If you’ve ever looked at a map of all the pipelines transporting natural gas, oil and other liquids across the United States, you’d be looking at nearly 2.5 million miles — roughly four times the distance to the moon. It’s a lot of ground to keep track of, particularly when 50 percent of transmission pipe was installed before 1970, and most of those pipelines are underground.
With that many miles of pipeline, knowing the location and condition of the pipes is a formidable task, and one that’s strongly tied to public safety. Federal regulations govern pipeline design and construction, protection from corrosion, pressure requirements, operation and maintenance, qualification of personnel and integrity and risk management practices. On top of that, many states have their own programs for intrastate pipelines.
In the last five years, a handful of high-profile pipeline safety incidents have resulted in closer scrutiny of the nation’s pipeline regulations. Gas ruptures, leaks and explosions have led regulatory agencies to demand better pipeline data management systems and practices. This includes a process for systematically validating records and the ability to demonstrate traceable, verifiable and complete records on every foot of pipeline across the country.
This was a call to action heard by Spectra Energy, one of North America’s leading pipeline and midstream companies based in Houston, Texas.
Spectra Energy has more than 12,000 miles of pipeline in the United States, which have been catalogued within a mature Geographic Information System (GIS) in order to track pipeline compliance. Every foot of pipeline has to be vouched for — where it’s located, any testing or inspections, even reviews of design or construction. Source documents of the attribute data must correlate with the information within the GIS and have the capability to be retrieved for internal verification and during federal agency audits.
“The company is diligent in monitoring new regulations and tries to take a lead in getting out in front statutes,” says Cindy Brann, director of Operational Business Systems at Spectra Energy. “It is important for us to understand what the new regulations may require and make sure our documentation and verification of the company’s pipelines are accurate and available in a timely manner.”
Documenting pipelines is a regulatory reporting requirement, signed into federal law in 2012 by President Obama — the Pipeline Safety, Regulatory Certainty and Job Creation Act to substantiate the direction taken by federal regulators with respect to pipeline safety and security. Subsequently, the Pipeline Hazardous Materials and Safety Administration (PHMSA) issued a reminder to pipeline operators that if they are relying on the review of design, construction, inspection, testing and other related data to establish the Maximum Allowable Operating Pressure (MAOP) of their pipelines, they must “ensure that the records used are reliable, traceable, verifiable and complete.”
MAOP refers to the regulatory limit involving the strength of a pressurized cylinder such as a pipeline and how much pressure the walls may safely hold in normal operations.
The laws enacted in 2012 are in response to the aftermath of the September 2010 San Bruno, California, pipeline rupture and explosion, when it became apparent that some of the aging gas pipelines’ physical conditions were under-documented. PHMSA re-examined many of its regulations and began to revise, expand and strengthen them.
The Act contains a broad range of provisions addressing pipeline safety and security, including an increase in the number of federal pipeline safety inspectors, required automatic shutoff valves for transmission pipelines, mandated verification of maximum allowable operating pressure for gas transmission pipelines, and increased civil penalties for pipeline safety violations.
Although compliance was due a year ago in high population areas, many companies have not addressed lower population areas in relation to record verification and are waiting for additional published guidance from PHMSA before doing so.
Spectra Energy has been reconfirming MAOP for its pipelines for the past three years in both high and low population areas along the pipeline route, but also wanted to be sure the processes and procedures were properly documented for this program. The company also wanted to recognize and implement any process improvements before the program creates long-term plans.
Spectra Energy’s MAOP Verification Efforts
As part of Spectra Energy’s compliance with MAOP verification, the company created a plan to meet the spirit of the PHMSA requirement to have a foot-by-foot correlation of pipeline location to relevant records that provide attribute and hydrostatic test data for those systems.
According to the PHMSA Advisory Bulletin from January 2011, Spectra Energy and other pipeline companies must “diligently search, review and scrutinize documents and records, including but not limited to, all as-built drawings, alignment sheets, and specifications, and all design, construction, inspection, testing, maintenance, manufacturer and other related records.” The documents have to be verified, and must have an authorized signature of the person in charge.
“For nearly three years, Spectra Energy has been verifying our pipeline system through a formalized Data Integrity Program and has been documenting our workflows and creating processes and procedures for that verification,” Brann says. “We wanted PHMSA to know our pipeline verification process was up-to-date and working as it should be.”
Pipelines constructed before July 1970 were given a grandfather clause for pipeline segments. Grandfathered clause means that pipe installed before July 1, 1970, may operate at the highest recorded pressure during 1965 and 1970 even if it is higher than what current regulations allow. Thus MAOP was grandfathered until the pipe needs to be replaced for other regulatory reasons.
“This does not mean we can have insufficient records,” Brann says. “On the contrary, it is essential that the older pipeline assets be fully documented to support the grandfathered MAOP. The documentation to support the grandfathered MAOP is a critical element to maintaining our strategic business advantage and asset footprint as we safely deliver natural gas to our customers without realizing additional business costs.”
Spectra Energy has been gathering evidence to show their verifiable pipeline system. The company also needed to cross-check the data collected from records and ensure high data quality through the use of a MAOP calculator, an application that applies algorithms against verified pipe information to ensure compliance with federal regulations. The calculator would then seamlessly integrate the MAOP calculations with Spectra Energy’s current GIS database, providing a single compliance data source, thus simplifying the data reporting process, both internally and to PHMSA.
To have the data easily accessible, Spectra Energy needed an internal company portal to communicate the MAOP reconfirmation results to stakeholders and provide a central repository to house updated maps and alignment sheets of pipelines and detailed program information for the company’s U.S. pipeline system.
In addition to the MAOP calculator and the focused internal company portal, Spectra Energy also recognized the need for program documentation and knowledge sharing.
“Even though we started our validation program early, we wanted to ensure that we outlined our assumptions, business rules and procedures right the first time and transferred expert knowledge internally in a seamless manner,” Brann adds.
A Teamwork Approach from Mosaic
In July 2013, Spectra Energy employed the services of Mosaic, a national training and workforce performance consulting firm, to formalize MAOP verification workflows, process maps and procedures. In addition, Mosaic validated, documented and finalized the development of a MAOP calculator application to be used for validating regulatory compliance and designed an internal company portal to provide program transparency to employees.
“We built the MAOP calculator according to PHMSA regulations, but also to Spectra Energy’s requirements,” says John Benoit, Mosaic director of oil and gas. “The calculator is used as a quality assurance tool. It equips Spectra Energy with an ability to perform extensive analysis, tracking and reporting on the data available in the company’s current GIS and can spot if there is any human error. It provides a high degree of confidence and assures that the pipeline asset data meets Spectra Energy’s rigid quality standards.”
Quality controls were put in place and a stakeholder communications plan was developed to keep information flowing throughout all levels of Spectra Energy’s stakeholder audience, providing key messages regarding the importance of MAOP and building confidence in the data becoming available from the data scrubbing process. The Spectra Energy/Mosaic team created an overall project management plan, including the documentation of the process with visual process maps and formalized technical procedures.
In January 2014, a similar initiative to the range pipe process was launched for the MAOP verification for pipeline sites, such as compressor stations. It was a unique challenge as it involved the creation of new processes and tools. A key win in the project was developing requirements for an ArcMap tool designed to capture site inventories and represent them geospatially in the GIS environment.
Mosaic is working on a SharePoint portal that will display essential information resulting from the data verification for the 12,000 miles of pipeline. This central repository becomes an easy to use access point to use the data and to understand what MAOP is and how it impacts many different departments within Spectra Energy.
“Our stakeholders need to have this information at their fingertips,” says Brann. “This enables them to make the best operational decisions possible, based on accurate, dependable data which is available electronically via maps, alignment sheets, spreadsheets and other medium. It gives them a reliable representation of what’s in the ground and provides that access instantaneously.”
According to Brann, stakeholder engagement is critical and communication opportunities have to be leveraged. The new MAOP-focused internal portal emphasizes the importance of MAOP to stakeholders outside of the immediate operational compliance and pipeline integrity focus areas. The Spectra Energy employees that ‘touch the pipe’ every day and are responsible for daily operations must also be engaged to provide feedback to keep the data quality at the highest level possible.
Reliable asset data is a key component of reliable operations — and reliable operations leads to better safety measures that enhance public safety. Spectra Energy is committed to the goal of safe and reliable operation of their transmission pipeline system and the MAOP Reconfirmation Program is one example of that commitment.
Christina Kelly is director of communications at Mosaic.