This week’s Pipeliners Podcast episode features Mark Piazza discussing the new API Recommended Practice 1188 (Hazardous Liquid Pipeline Facilities Integrity Management). The episode covers the content of API 1188 and how pipeline operators can incorporate the RP into their Integrity Management Program.

In this episode, you will learn about what RP 1188 is, why the industry thought it was necessary, how it relates to other RPs, and how to overall improve facility integrity management.

API 1188: Show Notes, Links, and Insider Terms

• Mark Piazza is the Senior Policy Advisor at API. Connect with Mark on LinkedIn.
  • API (American Petroleum Institute) represents all segments of America’s oil and natural gas industry. Its nearly 600 members produce, process and distribute most of the nation’s energy. The industry supports millions of U.S. jobs and is backed by a growing grassroots movement of millions of Americans. API was formed in 1919 as a standards-setting organization. In its first 100 years, API has developed more than 800 standards to enhance operational and environmental safety, efficiency and sustainability.
  • Read API’s press release announcement of the new API 1188 (New API Standard Provides Framework for Pipeline Facility Safety Management Program).
• Pipeline SMS (Pipeline Safety Management Systems) or PSMS is an industry-wide focus to improve pipeline safety, driving toward zero incidents.
• The PRCI (Pipeline Research Council International) is the preeminent global collaborative research organization of, by, and for the energy pipeline industry.
  • Read more about the PRCI collaborative research projects, papers, and presentations.
  • Listen to recent Pipeliners Podcast episodes with PRCI President Cliff Johnson.
• API RP 1188, Hazardous Liquid Pipeline Facilities Integrity Management, is a recommended practice that provides a framework for pipeline operators to develop a comprehensive pipeline facility integrity management program to strengthen efficiencies, prevent incidents, and further reduce greenhouse gas emissions.
• PHMSA (Pipeline and Hazardous Materials Safety Administration) is responsible for providing pipeline safety oversight through regulatory rule-making, addressing NTSB recommendations, and other important functions to protect people and the environment through the safe transportation of energy and other hazardous materials.
• OSHA (Occupational Safety and Health Administration) is an agency in the United States Department of Labor. Their mission is to assure safe and healthy working conditions for working men and women by setting and enforcing standards and by providing training, outreach, education, and assistance.
• PDCA (Plan-Do-Check-Act) is a management method to enhance control and build continuous improvement into processes.
• Pipeline Right-of-Way is a strip of land encompassing buried pipelines and other equipment allowing them to be permanently located on public and/or private land to provide energy products to consumers.
• API RP 1160, Managing System Integrity for Hazardous Liquid Pipelines, is a recommended practice providing a process for establishing safe operations of hazardous liquid pipelines, including robust assessments of potential risks and the establishment of systems to safely and sustainably manage them throughout day-to-day operations.
• API RP 1176, Assessment and Management of Cracking in Pipelines, is a recommended practice providing pipeline operators with best practices in the integrity management of cracks and threats that give rise to cracking mechanisms.
• IPE means incidents impacting the people or the environment.
• API TR 1189 includes methods to prevent, investigate, mitigate, and remediate internal corrosion threats in liquids pipeline facility operations. This technical report will also highlight functional use cases, such as cases where internal corrosion was successfully managed and cases where internal corrosion resulted in a leak. TR 1189 is expected to be published by the fall of 2022.
• AMPP (Association for Materials Protection and Performance) is a global community of professionals dedicated to materials protection through the advancement of corrosion control and protective coatings. AMPP protects infrastructure and assets worldwide through member and workforce education and credentialing, company accreditation, technological innovation, and global standardization. Formerly known as NACE.
• ILI (In-line Inspection) is a method to assess the integrity and condition of a pipeline by determining the existence of corrosion, cracks, deformations, or other structural issues that could cause a leak.
• API RP 1184, Pipeline Facility Construction Inspection, provides detailed requirements for inspectors covering all aspects of facility construction, stop work authority, a code of conduct for pipeline inspectors, and more. 
• API RP 1169, Pipeline Construction Inspection, covers the basic requirements and their associated references needed to perform inspection activities safely and effectively during onshore pipeline construction. This recommended practice provides the details related to the role of the operator’s pipeline construction inspector, in terms of monitoring and inspection requirements throughout the pipeline construction process.

API 1188: Full Episode Transcript

Russel Treat:  Welcome to the Pipeliners Podcast, episode 238, sponsored by the American Petroleum Institute, driving safety, environmental protection, and sustainability across the natural gas and oil industry through world-class standards and safety programs. Since its formation as a standard-setting organization in 1919, API has developed more than 800 standards to enhance industry operations worldwide. Find out more about API at API.org.

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Announcer:  The Pipeliners Podcast, where professionals, Bubba geeks, and industry insiders share their knowledge and experience about technology, projects, and pipeline operations. And now, your host, Russel Treat.

Russel:  Thanks for listening to The Pipeliners Podcast. I appreciate you taking the time, and to show that appreciation, we give away a customized YETI tumbler to one listener every episode. This week, our winner is Scott Fannin with Pacific Gas and Electric. Congratulations, Scott. Your YETI is on its way. To learn how you can win this signature prize, stick around until the end of the episode.

This week, Mark Piazza with API joins to talk about the new API Recommended Practice 1188, Pipeline Facility Integrity Management. Mark, welcome to the Pipeliners Podcast.

Mark Piazza:  Thanks, Russel. I really appreciate the opportunity to share the great work being conducted by API through its committees and our member company SMEs that lead development of RPs and standards, and really appreciate you providing a forum for sharing and learning across the industry.

You know that that’s a big part of pipeline SMS. We have an internal sharing and learning subteam at API, so again, I really appreciate the opportunity to share this information.

Russel:  Likewise, Mark. I appreciate you coming on. Whenever there’s a new standard that comes out, I always find it very valuable for someone who has the background and the context to talk about that, because it makes those standards so much easier to read, understand, and utilize. Thanks to you as well.

Mark:  In addition, we always look for deployment opportunities. We spend a lot of time developing these RPs, so the opportunity to share this information, like I said earlier, really does help with that deployment, and hopefully the uptakedate of the RP into operators’ integrity programs.

Russel:  Yes, exactly. Mark, if you would, why don’t you tell people a little bit about your background and how you landed at API?

Mark:  Like Jerry Garcia said, “What a long, strange trip it’s been.”

[laughter]

Mark:  17 years in the industry. Got my start in the pipeline industry at Pipeline Research Council International. I think most of your listeners know PRCI pretty well. You’ve had Cliff Johnson on several times to talk about some of the PRCI programs. Spent seven years there.

Following PRCI, I had the opportunity to work at Colonial Pipeline Company in their Asset Integrity Program and also Regulatory Compliance Program. Again, I learned a lot from the operating company perspective to tie to the research program management that I had done at PRCI, and actually bringing a lot of that research from PRCI into Colonial integrity programs and continuing to be involved in that process.

More recently, it’s been about seven months now that I’ve been at API. I’m a senior policy adviser in the midstream group, working with the pipeline team on addressing issues related to pipeline safety, and advocating, again, for best practices, developing recommended practices and standards, and working with our member companies to solve problems.

Russel:  I always think it’s a great thing when somebody with a technical background and skillset is working in the policy world, because it certainly is nice when people who are putting together policy or supporting that effort have some really understanding of what’s required and the technical nitty gritty of how this stuff works.

Mark:  Yeah, it can get very complex when you get into the technical nitty gritty, right?

Russel:  Yes, no doubt, no doubt. I asked you to come on to talk about the new RP 1188. This is a brand new standard, first edition, recently released. Can you tell us a little bit about what RP 1188 is, and why did API and industry think this was something that was required?

Mark:  RP 1188 covers integrity management of liquidall types of liquid facilities. It’s pretty broad in its context as far as facility integrity goes. It includes terminals and pipeline stations and piping systems within terminals. Really, anything within the boundary lines of a pipeline facility. It focuses on pressure-containing components that are used in transport and/or storage of hazardous liquids in these pipeline facilities, and also includes tanks. There’s other standards related to tank maintenance, tank integrity, tank construction, the API 650, 653, 651. There’s several other recommended practices out there that deal with tanks, but from the integrity side, the risk perspective, it’s also covered in the RP 1188 document as well.

There’s several other recommended practices out there that deal with tanks, but from the integrity side, the risk perspective, it’s also covered in the RP 1188 document as well. I think the genesis for 1188 was really the pipeline integrity group within API looking at data and statistics for facility incidents from the PHMSA database, as well as some internal operator databases. Noticing and recognizing that, while facility incidents are generally less problematic than those on the right of way, there were still a number of incidents occurring – it was clearly higher than what we seeay on the pipeline right-of-way – I think just to improve programs, Russel, that were already in place.

Facility integrity is not a new thing. This RP, being the first edition, I don’t want people to walk away thinking that facility integrity is a brand new issue that we’re just now addressing. Operators have been implementing programs for years and years.

There were a lot of different approaches being used. There was no consensus document, guidance document, to provide to pipeline operators to use as a basis for really developing that program on a consistent basis, using some of the best practices that operators, as I said, had already been implementing these programs. Let’s bring some of those learnings and experiences back, and let’s also keep driving for continuous improvement. That’s a big part of pipeline integrity programs, reviewing data, reviewing incidents, and becoming better at what we do. That was really the background and basis for the RP 1188 document.

Russel:  Thanks for that. I have a question, and this may be a little out of left field. What comes up for me, when I think about pipeline facilities, and in particular, liquid facilities, those assets, if you will, they can be governed by OSHA as well as PHMSA, versus just pure PHMSA governance. It’s not like there’s no standards, and processes, procedures, etc., for effective integrity management there, but with the advent of pipeline safety management, and the desire for us as an industry to learn together and move forward together, how does this recommended practice fall into that?

I’m going to do a little bit more elaboration about the question, but where I’m coming from is I believe that we have a need in our business to address these gaps and come up with pipeline specific RPs where they don’t currently exist. Anyways, awfully long, convoluted question. [laughs] I’ll let you respond, Mark.

Mark:  I’ll try and answer that. I agree with you, there are several regulatory elements, programs that could be part of operating a facility. You mentioned OSHA.

There’s also just state programs for things that aren’t PHMSA-regulated assets that a lot of our operators do manage on a routine basis. 1188 was primarily developed for facilities where there are some PHMSA-regulated elements but can be expanded more broadly. To the extent that it can apply to some of the issues that need to be addressed with regard to OSHA requirements under, say, a PSM program, and 1188 makes sense to apply as a practical approach, and help development a comprehensive integrity program around a different regulatory requirement, I don’t see that there’s any issue there.

I think that applies for all of the RPs or any other industry standard that generally makes sense to apply to, even if it’s not specifically a hazardous liquid pipeline facility, applying it, say, let’s say to a natural gas compressor station. If that makes perfect sense, I think operators have full discretion to apply it as appropriate. I also believe that a lot of our RPs, Russel, make kind of a statement, that it’s really geared towards this program, but if it is applicable to another, and an operator can substantiate the use of that document in developing the program, that’s perfectly OK.

Russel:  Right. That’s not really where I come from. My come from is more of a pipeline safety management focus, and having a common technical basis to work against as an industry.

Mark:  Understood.

Russel:  What was the rationale for the development of 1188? How did the working group work through, “What are the issues we need to address, and how are we going to go about addressing those issues?”

Mark:  What we’ve typically done with recommended practices from the integrity side recently is apply the SMS plan-do-check-act process cycle, continual improvement, and we do line up the programs so that the facility integrity plan-do-check process will have different steps in the process, different things that you’re focusing on as part of that process.

Following that same wheel around, so planning what your program needs to look like, gathering data, looking at things like data integration, using that data and the data analysis to identify threats, do the threat identification, the threat assessment. “Where are my biggest threats and risks?” Then conducting that risk evaluation. Based on that, you apply inspection, reinspection principles, figure out what you need to do to continue to evaluate, and how frequently you need to do that based on the threats that you have and the technologies that are available.

One of the things that we do learn and we do know from facilities is that a lot of it’s buried and underground. Its flanges and piping, just like the mainline piping that are underground, and you can’t see it to inspect it. They’re also much more convoluted sometimes in the design of the systems. They’re smaller diameter piping for a lot of the components at facilities. The application of different approaches, different technologies is really important in understanding how frequently you need to reinspect.

Then also, looking at things like preventive and mitigative measures. Do you use things like inhibitors or biocides? Focus on dead legs. Look at what things you can do to prevent and mitigate the releases that we’ve seen at these pipeline facilities and use data as the basis for doing that, past experience. Looking, again, at those PHMSA statistics, and where we’ve seen the leaks occur, or are what the driving factors, the causal forces, [maybe factors?] etc. Then, I think as part of any program that’s implemented, you have to evaluate it. Establishing a basis for what that program evaluation needs to be. What are your performance measures? Are you looking at leading or lagging? Performance tracking and trending is obviously very important to make sure that you’re learning, you’re applying the lessons learned.

You’re seeing where you’re having positive results, and potentially seeing where you’re not having as positive a result, and making the adjustments that are necessary, again, as part of that PDCA process. We’ve been applying that. 

That applies to RP 1160, which is the more comprehensive liquids pipeline integrity management RP. RP 1176, which is the crack management recommended practice, all have that concept of using the plan-do-check-adjust. Adjust or act, people say it differently. Using that cycle as the basis for really looking at how to structure the RP, and what are the important factors to consider in that recommended practice.?

Russel:  When you were looking at the PHMSA report, the PHMSA data, I’m curious, was there anything that you saw that were like, “Oh, if we just focus on this area, that’s going to move the needle in a significant way”? Like just the type of leak or the type of risk, I guess is what I’m driving at. Anything that rose to the top? 

Mark:  We saw a lot of incidents with corrosion. By far, corrosion and equipment and material failure at facilities. The corrosion is tied to primarily internal corrosion. Not exclusively, but we see a much higher number of incidents of internal corrosion at facilities than we generally see on pipeline right-of-ways.

The clear distinction between and facilities is that the facility releases tend to be much smaller in volume, controlled on the operator’s property, and the term impacts the people and the environment. They tend to not be IPE incidents, where your right-of-way releases can be.They have a much higher proportion of IPE incidents on right-of-ways than we see at facilities. Facility numbers are, as I mentioned earlier, higher than we see on the right-of-way, although coming down over the past few years, we’re seeing some improvement in that area.

Generally speaking, again, it’s really the facility releases tend to be small, tend to be controlled, and again, equipment failure and corrosion are what drive those. Volumes spilled, again, total year by year, they’re coming down.

We’re seeing improvements in the effective approaches that operators are using. The other thing that really comes out significantly with the internal corrosion is the number of crude oil incidents in facilities is certainly higher. That’s a big part of a technical report that I think we’ll talk about, TR 1189, which is a complement to RP 1188, focusing specifically on the threat of internal corrosion at facilities and providing some guidelines on how best to manage that.

Russel:  Why don’t we go ahead and just segue? That’s a great transition. Tell me a little bit about what TR 1189 is, and how does it work together with RP 1188?

Mark:  Thanks, Russel. Great question. 1189 is, as I said, a technical report, versus a recommended practice. These are generally developed on a very specific issue and topic, and often complement recommended practices. 1189 focuses on internal corrosion at facilities, looking at what are the contributing factors, whether they’re biological, chemical, operational. Considering facility design, whether it’s flow rates through the facility, piping elevations, other things that influence and affect internal corrosion.

It’s also looking at, again, those preventive and mitigative measures that can be taken, based on some of the analysis that’s done, and detailed evaluations of the factors that lead to internal corrosion. It’s also going to include several case studies to help operators better understand how all those factors tie into an effective internal corrosion strategy. Also, we want to make sure that we’re collaborating, coordinating with the other standards organizations who are working on similar issues. I know that AMPP has a task group, 370, that’s looking at a comprehensive approach to corrosion management for an entire company, an entire system. We want to make sure that we’ve got the coordination, and we’re feeding that information into them as well.

Russel:  Sorry, Mark, what is AMPP?

Mark:  Oh, Materials, Performance…I, wow, Russel, you stumped me.

Russel:  Association of Materials Performance…I don’t know. I’m guessing. [laughs]

Mark:  It’s the former NACE, which is the National Association of Corrosion Engineers.

Russel:  Oh, right. [laughs] That just made me think of a Monty Python sign, “We are the pipeliners formerly known as NACE.” [laughs]

Mark:  Yeah, perfect. AMPP is an acronym that has not been emblazoned in my brain yet, but I’ll get there soon.

Russel:  Right, that’s funny. That’s helpful to understand. How are folks going about implementing this recommended practice? I think, whenever a new recommended practice like this comes out, and the industry’s already doing something, how are they going about implementing this?

Mark:  That’s a great question, and glad you asked that. As I said, the program’s been going on for a while. Implementation has been underway, but some of the things we’ve noticed recently whether it’s by communication or awareness of RP 1188, or just the industry statistics, and the operators’ continual push for zero incidents, and making sure that we’re addressing the incidents, doing the analysis, root cause evaluations, and then the improvements that need to be made.

We had a workshop following the release of RP 1188, and it was pretty clear that operators have some pretty sophisticated programs and approaches that they’re taking to facility integrity management. We also had the pipeline conference recently in May of 2022, where there were several presentations that, again, focused on facility integrity, approaches that companies are taking, some case studies and lessons learned on various elements of facility integrity which were very well received and very well attended.

Operators are looking at really breaking facilities into what’s termed “circuits.” The circuits are based on a review of design data, facility drawings. You define a circuit by flow path, flow velocities, and other operational factors, and maybe even age, how many components you have. That seems to be a relatively standard approach that a lot of operators are taking to really look at how to approach development of a facility integrity program, and of similar circuits or unique circuits. Basically, using that circuit evaluation process as a way to calculate threat scores.

Different companies do it in different ways. It depends on the operation. It depends on the complexities, the type of materials that you’re moving through your system. Again, that design for low flow and dead legs at facilities. Basically, that was one thing that’s learned. That’s a process that everybody’s using. We’re also looking at improvements to the threat assessment process, and then also looking at are there opportunities to modify facilities to mitigate those threats that we talked about, or provide easier access to, let’s say, inspecting tank lines.

There was a great presentation at the workshop where a company had made an adjustment to add traps and pig launchers, ILI tool launchers, to their tank lines that they didn’t have previously. There’s a lot happening. I think operators are taking a lot of different approaches. Again, it depends on the facility, but we’re seeing a lot of activity. We’re seeing a lot of uptake, and again, advocacy by our membership to really go out and apply 1188 has been made clear.

Russel:  Interesting. As I’m listening to this, Mark, I just had an ‘aha’ about the challenge of integrity management in a facility versus what you would do in a pipeline, because of the nature of the valving and the flow paths, and how that facility is run would impact the risk and threats associated with integrity management.

I’ve never really thought about that before. That’s a bit of an ‘aha’ for me.

Mark:  Agreed, Russel. The risk models, as you know, for the mainline segments are pretty well developed and established. Risk modeling at facilities is different. There’s different approaches. Some of those risk modeling elements are more qualitative than, say, quantitative, which a lot of pipeline operators are now using on the right-of-way.

It presents its challenges, that’s for sure. As I mentioned, I think that’s one of the reasons this breakdown into circuits makes sense. Trying to segregate your facility based on, it could have really small diameter drain lines that are at a facility. You could also have 36-inch tank lines. The complexities, again, of the assets that are there are pretty unique. A lot of the equipment can be interdependent. It is a different thought process from a risk perspective.

Russel:  As I’m just thinking about it, it seems to me that it would be somewhat more complex, because you would be having to decide, what are the various cases I’m going to evaluate?

Mark:  Yeah, it can be.

Russel:  Interesting. Very interesting. I think the other question that comes up for me, about 1188 and what we’re talking about here, is how does this also relate to the Recommended Practice 1184, which is new facility construction? I would think that these things ought to be aligned.

Mark:  They are aligned. 1184 was also recently released, and is going to be tied to an independent certification program for construction inspectors for facilities, similar to what we have through API 1169 for mainline pipeline assets.

Really, 1184 just covers the requirements for inspectors for all aspects of facility construction. When you build a facility, just like when you build a pipeline, there are standards and specifications. Obviously, there’s design drawings. 1184 fundamentally assures that new facilities are constructed in a manner to ensure long-term integrity. Some of the learnings from what we’ve seen over the years of operating facilities and incidents, again, that have occurred, equipment failures, etc., you want to always bring those to updated standards, new standards that help prevent those from happening.

I think fundamentally, it’s a document that says, “Here’s how we need to do our business. Here’s how we need to ensure that assets that are constructed are reliable in the long term and are going to operate with full integrity.”

Russel:  That’s very interesting. That’s one of the things about the US market that’s different from the rest of the world, is the way we often build pipeline facilities, and how those facilities are owned, and how that ownership transitions.

This is so true, just in our business in general. There’s so much, whenever you’re building something new, the focus is to get it up and get it running, because then we have the cash flow to do the other things we need to do.

Building something from inception with a view towards how we’re going to operate it in the long term is challenging.

Mark:  Indeed, it is. The one benefit – and I think the lesson we all learn, Russel, as you alluded to – is that a lot of the transitions or acquisitions, divestitures that have occurred, transitions of operations from one company to another, drawings, and really understanding at facilities what the asset base is. That, again, presents some challenges. I think a lot of operators have now taken a very aggressive approach to any time a shovel goes in the ground and piping is exposed, it’s documented, it’s well mapped out, it’s confirmed as to its location because, again, you need to know your assets to manage it.

Back to 1184, it’s really record retention. That’s a big part of it, making sure that you’ve got a thorough process for capturing information, capturing records, and making sure that they are maintained throughout the life of the asset.

Russel:  One last question for you, Mark, before we wrap this up. What would be your recommendation to operators as it relates to this new 1188 standard for facility integrity management?

Mark:  My recommendation would be, to the extent that you have not established a robust program, 1188 certainly provides the foundation for doing that. I would say that one of the key things with regard to applying 1188, or developing any facility integrity program, is knowing your asset, knowing the infrastructure, and knowing your system. Think about the various failure modes and mechanisms that could occur, and make sure you’ve got all the preventive and mitigative approaches that are available to you. 

To the extent that you can apply new technology, because you know, Russel, we’ve talked about in the past, . Tthere’s always new technology. It’s amazing what inspection capabilities continue to evolve and continue to improve and find opportunities for applications. Think outside the box a bit for how you can address the challenges at facilities. Benchmark. Reach out to your peers. There’s a lot of smart people out there who are doing this very effectively.

Russel:  I think you just said a mouthful there. That’s making my head hurt a little bit, but that’s good. My head sometimes needs to hurt.

Mark:  I don’t want to make your head hurt, Russel.

Russel:  All right. Well, look, Mark, it’s been a pleasure. I always enjoy our conversations and look forward to having you back when API is bringing out another new one.

Mark:  I welcome the opportunity, Russel. Thanks very much.

Russel:  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 and enter yourself in the drawing.

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Russel:  If you have ideas, questions, or topics you’d be interested in, please let me know on the Contact Us page at PipelinePodcastNetwork.com, or reach out to me on LinkedIn. Thanks for listening. I’ll talk to you next week.

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