DOT PHMSA 49 CFR 195 Integrity Program Implementation
October 21, 2018
Tank Spill – Fit To Service
June 17, 2019

Problem:
In order to comply with DOT PHMSA 49 CFR 192 regulations, a gas transmission pipeline operator needed the following O&M compliance survey services completed on 35 miles of pipeline:

  • Right-of-way inspection; DOT 192.705, DOT 192.707
  • Leak detection survey; DOT 192.706
  • Cathodic protection survey; DOT 192.465
  • Class location verification; DOT 192.5

In an effort to remain compliant and produce documentation pursuant to the regulations specified above, the operator hired Integrity EPC to conduct Operations & Maintenance (O&M) field compliance specific tasks as noted above.
Approach and Solution:
Integrity EPC’s staff maintains multiple certifications across a variety of integrity management techniques and industry standards. Integrity EPC was able to assign NACE-certified technicians in Corrosion, PCIM, CP, and Coating, as well as an API 1169 certified technician to perform the inspection and analysis. The technicians completed the inspections in the field in accordance with the operator’s O&M manual.
Execution:

Problem:

In order to comply with DOT PHMSA 49 CFR 192 regulations, a gas transmission pipeline operator needed the following O&M compliance survey services completed on 35 miles of pipeline:

  • Right-of-way inspection; DOT 192.705, DOT 192.707
  • Leak detection survey; DOT 192.706
  • Cathodic protection survey; DOT 192.465
  • Class location verification; DOT 192.5

In an effort to remain compliant and produce documentation pursuant to the regulations specified above, the operator hired Integrity EPC to conduct Operations & Maintenance (O&M) field compliance specific tasks as noted above.

Approach and Solution: 

Integrity EPC’s staff maintains multiple certifications across a variety of integrity management techniques and industry standards. Integrity EPC was able to assign NACE-certified technicians in Corrosion, PCIM, CP, and Coating, as well as an API 1169 certified technician to perform the inspection and analysis. The technicians completed the inspections in the field in accordance with the operator’s O&M manual.

Execution: 

Result:
Integrity EPC produced several reports detailing the findings of each inspection and recommendations for next steps. In some instances, the findings indicated a need for additional surveys including an AC mitigation inspection and atmospheric corrosion inspection – which Integrity EPC conducted for the operator. Further, Integrity EPC noted and reported non-DOT observations.
The operator was extremely happy with thorough inspections and completeness above and beyond the intended scope of work. They were very happy with the level of detail and the reporting that was delivered. The operator is considering the recommendations of Integrity EPC as part of their ongoing Integrity Management Program (IMP).

Result: 

Integrity EPC produced several reports detailing the findings of each inspection and recommendations for next steps. In some instances, the findings indicated a need for additional surveys including an AC mitigation inspection and atmospheric corrosion inspection – which Integrity EPC conducted for the operator. Further, Integrity EPC noted and reported non-DOT observations.

The operator was extremely happy with thorough inspections and completeness above and beyond the intended scope of work. They were very happy with the level of detail and the reporting that was delivered. The operator is considering the recommendations of Integrity EPC as part of their ongoing Integrity Management Program (IMP).
ROW Inspection
Integrity EPC performed field inspection of 35 miles of pipeline, driving where available and walking the line where necessary. Markers were observed and noted for road and RR crossings as well as line of sight. Any 3rd party construction activity was noted as well.

Leak Detection
Utilizing a FLIR camera, Integrity EPC resources drove and walked the ROW with the camera pointed to the ditch line from the center of the pipeline. All results were documented.

Cathodic Protection Survey
Integrity EPC performed CP tests at 37 test stations as well as 2 valve settings where the rectifiers were located. Integrity EPC interrupted the system at 7 seconds on, 3 seconds off, and took pipe-to-soil readings with a FLUKE 287 Multi Meter. Additionally, readings were taken at 4 test points were test stations were not available. All readings were documented, along with wiring schematic for each test station, a distance/location report, waypoints, and a plot graph.

Class Location Verfication
Updated imagery was not available for the pipeline so IEPC resources utilized a range finder from the centerline of the pipeline to verify distances to any new structures. Results for the range finder survey were incorporated into the class location unit analysis as noted in 49 CFR 192.5 – Class locations.

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