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Total Asset Integrity ManagementRAE
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RAE Engineering and Inspection Ltd.RAE Engineering and Inspection Ltd.Pipelines Regulatory CompliancePipelines Regulatory Compliance
Presented byFranklin Del Rosario, P.Eng.
RAE Engineering and Inspection Ltd.
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Pipeline Integrity Management Program
WELCOME
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Objectives
Introduction
AER (Alberta Energy Regulator) focus
Pipeline Integrity Management Program
PLIMP & POMM
Work Order System
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JurisdictionJurisdiction
Federal Jurisdiction» NATIONAL ENERGY BOARD (NEB) Canada
Provincial Jurisdiction» ALBERTA ENERGY REGULATOR (AER)» BC OIL and GAS COMMISSION (BC OGC)
» Saskatchewan The Ministry of the Economy
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Regulated by NEBRegulated by NEB
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Pipeline Regulated by NEB Pipeline Regulated by NEB 73,000 km73,000 km
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Jurisdiction in AlbertaJurisdiction in AlbertaAlberta Energy Regulator (AER) formerly Energy Resources Conservation Board (ERCB)
Provincial Pipelines 415,152 km
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Jurisdictional FrameworkJurisdictional Framework
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Pipeline Act
Pipeline Rules
AERDirectives
CSA Z662CSA Z245
Alberta Pipeline Alberta Pipeline LegislationLegislation
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Sometimes it may LOOK right, but…….
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AER – Alberta Energy RegulatorAER – Alberta Energy Regulator
• An independent, quasi-judicial agency authorized by the Government of Alberta.
• Regulate the safe, responsible and efficient development of Alberta’s energy resources: oil, natural gas, oil sands, coal, and PIPELINES.
• Act under the umbrella of the Energy Resources Conservation Act.
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Safety component – sour gas emissions, spills, pressure testing, ground disturbance
Land use component – pipeline right-of-ways, urban and protected area encroachment
Water use component – oil sands projects
Environmental component – orphaned facilities, carbon dioxide emissions
Emergency response planning and notification
Scope of AERScope of AER
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AER PolicyAER Policy
Directives GuidesInformation LettersBulletins
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AER DirectivesAER Directives
• Documents setting out new, or amended, AER requirements or processes, to be implemented by licensees, permittees, and other approval holders.
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Pertinent AER DocumentsPertinent AER Documents
• Directive 41 – “Adoption of CSA Z662 Annex N as mandatory”
• Directive 55 – “Tanks”
• Directive 56 – “Applications for Energy Developments”
• Directive 66 – “Requirements and Procedures for Pipelines”
• Directive 77 – “Pipelines – Requirements and Reference Tools”
• Directive 60 – “Flaring Requirements”
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Where to find Acts and Where to find Acts and RegulationsRegulations
• Acts and regulations are protected by copyright
• Province Pipeline Regulatory Regime» AER website www.aer.ca» BC website www.bcogc.ca» Saskatchewan
http://economy.gov.sk.ca
• Alberta Queen’s Printer• www.qp.gov.ab.ca
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In Alberta Pipelines In Alberta Pipelines CSA Z662CSA Z662
Jurisdiction Boundaries» ABSA – Safety Codes Act
(Streamline's, Pressure Piping's)
» AER – Pipeline Act
» Oil and Gas Act
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Pipelines: – AER
» Pipeline Act and Regulation
Well Downhole, Well site Piping: – AER
» Oil and Gas Conservation Act and Regulation
Alberta – Jurisdictions to deal withAlberta – Jurisdictions to deal with
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Above and Below ground Storage Tanks: – AER
» Oil and gas Conservation Act and Regulations
Facilities, including Process Piping: ABSA, the Pressure Equipment Safety Authority
» Safety Codes Act and Pressure Equipment Safety Regulations
Steamlines – dual jurisdiction» ABSA (Design) and AER (operation)
Alberta – Jurisdictions to deal withAlberta – Jurisdictions to deal with
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In Alberta
» Published as part of AER Directive 77
» Pipelines: Requirements and Reference Tools
Jurisdiction Breaks In AlbertaJurisdiction Breaks In Alberta
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Relationship between ASME Relationship between ASME B31.3 and CSA Z662 (D77)B31.3 and CSA Z662 (D77)
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Integrity Management Integrity Management ProgramProgram
Integrity Management Program is mandatory, as per AER Directive 41, entitled “CSA Z662-13, Annex N as Mandatory.”
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“If it is not written down, it does not exist.”
“If it is not written down, it does not exist.”
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1. CSA Z662-11 Annex N1. CSA Z662-11 Annex NIntroduction
IMP Scope
Corporate policies, objectives, and organization
Description of pipeline system
IMP Records
Change of Management
Competency and Training
Hazard Identification and Control
Risk Assessment (Annex B)
Options for reducing frequency and consequences of failure or damage incidents
IMP Planning
Inspection, Testing, Patrols and Monitoring
Evaluation of Inspection, Testing, Patrol, and Monitoring Results
Mitigation and Repair
Continual Improvement
Incident Investigations.
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N.2 Integrity Management N.2 Integrity Management Program ScopeProgram Scope
Documentation required:» Design and Construction
» Condition Monitoring
» Maintenance and Repair
» Operating Condition
» Failure Incident
» Damage Incident
» Manufacturing Imperfection
» Environmental Protection ; and
» Safety
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N.3 Corporate Policies, Objectives N.3 Corporate Policies, Objectives and Organizationand Organization
Shall identifies person in charge of company operation
Personnel that are responsible to keep IMP
Corporate Organizational Chart.
Corporate Policies, Values, Objective
Record of Management, Planning, and Reporting
Performance Indicators
IMP Audits, Reviews and Evaluation
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N.4 Description of Pipeline SystemN.4 Description of Pipeline System
Purpose, Capacity and Location
Dimension and Material characteristic of Pipeline System
Condition of pipeline system types of coating, location and function of ancillary equipment
Operating condition service fluids, pressure and temperature range
Physical surroundings along the pipeline route; and
Physical boundaries of the pipeline system.
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N.5 IMP RecordsN.5 IMP Records
Management of Record related to Pipeline System Design, Construction Operation and Maintenance.
Location of Pipeline with respect to Crossing, Land Use, Structure and Class Location(s).
Material Test Reports, Joining, Coating, and Inspection Records, Pressure Testing,
Cathodic Protection System Design and Performance.
Terrain, Soil Type, Backfill Material, and depth of Cover.
Methods used and the Results Obtained for above activities.
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N.6 Change ManagementN.6 Change ManagementShall develop, document and implement a change management process for changes that might affect the integrity of pipeline system. Changes such as;» Ownership of the pipeline system, organization and personnel.
» Piping & control system, system operating status & condition, service fluid, methods, practices and procedure.
» Record of Management, Planning, and Reporting
» Industry standards, recommended practices and regulations
» Physical environment changes
Shall have procedures in place for change management process.
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Management of Change (MOC)Management of Change (MOC)Process for defining safe operating limits for pipeline and the processes.
Identification of responsibilities for approving and implementing changes, Reason for the changes
Documented MOC process
Formal system that evaluates, authorizes, and documents change
Record retention
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N7. Competency and TrainingN7. Competency and Training
Method used to evaluate the knowledge skills of » Personnel
» Contractors
» Consultants
Formal Training Courses, Work Shop and Conferences.
Research and Development project related to pipeline system integrity
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N8. Hazard Identification & ControlN8. Hazard Identification & Control
All hazards can be classified into two groups: » Work-related hazards; and
» Equipment operations and failure-related hazards
All hazards shall be recorded and the proper company authority notified.
A hazard may initiate the MOC Process
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N9. Risk Assessment & ReductionN9. Risk Assessment & Reduction
A risk assessment is used to classify the level of identified hazard
Hazard and Risk Assessment
CSA Z662-11 Annex N, section N.10 contains solutions to possible hazards
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N10. Reducing Frequency and N10. Reducing Frequency and consequences of Failure consequences of Failure
Operating Error» Modified operating and maintenance practices.
External Interference» Increase frequency of right of way inspections and patrol
Imperfections» Improve performance of cathodic protection, pressure test
Natural Hazards» Program to monitor ground movement, soil erosion.
Consequences Reduction» Improve emergency response procedure
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N11. IMP PlanningN11. IMP Planning
Shall establish and document plans and schedule for activities related to pipeline system integrity management
Shall take into consideration condition that lead to failure incidents
Shall include steps for reviewing completed integrity activities
Shall include steps for consulting with and informing appropriate personnel about issues and programs.
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Pipeline OperationPipeline Operation
Routine pipeline operation: » Pigging and logging
» Hydrate management
» Purging and release of product
» Chemical programs
» Leak detection
Non-routine pipeline operations is evaluated by Engineering
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N12. Inspection, Testing, Patrols & N12. Inspection, Testing, Patrols & MonitoringMonitoring
Stress Corrosion Cracking (SCC) monitoring
Leak Detection inspection
Cathodic protection System
Right-of-Way (ROW) inspections
Non-Destructive Examination (NDE) inspections
Safety relief devices
Location Pipeline Valves
Inspection of Exposed piping corrosion.
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Measuring Equipment & Measuring Equipment & Instrumentation CalibrationInstrumentation Calibration
All measurement equipment and any instrumentation associated with a pipeline shall be properly calibrated and reported
Contractor’s equipment calibration certification must be reviewed, prior to the use of the equipment
All calibration certificates should be available on sites
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N13. Evaluation of inspection, N13. Evaluation of inspection, testing, patrol, and monitoring testing, patrol, and monitoring
resultsresultsAnything that may lead to failure shall perform an Engineering Assessment
Evaluation of indication of imperfections
Natural Hazard Evaluation
Maintain records of recommendations.
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N14. MITIGATION AND REPAIRN14. MITIGATION AND REPAIR
Should document the type of corrective actions that will be considered condition that could cause a failure
Shall document procedures for mitigation and repair
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Corrosion ManagementCorrosion Management
External Corrosion Protection and Monitoring» Above-ground pipelines
» Underground pipelines
Internal Corrosion Monitoring and Management
Pipeline Deterioration
Pipeline Repair
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Special ProcessesSpecial Processes
Not covered under normal operations and inspections» Pipeline external NDE inspections
» Pipeline smart pigging operations
» Welding and hot tapping
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N15. Continual ImprovementN15. Continual ImprovementShall plan and implement the monitoring, measurement, analysis and improve the effectiveness of the IMP
Shall review and evaluate periodically in accordance with the provision of the standard.
Shall periodically audit the IMP.
Shall establish authority and responsibility in handling non-conformance issues.
Shall take action to complete corrective and preventive action.
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N16. Failure & Incident N16. Failure & Incident InvestigationInvestigation
A pipeline failure or an external interference incident must be reported to AER
When cause of the failure is unknown, a investigation is required
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STAY WITHIN KNOWN PARAMETERS
STAY WITHIN KNOWN PARAMETERS
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Pipeline Management & Pipeline Management & AdministrationAdministration
Regulatory reports and compliance Suspension of pipelines
Abandonment of pipelines
Change of service or pressure» Sweet service to sour service
» Decrease operating pressure or increase the maximum allowable operating pressure requires a full engineering assessment
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Pipeline IntegrityPipeline Integrity
Manage corrosion activity» Internal Corrosion
» External Corrosion
Determine condition» Third Party Activities
» Inspection and Investigation
» Engineering Assessments
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Documentation Control & Documentation Control & ManagementManagement
Covers all procedures, codes, standards, records and other documents relevant to Integrity Management System
Data Control – RAE Equipment Management System (REMS) available 24 /7 at www.raeengineering.ca.
Work Order System Management of Mitigation Strategy
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Pipeline Integrity Program by Pipeline Integrity Program by RAE EngineeringRAE Engineering
This program are managed with as per 3 guiding documents:
PLIMP
POMM
PIMS
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Pipeline Integrity ManualsPipeline Integrity Manuals
Three different manuals which are involved with pipeline integrity:» Pipeline Integrity Management Program
(PLIMP)
» Pipeline Operations and Maintenance Manual (POMM)
» Pipeline Integrity Management Strategy (PIMS)
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PLIMPPLIMP
High-level document (a.k.a Tier 1 document)
Quasi-legal document as it is signed by a VP or equivalent and outlines commitments
“Statement of policy and Who does what” document
Identifies main players:
» Top Management
» Jurisdiction
» Contractors
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PLIMP cont’dPLIMP cont’d
The PLIMP is required under the Pipeline Regulation (Section 1.7).
Guidelines for manual are present in CSA Z662 Annex N.
The AER may request the document at any time.
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PLIMP: Sections to NotePLIMP: Sections to Note
Key Positions & Responsibilities» Who is responsible for major integrity activities.
Documentation (Methods & Integrity Records)» How Client manages documents.
» If activities were not documented, they never happened.
Competency & Training» How does Client ensure that people performing
integrity activities are trained properly and competent.
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PLIMP: Sections to NotePLIMP: Sections to Note
Management of Change (MOC)» What is considered a change, and how are changes
dealt with within the organization.
Accidents & Incidents» Reporting responsibilities for accidents, incidents,
near misses, and unsafe conditions.
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PLIMPPLIMP
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ABC CORP
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PLIMP IndexPLIMP Index
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ABC CORP
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POMMPOMM
Tier 2 “How-to” document required under the Regulation (Section 1.7)
No guidelines for this document
Usually signed by a person responsible for technical work
It can be a corporate-wide document, but does not have to be,
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POMM cont’dPOMM cont’d
Typically a “How and When” document supported by safe operating procedures or safe work practices.
Whereas the PLIMP focuses more on integrity policy, this document focuses on performing activities safely.
Must be forwarded to AER upon request.
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POMM: Sections to NotePOMM: Sections to NoteOperation and Maintenance Tasks List» Pipeline Operating Condition (PL Data)
» Internal Corrosion Mitigation› Chemical Inhibitor Program
› Pigging Program
› Corrosion and Process Analysis
» Corrosion Coupon
» UT/RT of Predesignated Area
» Gas Analysis
» Water Analysis
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POMM: Sections to NotePOMM: Sections to Note» External Corrosion Mitigation
› External Coating Type and Condition
› Investigation and Inspection
› Cathodic Protection
» CP Survey Result
» Immersion Current
» Galvanic
» Pipeline Inspection and Monitoring› Right of Way (ROW) Inspection
› Leak Detection and Surveillance
› Isolation Valve and Carseal Program
› Pressure Control and Overpressure
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POMM: Sections to NotePOMM: Sections to Note
Abnormal Operating Condition.» Reporting responsibilities for abnormal operation,
accidents, incidents, near misses, and unsafe conditions.
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POMMPOMM
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BEAR OIL SAND
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POMM IndexPOMM Index
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BEAR OIL SAND
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PIMSPIMS
Supporting document to the PLIMP
Can be seen as a planning document, identifying the frequency and scheduling of integrity tasks.
Usually field-specific, and updated annually.
Not a legally required document; however, RAE experience has shown that ABSA supports it for steam lines.
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Pipeline Data Base Management
Pipeline Compliance and Integrity
Task Scheduling and Assignment
Risk Analysis and Assessment
Tasks Document Control Storage and Archival.
WORK ORDER SYSTEMWORK ORDER SYSTEM
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Work Order Task ListWork Order Task List
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Work Order FormatWork Order Format
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Work Order Process FlowWork Order Process Flow
NO
POMM
PLIMP
Any applicable Regulation
Maintenance Work Order submission
Pipeline Maintenance Task List
Work Order received by responsible person
Work Order Execution
Supported documentation
necessary?
Send the supported documentation
Work Order completion
Send Work Order signed and dated
Are there any severe issues?
Any recommendations?
Notify and work with all involved personnel to correct
the issue
Inform the detailed recommendation
Close the Work Order
Upload the Work order
Work order Summary Report
YES
NO
YES
NO
YES
End
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Work Order Process FlowWork Order Process Flow
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Risk Analysis and AssessmentRisk Analysis and Assessment
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DOCUMENTATIONSDOCUMENTATIONS
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Riser DesignRiser Design
Common failure points found in risers (industry experience)
» Weld between line pipe and heavier wall riser
» Excessive stress at riser due to expansion/contraction of pipeline
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Poor Design and Installation of RisersPoor Design and Installation of RisersExample ofintended installation
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Poor Design and Installation of RisersPoor Design and Installation of Risers
The “as-built”, resulting in failure on start-up
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Example of Improved Riser Example of Improved Riser DesignDesign
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RAE
“If it is not written down, it does notexist.”
“If it is not written down, it does notexist.”
Due Diligence
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QUESTIONS?