Anomaly Evaluation,

Response, and Repair Summit

Presentation by
INGAA
June 3, 2008
 Context of Today’s Meeting
• Basis for Anomaly evaluation and
response has become an issue on:
– Enforcement
• Integrity Management Audits
• Correction Action Orders
– Special Permits
• MAOP
• Class Change
– Extending Re-assessment Interval
– Inspections
• O&M
• Integrity Management

2
 Concerns
• Varying opinions from PHMSA
• Lack of technical basis for some
opinions
• Substantial impact of varying
opinions
• Concern about bypassing regulatory
and standards process
• Some concerns voiced in INGAA
comments to “Interim Final
Rulemaking” and “80% Rulemaking” 3
Our Goal Is Incident Free
Operation
.
 Sequence of Presentation

• What are we doing now

• What we think the regulations and
standards mean
• What the research says
• No apparent increase in safety risk
• Large Impact on pipeline companies

5
 Presentation Agenda and
Presenters
1. “Standards and Regulations”- Chris
Bullock, CenterPoint
2. “Current Practices in INGAA
Companies” - Bob Travers, Spectra Energy
3. Break
4. “Research” - Dave Johnson, Panhandle
Energy, Mike Rosenfeld, Kiefner and
Associates, Inc. and Keith Leewis, P-PIC
5. “Safety Risk” - Frank Dauby, PG&E
6. “Impact of Change” - Chris Whitney, El
Paso
6
Standards and Regulations

Chris Bullock
CenterPoint Energy

7
 Definitions

• Anomaly Response Criteria

– Applies to ILI after receipt of ILI
log/report
– How soon must the anomaly be
investigated?
• Defect Repair Criteria
– Applies to actions in the bell hole
– What defects must be repaired?
8
 Applicable Consensus
Standards and Regulations
• Anomaly Response Criteria
– General - ASME B31.8S, §7.2, Table 3
and Figure 4; 49 CFR 192.933
• Defect Repair Criteria
– General - ASME B31.8, §851.4,
§862.213; 49 CFR 192.711, 713, 485.
ASME B31.8S, §7.2 (and Table 4); 49
CFR 192.713
9
 Evolution of
Standards and Regulations
Hi-Resolution In-Line Inspection
Battelle developed
Standard Resolution In-Line Inspection
strength of corroded ASME B31.8S
pipe for AGA-PRC Table 3 and
ASME B31.8 ASME B31.8 ASME B31.8 RSTRENG
Figure 4
B31G Mod B31G
1968 1984 1989 1989 2002

1971 1996 2003

49 CFR 49 CFR 49 CFR

192.485(a) and (b) Regulation Amended 192.485(c ) 192.933
To Reflect Corrosion And
Evaluation Methods Subpart O
For Use in The
Ditch First Application of
Anomaly
Incorporation of Response
Standard Language Timing
Into Regulation
Incorporation of
Standard Language
Into Regulation
ASME B31G – 1984, 1991, 2004
• 1.6 THE MEANING OF ACCEPTANCE
(a) Any corroded region indicated as acceptable by the
criteria of this Manual for service at the established MAOP
is capable of withstanding a hydrostatic pressure test that
will produce a stress of 100% of the pipe SMYS.
• 4.2 COMPUTATION OF P’
P’ is a function of P
P equals the greater of either the established MAOP
(192.611 or 619) or 2*S*t*F*T/D
• 4.3 MAOP AND P’
If the established MAOP is equal to or less than P’, the
corroded region may be used for service at that MAOP. If it
is greater than P’ then a lower MAOP should be established
not to exceed P’ or the corroded region should be repaired
or replaced.

11
 ASME B31.8
• 862.213 Repair of Corroded Pipe. If the extent of
corrosion has reduced the strength of a facility
below its maximum allowable operating pressure,
that portion shall be repaired, reconditioned, or
replaced, or the operating pressure shall be
reduced, commensurate with the remaining
strength of the corroded pipe. For steel pipelines
operating at hoop stress levels at or above 40% of
the specified minimum yield strength, the remaining
strength of corroded pipe may be determined in
accordance with Appendix L. For background
information on Appendix L, refer to ANSI/ASME
B31G, titled Manual for Determining the Remaining
Strength of Corroded Pipelines.

12
 General Regulations –
In The Ditch
• Sec. 192.485 Remedial measures: Transmission lines.
(a) General corrosion. Each segment of transmission line
with general corrosion and with a remaining wall thickness
less than that required for the MAOP of the pipeline must
be replaced or the operating pressure reduced
commensurate with the strength of the pipe based on
actual remaining wall thickness. However, corroded pipe
may be repaired by a method that reliable engineering
tests and analyses show can permanently restore the
serviceability of the pipe. Corrosion pitting so closely
grouped as to affect the overall strength of the pipe is
considered general corrosion for the purpose of this
paragraph.

13
 ASME B31.8S-2001, 2004
• 7.2.1 Metal Loss Tools for Internal and External Corrosion.
Indications requiring immediate response are those that
might be expected to cause immediate or near-term leaks
or ruptures based on their known or perceived effects on
the strength of the pipeline. This would include any
corroded areas that have a predicted failure pressure level
less than 1.1 times the MAOP as determined by ASME B31G
or equivalent.
Indications in the scheduled group are suitable for
continued operation without immediate response provided
they do not grow to critical dimensions prior to the
scheduled response. Indications characterized with a
predicted failure pressure greater than 1.10 times the
MAOP shall be examined and evaluated according to a
schedule established by Fig. 4.

14
 ASME B31.8S
• Developed for managing system
integrity (HCAs and non-HCAs)
• Operators can elect to use Table 3
and Figure 4 as
basis for anomaly
response timing

15
 ASME B31.8S
Table 3 defines
assessment methods
and end points

Figure 4 provides basis for

scheduling responses

16
 68 FR 4306, Jan 28, 2003
What Actions Must Be Taken To Address Integrity Issues?

• 180-day evaluation. Except for conditions listed in

‘‘immediate repair’’ conditions of this section, an operator
must complete evaluation and schedule remediation of the
following within 180 days of discovery of the condition:
• Calculation of the remaining strength of the pipe shows a
predicted failure pressure between 1.1 times the
established maximum operating pressure at the location of
the anomaly, and the ratio of the predicted failure pressure
to the MAOP shown in Figure [4] of ASME B31.8S to be
appropriate for the stress level of the pipe and the
reassessment interval. For example, if the pipe is operating
at 50% SMYS and the reassessment interval is ten (10)
years, then the predicted failure pressure ratio for
scheduling examination and remediation during that ten
year period would be 1.39.

17
49 CFR 192.933, Dec. 15, 2003
(c) Schedule for evaluation and remediation. An
operator must complete remediation of a
condition according to a schedule that
prioritizes the conditions for evaluation and
remediation. Unless a special requirement for
remediating certain conditions applies, as
provided in paragraph (d) of this section, an
operator must follow the schedule in ASME/ANSI
B31.8S (ibr, see § 192.7), Section 7, Figure 4.

18
 Applicable FAQs
FAQ-225 [1/4/2005]
Question: Must I fix anomalies found in non-covered segments?

Answer: Yes. Operators may find problems in non-covered

segments while performing assessment of covered segments
(e.g., because non-covered segments are also inspected during
an ILI assessment) and must take appropriate actions to meet
the requirements in 192.485, 192.703(b), 192.711, 192.713,
192.715, 192.717, and 192.719 as applicable. The provisions and
requirements in Section 192.933(d) apply only to covered
segments. In non-covered segments, operators are responsible
for determining the appropriate criteria and schedule for
remediating anomalies, consistent with the significance of the
identified problem.

19
 Applicable FAQs
FAQ-224 [3/9/2005]
Question: What actions must I take on non-covered
segments if I find corrosion during an
assessment of segments in HCA?
Answer: …The special scheduling requirements
and requirements to reduce pressure or take
other action of Section 192.933(d) do not apply
to non-covered segments. OPS expects
operators to take action to address these
segments in a timely manner, consistent with the
importance to safety of the potentially degraded
condition of the pipeline.
20
 Applicable FAQs
FAQ-66 [5/17/2004]
Question: If a covered segment is relatively short (e.g., only 2
miles in length), yet the operator internally inspects a
longer portion around this segment (e.g., 50 miles from pig
launcher to receiver), do the repair schedules in 192.933
apply to the covered segment or the entire distance over
which the pig is run?

Answer: The repair schedules in 192.933 apply only to the

covered segment. However, the operator is responsible
for promptly addressing anomalies identified in the other
portions of the pigged section in accordance with
192.703(b).

21
 Applicable FAQs
FAQ-70 [5/17/2004]
Question: Must anomalies identified during pig runs not considered
"baseline" or "re-assessments" under the rule be repaired in
accordance with the rule's repair criteria?
Answer: ... The integrity management rule repair criteria apply to
high consequence areas. If anomalies fall in a high consequence
area the answer is yes. The integrity management rule requires a
program that integrates all information regarding the integrity of
the pipeline. Anomalies discovered in segments in high
consequence areas after the effective date of the rule must be
repaired in accordance with the criteria and schedules for repair
conditions specified in 192.933. Anomalies discovered in
segments in non high consequence areas must be repaired in
accordance with existing rules in Subpart M, Maintenance, of
Part 192.

22
 Evolution of
Standards and Regulations
Hi-Resolution In-Line Inspection
Battelle developed
Standard Resolution In-Line Inspection
strength of corroded ASME B31.8S
pipe for AGA-PRC Table 3 and
ASME B31.8 ASME B31.8 ASME B31.8 RSTRENG
Figure 4
B31G Mod B31G
1968 1984 1989 1989 2002

1971 1996 2003

49 CFR 49 CFR 49 CFR

192.485(a) and (b) Regulation Amended 192.485(c ) 192.933
To Reflect Corrosion And
Evaluation Methods Subpart O
For Use in The
Ditch First Application of
Anomaly
Incorporation of Response
Standard Language Timing
Into Regulation
Incorporation of
Standard Language
Into Regulation
Current Practices In INGAA
Companies
Bob Travers
Spectra Energy

24
 Definitions

• Anomaly Response Criteria

– Applies to ILI after receipt of ILI
log/report
– How soon must the anomaly be
investigated?
• Defect Repair Criteria
– Applies to actions in the bell hole
– What defects must be repaired ?
25
 Response Criteria
Evaluation of ILI Results

• Modified B31G or B31G generally

applied to evaluate ILI results and
calculate FPR values (failure pressure ratio)
• Some operators apply effective area
methods (e.g.,RSTRENG, LAPA,
etc.)

26
 Response Criteria
B31.8S, Figure 4

• Figure 4 is then used to apply a

due date for response to the
anomalies
• Additional Considerations
– Adjustments can be made to account
for site specific characteristics such
as actual pipe specs, estimated
corrosion rates, tool tolerances,
accelerated due dates, etc…
27
 Repair Criteria
Bell Hole Assessments

• Multi-step Screening Process

– B31G
– Mod B31G or
– RSTRENG (Effective Area Method - EAM)
• The calculated failure pressure is then
multiplied by the appropriate safety factor
to determine a safe operating pressure.
• Then the decision is made to repair or
not.
28
ILI Process Summary Anomaly and Pipeline Data Analysis

USE B31G,
MOD B31G,
APPLY B31.8S
OR
ILI REPORT FIG 4 TO ASSIGN
RSTRENG,
DUE DATE
TO CALCULATE
FAILURE PRESSURE

Adjustments: growth rates, pipe

specs, tolerance, due dates, etc.
Actionable Anomalies RESPONSE

PRIOR TO REPAIR
DUE DATE

EVALUATE IN THE THE CALCULATED

DITCH USING FAILURE PRESSURE
IS THEN MULTIPLIED
SAFE YES
B31G BY AN ACCEPTABLE
OPERATING PRESSURE
SAFETY FACTOR
> MAOP
MOD B31G TO DETERMINE
A SAFE OPERATING
RSTRENG PRESSURE. NO

REPAIR or
LOWER PRESSURE RECOAT
29
Break

.
 Research
Dave Johnson
Panhandle Energy
Mike Rosenfeld
Kiefner Associates, Inc.
Keith Leewis
P-PIC
 Research
As Applied to
Anomaly Response and Evaluation
• Development of Models
• Evolution of Models
• Validation of Models
– PRCI – B31G, modB31G, RSTRENG
– Advantica - independent evaluation for
PHMSA

32
 Method Development
• B31G - original, simple two parameter
model
• Modified B31G - application of flow
stress and 0.85 effective area in the
Folias factor to better reflect
characteristics of actual corrosion
• RSTRENG or KAPA - effective area
method, utilizes “River Bottom
Profile”
• PRCI periodically funded validation
work
33
 Model Development
• NG-18 Ln-Secant basis by Battelle in 1971
• B31G by ASME in 1984
• modB31G Kiefner and Veith (1989)
• RSTRENG Kiefner and Veith (1989)

34
Pipe tests validated corrosion
assessment methods
• 124 experiments, service failures, and test
failures: Vieth, P.H. and Kiefner, J.F.,
“Database of Corroded Pipe Tests”, AGA
Pipeline Research Committee, PR-218-9206
(April 4, 1994).
• 90 additional experiments, service failures,
and test failures: Kiefner, J.F., Vieth, P.H.,
and Roytman, I.R., “Continued Validation of
RSTRENG”, AGA Pipeline Research
Committee, PR-218-9304 (Dec. 20, 1996).
• 322 experiments–from Grade B to x100 done
all over the world, Advantica 6781 report

35
 Attributes in Validation Tests
Parameter NG-18 ln-sec Corrosion
Equation Methods
OD (inches) 6.625 to 48.0 10.75 to 48
Wall (inch) 0.195 to 0.861 0.197 to 0.500
D/t ratio 26.4 to 104.3 40.6 to 100.0
Actual YS (ksi) 32.0 to 106.6 28.4 to 74.8
Actual UTS (ksi) 53.4 to 131.7 40.2 to 85.5
CVN (ft-lb) 15 to 100 n/a
No. of tests 130 215

36
Corrosion Assessment Methods:
Spectrum between
complexity & conservatism

37
 Independent Evaluation
Sponsored by PHMSA
Considered two-parameter methods
• Case 1 - Flow stress based on recommendation made by each
assessment methods, but using actual material properties
• Case 2 - Flow stress based on recommendation made by each
assessment methods, but using specified minimum material
properties
• Case 3 - Flow stress modified to equal actual tensile strength of
pipe.
• Case 4 - Flow stress modified to equal specified minimum tensile
strength of pipe.
• Case 5 - Flow stress modified to equal the mean of the actual
yield and ultimate tensile strength.
• Case 6 - Flow stress modified to equal the mean of SMYS and
ultimate tensile strength.

38
 All Two Parameter Methodologies
Are Basically Conservative
Failure Pressure vs Normalized Defect Length
(All Prediction Methods)

6
Failure Pressure Ratio (Pa/Pf)

5
ASME B31G PA/Pf
Mod ASME B31G PA/Pf
4
RSTRENG PA/Pf
LPC-1 PA/Pf
3
SHELL 92 PA/Pf
PCORRC PA/Pf
2

0
0 50 100 150 200 250 300
Normalized Defect Length {L/(Dt)^0.5}

Using Advantica Report # 6781 for PHMSA

39
Prediction Reliability (case 2- normal)

Advantica Report # 6781 for PHMSA

40
 ModB31G Performance
Case 2 B31G Pa/Pf vs log(Normalized Length)

10
Failure Pressure Ratio (Pa/Pf)

9
X100
8
x80
7 X65
6 X60
5 X56
4 X55
3 X52
2 X46
1 X42
0 B/X42
0.1 1 10 100 1000 B
Log {Normalized Length} - log {L/(50Dt)^0.5}

Using Advantica Report # 6781 for PHMSA

41
 RSTRENG Performance
Case 2: Rstreng Pa/Pf vs Log {Normalized Length}

2
Failure Pressure Ratio (Pa/Pf)

1.8 x100
1.6 x80
1.4 x65
1.2 x60
1 x56
0.8 x55
0.6 x52
x46
0.4
x42
0.2
B/x42
0
B
0.1 1 10 100 1000
A25
Log {Normalized Length} - log{L/(50Dt)^0.5}

Using Advantica Report # 6781 for PHMSA

42
Comparison of Actual and Predicted Failure
Pressures Using the RSTRENG Method
(Case 2 Specified Minimum Material Properties)

Advantica Report # 6781 for PHMSA

43
 Comparison of Actual and Predicted Failure
Pressures Using the Modified ASME B31G Method
(Case 2 Specified Minimum Material Properties, including Ring Expansion Tests) –

Split Between Machined and Real Corrosion Defects

Advantica Report # 6781 for PHMSA

44
Testing showed that machined defects are worse than actual 
corrosion. Also d/t>50% for pipe to fail at normal operating 
stress levels.

45
Comparison of Actual and Predicted Failure Pressure Using the
RSTRENG Method
(Case 2 Specified Minimum Material Properties) –
Split Between Machined and Real Corrosion Defects

Advantica Report # 6781 for PHMSA

46
 Conclusions - Advantica

1. For the majority of the tests investigated in this report,

standard assessment methods used by the pipeline
industry give conservative failure predictions.
2. For a very small number of test points reviewed in this
report, use of the ASME B31G and Modified ASME B31G
methods resulted in non-conservative failure
predictions. These were for test points with defects
greater than 40% of the pipe wall and in line pipe of
grade X52 and above.
3. RSTRENG is the most accurate method for predicting
the failure pressure in pipelines. RSTRENG predicts
conservative failure pressures for defect depths up to
80% of the pipe wall in line pipe of strength grades up to
X100.
...
47
Safety Risk

Frank Dauby
PG&E
 Risk Posed By Remaining
Anomalies
• Anomalies with FPR > 1.25
• Anomalies with FPR > 1.39
• What Are The Characteristics of
These Anomalies?

49
 Is There Safety Value
in Examining Anomalies
With Predicted Failure
Pressure>SMYS?
• No Discernable Safety Value in
Examining Anomalies > SMYS as
those anomalies are:
– Longer anomalies are not deep
– Shorter anomalies are typically <60%
and will leak not rupture

50
 Example ILI Data Set -
Line To Operate at 80%
80%

70%

60%
Depth (%)

50%

40%

30%

20%

10%

0%
0 2 4 6 8 10 12 14 16 18 20
Length (inches)

MAOP 1333 MAOP 1.1 1466 1.25MAOP 1666 2248

1878 1899 1687 1760
2271 1898 1896 1894
1902 1744 1511 1298
1824 1828 1747 1706
1846 1828 1780 1700
1652 1682 1642 1905
1900

51
 Example at 72% SMYS
Predicted Failure Pressure
m od B31.G
36", x70, 0.450" w all

80%
Depth Percent of Wall (d/t)

70%
60%
1260 72% SMYS
50%
1386 1.10 MAOP
40%
1575 1.25 MAOP
30%
1751 1.39 MAOP
20%
10%
0%
0 5 10 15 20 25
Anomaly Length (in)

52
Impact of Change

Chris Whitney
El Paso Pipeline Group

53
 Impacts

• Pipeline System
• Customer Needs
• Land Owner/Environmental

54
 Pipeline System Impacts
• Significant increase in excavation activities
– Requiring operators to apply a design factor to the
failure pressure ratio, will result in significant number
of additional digs.
• Practically all corrosion anomalies require investigation
• Increased number of excavations does not equal
increased safety
– More opportunities for damage to pipe or other
facilities
• 1st, 2nd, 3rd party damage
• Change stress profile of pipeline in ditch
– Girth welds, wrinkle bends, dents, etc.
– More disruption to CP system and coatings

55
 Class Bump Case Study
• An Operator Reported 86 miles of 26” pipeline
– 13% Class 2 operating at 750 MAOP (67% SMYS) with
class bump
– No HCAs and no immediate digs
• ILI in 2007 resulted in 21 scheduled corrosion
anomaly investigations
– 11 < 1.39 (1.24 to 1.39)
– 10 other involving metal loss in wrinkles or welds
• If evaluate Class 2 areas at 60% design factor,
results in ~50 additional digs (1.4 to 1.67).

56
 Customer Impacts
• If FPR < 1.39 = Immediate
– Increase in unscheduled pipeline disruption
– Longer duration of pressure reduction
• Affects ability to meet firm demand
• Ability to fill storage in summer and meet
power loads
• Potential to reduce amount of ILI in order
to manage anomaly investigations

57
 Land Owner/Environmental
Impacts
• Potential for significant impact to Land usage
requirements – increased footprint and duration
• Significant issues with timing of work in sensitive
environmental areas
– Wetlands/Restrictive habitats
– Recreational areas
– Farm lands
– Golf courses
• Excessive permit burden
– Waiver requests to PHMSA
– Local authorities

58
 Impact Conclusion
• Advantage of ILI is to understand what is
happening and take appropriate action
• Eliminating unnecessary digs minimizes
pipeline disruption and enhances our
ability to meet market demands
• Planned execution of integrity work is
essential for meeting customer reliability
expectations

59
ILI Process Summary Anomaly and Pipeline Data Analysis

USE B31G,
MOD B31G,
APPLY B31.8S
OR
ILI REPORT FIG 4 TO ASSIGN
RSTRENG,
DUE DATE
TO CALCULATE
FAILURE PRESSURE

Adjustments: growth rates, pipe

specs, tolerance, due dates, etc.
Actionable Anomalies RESPONSE

PRIOR TO REPAIR
DUE DATE

EVALUATE IN THE THE CALCULATED

DITCH USING FAILURE PRESSURE
IS THEN MULTIPLIED
SAFE YES
B31G BY AN ACCEPTABLE
OPERATING PRESSURE
SAFETY FACTOR
> MAOP
MOD B31G TO DETERMINE
A SAFE OPERATING
RSTRENG PRESSURE. NO

REPAIR or
LOWER PRESSURE RECOAT
61
 Thank You

Questions And Discussion

62