be a catalyst for operators to meet Materials Property Verification requirements, and more topics to help pipeline operators move the needle in MAOP re-confirmation.
Using ECA For MAOP Re-Confirmation: Show Notes, Links, and Insider Terms
- Mark Wright is a principal engineer at ROSEN. Connect with Mark on LinkedIn.
- ROSEN is the current episode sponsor of the Pipeliners Podcast. Learn more about ROSEN — the global leader in cutting-edge solutions across all areas of the integrity process chain.
- Integrity Management (IM) (Pipeline Integrity Management) is a systematic approach to operate and manage pipelines in a safe manner that complies with PHMSA regulations.
- ECA (Engineering Critical Assessment) is a type of analysis that evaluates the integrity of pipe based on its material properties to determine whether a given flaw is safe under specified loading conditions.
- PHMSA (Pipeline and Hazardous Materials Safety Administration) ensures the safe transportation of energy and hazardous materials.
- MAOP (maximum allowable operating pressure) was included in a bulletin issued by PHSMA informing owners and operators of gas transmission pipelines that if the pipeline pressure exceeds MAOP plus the build-up allowed for operation of pressure-limiting or control devices, the owner or operator must report the exceedance to PHMSA on or before the fifth day following the date on which the exceedance occurs. If the pipeline is subject to the regulatory authority of one of PHMSA’s State Pipeline Safety Partners, the exceedance must also be reported to the applicable state agency.
- MAOP Verification includes six approved methods for reconfirming MAOP, as outlined by PHMSA in the recent Mega Rule: pressure test, pressure reduction, engineering critical assessment (ECA), pipeline replacement, pressure reduction for pipeline segments with a potential impact radius less than or equal to 150 feet, or alternative technology. If pipeline operators do not have the necessary information or records to confirm MAOP, they must use one of these methods to verify MAOP.
- Corrosion in pipeline inspection refers to a type of metal loss anomaly that could indicate the deterioration of a pipe. Inline inspection techniques are used to evaluate the severity of corrosion.
- Cracks in pipeline inspection refer to breaks, splits, flaws, or deformities in the surface of a pipe. Inline inspection tools are used to evaluate the severity of the crack.
- Girth Welds join two pipes along the circumference to enhance the viability of the pipes when placed into the field. Girth welds are helpful reference points to detect the location of an anomaly in the pipe.
- ILI (Inline Inspection) is a method to assess the integrity and condition of a pipe by determining the existence of cracks, deformities, or other structural issues that could cause a leak.
- Materials Property Verification (MPV) is the process of identifying the fundamental make-up — or DNA — of a piece of pipe based on existing information such as as-built drawings, pipe books, mill certificates, hydro test pressure records, etc.
- ROSEN offers a Material Property Verification solution that closes the gap on unknown material information and provides a detailed picture of the pipeline’s DNA.
- API Recommended Practice 1173 established the framework for operators to implement Pipeline Safety Management Systems (SMS). A significant part of this recommended practice is a training and competency aspect.
- PipelineSMS.org is a useful resource with various safety tools that was developed by pipeline operators to help other operators enhance safety in their operation. Read the website resources or email firstname.lastname@example.org with inquiries.
- The Plan Do Check Act Cycle (Deming Method) is embedded in Pipeline SMS as a continuous quality improvement model consisting of a logical sequence of four repetitive steps for continuous improvement and learning.
Using ECA For MAOP Re-Confirmation: Full Episode Transcript
Russel Treat: Welcome to the Pipeliners Podcast, episode 194, sponsored by ROSEN, the global leader in cutting-edge solutions across all areas of the integrity process chain, providing operators the data they need to make the best Integrity Management decisions. Find out more about ROSEN at ROSEN-Group.com.
Announcer: The Pipeliners Podcast where professionals, Bubba geeks, and industry insiders share their knowledge and experience about technology, projects, and pipeline operations. Now, your host, Russel Treat.
Russel: Thanks for listening to the Pipeliners Podcast. I appreciate you taking the time, and to show the appreciation, we give away a customized YETI tumbler to one listener every episode. This week, our winner is Ian Cragun with Diversified Utilities. Congrats, Ian. Your YETI is on its way. To learn how you can win this signature prize, stick around till the end of the episode.
This week, Mark Wright, Principal Engineer for Integrity Solutions with ROSEN, joins us to talk about the use of engineering critical analysis for MAOP reconfirmation as a risk management approach. Mark, welcome to the Pipeliners Podcast.
Mark Wright: Thank you, Russel. It’s good to be here.
Russel: Tell us about yourself. How’d you get into pipeline? How’d you get into Integrity Management?
Mark: I think pipeline and Integrity Management was probably a little bit of a happy accident. I’ve worked in a few different industries like chemical process and some real downstream stuff, but an opportunity arose about 10 years ago with ROSEN. I took it and here I am.
Russel: I ask you then to talk about ECA as a way to do MAOP reconfirmation. I know that this is a big topic. There’s some new rules out around all of this. Maybe a good place to start is just a really simple question. What the heck is ECA?
Mark: ECA is just an assessment, the common assessment that pipeline operators have to do periodically. We have to do the same thing, but this one is intended to simulate the conditions of a hydrostatic test. If you need to reconfirm your MAOP, instead of taking all of the time out to do an actual hydrostatic test, you can simulate that through analytical means. That is an ECA.
Russel: That acronym stands for Engineering Critical Assessment. Correct?
Russel: It’s distinct from engineering assessment, which would be the more standard thing.
Mark: I mean, the term ECA is a little bit ubiquitous. We would use it for any kind of discreet assessment, but I don’t think it’s particular to this process. We’ve wrapped it all in a ball, and we’ve called it ECA for MAOP reconfirmation.
Russel: One of the things that about lining up with Integrity Management engineers and having conversations with them is you have to decode the acronyms.
Mark: I work in an industry that is so full of acronyms and jargon. Yes, there is a code book out there. But I think that’s the same for every industry.
Russel: I think that’s true. I think that’s one of the things I try to do in the podcast, is be the decoder for all the various engineering disciplines, right?
Mark: Yeah. We have our own language to protect ourselves, I guess.
Russel: It’s easier than saying all those big, long, multi-syllable words, I suppose.
Mark: Yes, exactly. [laughs]
Russel: ECA, in this context, we’re talking about a particular type of assessment, designed to be a replacement for a hydro test. What are the things you have to do in order to be able to do an assessment that would replace a hydro test?
Mark: The rationale behind that in the new rule is that — through various failure investigations and things like that — the regulator found that a lot of the failures, one of the underlying problems was that people hadn’t really substantiated the MAOP and didn’t know in sufficient detail what materials were in the ground and things like that.
They’ve explicitly looked for a way to make up that gap. When we do an ECA for MAOP reconfirmation, I think the easiest way to think of it is that there’s a menu if you went to an upmarket restaurant. There’s a set menu, and then there’s an à la carte menu. The set menu is quite comprehensive, so you have to look for anything that’s a degradation mechanism, such as corrosion, cracks, seam weld anomalies, dents, wrinkles, any kind of other geometric anomaly.
Then there’s a few little à la carte items, which are things like hard spots and any kind of problems with girth welds. Those are really on performance metrics. If you’ve suffered any of those in the past, then you’re going to have to look for them, but that set menu is really quite comprehensive.
Russel: Interesting. Does a regulation lay out all of that in detail?
Mark: Yeah. There are a couple of must statements in the regulation. There’s not an awful lot of wriggle room if an operator chooses to go down this path. It really is quite comprehensive. An ECA, if you’re going down that path, it means you’re going to do some kind of inline inspection. Explicitly, there’s a range of technology that you’re going to have to run and assess and get that through the assessment.
Russel: Does the rule make allowances for anything where you can’t physically run a tool for other kinds of data collection to be able to do this type of assessment?
Mark: There’s no room in that book. If you take a step back, then you have to go back to the intent. The intent is MAOP reconfirmation. There are multiple routes to do that, including you could do a hydro test. I think there are six options that are laid out in the regulation, and ECA is one of them.
With the explicit nature of how an ECA should be done and achieved, if there’s a reason that you can put an inspection gauge through it, then you’re probably going to go down one or the other routes rather than trying to adapt to that.
Russel: I guess one of the things that’s driving operators to use ECA is it has some advantages over a hydro test. Maybe we should talk about…To those that don’t know, what is involved in doing a hydro test?
Mark: A hydro test, basically, you fill the pipeline full of a test medium, usually water. You pressurize air over water to a sufficient test pressure. You hold that pressure. If the pipeline survives intact, you’ve passed the hydro test.
The problem with that, or I guess the decision that operators are going to take, is that it takes quite a lot of time. In a recent loose survey that we did on a webinar, I think the consensus was somewhere between four and six weeks would be a rough time frame for a hydro test. That is a very, very long time to take a pipeline out of commission and to do that.
Russel: There’s no doubt. That’s a long time for a pipeline to be out of service. I know enough about hydro testing. Again, I’m a novice, but I know enough to know that there’s a lot beyond the out-of-service. There’s a lot of operational difficulties with the idea of emptying a pipeline, filling it with water, closing it up, pressurizing it up. There’s a lot that goes into all of that.
Mark: Where you get the water from, where the water then goes thereafter because it’s now contaminated, so environmental issues that are associated with that. There is a litany of operational challenges that are associated with it. That’s why inline inspection is an appealing option because that minimizes that.
Russel: I think there’s another really big benefit that might not be understood by the industry. That is, if you run a hydro test, what that does is it says I can take the system and I can run it up to this pressure, and it holds that pressure.
Generally, when you run a hydro test, you’re running the pressure up above what your MAOP that you’re trying to validate is. The assumption being that if I operate that lower pressure, I’m fine. It will identify anything that’s bad enough to break, but it really doesn’t tell you anything other than that.
Mark: Yeah, and that is one of the significant challenges. The perception of hydro test is generally that it’s a very objective assessment. If something’s going to fail, it’s going to fail. That is mostly true, but there are several things that can happen as a result of hydro test.
Let’s say that you have a very deep corrosion pit, which is not very long in terms of its length. That will likely survive a hydro test even though it’s almost through wall. A week later, that could start leaking. Now, I don’t think it’s going to rupture. I think that’s going to leak if it’s going to fail at all, but it’s something that, when running a hydro test, it’s a data point that could never be captured.
There’s also the issue of when you run the test pressure that high, you’re putting a lot of stress on the material. If there are pre-existing anomalies in there such as cracks and things like that, particularly in seam welds, you can react a bit or extend growth mechanisms in those.
When we do hydro testing, we get this phenomenon called pressure reversals, where if you are performing like a spike test, where you’re putting the pressure up and down, you can fail at a low pressure and then you’ve just held it out, because you’ve reactivated something that was pre-existing but dormant, and you’ve just made it worse.
I’m not actually a big fan of hydro testing. I think it’s a good test at the start of a pipeline, and depending on what you’re trying to address, it can be a good option. I’m quite a big fan of things like ECA and all of the data that I’m going to collect alongside that and the knowledge that I’m going to gain about, not just the pipeline condition now but really going into the future.
Russel: That’s a great point, Mark. I’m not an IM guy, but I am a bit of an IT guy. I do understand data. One of the things that is true is to do an ECA, you have to gather a whole lot of information, and that information is going to be way more detailed and robust than what I’d get from a hydro test.
I’ve actually created a whole foundation for an Integrity Management program. It should have data that will allow me to identify what kind of threats I have, what kind of features I have, and so forth.
Mark: Absolutely. It’s really the interaction between a lot of the new rules that will drive you towards that. In the old periodic assessments, maybe you had your pipeline data in some kind of database or pipe book.
With the new advent of this material properties verification [MPV], there is a very, very high standard of the knowledge that you have to have and proof that you have in order to substantiate what you’re doing on the assessment and what those outcomes are.
You end up in a situation, if you’re going down the ECA route, the bar is significantly higher than it was previously. If you go through that process, you will probably have a much more thorough understanding of what you’ve got in the ground and its condition than you’ve ever had at any point in the life of the asset.
Russel: Walk me through that a little bit in the details. What kinds of things do you have to know either with a greater level of confidence, or what kind of details do you need to pick up that are above and beyond what has historically been done in order to do this ECA?
Mark: Simple things. Material properties, diameter, wall thickness, toughness if you’re dealing with cracks, all of those specifically called out elsewhere in the new rule. In the ECA part, there are specific rules about how those assessments are conducted and the types of input data that you can use.
If they are not substantiated by verified material test records, then there’s a hierarchy of the kind of data inputs that you can use. You can’t just say, “Well, this is what I think it is based on my history.” You have to substantiate it in some way.
For a lot of pipeline assets, there’s been a lot of transfers, and legacy, and grandfathering, and things that have happened over the years that mean not necessarily all of the original data to substantiate the way that we operate pipelines has followed the asset over time, and so there are some significant gaps out there.
Russel: My mind blew up a little bit there. You’re talking about two kinds of fundamental issues. They’re first cousins to one another. One is the fact that to do this ECA, I need more data. That data has to be substantiated in some way, and the mechanisms for that are defined in the rule.
Then the other reality is you have to know what data you do and don’t have. That in itself, I think, for a lot of operators could be challenging because it’s one thing to believe you have the data. It’s another thing to know whether or not you have that data, and is that data substantiated?
Mark: This is the real complicating part of this. Like I said earlier, it’s a significantly higher bar with many more moving pieces. I think the industry’s got a reticence at the moment. That’s the feeling that I’m getting over what this means and how it’s going to transpire.
As long as the data inputs are good, I think the assessment parts and are pretty straightforward. It is managing all the moving pieces, and that’s the complicating factor.
Russel: What are people doing to get a footing to be able to do this analysis?
Mark: It is a range of different things. The first thing that they’re doing is trying to get that data in order, and that is a significant challenge. Doing the actions necessary, if you’re starting from scratch to collect all the data that you need to run this is going to take a while.
For those operators who have already anticipated this and have been working on it for some years, they’re in a pretty good position. With maybe one or two gaps, there’s going to be a lot of inline inspection to confirm material properties.
There’s going to be a lot of in-the-ditch work, and there’s going to be a lot of work in test houses to verify all of those findings, or that’s going to be collected up into databases. Once that’s done, if they’re going down the ECA route, then it’s going to be an awful lot of inline inspections, multiple on each line. Vendors are reacting to that.
Finally, you’ve got the actual assessment routine. That’s teams of engineers, perhaps doing things in the past they were probably not familiar with such as things like crack assessments and things like that. They’re not always things that are commonly done. Expanding that and the skills and knowledge that people need to do that is going to be a critical factor as well.
Russel: [laughs] It’s interesting. If you look at a large operator, they can generally can build a team and they can build into that team. The expertise, they need to do all these things just because they have the economies of scales to justify. But for the smaller and even the mid-tier operators, that may not be the case.
I think historically, what they’ve attempted to do is simplify their programs and figure out what the threats are and what a program would make sense for their asset, and then that’s their program. That kind of approach doesn’t really work for ECA, I would think. Am I tracking here?
Mark: I think so. Given the kind of set menu nature of it, at its very best level, if you are a small operator, you’re probably going to be dealing with technology and assessments that you likely haven’t seen in the past. There’s a lot of knowledge acquisition to go through to get to that point. The help is out there. There are lots of people who are capable and set up to help people in that regard. The market does react.
Russel: Absolutely. That’s where I was going because I think what you have to think about if you’re going to build a program to do this is you have to think about, “What are the resources I need, and how am I going to get them?”
That might look at a strategic plan around how you’re going to do it, what kind of subcontractors and consultants you need to support implementing and maintaining a program like this.
Mark: The option is out there for a turnkey. It’s a relatively lengthy process, but you could turnkey the whole lot. There are people out there to support them, but if you’re looking to optimize that, then working out who can do what and who can do that best is probably a very, very sensible plan.
There is always a good reason to try and bring knowledge and skills into the operator. This is an opportunity, but effectively it’s a short-term technical challenge. This is not an ongoing assessment. All of the pipelines in the scope have to be done within the next 15 years. That’s the need.
Russel: One of the morals of this story is if you’re putting in new pipe, you need to get all this data and make sure you have it in a way that it meets the requirements. That’s the first thing because that greatly simplifies your whole program.
Mark: Oh, absolutely. I’ve been in some conversations with the companies that construct pipelines. That situation is improving. I think people recognize that they need good, strong, accurate, reliable digital records.
Some of the people who would design and construct pipelines associate in that task with developing a database, which holds all of that data and the digital records that support all of the engineering that went into it.
The old days of this design book somewhere in a cupboard or in the archives somewhere disappearing — now there will be a hard drive, which is backed up in triplicate available to people who need to do those kinds of assessments all in systems of record.
Russel: I owned a small piece of pipeline at one time, and I remember a conversation about “Where are the X-rays?” and what it took to find the X-rays. That’s the nature of old paper, film kind of records. They ended up in a file cabinet someplace.
Nowadays, you can digitize all that and store it in an orthogonal way, but I think we’re probably still learning about all that. I know we’re going to do another podcast here in a few weeks on that subject, specifically. I don’t want to take too much of the wind out of those sails.
I do want to ask another train of questions, if I might. One of the things that occurs to me is there’s a lot of talk about doing risk management approaches around my IM programs. One of the things that is a predicate to being able to do effective risk management is to have a well-ordered, well-understood data structure.
I would think that on the backend of an ECA project or program, you’re going to be in a much better position to apply risk management to your overall integrity program, then you would be ahead of having all that data collected, organized, and verified. Can you talk to that at all?
Mark: Yes. You’re getting into a pet subject of mine. Risk management is Integrity Management, and Integrity Management is risk management. The two should be indivisible. You’re right that a thorough knowledge of the asset condition is required in order to make sense of any kind of risk management or risk mitigation strategy.
I think a lot of assets — particularly with the regulatory structure that we have in the U.S. — we do the assessments, we do everything we can to try to meet the regulation. That’s not quite the same as complete risk management. We use risk as a baseline to prioritize things but not necessarily manage the risk as it were.
That’s improving a little bit, but what I would anticipate on the back of ECA is that there’s going to be at least some operators out there who because they’re going to deal with technology and tools that they’re perhaps not as familiar with, they’re going to discover that they probably had some threats in their assets that they will maybe not aware of before.
Building that awareness overall is probably going to result in some short-term shock, but it is going to be good for the long-term health of the assets and the industry.
Russel: You just said a mouthful there, Mark. You said a whole lot in a little bit. I think you’re right. I think you’re absolutely right. This whole conversation is part of what it’s going to take us to get to an order of magnitude improvement on our safety performance as an industry.
Mark: We should bear in mind that we, as an industry, if you start sometime in the 1970s, then I think we’re about fivefold better than we were at that point in terms of how many pipelines fail and how much spillage we have, but there is increasing public and governmental scrutiny of the operations. Rightly so, there is still significant room for improvement.
The industry has improved so much, but it’s fair to say that in recent years, it’s plateaued a bit. I think the new rules are in response to that. I think re-establishing a baseline through MAOP reconfirmation and ECA is a good idea, but there are further steps that we should and could take.
Russel: Part of what we’ve got to do in order to be able to take those steps is we’ve got to be able to apply technology more effectively.
If you look at the last 30 years in pipelining, a lot of the progress we have made has been around what we do about the metal, the cathodic protection, and the Integrity Management — the tools and how those tools have improved in our ability to do more complicated algorithms, gather more data, get information that’s more precise, more comprehensive.
What we haven’t done much of yet — and it’s probably the next wave — is we haven’t done a whole lot of management science around all that data. That’s what’s coming next. Everybody talks about data science, and analytics, and all that kind of stuff.
Again, I think there’s a lot of opportunity there, but for that to really make a difference, industry-wide, there needs to be some standards around the data. There needs to be some information-sharing and some other things to be able to get there. We’re moving that direction. ECA, one of the promises is that it sets a platform that allows you to get there.
Mark: Yes, it does. There are probably three elements to it. There is the purely technology and technical element, which is over there. I don’t think that’s where our problems lie. There is the data element, which I think right now is the significant issue and the thing that we need to solve, and I think you’re right in identifying that ECA as an opportunity to get alignment on there.
The third element of that is organizational — both in terms of our individual organizations and our industry as a whole. We do not share enough data, and knowledge, and lessons learned, and all of the things that we know from other industries that represent good practice. We’re a very insular industry, both as an industry and the individual companies.
Russel: Well, even inside of the company, sometimes you get into that because you tend to have these…I don’t think we do it intentionally. I don’t think there’s not there because we’re not good teams. It’s just that we have these various highly technical domains that are dissimilar, and it makes that collaboration challenging.
Mark: Absolutely. As a risk practitioner, I’m constantly challenged to get people over here that are working on maybe something like corrosion problems together with people over here who are dealing with geotechnical problems. They don’t speak the same language. Trying to get them to work together, and especially to prioritize and work out what’s really important, is a significant challenge because each one’s fighting their own battles.
Russel: That’s absolutely true. What you’re really teeing up is that as we begin to get a handle on the data, the next thing we’re going to need to get a handle on is what I would call the quality systems or the safety management systems around all of this.
Mark: A couple of years ago, there was an API document that was released 1173. That really built on some international standards like ISO 55000. What that talks about is not quite quality management. It’s different. Quality management specifically looks for a reliability rate. It says we need to be right 99.9 percent times out of whatever, because it’s a factory standard.
Safety management is slightly different. Safety management means that we have to be cognizant that failure is not an acceptable outcome. This search for zero failures should embrace more of a safety management culture than the quality management culture, although they have some symbiotic elements.
Russel: They’re first cousins. You make a very good point, and I’ve done a number of podcasts on this subject. This is a passion of mine. It’s really about understanding the outcome you’re trying to achieve.
In a quality manufacturing standard, the outcome is, “I want a product without defects.” Then the safety standard is, “I want the operation without failure.” That is a very subtle but very important differentiator. A lot of the processes and the science and so forth behind all that and even the stuff going back to Deming’s original work, it all comes from that.
Mark: What you’re looking for is an organization that’s working together for a single goal, and that goal is zero failures. If you bring that conversation back to something like ECA and all of the moving parts, you see all the different people, and roles, and resources that are involved in.
That goes through the organization from the most highly technical person who is leading that operation right down to the person in the archive room who is responsible for having a digital record of the input data that you’re looking for. It’s right through.
Ensuring that that is correctly resourced, it’s the right people with the right training and right competence, doing all of those things is critical. That’s what safety management is. It’s making sure that the right people are in the right place with the right resources to achieve the goal. It’s a very organizational thing, not a technical thing. First cousins is probably the best description.
Russel: I think that’s a great place to leave this conversation, Mark. I really appreciate you taking the time and coming on.
I hope you enjoyed this week’s episode of the Pipeliners Podcast and our conversation with Mark. Just a reminder before you go, you should register to win our customized Pipeliners Podcast YETI tumbler. Simply visit pipelinepodcastnetwork.com/win to enter yourself in the drawing.
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