Situation Analysis
REGULATORY REQUIREMENTS

Standardizing Regulations
A recent trend worldwide has been the movement towards standardization and increased vigilance in the monitoring of pipeline and storage vessel operations. Regulatory boards and local government departments typically undertake this monitoring, with the end goal of reducing leaks and failures that pose risks to the safety of employees and the general public, and to the environment. The impact to pipeline and production facility operators is that corrosion monitoring is becoming mandatory in many jurisdictions.

Regulatory Requirements (Canada)
Canadian jurisdictions are moving towards mandatory monitoring, one example being Alberta, the top energy-producing province in the country. After studying performance records and trends of oilfield production and transmission facilities in the 1990’s, the Alberta Energy and Utilities Board revised its regulations in 2001. Revisions included standardizing pipeline inspection requirements and a new system of measuring and penalizing noncompliance.

A critical aspect to pipeline operations that came out of the study was the recognition of the importance of an internal corrosion monitoring program. The revised regulations, entitled Guide 66, now categorize this type of monitoring as mandatory for operations.

Guide 66 cites specific regulatory requirements detailed in the Alberta Pipeline Act and Regulation and the CSA Z662 Standard, Oil and Gas Pipeline Systems. The guide also includes the EUB Pipeline Inspectors' Guide to Corrosion Failure Procedures, which details the requirements specific to follow-up of corrosion incidents. The EUB developed this section in consultation with industry pipeline corrosion specialists.

Guide 66 lists Satisfactory and Minor (U) / Major (M) / Serious (S) unsatisfactory inspection criteria, as well as consequences for noncompliance as per the EUB's enforcement process. A summary of the guide’s application to internal corrosion control is as follows:

Operations Review
51. Internal Corrosion Control - Appropriate methods to detect and mitigate internal corrosion are employed to protect pipelines transporting any liquid or gas or combination thereof that may cause the interior to corrode (CSA Standard Z662, Clause 9; Pipeline Regulation, Section 53(a,b,c).

Each licensee must monitor to determine the effectiveness of mitigation procedures (CSA Standard Z662, Clauses 9.4.3 and 9.5). The results of the inspection or tests must be recorded and retained for a minimum of six years (Pipeline Regulation, Section 53).

Type of Installation
Requirement Infraction Rating
Operational Deficiencies  
Pipeline No records in corrosive environment Major
  No records in non-corrosive environment
Minor
  No monitoring and mitigation in corrosive environment Major
Storage Tank Records of inspection and corrosion monitoring programs not available Minor
     
Incident Causes  
Pipeline No documented monitoring or mitigation program in place and/or company is not following program Major
  No monitoring or mitigation program in place for pipelines with major potential public and environmental consequences, as referenced in Appendix 3, Section 4. Serious
  Failure to follow the investigative procedures detailed in Corrosion Guide, Sections 2, 3, and 4 (Appendix 3). Major
  Failure to follow the investigation procedures detailed in Corrosion Guide, Sections 1.1, 1.2, and 3 (Appendix 3). Minor

Pipe Failure—includes pipe body failures, stress corrosion cracking, hydrogen-induced cracking, brittle cracks, running cracks, failure of plastic pipes, failure due to fatigue and lamination separations.

1.1.8 Corrosion Mitigation Plan
If a failure indicates a corrosive condition, the operator must have a documented plan to prevent further corrosion failures. This plan must consider other lines within the same pipeline system and include details of the mitigative measures to be adopted. The Pipeline Regulation, Sections 52 and 53, requires the operator to maintain records of any corrosion maintenance activities for at least six years. Typical mitigative and monitoring measures for internal corrosion could include combinations of the following:

  • corrosion coupons
  • electronic monitoring devices
  • inhibition (continuous and/or batch)
  • lab analysis to determine failure cause
  • pipeline cleaning by pigging or chemicals
  • fluids analysis
  • flow modelling

If operator expertise is insufficient, the operator should enlist expert third-party assistance. A pressure test alone will not be considered as adequate proof of long-term integrity. Note that sour natural gas lines require pressure testing to 1.4 x MOP. Random cutouts, ultrasonic inspection, and shadow shots are not adequate proof of integrity.

The EUB has adopted an enforcement process that includes guidelines for EUB enforcement actions when dealing with regulatory noncompliance. Companies failing to meet requirements or follow EUB direction will be subject to escalating enforcement consequences.

To access Guide 66 on-line, click: http://www.eub.gov.ab.ca/bbs/products/guides/g66.pdf

Pipeline Performance
EUB Report 98-G, Pipeline Performance in Alberta, 1980-1997 examines operating trends over the past 18 years. Several conclusions reached were:

Failure Cause

  • Leaks comprise about 87% of all failures.
  • 63% of leaks are caused by corrosion. Of these, half are caused by internal corrosion.

Failure Frequency

  • Most failures occur on water and multiphase oil effluent (a mix of oil, water and gas) pipelines. These small-diameter, lower-volume pipelines are common in Alberta’s oil and gas industry because of their use in gathering systems.
  • The overall frequency for sour gas pipeline failures remains very low and has declined over the last decade. This may be due to the extra care that operators are taking in corrosion inspection, monitoring, and mitigation for sour lines.
  • A decline in external corrosion failures also indicates advancements in and use of superior pipeline protective coatings in Alberta.
  • While pipeline age can be a factor, proper corrosion prevention and failure mitigation programs allow older pipelines to be operated safely and within requirements.
    (Source: EUB Website)