Cliff Johnson, director of Public Affairs at NACE International, The Corrosion Society, recently assembled a panel of NACE pipeline corrosion control experts to answer a series of questions on how recent regulations and developments are affecting the pipeline industry.
“The pipeline industry has seen dramatic regulatory change over the last 10 years and has been impacted by a number of high-profile pipeline failures,” said Johnson. “The relationship between the industry and government has evolved significantly in this time frame, as we work together to ensure public safety and environmental protection with the use of these critical transportation systems.”
The five expert panelists have extensive experience with today’s regulations, standards and corrosion-control methods for oil and gas pipelines. The panelists are Mark Gluskin, senior vice president of Mears Group, Inc.’s Pipeline Integrity Services; Kimberly-Joy Harris, lead corrosion control coordinator at Enbridge Pipelines, Inc.; David H. Kroon, executive vice president and chief engineer of Corrpro Companies, Inc.; David L. Johnson, technical consultant for Panhandle Energy’s Technical Services Department; and Neil G. Thompson, director of the Onshore Pipeline Segment for the Materials and Corrosion Technology Center at DNV Columbus, Inc.
Q: As we look back over the last 10 years, how has the industry improved pipeline safety and integrity? How would you rate the industry in terms of asset preservation, public safety, pipeline integrity, and corrosion?
Johnson: Wow, the last 10 years – that sounds like a lot, and, in fact, it is. Early on, we worked very hard with the federal Office of Pipeline Safety (OPS) to develop a common background, understanding, and basis for Subpart O of the regulations – “Integrity Management.” The implementation of these requirements was accomplished, in part, by the development and application of consensus standards, including several under the auspices of NACE, to provide operators with consistent, technically sound guidance. As we have progressed through the baseline inspection period, we have learned a lot about the threats to pipeline integrity and how to assess them, and we have inspected tens of thousands of miles of transmission pipelines. As this work has progressed, we have eliminated pipeline defects, mitigated risks, and driven technological advances in inline inspection (ILI) technology, direct assessment (DA) methodologies, pressure testing strategies, and analysis of pipeline responses and behavior in the presence of anomalies. We’re not perfect, but the improvements have been significant.
Kroon: There is no question that improvements have been made in the safety of regulated pipelines over the last decade. These safety improvements and emphasis on pipeline integrity have been a direct result of operator compliance with the U.S. Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) regulations. With increased testing and inspection, the industry has further enhanced its excellent record for safe operations. There is, however, a need to continue to develop technologies and programs that apply multiple technologies to further corrosion detection and mitigation.
Harris: I would definitely rate the industry positively in terms of asset preservation, public safety, pipeline integrity and corrosion control. This is largely based on improved pipeline coatings; enhanced public safety awareness with programs such as the nationwide 811 “Call Before You Dig” initiative and dissemination of information through publications and public forums; and improved ILI tools, over-the-line surveys, and other assessment methods.
Thompson: The pipeline industry was affected by the product pipeline failure that occurred in Bellingham, WA in 1999 and the natural gas pipeline failure that occurred in Carlsbad, NM in 2000. Changes include improved regulations with enhanced personnel training and increased focus on the pipeline integrity decision process. A major improvement in the regulations was the recognition of high consequence areas as a component of a risk-assessment approach for both liquid and gas pipelines. An indication of the success of the industry’s commitment to the improvement of the integrity of pipeline systems is the overall decrease in reportable leaks as concluded by the Association of Oil Pipelines:
- Spills along the right-of-way have fallen from two incidents per thousand miles in 1999-2001 to 0.8 incidents per thousand miles in 2005-2007, a decline of 60%.
- The volume released along the right-of-way has fallen from just over 600 barrels per thousand miles to 300 barrels per thousand miles in the same time periods, a decline of 50%.
- Several cause categories have been identified for onshore pipeline incidents, including corrosion, third-party excavation damage, equipment and non-pipe failures, operator error, and pipe material failures. The number of incidents in each of these categories has fallen in the last review period (2005-2007) over the previous period (1999-2001) anywhere from 20-71%.
Q: As we continue to ask for more out of our aging pipeline infrastructure – a longer life and moving new production streams through pipelines – what are the challenges in regards to asset preservation and corrosion?
Gluskin: One of the continued challenges in asset preservation is that while the spending is heavy for complying with regulatory requirements, less money is available for reliability-based maintenance and remedial work. Often at operating companies, there is not sufficient weight put on maintaining the overall reliability of an asset, and the inherent culture tends to be more reactive than proactive. The funding challenges we face are much the same as they have been historically, in particular for buried or submerged structures – out of sight, out of mind. Initiatives must be driven from the top down with a business objective focused on reliability and the financial strategy set to forecast and predict maintenance and remediation costs over a fixed period of time.
Johnson: We all know that corrosion control is one of the primary keys to asset preservation, particularly when those assets are largely underground steel structures. The challenges continue to grow and have several aspects. We have more people living closer to pipelines, new and different products moving through pipelines, and more challenging environments. Inspection, evaluation, and rehabilitation methods that can be accomplished safety and reliably in close proximity to populations and without undue environmental impacts must continue to be enhanced.
Thompson: Spending wisely is one of the pipeline company’s major challenges. There is a strong push for condition assessment (inline assessment and direct assessment). Condition assessment is only one of four major activities required for an asset-management program that should be based on continuous improvement – the other activities are monitoring, prevention, and maintenance. Focusing spending on one area sometimes means a decreased focus in another. A strong focus on assessment, for example, can lead to a “find it and fix” it mentality and this is a losing proposition for long-term asset preservation. Threat prevention, regular monitoring, and routine maintenance as well as regular repair and rehabilitation are all required for a healthy asset-management program.
Kroon: Improved methodologies and technologies are needed for pipeline inspection and defect detection for facilities where ILI is not feasible because of such things as low pressure, low flow, tight radius bends, or cast iron pipe. Addressing these needs is particularly important for gas distribution systems.
Q: Is the partnership between industry and government working to produce a higher level of safety?
Gluskin: Absolutely, and this collaboration has been accelerated since the Pipeline Safety Act was signed into law at the beginning of this decade. The resulting regulations have caused operators to focus on integrity insurance in areas that potentially pose the highest risk to public and environmental safety.
Kroon: The partnership is clearly working. Without government regulations, responsible pipeline operators would be at a disadvantage to competitors that might not place appropriate emphasis on pipeline integrity management.
Harris: There is a strong partnership between the oil and gas industry and the government to produce a higher level of safety. NACE has been very active in forging this relationship with programs such as Legislative Day where industry representatives meet with Congress on Capitol Hill to heighten the awareness of our aging infrastructure and enlighten them on the various means available to mitigate and control corrosion.
Johnson: Again, thinking about the past decade, we have seen some key indicators that the partnership is working. First, as issues of concern have been identified, a common approach has been to convene a workshop or public meeting to discuss the issue, collect information and experiences, and develop a plan to address it. Some fairly recent examples include construction and pipe-quality concerns, casing issues, and anomaly response and remediation. Second, OPS has become a more active participant in safety-related research and development. This has followed a similar model, with highly attended forums to discuss, identify, and prioritize research needs.
Thompson: One clear area of cooperation over the last five to 10 years has been the increased number of industry-government research programs conducted jointly by the Pipeline Research Council International (PRCI) and PHMSA. These two organizations have combined to provide funding and in-kind operator assistance for several industry research programs aimed at solving difficult problems related to pipeline integrity management. The NACE technical committees that develop industry standards and practices are often a direct result of joint industry committees containing operators, consultants, suppliers, and regulators. In addition, the standards developed by NACE are often adopted in whole or in part into government regulations.
Q: Is there a need for additional investment in research and development for the pipeline industry and are we looking far enough into the future to address any problems?
Gluskin: In virtually all industries, there is always a need for continued improvement through innovative development, and the pipeline industry is no different. Many of our pipeline systems are nearing the end of the original design life – nothing lasts forever. Therefore, the need to develop technologies for identifying deficiencies and to efficiently remediate is of great importance. We need to develop technology that finds the problems before the problems find us. The future is now.
Thompson: Research and development is a continuous improvement activity. Advances in research are typically small steps and very seldom is a truly major advancement realized. Unfortunately, most often pipeline research is solving an immediate problem that has become critical to operations. Far too seldom is research leading an advancement or predicting a problem before it has become critical. This is often a budgetary commitment issue. There are too many pressing topics and problems to be solved that will impact operations to look too far into the future unless funding is specifically targeted for long-term research ideas.
Kroon: The vast majority of the research and product development for pipeline integrity inspections and repair is funded by service companies. Companies are funding projects for the purpose of bringing products or services to the marketplace to increase profitability. Pipeline operators will need to direct funding for specific research or technology development (or partner with service companies) if the goal is more rapid and targeted technology development.
Johnson: The industry has been self-funding collaborative R&D for almost 60 years now, but there is still much to do. Much of our R&D has focused on current or near-term issues; however, we are also trying to look further down the road and engage in longer-term R&D. That tends to be riskier in terms of likelihood of success, but the results may also be more beneficial. Everything we do must be accomplished with safety and integrity as the utmost concerns, with as little impact on landowners and the environment as we can manage.
Q: As we continue to look at alternative fuels, what will be the limiting factors for moving and storing the products (CO2, biofuels, biomass, etc.)?
Thompson: A primary limiting factor is the lagging of engineering information and operating standards for alternative fuel transportation. There is a lack of historical operating knowledge of the risks and challenges associated with transporting these products. Research in these areas is ongoing to define critical operating issues. Each of the products has unique issues and requires specific operating standards. A significant concern is the requirements for transitioning a pipeline system from one product to another.
Johnson: One of the first questions regarding such materials is whether we can handle them safely and reliably with the existing infrastructure, whether we need to modify the existing infrastructure, or whether we will need to construct infrastructure specifically for them. The corrosion potentials of some of these products can be quite high under some conditions – CO2 that is not completely dry, for example – or variable under other conditions, such as biofuels and biomass from various sources and compositions. In addition to pipe material compatibility, we must address the compatibility with other components and materials in our systems – pumps and compressors, valves and valve seals, measurement facilities, and others.
Kroon: Pipelines are the safest and most efficient means of transporting bulk liquids and gas fuels. The marketplace will respond to the new challenges of storage and transportation of new or alternative fuels. Pipeline companies are innovative and are already in the CO2, biofuel, and ethanol transportation and storage business. As demand grows, pipeline companies will respond with additional transportation and storage infrastructure.
Q: This year in Congress, PHMSA will have reauthorization hearings on Capitol Hill. How does the pipeline industry need congressional assistance; for example, more funding for R&D, more training requirements for regulators, or more reliability-based regulations?
Gluskin: Yes! All the above are of equal priority, not only for public safety, environmental safety, security, and reliability, but also for resource preservation and the overall affordability for the end user.
Kroon: Technology development for the pipeline industry needs more funding to keep in front of newly identified threats, such as alternating current corrosion. More training is always beneficial for regulators, pipeline operators, and service companies alike. Regarding additional regulations, there are still pipeline companies discovering that they operate regulated pipelines. Some efforts could be directed toward operator awareness and compliance guidance.
Johnson: The Pipeline Safety Act is due for reauthorization this year and we anticipate some congressional hearings, inquiries by congressional staff, and the development of testimony and position papers. Certainly, some additional R&D funding would be welcome and may enable us to do more long-range work. In the last couple of reauthorizations, Congress has made it clear that enhanced damage prevention and public awareness programs are important. An additional step we would like to see them take is to “strongly encourage” the states to eliminate exemptions from one-call laws. Risk-based re-inspection intervals, as favored by the industry, OPS, and U.S. Government Accountability Office, would also be welcome.
Thompson: At some point, and now is the time to start the discussion, the whole set of pipeline rules and regulations (natural gas and hazardous liquids including new regulations for “new” products such as CO2, ethanol, biofuels, etc.) should be reviewed, consolidated, and re-worked in order to improve the overall pipeline asset risk management. Take, for instance, the external corrosion threat for pipelines: 10 years ago, the cathodic protection (CP) criteria were used for maintaining the CP system, but there was no means of assessment beyond leak history, which is a very trailing indicator. The current methodologies for condition assessment (inline inspection and direct assessment) allow the ability to establish the pipeline condition and multiple assessments make it possible to determine changes in the condition, including active external corrosion. The combination of a CP criterion and multiple condition assessments provides complementary tools for a more comprehensive “Corrosion Management Practice,” which could ultimately result in meeting pipeline integrity requirements and optimizing costs. This is, of course, one example – there are many more when the whole of pipeline regulations are considered.
Q: Do you have any other comments you would like to provide?
Kroon: Pipelines in casings is one of the areas needing further development of both inspection methodologies and corrosion control systems. Inline tool inspections using magnetic flux leakage or ultrasonic testing to detect metal loss are in widespread use for pipelines that can be pigged on-stream with the product being transported. Pressure testing is also being used, but to a lesser degree. Technologies under development include guided wave ultrasonic inspection and electromagnetic wave inspection, but the pipe must be excavated for attachment of the equipment used to propagate the inspection signal along the pipeline in the casing. External corrosion direct assessment (ECDA) is being used, although more research and testing would be beneficial to improve and standardize the process.
Harris: There is a need to recruit more universities to offer corrosion-control curriculums to assist with developing the next generation of corrosion control professionals, such as the University of Akron’s new corrosion engineering degree program that will be launched this fall. The industry corrosion-control knowledgebase of professionals is aging, making this a serious issue in the upcoming decade. On a positive note, NACE has been very proactive in enhancing its education and certification programs to support industries in addition to pipelines, including nuclear, power, maritime, bridges, and other infrastructure, and a partnership with the Department of Defense to control corrosion in all of their systems. I look forward to doing my part to work with manufacturers on enhancing their corrosion-control research and technologies, assisting with developing the next generation of corrosion control professionals, and working to further educate Congress on the existing concerns with our infrastructure and how we can mitigate them.
Thompson: The need for flexibility in any standard practice and the need for continuing research are two necessities for the pipeline industry unlikely to change anytime soon. Advances in monitoring practices, improved risk-assessment methods, evolving steels for pipeline construction, improved construction practices, enhanced repair methods, development of threat prediction models, an aging pipeline infrastructure, and public encroachment all drive the future needs of the pipeline industry. At the same time, it cannot be ignored that pipeline operation is a business and the economic viability of that business must be maintained. The most elaborate and extensive asset-management plan cannot be placed into effect unless there is an economic justification. Therefore, there is a need for cost benefit/life-cycle modeling to provide the best use of available funds.
Johnson: We started this discussion by looking back over the past decade. I am looking back at a career of slightly over three decades. When I started as a metallurgist a few years out of school and new to the industry, I wondered if there would be enough challenges and interesting things to do, or if looking at an occasional corrosion failure on a pipeline and a fatigue failure in a compressor station would be about it. The challenges have continued, and working collaboratively with people throughout the industry in peer companies, trade associations, technical societies, research organizations, and regulating agencies has proven to be very rewarding.
The moderator and panelists
Cliff Johnson, moderator, is the public affairs director at NACE International, the technical society for corrosion professionals. Founded in 1943 by 11 pipeline engineers, NACE now has more than 21,000 members in over 100 countries and is involved in every industry and area of corrosion prevention and control. With a mission to protect people, assets, and the environment from the effects of corrosion, NACE offers training and certification programs, sponsors conferences, and produces industry standards, reports, publications, and software. For more information, visit www.nace.org.
Mark Gluskin is senior vice president of Mears Group, Inc., Pipeline Integrity Services, in San Ramon, CA. He has 30 years of work history in the corrosion control field and is a NACE-certified Corrosion Specialist.
Kimberly-Joy Harris is the lead corrosion control coordinator for Enbridge Pipelines, Inc., in Griffith, IN. She has been involved in the industry for over 21 years, overseeing various corrosion control programs for the past 18 years. She has obtained multiple university degrees in the fields of applied science, engineering, and business administration. Harris is NACE-certified in multiple levels cathodic protection, and is a Corrosion Technologist, Internal Corrosion Technologist and Coating Inspector. She also is a Craft Instructor and Master Trainer for the National Center for Construction Education and Research. She has worked abroad on various projects in the area corrosion control and pipeline rehabilitation.
David L. Johnson is a technical consultant in Panhandle Energy’s Technical Services Department in the areas of pipeline safety and integrity. He has a B.S. degree in engineering and a Ph.D. degree in materials science and metallurgical engineering from Purdue University. He has been involved with various aspects of pipeline integrity, including specification, design, failure analysis, construction, operations, corrosion control and regulations. He has been the U.S. delegate on gas transmission to the International Gas Union and is active in ASME on the B31.8 (Gas Transmission Pipeline) committee, the Pipeline Research Council International, and currently serves as chairman of the Pipeline Safety Committee of the Interstate Natural Gas Association of America. He has worked with PHMSA on several initiatives and rulemakings, including the development of the integrity management regulations. He is a registered professional engineer in the State of Texas.
David H. Kroon is executive vice president and chief engineer of Corrpro Companies, Inc. in Houston. He has 39 years of experience in corrosion prevention, including material selection, protective coatings, pipeline integrity, cathodic protection, and alternating current/direct current interference mitigation. Over his entire career he has been actively engaged in solving corrosion problems for the pipeline industry. In recent years, he has contributed to the development of direct assessment standards and to the execution of numerous ECDA and stress corrosion cracking direct assessment projects. Kroon as a B.S. degree in chemistry from Yale University and is a registered professional engineer in eight states.
Neil Thompson is founder and chairman of CC Technologies, Inc., now DNV Columbus. He is the DNV Segment Director for Onshore Pipelines and Deputy Head of DNV Materials and Corrosion Technology Center. A NACE Past President, he currently serves as President of the NACE Foundation, promoting education and awareness within corrosion science and engineering. He has directed 32 major research projects and numerous field studies and testing projects examining various aspects of corrosion science, corrosion monitoring, and cathodic protection (CP). A large portion of his research has been in the area of underground corrosion and CP for the pipeline industry. He was a major contributor to “Corrosion Cost and Preventive Strategies in the United States,” which was a Congressional funded study that established the impact of corrosion to the United States economy as $276 billion annually. He has a Ph.D. degree in materials science engineering from Vanderbilt University.