Proceedings of the 2012 9th International Pipeline Conference IPC2012 September 24-28, 2012, Calgary, Alberta, Canada

IPC2012-90304

MANAGING AND ADDRESSING FITNESS FOR SERVICE OF VINTAGE PIPELINES

Steven V. Nanney US DOT / PHMSA Houston, TX, USA Kenneth Y. Lee US DOT / PHMSA Washington, DC, USA

ABSTRACT Recent pipeline accidents in the United States have highlighted concerns with older vintage natural gas and hazardous liquid pipelines. The United States Department of Transportation (USDOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) is performing a comprehensive review to determine the fitness for service of vintage pipelines, and if the risks associated with vintage pipelines can be better managed by changes to US pipeline safety standards and regulations. Concerns with vintage pipelines include weld seam manufacturing issues, such as low frequency electric resistance welding (LF-ERW) and submerged arc welding (SAW), cast iron pipe, plastic pipe and certain coatings. This paper presents findings from vintage pipeline failure investigations, recent PHMSA actions, and some approaches to address key vintage pipe concerns. These approaches include knowledge assurance (adequacy and quality of historical data), methods to systematically obtain missing data, and processes and criteria for determining fitness-forservice, including assessment, remediation, and replacement programs.

longitudinally oriented weld zone. The defects generic to these pipe materials include, but are not limited to, fatigue cracks, lack of fusion, burned metal defects, stitched welds, cold welds, cracks in hard heat affected zone (HAZ), surface breaking hook cracks near the weld, and selective seam (grooving) corrosion. Recent pipeline accidents have led PHMSA to conclude that current practices to manage the integrity of vintage pipe need to be improved. The purpose of this paper is to describe specific areas of needed improvement have been gleaned from recent accident investigations.

INTRODUCTION Recent failures associated with vintage pipelines have raised concerns related to determining the fitness for service of these pipelines. Some older pipelines may contain material or pipe manufacturing defects. Affected types of vintage pipe include, but are not limited to, low frequency electric resistance welded (LF-ERW), direct current electric resistance welded (DC-ERW), furnace lap-welded, electric fusion welded (EFW), submerged arc welded (SAW), cast iron, and plastic pipe. With the continuing operation of an aging infrastructure containing such vintage pipe materials, the propensity for the timedependent growth of defects to critical sizes and subsequent failure requires reliable periodic nondestructive inspection and accurate integrity evaluation. For seam welded pipe, the nondestructive inspections must be able to provide a reliable indication of the presence of defects within the narrow

BACKGROUND A significant percentage of the pipelines in the United States were installed prior to enactment of federal pipeline codes in 1970. 55% of the hazardous liquid pipelines, 59% of the natural transmission pipelines, and 31% of the natural gas distribution pipelines were installed prior to 1970, as shown in Figures 1-3. Many of the issues encountered with vintage pre-1970 pipelines are different from newer constructed pipelines. The line pipe materials, coatings, construction practices, and testing used many decades ago were often different from present-day requirements, resulting in different risks. Increased time-inservice increases the severity of time dependent threats, which include corrosion and fatigue. Also, past codes and standards were different or did not exist at the time of construction. Modern natural gas and hazardous liquid pipelines in the United States typically receive a post-construction hydrostatic pressure test at a minimum of 125% of the maximum allowable operating pressure (MAOP) or Maximum Operating Pressure (MOP). The testing must be completed in accordance with 49 CFR 192 Subpart J for natural gas pipelines, or 49 CFR 195 Subpart E for hazardous liquid pipelines. There are exemptions for certain pipelines, including pipelines constructed before 1970, where historical operating conditions or engineering analysis may be used to establish the MAOP or MOP.

1 This material is declared a work of the U.S. Government and is not subject to copyright protection in the United States. Approved for public release. Distribution is unlimited.

Hazardous Liquid Pipeline Vintage

25% 20% 15% 10% 5% 0% < 1940 1940s 1950s 1960s 1970s 1980s 1990s 2000s

Figure 1: Percentage of U.S. hazardous liquid pipeline distance by decade of construction

Gas Transmission Pipeline Vintage
25% 20% 15% 10% 5% 0% < 1940 1940s 1950s 1960s 1970s 1980s 1990s 2000s

Recent pipeline accidents in the United States have highlighted concerns with older vintage pipelines: 2011 failures of 12-inch cast iron natural gas distribution pipelines in Allentown, Pennsylvania, constructed in 1928, and in Philadelphia, Pennsylvania, constructed in 1942. 2010 failure of a 30-inch diameter, grade X52, a natural gas transmission pipeline in San Bruno, California at a defective submerged arc welded (SAW) longitudinal seam in pipe pup, constructed in 1956 (Figure 4). 2007 failure of a 12-inch, grade X52, liquid propane transmission pipeline in Carmichael, Mississippi at a low-frequency electric resistance welded (LF-ERW) pipe seam, constructed in 1961 (Figure 5). Natural gas distribution in-service failures of plastic pipe collected by the American Gas Association (AGA) since 2001.

Figure 2: Percentage of U.S. natural gas transmission pipeline distance by decade of construction
Gas Distribution Pipeline Vintage

25% 20% 15% 10% 5% 0%

Figure 4: Cross-section of defective SAW longitudinal seam discovered in San Bruno (2010)

1940s

1950s

1960s

1970s

1980s

1990s

2000s

Figure 3: Percentage of U.S. natural gas distribution pipeline distance by decade of construction

Vintage pipelines, built before federal pipeline regulations were enacted in the 1970s, were subject to fewer and less stringent requirements at the time of construction. As mentioned above, many vintage pipelines did not undergo a post-construction hydrostatic pressure test. Also, test reports and records may have been lost or destroyed over time, and the accuracy of the records which remain may be questionable.

Figure 5: Photo taken of pipeline after LF-ERW seam rupture in Carmichael (2007)

VINTAGE LINE PIPE AND COATING TYPES WITH INTEGRITY CONCERNS There are several specific types of line pipe which have been documented to have experienced higher failure rates. LF-ERW Low frequency electric resistance welded (LF-ERW) pipe was widely manufactured from the 1920s until the late 1970s, and has since been replaced by high frequency (>360 Hertz) electric resistance welded (HF-ERW) pipe, which continues to be widely used today. LF-ERW pipe have experienced higher failure rates compared to other types of line pipe, especially in hazardous liquid pipes, which experience more severe pressure cycling (Figure 4). Failures have been associated with lack of fusion, selective seam corrosion, fatigue/corrosion fatigue, and hook cracks. In 1988 and 1989, PHMSA issued advisory bulletins ALN-88-01 and ALN-89-01 to natural gas pipeline transmission and hazardous liquid pipeline operators regarding failures of ERW pipelines constructed prior 1970. EFW Electric flash welded (EFW) pipe was produced by a single manufacturer between 1930 and 1969. EFW pipe is similar to LF-ERW pipe and shares many of the above noted quality issues associated with LF-ERW. SAW Submerged arc welded (SAW) pipe was first manufactured in the 1930s and 1940s using the single submerged arc welding (SSAW) method, and shortly thereafter was replaced by double submerged arc welding (DSAW), which is still widely used today. While DSAW is generally considered to be one of higher quality types of line pipe, failures have been observed with SSAW line pipe and certain older DSAW pipe sections which have inadequate records or not traceable to a pipe mill. Observed defects include lack of fusion and cracking. Cast Iron Cast iron pipelines for natural gas distribution were installed in the United States from the 19th to the early 20th century. Cast iron pipe is no longer being installed for gas distribution, and in most states with cast iron mains, there is a program requiring its replacement. Presently, approximately 3% of the natural gas distribution pipeline mains in the United States are cast iron, which are primarily located in the northeastern states. Cast iron tends to be brittle, prone to corrosion in certain soil types, and have joint connections with poor strength and flexibility. Failures have occurred in winter conditions due to thermal stress and frost loading. PHMSA has issued alert notices ALN-91-02(1991) and ALN-92-02(1992) to owners and operators of natural gas cast iron distribution pipelines.

Plastic Certain types of plastic pipe and pipe components installed between the 1960s and 1980s are susceptible to premature brittle-like cracking, including: Aldyl A, PE 3306 polyethylene, Delrin insert tap tees, and Plexco service tee Celcon (polyacetal) caps. Brittle-like cracks may develop in these materials in areas of high localized stress. PHMSA has issued 4 advisory bulletins to owners and operators of natural gas distribution systems concerning the susceptibility of older plastic pipe to premature brittle-like cracking: ADB-9901(1999), ADB-99-02(1999), ADB-02-07(2002), and ADB-0701(2007). COATING Vintage pipelines with certain coating types have experienced higher failure rates. Tape coatings susceptible to disbondment and tenting over the pipe longitudinal seam weld may result in inadequate protection, allowing the exterior environment to contact the pipe surface. Also, some vintage coatings when disbonded from the pipe surface, shield the pipe from cathodic protection (CP) current, and do not allow the CP to provide adequate corrosion protection to the steel pipe.

PHMSA ACTIONS On January 10, 2011, PHMSA issued Advisory Bulletin ADB-11-01 in response to the National Transportation Safety Board (NTSB) findings from the investigation of the gas pipeline rupture and explosion in San Bruno, CA on September 9, 2010. Among the major findings, NTSB concluded that the operators knowledge and records of the vintage pipe that failed were incomplete and, in some cases, erroneous. This resulted in flawed operational decisions concerning establishing the proper MAOP, integrity management, threat and risk identification, risk assessment, and implementation of preventive and mitigative measures. The advisory bulletin reminded operators of several key responsibilities. Records used to establish MAOP (or MOP) must be complete, valid, and reliable. PHMSA emphasized the need for operators to be fully cognizant of the physical and operational characteristics of their systems, identify all risk factors, understand the threats to their systems, understand the risks posed by their systems, and perform a robust, integrated analysis of risk data that is capable of identifying preventive and mitigative measures to address all risks. Any operator that is not fully cognizant of any pertinent risk data should: 1) Institute an aggressive program as soon as possible to obtain this information, 2) Assess the risks, and 3) Take the proper mitigative measures In addition, if these operators do not have verified information on key risk factors, an immediate and interim mitigation measure that should be strongly considered is a pressure reduction to 80 percent of the operating pressure for

the previous month, hydrostatic testing the pipeline, or creating a remediation program to identify threat risks. On July 21, 2011, PHMSA, in conjunction with the National Association of Pipeline Safety Representatives (NAPSR), sponsored a workshop on risk assessment and recordkeeping which further emphasized these aspects of a solid integrity management program. The workshop provided a forum for exchanging information on identifying threats, improving risk assessments, and validating records. Various stakeholders provided informative case studies, perspectives on dealing with these challenges, and identifying effective approaches to improving risk assessments. Specific attention was focused on addressing interactive threats associated with legacy pipelines and approaches for dealing with recordkeeping gaps. On July 20, 2011, PHMSA, in conjunction with NAPSR, sponsored a public workshop to address vintage seam weld issues and provide a stronger focus on better managing challenges associated with vintage pipe seam welds. The event provided an open forum for exchanging information on the nature and extent of the issue. Various stakeholders presented perspectives on how anomalies in seam welds are identified and managed. In addition, the scope of a PHMSA research study on seam welds was presented. The project Comprehensive Study to Understand Longitudinal ERW Seam Failures was initiated by PHMSA in 2011 with three primary objectives: 1) Integrate industry and PHMSA data to quantify vintage seam failure statistics with focus on LF-ERW seams 2) Understand longitudinal ERW seam failures, and on that basis, quantify the effectiveness of inspection and hydrostatic testing to manage integrity and ensure safety to avoid/eliminate catastrophic failures 3) Combine outcomes of the first two objectives to help satisfy National Transportation Safety Board (NTSB) Recommendation P-09-1 from the 2007 Carmichael, Mississippi accident. The study will identify actions that can be implemented by pipeline operators to eliminate catastrophic longitudinal seam failures in ERW pipe. It will include assessments of in-line inspection tools, hydrostatic pressure tests, and spike pressure tests; study pipe material strength characteristics and failure mechanisms; investigate the effects of aging on ERW pipelines; investigate the effects of operational factors (such as pressure cycling) on ERW pipelines; and develop a process for data collection and predictive analysis. OVERVIEW OF VALIDATION APPROACHES For vintage pipelines, pipeline operators must review the design, construction, inspection, testing, and other related integrity data to confirm the pipeline segment MAOP or MOP, material strength, and operational gaps. The data and records used to establish and manage vintage pipe must be reliable. In

the January 2011, PHMSA issued Advisory Bulletin ADB-1101, providing guidance to pipeline operators with methods to validate missing records. Records Validation Operators must review and scrutinize pipeline infrastructure documents and records, including, but not limited to, all as-built drawings, alignment sheets, specifications, design, construction, inspection, pressure testing, manufacturer material tests, maintenance, and other related records. This includes those records in locations controlled by second-party or third-party personnel or firms relating to pipeline system components, such as pipe segments, valves, fittings, and weld seams, to ensure operator records accurately reflect the pipelines actual physical characteristics. These records should be traceable, verifiable, and complete. If such a document and records search, review, and verification cannot be satisfactorily completed, the operator may need to verify the characteristics of the pipeline by other regulatory Code approved methods when identifying and assessing threats or risks and making anomaly integrity assessments. In addition, the operator cannot rely on historical records for establishing or calculating MAOP or MOP if those records are incomplete, missing, inaccurate, or of questionable quality. 49 CFR Parts 192 and 195 specify the requirements to maintain compliance for MAOP/MOP and pipeline materials. An operator also has the option of petitioning PHMSA to allow alternative compliance and integrity verification methods Fitness-for-Service Assessment Methods 49 CFR Parts 192 and 195 does not allow using fitness-forservice techniques to ascertain pipeline integrity where there is a lack of pressure test records, materials grade is unknown, seam type is unknown, or other important integrity records are lacking. Operators are required to follow 49 Parts 192 or 195 (regulatory Code). If an operator wants to propose usage of a fitness-for-service methodology, they must petition PHMSA for approval of a special permit to use the alternative methodology. Resulting Actions Pressure Testing, Remediation, and Pipe Replacement Operators with pipelines that lack valid data and records for MAOP/MOP determination, material grade, and seam type must use conservative integrity management methods as outlined in the regulatory Codes, 49 CFR Parts 192 and 195. If pressure testing records are not available for vintage pipe, an operator may need to retest or lower the pipeline operating pressures. If the pipeline segment can be retested, the operator may petition PHMSA for alternative operating pressures until the pipeline segment can be certified by pressure testing or other approved alternative methods. For pipeline segments without pipe grade and seam documentation, the operator must follow the regulatory Code (see 49 CFR 192.107 or 195.106) in determining pipe conditions or petition PHMSA for

approval of a special permit to use alternative verification methods. RISK REVIEW Operators must be fully cognizant of the physical and operational aspects of their pipeline systems, understand their systems threats and the risks. The operator is ultimately responsible for identifying all potential threats, analyzing all risk factors, and analyzing all potential consequences, as required in the regulatory codes. Any operator of a hazardous liquid or gas transmission pipeline operating at or above 30% SMYS that is not fully certain of the location, line pipe material and seam type, coating, cathodic protection history, repair history, pressure test history, in-line inspection history, soil type, environmental threats, operational history, or other risk factors should: 1) Institute an aggressive program as soon as possible to obtain this information, 2) Assess the integrity risks, and 3) Take the proper mitigative measures based upon the operators IM program risk findings In addition, if an operator does not have information on key risk factors, immediate and interim mitigation measures should be strongly considered, such as pressure reduction to 80% of the previous months operating pressure, or a remediation program to identify and mitigate integrity risks. Operators of natural gas transmission pipelines operating below 30% SMYS should conduct an integrity threat and risk review in a responsive manner to ensure safety in High Consequence Areas (HCAs). For U.S. regulated pipelines, the operator is required to follow an acceptable approach, 49 CFR 192.939(b) to mitigate integrity findings. CONCLUSION Recent pipeline accidents have highlighted the need to better understand the issues associated with managing the integrity of vintage pipelines and the consequences of failing to do so. Pipeline operators should understand the risks associated with vintage pipelines and take the appropriate actions to properly address and mitigate these risks. REFERENCES [1] United States Department of Transportation, Research and Special programs Administration, Office of Pipeline Safety (August 1989) Technical Report OPS 89-1, Electric Resistance Weld Pipe Failures on Hazardous Liquid and Gas Transmission Pipelines [2] Kiefner, J.F. and Clark, E.B. (1996). History of Line Pipe Manufacturing in North America, American Society of Mechanical Engineers. [3] United States Department of Transportation, Pipeline and Hazardous Materials Safety Administration. Cast Iron Pipeline

R&D Project, http://opsweb.phmsa.dot.gov/pipelineforum/ reports-and-research/cast-iron-pipeline/ [4] National Transportation Safety Board, Materials Laboratory Factual Report 110-19, Docket SA-534, January 21, 2011. [5] United States Department of Transportation, Pipeline and Hazardous Materials Safety Administration (January 28, 1988) Advisory Bulletin ALN-88-01, Recent findings relative to factors contributing to operational failures of pipelines constructed with ERW prior to 1970, http://www.phmsa.dot.gov/pipeline/regs/advisory-bulletin [6] United States Department of Transportation, Pipeline and Hazardous Materials Safety Administration (March 8, 1989) Advisory Bulletin ALN-89-01, Update: Additional findings relative to factors contributing to operational failures of pipelines constructed by ERW prior to 1970, http://www.phmsa.dot.gov/pipeline/regs/advisory-bulletin [7] United States Department of Transportation, Pipeline and Hazardous Materials Safety Administration (October 11, 1991) Advisory Bulletin ALN-91-02, NTSB recently issued recommendation P-91-12 related to the August 1990 explosion and fire in Allentown, PA, caused by a crack in a 4-inch cast iron gas main, http://www.phmsa.dot.gov/pipeline/regs/ advisory-bulletin [8] United States Department of Transportation, Pipeline and Hazardous Materials Safety Administration (January 26, 1992) Advisory Bulletin ALN-92-02, Addresses concerns arising from Allentown, PA, explosion, http://www.phmsa.dot.gov/ pipeline/regs/advisory-bulletin [9] United States Department of Transportation, Pipeline and Hazardous Materials Safety Administration (September 1, 1999) Advisory Bulletin ADB-99-01, Potential failures due to cracking of plastic pipe manufactured by Century Utility Products, Inc., http://www.phmsa.dot.gov/pipeline/regs/ advisory-bulletin [10] United States Department of Transportation, Pipeline and Hazardous Materials Safety Administration (October 1, 1999) Advisory Bulletin ADB-99-02, Potential failures due to cracking of plastic pipe in natural gas systems, http://www.phmsa.dot.gov/ pipeline/regs/advisory-bulletin [11] United States Department of Transportation, Pipeline and Hazardous Materials Safety Administration (November 26, 2002) Advisory Bulletin ADB-02-07, Notification of the Susceptibility to Premature Brittle-Like Cracking of Older Plastic Pipe, http://www.phmsa.dot.gov/pipeline/regs/ advisory-bulletin [12] United States Department of Transportation, Pipeline and Hazardous Materials Safety Administration (September 6,

2007) Advisory Bulletin ADB-07-01, Updated Notification of the Susceptibility to Premature Brittle-like Cracking of Older Plastic Pipe, http://www.phmsa.dot.gov/pipeline/regs/ advisory-bulletin [13] United States Department of Transportation, Pipeline and Hazardous Materials Safety Administration (January 10, 2011) Advisory Bulletin ADB-11-01, PHMSA-2010-0381, Pipeline Safety: Establishing Maximum Allowable Operating Pressure or Maximum Operating Pressure Using Record Evidence, and Integrity Management Risk Identification, Assessment, Prevention, and Mitigation, http://www.phmsa.dot.gov/ pipeline/regs/advisory-bulletin