Welcome to the Pipe Liners Podcast, Episode 194, sponsored by Rosen, the global leader in cutting-edge solutions across all areas of the integrity process change, providing operators the data they need to make the best integrity management decisions. To find out more about Rosen, go to rosen-group.com. The Pipe Liners Podcast, where professionals, bubblegeeks, and industry insiders share their knowledge and experience about technology, projects, and pipeline operations. And now your host, Russell Treet.
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To learn how you win this signature prize, stick around until the end of the episode. This week, Mark Wright, Principal Engineer for Integrity Solutions with Rosen, joins us to talk about the use of engineering critical analysis for MAOP re-conformation as a risk management approach. Mark, welcome to the Pipe Liners Podcast. Thank you, Russell.
It's good to be here. Well, just so the listeners know, Mark and I have been leaping through a whole series of technical hurdles, but hopefully this time we got it all smoothed out. So with that little bit of an intro, explaining why we're a bit on edge, I'll ask Mark, tell us about yourself. How did you get into a Terri management?
I think pipeline and integrity management was probably a little bit of a happy accident. I've worked in a few different industries, like clinical process and some real downstream stuff. But an opportunity to use a rose about 10 years ago with Rosen, and I took it, and here I am. So I asked you to talk about ECA as a way to do MOP re-conformation.
And I know that this is a big topic. There's some new rules out around all of this. Maybe a good place to start is just a really simple question. What the heck is ECA?
So ECA is just an assessment. So the common assessment that pipeline operators have to do periodically, we have to do the same thing, but this one is intended to simulate the conditions of a hydrostatic test. And so if you need to reconfirm your MAOP instead of taking all of the time out to do an actual hydrostatic test, you can simulate that through analytical means and that is an easier. And that acronym stands for Engineering Critical Assessment, correct?
Correct. As distinct from engineering assessment, which would be the more standard thing. Yeah. I mean, the term ECA is a little bit ubiquitous.
We would use it for any kind of discrete assessment. But I don't think it's particular to this process. But we've wrapped it all in a ball and we call it ECA for MAOP re-conformation. Okay.
Well, you know, one of the things about lining up with integrity management engineers and having conversations with them is you have to decode the acronyms. I work in an industry that is full of acronyms and jargon. And yes, there is a code book out there. But I think that's in for every industry.
Oh, I think that's true. I think that's one of the things I try to do in the podcast is kind of be the decoder ring for all the various engineering disciplines, right? Yeah. No, we have our own language to protect ourselves, I guess.
Well, it's easier than saying all those big, long, multi-syllable words, I suppose. Yes, exactly. Okay. So ECA, in this context, we're talking about a particular type of assessment designed to be a replacement for a hydrate test.
So what are the things you have to do in order to be able to do an assessment that would replace a hydrate test? Yeah. So the rationale behind that in the new rule is that the three various failure investigations and things like that, the regulator found that a lot of the failures, one of the underlying problems was that people hadn't really substantiated the MUP and didn't know in sufficient detail what materials were in the ground and things like that. And so they've explicitly looked for a way to make up that gap.
When we do an ECA for MUP recombination, I think the easiest way to think of it is that there's a menu, if you want to, in a market restaurant. And so there's a set menu and then there's an alicard menu and the set menu is quite comprehensive, so you have to look for anything that's a degradation mechanism. So corrosion, cracks, seam weld anomalies, dents, wrinkles, any kind of other geometric anomaly. And then there's a few little alicard items, which are things like hard spots and any kind of problems with girth welds.
And those are really on performance metrics. So if you've suffered any of those in the past, then you're going to have to look for them. But that set menu is really quite comprehensive. Interesting.
So does the regulation layout all of that in detail? Yeah. So there are a couple of must statements in the regulation. So there's not an awful lot of wriggle room if an operator chooses to go down this path.
It really is quite comprehensive. I mean, an ECA, if you're going down that path, it means you're going to do some kind of in mind inspection. And explicitly, there's a range of technology that you're going to have to run an assess and get that through the assessment. Does the rule make allowances for anything where you can't physically run a tool for other kinds of data collection to be able to do this type of assessment?
There's no room in that book. If you take a step back, then you have to go back to the intent. And the intent is ME or PV confirmation. There are multiple routes to do that, including you could do a hydro test.
I think there are six options that are laid out in the regulation and ECA is one of them. And so with the explicit nature of how an ECA should be done and achieved, then if there's a reason that you can't put an inspection gauge through it, then you're probably going to go down one of the other routes rather than trying to adapt to that. So I guess one of the things that's driving operators to use ECA is it has some advantages over a hydro test. So maybe we should talk about, you know, what those that don't know, what is involved in doing a hydro test.
So a hydro test, basically you fill the pipeline full of a test medium, usually water. You pressurize that air over water to a sufficient test pressure. You hold that pressure. And if the pipeline survives, in fact, you've passed this hydro test.
The problem with that, or I guess the decision that operators are going to take is that it takes quite a lot of time. In a recent kind of loose survey that we did on our webinar, I think the consensus was somewhere between four and six weeks would be a rough time for a hydro test. And that is a very, very long time to take a pipeline out of commission and to do that. Yeah, there's no doubt that's a long time for a pipeline to be out of service.
And I know I know enough about hydro testing again, I'm a novice, but I know enough to know that there's a lot just beyond the out of service. There's a lot of operational difficulties with the idea of emptying a pipeline, filling it with water, closing it up, pressurizing it up. There's a lot that goes into all that. Yeah, where you get the water from, where the water then goes thereafter, because it's now contaminated.
So right environmental issues that are associated with that. There is a litany of operational challenges that are associated with it. And so that's why in line inspection is an appealing option, because that minimizes that. I think there's another really big benefit that might not be understood by the industry.
And that is, if you run a hydro test, what that does is it says I can take the system and I can run it up to this pressure and it holds that pressure. And generally when you run a hydro test, you're running the pressure up above what your MAOP that you're trying to validate is. So the assumption being that if I operate that lower pressure, I'm fine. Yep.
And so we'll identify anything that's bad enough to break, but it really doesn't tell you anything other than that. Yeah. And that is one of the significant challenges. So the perception of hydro test is generally that it's a very objective assessment.
If something's going to fail, it's going to fail. And that is mostly true. But there are several things that can happen as a result of hydro tests. So you can have, let's say that you have a very deep corrosion pit, which is not very long in terms of its length.
That will likely survive a hydro test, even though it's almost through wall and a week later that could start leaking. Now, I don't think it's going to rupture. I think that's going to leak if it's going to fail at all. But it's something that a hydro test is a data point that could never be captured there.
There's also the issue of when you run the test pressure that high, you're putting a lot of stress on the material. And if there are preexisting anomalies in there, such as cracks and things that are particularly in seam welds, you can reactivate or extend growth mechanisms in those. And so when we do hydro testing, we get this phenomenon called pressure reversals, where if you perform in a spy test where you're putting the pressure up and down, you can fail at a low pressure, and then you've just held it out. Because you've reactivated something that was preexisting, but dormant, and you've just made it worse.
And so I'm not actually a big fan of hydro testing. I think it's a good test at the start of the pipeline. And if you're depending on what you're trying to address, it can be a good option. But I'm quite a big fan of things like ECA and all of the data that I'm going to collect alongside that.
And the knowledge that I'm going to gain about, not just the pipeline condition now, but really going into the future. Yeah, that's a great point, Mark, because I think I'm not an IEM guy, but I am a bit of an IT guy to do understand data. And one of the things that's true is to do an ECA, you've got to gather a whole lot of information. And that information is going to be way more detailed and robust than what I'd get from a hydro test.
So I'm actually creating a whole foundation for an integrity management program. I should be identified. You should have data that will allow me to identify what kind of threats I have, what kind of features I have, and so forth. Oh, absolutely.
And it's really the interaction between a lot of the new rules that will drive you towards that. So in the old periodic assessment, so you could have maybe you had your pipeline data in some kind of database or playbook. But with the new advent of this material properties verification, there is a very, very high standard of the knowledge that you have to have and proof that you have in order to substantiate what you're doing on the assessment and what those outcomes are. And so you end up in a situation, if you're going down the ECA room, the bar is significantly higher than it was previously.
And if you go through that process, you will probably have a much more thorough understanding of what you've got in the ground and its condition than you've ever had at any point in the life of the asset. So walk me through that a little bit in the details. What kinds of things do you have to know either with a greater level of confidence or what kind of details do you need to pick up that are above and beyond what has kind of historically been done in order to do this ECA? Yeah, I mean, simple things, material properties, diameter, wall thickness, toughness, if you're dealing with cracks, all of those are specifically called out elsewhere in the new rule.
In the ECA part, there are specific rules about how those assessments are conducted and the types of input data that you can use. And if they are not substantiated by verified material test records, then there's a hierarchy of the kind of data inputs that you can use, you can't just, well, this is what I think it is based on my history. You have to substantiate it in somewhere. And so for a lot of pipeline assets, there's been a lot of transfers and legacy and grant furthering and things that have happened over the years that mean not necessarily all of the original data to substantiate the way that we operate pipelines has followed the asset over time.
And so there are some significant gaps out there. My mind blew up a little bit there because you're talking about two kind of fundamental issues. They're first cousins to one another. One is just the fact that to do the CCA, I need more data, and that data has to be substantiated in some way, and those in the mechanisms for that are defined in the rule.
And then the other reality is you have to know what data you do and don't have. And that in itself, I think for a lot of operators could be challenging because it's one thing to believe you have the data to know whether or not you have that data and is that data substantiated. Yeah, no. And this is the real sort of complicating part of this.
And like I said earlier, it's a significantly higher bar with a much more moving pieces. And so I think the industry's got kind of reticence at the moment. That's the feeling that I'm getting over what this means and how it's going to transpire. But as long as the data inputs are good, I think the assessment part is pretty straightforward.
But it is managing all the moving pieces, and that's the complicating factor. Yeah, so what are people doing to kind of get a footing to be able to do this kind of analysis? It is a range of different things. The first thing that they're doing is trying to get their data in order.
And that is a significant challenge. So doing the actions necessary, if you're starting from scratch to collect all the data that you need to run this is going to take a while. For those operators who have already anticipated this and have been working on it for some years, they're in a pretty good position with maybe one or two gaps. There's going to be a lot of inline inspection to confirm material properties.
There's going to be a lot of in the ditch work and there's going to be a lot of work in test houses to verify all of those findings. All of that's going to be collected up into database is once that's done, if they're going down the ECA route, then it's going to be an inline inspection multiple on each line. So vendors are reacting to that. And then finally, you've got the actual assessment routines.
And so that's teams of engineers perhaps doing things that in the past they were probably not familiar with such as things like crack assessments and things like that. They're not always over. Things that are commonly done. And so expanding that and the skills and knowledge that people need to do that is going to be a critical factor as well.
Yeah, but it's interesting. You look at a large operator. A large operator generally they can build a team and they can build into that team the expertise they need to do all these things just because they have the economies of scales to justify. But for the smaller and even the mid-tier operators, that may not be the case.
So I think historically what they've attempted to do is simplify their programs and figure out what the threats are and what a program would make sense for their asset. And then that's the program. That kind of approach doesn't really work for ECA, I would think. Am I tracking here?
I think so. Given the kind of set menu nature of it, so at its very base level, you're probably, if you are a small operator, you're probably going to be dealing with technology and assessments that you likely haven't seen in the past. And so there's a lot of knowledge acquisition to go through to get to that point. But the help is out there.
There are lots of people who are capable and set up to help people in that regard. The market just react. Right. Absolutely.
Well, that's kind of where I was going because I think what you have to think about if you're going to build a program to do this is you have to think about what are the resources I need and how am I going to get them. And that might look at a strategic plan around how you're going to do what kind of subcontractors and consultants you need to support implementing and maintaining a program like this. Yeah. I mean, the option is out there for a turnkey.
And it's a relatively lengthy process, but you could turnkey the whole lot. And there are people out there to support that. But if you're looking to optimize that, then working out who can do what and who can do that best is probably a very, very sensible plan. And there is always a good reason to try and bring knowledge and skills into the operator.
And so this is kind of an opportunity. But it's a effectively a short technical challenge. This is not an ongoing assessment. All of the pipelines in the scope have to be done within the next 15 years.
And so that's the need. Well, I think one of the morals of this story is if you're putting in new pipe, you need to get all this data and make sure you have it in the way that it meets the requirements. That's kind of the first thing because that greatly simplifies your whole program. Oh, absolutely.
I've been in some conversations with the kind of companies that construct pipelines. And that situation is improving. I think people recognize that they need really good, strong, accurate, reliable digital records. So some of the people who would design construct pipelines associate in that task with developing a database which holds all of that data and the digital records that support all of the engineering that went into it.
And so the old days of there's a design book somewhere in a cupboard in the archive somewhere disappearing. And there will be a hard drive which is backed up in Triplek available to people who need to do those kind of assessments, all in systems of record. Yeah, you've reached into converted. I own a small piece of pipeline at one time.
And I remember a conversation about where the x-rays and what it took to find the x-rays. But that's the nature of old paper film kind of records. They ended up, they had to end up in a file cabinet someplace. Nowadays, you can digitize all that and store it in an orthogon away.
But I think we're probably still learning about all that. And I know we're going to do another podcast here in a few weeks on that subject specifically. So I don't want to take too much of the wind out of those sales. Yeah.
So I do want to ask another kind of train of questions if I'm right. And one of the things that occurs to me is there's a lot of talk about doing risk management approaches around my IM programs. And one of the things that is kind of a predicate to being able to do effective risk management is to have a well-ordered, well-understood data structure. I would think that on the back end of an ECA project or program, you're going to be in a much better position to apply risk management to your overall integrity program than you would be ahead of having all that data collected and organized and verified.
Can you talk to that at all? Yes. So you're into a subjective mind. So risk management is integrity management and integrity management is risk management.
Other two should be indivisible. And you're right that a thorough knowledge of the asset condition is required in order to make sense of any kind of risk management or risk mitigation strategy. I think a lot of assets, particularly with the regulatory structure that we have in the US, we do the assessments, we do everything we try and meet regulation. And that's not quite the same as complete risk management.
We use risk as a kind of baseline to prioritize things, but not necessarily manage the risk as well. I think that's improving a little bit. But what I would anticipate on the back of ECA is that there's going to be at least some operators out there who because they're going to deal with technology and tools that they're perhaps not as familiar with, that they're going to discover that they probably had some threats in their assets that they were maybe not aware of before. And building awareness is probably going to result in some kind of short term shock.
It's going to be good for the long term health of the assets and the industry. Yeah, you just said a mouthful there, Mark. You just said a whole lot in a little bit. I think you're right.
I think you're absolutely right. And I think that this whole conversation is part of what it's going to take us to get to order a magnitude improvement in our safety performance as an industry. Yeah, I mean, we should bear in mind that we as an industry, a few start sometime in the 1970s. Then I think we're about fivefold better than we were at that point in terms of how many pipelines fail and how much spillage we have.
But there is increasing and public and governmental scrutiny over the operations. And rightly so, there is still significant room for improvement. The industry has improved so much. But it's fair to say that in recent years it's plateaued a bit.
I think the new rules are in response to that. I think establishing a baseline through MUPE confirmation and ECA is a good idea. But there are other steps that we should and could take. Well, part of what we've got to do in order to be able to take those steps is to get we've got to be able to apply technology more effectively.
I think if you look at the last 30 years in pipelining, a lot of the progress we have made has been around what we do about the metal, the cathodic protection and the integrity management and the tools and how those tools have improved and our ability to do more complicated algorithms, gather more data, get the information that's more precise, more comprehensive. What we haven't done much of yet, I think it's probably the next wave is we haven't done a whole lot of management science around all that data. That's kind of what's coming back there. Mike talks about data science and analytics and all that kind of stuff.
And again, I think there's a lot of opportunity there. But for that to really make a difference industry-wide, there needs to be some standards around the data. And there needs to be some information sharing and some other things to be able to get there. But we're moving that direction.
I think ECA kind of, one of the promises is that it sets a platform that allows you to get there. Yes, it does. And I think there are probably three elements to it. So there is the purely technology and technical element, which is over there.
And I don't think that's where our problems lie. There is the data element, which I think right now is the significant issue and the thing that we need to solve. And I think you're right in identifying that ECA as an opportunity to get alignment on there. And the third element of that is organizational.
And organizational, both in terms of our individual organizations and our industry as a whole, we do not share enough data and knowledge and lessons learned and all of the things that we know from other industries that represent good practice. We're a very insular industry, both as an industry and individual companies. Well, even inside of the company, sometimes you get into that because you tend to have these, I don't think we do it intentionally. I don't think there's not because we're not good teams.
It's just that we have these various highly technical domains that are dissimilar and it makes that collaboration challenging. Oh, absolutely. I mean, as a risk practitioner, I'm constantly challenged to get people over here that are working on maybe something like corrosion problems together with people over here who are dealing with geotechnical problems. And they don't speak the same language.
And trying to get them to work together and especially to prioritize and work out what's really important is a significant challenge because each one's fighting their own battles. Yeah, it's absolutely true. And what you're really teeing up is that as we begin to get a handle on the data, the next thing we're going to need to get a handle on is the what I would call the quality systems or the safety management systems around all of those. No, a couple of years ago, there was an API document that was released at 1173 and that really built on some international standards like ISO 55000.
And what that really talks about is it's not quite quality management, it's different quality management is specifically looks for a reliability rate. It says we need to be right 99.9% times out of whatever, because it's a factory standard. Safety management is slightly different. Safety management means that we have to be cognizant that failure is not an acceptable outcome.
And the search for zero failures should embrace more the safety management culture than the quality management culture, although they have some symbiotic elements. Well, they're first cousins. I mean, you make you make a very good point. I've done a number of podcasts on this subject because it's kind of a passion of mine.
It's really about understanding the outcome you're trying to achieve, right? And in a quality manufacturing standard, the outcome is I want a product without defects. And then the safety standards, I want to operation without failure. Yeah.
So that is a very subtle but very important differentiator. And a lot of the processes and the science and so forth behind all that, and even the stuff going back to Deming's original work, it all comes from that. Yeah. And I mean, what you're looking for is an organization that's working together for a single goal, and that goal is zero failures.
And if you bring a conversation back to something like ECA and all of the moving parts, you see all the different people and roles and resources that are involved in that. So that goes through the organization from the most highly technical person who is leading that operation, right down to the person in the archive room who is responsible for having a digital record of the input data that you're looking for. And it's right through and ensuring that that is correctly resourced. It's the right people with the right training and right competence.
Doing all of those things is critical. And that's what city management is, is making sure that the right people are in the right place with the right resources to achieve the goal. And it's a very organizational thing, not a technical thing. But I think first cousins is probably the best description.
Yeah. Well, I think that's a great place to leave this conversation, Mark. I really appreciate you taking the time to come in on. And I appreciate you working with me to struggle through the technical difficulties so we can actually have the conversation without things breaking.
Oh, it's yeah, I blame Steve Jobs completely. And I won't change that. All right. I hope you enjoyed this week's episode of the Pipeliners Podcast, our conversation with Mark.
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