U.S. Department of Transportation Safety Administration PHMSA...

U.S. Department of TransportationPipeline and Hazardous Materials Safety Administration

PHMSA R l tPHMSA R l tPHMSA Regulatory PHMSA Regulatory PerspectivePerspectivePerspectivePerspective

Composite Piping Systems, Development, Composite Piping Systems, Development, Application, and Evaluation WorkshopApplication, and Evaluation Workshop

Springfield VASpringfield VA

Max Kieba

Springfield, VASpringfield, VAJuly 17, 2012July 17, 2012

Max Kieba PHMSA Office of Pipeline Safety, Engineering and Research Division


P t ti O iP t ti O iPresentation OverviewPresentation Overview

Code Review• Code Review• Examples of applications for

state waivers or special permits state waivers or special permits submitted thus far

• Lessons learned thus far from • Lessons learned thus far from regulatory perspective

• Current Initiatives under way Current Initiatives under way to further evaluate

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49 CFR Part 192 (Gas)49 CFR Part 192 (Gas)

• Limited allowance of reinforced thermoset plastic

– § 192.59 (Plastic Pipe): Must be listed in accordance i h ifi iwith specification

• Appendix B: ASTM D2517 – Thermosetting plastic pipe and tubing - “Standard Specification for p p g pReinforced Epoxy Resin Gas Pressure Pipe and Fittings”

– § 192 121 (Design of plastic pipe)§ 192.121 (Design of plastic pipe)

• Using hydrostatic design basis (HDB) of 11,000 psig

• Petition for rulemaking to allow at higher pressures g g p(PHMSA-2010-003 – www.regulations.gov )

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49 CFR Part 195 (Liquids)49 CFR Part 195 (Liquids)

• § 195.8 Transportation of hazardous liquid or carbon dioxide in pipelines constructed with other than steel pipe.than steel pipe.

– No person may transport any hazardous liquid or carbon dioxide through a pipe that is constructed … of material other than steel unless the person has notified the other than steel unless the person has notified the Administrator in writing

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For Liquid and GasFor Liquid and Gas

• Regulations

– Design formulas and other requirements, such as in S b J (T R i ) b d i il Subpart J (Test Requirements), based primarily on Barlow’s formula for hoop stress and the use of homogeneous materials

– Do not accommodate the more complex composition and characteristics of composite materials

• Not as simple as asking for a special permit for design • Not as simple as asking for a special permit for design formula, and assuming rest of the code can easily apply. Multiple aspects of design, construction, testing, operation and maintenance specific to these products need to be p pvetted

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Applications for use of compositesApplications for use of composites

• Areas where it is very difficult and/or not cost effective to replace existing pipe (proposed insertion of composites)

U d i – Under rivers

– Plant piping or between plant piping, under railroads, etc.

• Alaska, off shore, or other environments where stress and strain can be an issue

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Special PermitsSpecial Permits

• February 25, 2005: Columbia Gas use of Fiberspar (March 3, 2005, RSPA–04–18757)

4200 f f 4 i h di i D d S Fi ld (fi – 4200 ft of 4-inch diameter in Dundee Storage Field (five storage wells and six lines), Class 1

– A number of conditions on qualification or personnel, q p ,follow-up inspections involving non-destructive and destructive testing

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Special PermitsSpecial Permits

• October 8, 2010: Anchor Point Energy Use of Fiberspar in Alaska (PHMSA 2010-0063)

6 3 il f i l i i – 6.3 mile segment of intrastate natural gas transmission, Two parallel 4.5-inch diameter lines, Class 1

– SP allowed calculation of HDB based on ASTM D-2517, ,resulting in MAOP of 1328 (Existing HDB in § 192.121 would limit MAOP to 464 psig)

– 16 special permit conditions (with many sub items) in 16 special permit conditions (with many sub items) in area of design, construction, testing, construction OQ, corrosion control, pressure and temperature control monitoring, O&M (including repair), annual reporting, g, ( g p ), p g,certification

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State WaiversState Waivers

• April 17, 2009: Cinco Natural Resources use of FlexSteel in gas gathering in Redfish Bay, offshore Nueces and San Patricio Counties in Texas through TxRRCPatricio Counties in Texas through TxRRC

– 25,000 feet of 6-inch FlexSteel through existing 12-inch steel pipe to rehabilitate

– 250 psi

– 12 conditions in addition to state waiver conditions

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• Oct 30, 2009: THUMS Long Beach use of Smartpipe in crude oil application through CA State Fire Marshall

§§ 195 406( ) 195 452( )(i)(B) d 195 452(f)(2)– §§ 195.406(a), 195.452( c)(i)(B) and 195.452(f)(2)

– Replacement of 315 foot steel pipe running between processing facility and tank farm, under access roads, p g y , ,multiple railroad tracks and multiple ancillary structures

– Inserted and encased within 20-inch steel line, sleeved in 30-inch steelin 30 inch steel

– 40 psi, normal operating temperature 120-125 F

– 14 conditions in addition to state waiver conditions

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• April 21, 2010: Cinco Natural Resources Corporation use of FlexSteel for gathering system in Corpus Christi Bay, Nueces County, TX through TxRRCNueces County, TX through TxRRC

– Impacted code sections: §§ 192.53, 192.55, 192.105, 192.107, 192.109, 192.111, 192.113, 192.221, 192 455 192 503(b) and 192 619192.455, 192.503(b) and 192.619

– Approximately 7,062 feet of 3-inch FlexSteel inserted into an existing (but previously abandoned) 6-inch pipeline

– 8 conditions in addition to TX waiver conditions

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• January 20, 2011: Monument Pipeline pilot installation of Smartpipe for test project at facility in Missouri City Texas through TxRRCthrough TxRRC

– §§ 192.53,192.121, 192.123 and 192.619(a)

– One segment as tight fit liner inside 12” nominal steel g gpipe

– One segment installed independent of steel pipe and exposed to environmental and atmospheric eventsexposed to environmental and atmospheric events

– Operating pressures 600 to 800 psi

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State WaiverState Waiver

• Sept 29, 2011: Nicor Gas Company use of Smart Pipe inside up to four 6-inch diameter steel lines underneath Illinois River through Illinois Commerce CommissionIllinois River through Illinois Commerce Commission

– §§192.53, 192.121, 192.123, and 192.619(a)

– 230 psip

– Class 1 area

– 12 conditions (with many sub-items) in addition to Illinois conditions

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For liquid and gasFor liquid and gas

• Standards

– Historically it has been difficult to regulate or even d h ’ f d l l accept products that weren’t manufactured to a clearly

defined code or standard

• Products “based on” certain standards do not mean “manufactured to” certain standards

– This is changing with more recent standard development but improvements still neededdevelopment, but improvements still needed

• Early standards very product (vendor) specific and a bit light on the details (proprietary)

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Early issuesEarly issues, that are improving, that are improving

• Design specs looked good on paper, but construction issues in the field

• Manufacturers overselling the product cost-effectiveness and • Manufacturers overselling the product, cost effectiveness, and understanding of the code

• Operators not understanding the products they’re getting, relying too much on manufacturery g

• Too much salespitch of the product, not enough technical detail and design calculations specific to the application

• Understanding characteristics of the materials particularly • Understanding characteristics of the materials, particularly during hydrotests

• Understanding and addressing permeation effects

F l i i h h di i d d• False impression that cathodic protection not needed

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Other Lessons Learned alsoOther Lessons Learned alsoOther Lessons Learned, also Other Lessons Learned, also improvingimproving

• Clear understanding and communication of potential failure modes, cyclic fatigue effects, and repair methodologies

QA/QC i i d l i fi • QA/QC, inspection, and long term testing to confirm integrity and risk assessment overall

• Fittings and interconnecting with existing standard facilities g g gand appurtenances

• Clear calculations of design pressures, burst pressures, and how they correlate to MAOP MOP and safety factors in the how they correlate to MAOP, MOP, and safety factors in the code

• Where is the common ground for standardization of these products while still being sensitive of proprietary products, while still being sensitive of proprietary information

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Initiatives to addressInitiatives to address

• Venues such as these, bringing multiple parties to the table

• Special Permits and State Waivers (h // h d / i li / / i l i )(http://www.phmsa.dot.gov/pipeline/regs/special-permits)

– Seem painful, but learn a lot through them and help validate through the appropriate processes in the g pp p pcontext of the code

• PHMSA intending to collect data on composite pipe as a material type through Gas Transmission and Distribution material type through Gas Transmission and Distribution Annual Reports as of 12-31-2012 annual report data

– Both the form and instructions will note that a PHMSA Special Permit is required to place composite pipe into Special Permit is required to place composite pipe into service

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Other InitiativesOther Initiatives

• Continued involvement in standards development:

– ASTM

– API (such as API 15S working group)

– ASME new committee and sub-committees underway

• Product specific standards still good, but also helpful to continue to develop more product generic standards, taking into context the whole system(s)

• Petitions for rulemaking

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QuestionsQuestions

Thank you!Thank you!Thank you!Thank you!Max KiebaMax Kieba

[email protected]@dot.gov, 202, [email protected]@dot.gov, 202, 202 493493 05950595

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