Off-pipe to be included
It is clear that the new Pipeline Integrity regulations apply not only to cross-country interstate pipelines, but also to "off-pipe" facilities attached to the pipeline. These are "compressor units, metering stations, regulator stations, delivery stations, holders and fabricated assemblies." This means that operators will have to document and track the same information for these off-pipe facilities that is done for cross country pipelines. It also means that given the single definition of a Potential Impact Circle (PIR), large diameter equipment, such as a filterseparator or dehy tower, may greatly increase a facility's PIR.

The assessment of pipelines is limited to those that are within an High Consequence Areas (HCA). Most compressor stations are located away from homes and businesses. This will keep most of them out of the HCA's and therefore out of the requirements for assessment and monitoring. The number of meter stations that are included in HCA's is much larger. This is due to the nature of the meter station being the transition from transmission pipeline to distribution pipeline - from cross country rural pipeline to urban pipeline. It is also expected that these last transmission pipeline miles to the meter stations will be the most difficult to assess. Other off-pipe facilities will probably fall into an HCA to the same percentage as the pipelines themselves. Initial assessments for HCA's need to be complete by June 17th, 2004, so this should be a top priority.

Regulatory impact
The impact of the Rule is that those offpipe systems that are in HCA's will have to go through an initial assessment and follow on assessments in accordance with the Rule. Underground facilities will most likely be assessed using Direct Assessment (DA). Even this is not as easy as it sounds, as visual inspection of portions of the affected pipes is the final step in DA. For aboveground facilities, visual inspection is more reasonable. Hydrostatic testing off off-pipe systems is not expected to be popular and in-line inspection is just not feasible.
The good news is that for the data integration and data evaluation requirements of the Rule, most operators should be able to append the facility information to their existing asset management systems. Managing the assets then becomes a GIS (Geographic Information Systems) and IT (Information Technology) exercise in maintaining and managing the appropriate databases (both spatial and non-spatial). Even though the rule allows for manual evaluation, this is expected to be a data management-intensive operation because of the requirements of the Rule for data integration, analysis and continuous improvement. To do this continuously - as required by the Rule - and efficiently - as required by management - spatial and non-spatial applications coupled with the right analytical software tools will be key.

Operators should document the materials and construction specifications for each facility, including all the pipe, fittings and equipment in compressor, metering and regulator stations. Required data should include the pipe and fitting size, strength or grade, and wall thickness. For manufactured equipment like compressor cylinders, compressor cases and gas coolers, the data will be similar but in a different format. Starting early will give pipeline operators a head start on a potentially daunting task.

However, information gathering on a pipeline facility will need to overcome one basic problem- although regular pipelines, such as those that travel across the country, are defined by distance markers and stations, piping inside stations usually have no such assignments. Since compressor and metering stations are usually built as an assembled piping structure and not on a per-foot basis, some operators have no easy way of documenting the specific components of their facility. To resolve this, operators can begin to document facilities as if they were pipelines by assigning line numbers. Though the process will require station walk downs, review of as-built drawings, and culling of all available information from databases, assigning line numbers can help operators manage the information required by the Rule.

To discuss how Basic Systems, Inc. can help you wade through these issues and get your facilities into compliance, contact:

Tom Stemmer, President
tstemmer@bsicos.com
(740) 432-3001

Regulatory Excerpts

Part 192.201
"This subpart prescribes minimum requirements for an integrity management program on any gas transmission pipeline covered under this part."

Part 192.3
“Pipeline means all parts of those physical facilities through which gas moves in transportation, including pipe, valves, and other appurtenance attached to pipe, compressor units, metering stations, regulator stations, delivery stations, holders, and fabricated assemblies."

"Transmission Line means
a pipeline, other than a gathering line, that:

(a) Transports gas from a gathering line or storage facility to a distribution center, storage facility, or large volume customer that is not downstream from a distribution center;

(b) Operates at a hoop stress of 20 percent or more of SMYS; or

(c) Transports gas within a storage field.

Related Links

"Pipeline Integrity
Frequently Asked Questions
http://primis.rspa.dot.gov/gasimp/ faqlist.gim
(Notice Question #6)

PART 192--TRANSPORTATION OF NATURAL AND OTHER GAS BY PIPELINE: MINIMUM FEDERAL SAFETY STANDARDS
http://ops.dot.gov/cfr99/part192.htm