Proceedings of the 2012 9th International Pipeline Conference IPC2012 September 24-28, 2012, Calgary, Alberta, Canada

IPC2012-90310

A NEW FOCUS WITH LEAK DETECTION FOR US PIPELINES

James Merritt US DOT, PHMSA Denver, Colorado, USA Patricia Jasion US DOT, PHMSA Washington, DC, USA Max Kieba US DOT, PHMSA Washington, DC, USA

ABSTRACT The United States (U.S.) Department of Transportations Pipeline and Hazardous Materials Safety Administration (PHMSA) is exploring methods for increasing usage and improving leak detection systems in both hazardous liquid and natural gas pipelines. This is a critical focus for PHMSA in the wake of several recent pipeline incidents where more effective and redundant leak detection systems may have lessened the experienced consequences. The U.S. Congress and the National Transportation Safety Board (NTSB) have recommended deploying more leak detection systems into the U.S. pipeline infrastructure to address increasing public safety and environment impact concerns. PHMSA has taken a number of actions to work toward this goal including increased operator guidance, fostering technology research, information gathering, and reports on state of the art technologies. This paper discusses PHMSAs actions regarding leak detection systems and the progress in advancing the dialogue amongst hazardous liquids and natural gas pipeline operators, other regulators, and the public, so that considerations in deploying systems on vintage and new construction pipelines can be identified.

other hazardous materials. However, transportation by pipeline does entail some risks. Pipelines can leak and pose a perpetual threat to public safety and the environment. Due to the vast mileage of pipelines throughout the nation, it is important that dependable leak detection systems are used to promptly identify when a leak has occurred so that appropriate response actions are initiated quickly. The swiftness of these actions helps to reduce the volume of the spill, and mitigate safety, environmental, and economic consequences of the release.

DRIVERS FOR SYSTEMS

EFFECTIVE

LEAK

DETECTION

Pipeline leaks can pose a hazard to people, the environment, and other societal functions. Significant leaks can cause injuries, deaths and catastrophic environmental effects. While the overall trend of pipeline spills and releases with major public and environmental impacts have been in a downward trend, see Figures 1 and 2 for historical data, there have still been several incidents that have had catastrophic impacts to the public, the environment and surrounding structures.

INTRODUCTION The safe and reliable transportation of oil and gas through pipelines is critical for our economy, mobility and quality of life. The pipeline infrastructure of the United States consists of over 2.5 million miles of pipe which transports trillions of cubic feet of natural gas and 13 billion barrels of liquid petroleum products each year. When compared to other modes of transportation (truck, rail, sea), pipelines are an extremely safe means of moving large quantities of oil, natural gas, fuels, and

Figure 1: Pipeline Incidents with Death or Major Injury

1 This material is declared a work of the U.S. Government and is not subject to copyright protection in the United States. Approved for public release. Distribution is unlimited.

PHMSA in their San Bruno Pipeline Accident Report, PAR-1101 [5]: Require that all operators of natural gas transmission and distribution pipelines equip their supervisory control and data acquisition systems with tools to assist in recognizing and pinpointing the location of leaks, including line breaks; such tools could include a realtime leak detection system and appropriately spaced flow and pressure transmitters along covered transmission lines.
Figure 2: Hazardous Liquid Pipeline Spills with Environmental Impacts

In order to protect the nation from pipeline leaks and releases, additional measures should be folded into both pipeline design and operating procedures. Additional measures may include enhancements to public awareness programs, additional or more thorough pipeline right-of-way (ROW) inspections, more operational data and advances to leak detection systems. Unfortunately, 2011 yielded several incidents that had significant impacts on the U.S. public and the surrounding environment. In an attempt to better protect the Nation from pipeline incidents, significant emphasis has been put on leak detection system advancement and deployment. The need to focus on leak detection has not just stemmed from PHMSA; the U.S. Congress, other federal agencies, and public advocacy groups have all voiced their concern on this topic. The U.S. Congress is heavily interested in the expanded use of leak detections systems throughout the nations infrastructure. In Section 12 of the Pipeline Safety Improvement Act of 2002 [1], leak detection technology was included as major program element for the research and development program. In the Pipeline Inspection, Protection, Enforcement, and Safety Act of 2006 [2], Section 21 required that the Department of Transportation submit a report that discussed the inadequacies of current leak detection systems and their ability to detect rupture and small leaks that are ongoing and intermittent PHMSA submitted a report Congress in December 2007 [3] that closed out this mandate, this report will be discussed in more detail below. The newest pipeline act, the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 [4], has called for PHMSA to submit another leak detection report to Congress. This report will further address many of the same issues identified in the 2007 report for hazardous liquid pipelines, and it will also provide an an analysis of the practicability of establishing technically, operationally, and economically feasible standards for the capability of such systems to detect leaks, and the safety benefits and adverse consequences of requiring operators to use leak detection systems. Efforts PHMSA is taking to supply Congress with an updated leak detection report are described later in this paper. The U.S. National Transportation Safety Board (NTSB) most recently issued the following safety recommendation to

Implementation of this recommendation would mean that all natural gas pipelines, new and existing, would be required to have some level of leak detection capabilities through their Supervisory Control and Data Acquisition (SCADA) systems. Since not all natural gas pipelines are equipped with SCADA systems, realization of this recommendation may be a lot more involved than just deploying leak detection systems. Furthermore, distribution lines are extremely different in operation and design than transmission lines, and current commercially available leak detection systems have not been developed with distribution systems in mind. Further studies must be conducted before implementation of the recommendation. The compressible nature of natural gas further complicates leak detection capabilities, a characteristic that is not as significant in many hazardous liquid pipelines. Other government agencies are now beginning to focus on natural gas and oil leaks as well. The Environmental Protection Agency (EPA) has labeled methane gas as a greenhouse gas under the Clean Air Act. In response to the Clean Air Act, the EPA rolled out the Natural Gas STAR Program [6] which serves as a partnership with oil and natural gas companies. The program seeks to encourage the adoption of cost-effective technologies and practices that improve operational efficiency and reduce emissions of methane, a potent greenhouse gas and clean energy source. The end goal of this program would be to detect and locate, report, and ultimately repair all methane leaks. Public advocacy groups, such as The Pipeline Safety Trust, have also noted the need for stronger leak detection requirements. The Pipeline Safety Trust published a report entitled, Leak Detection for Transmission Pipeline (An Experienced Perspective), on August 30, 2007 [7]. The report advocated for government regulations to be changed to require that leak detection systems are deployed to all critical areas. The wide interest of leak detection for pipelines has further encouraged PHMSA to advance the application of leak detection technologies. PHMSA is committed to making the Nations pipeline infrastructure safer; leak detection is just one of the many ways to protect both the public and environment. PHMSAs related efforts to advance leak detection are described in more depth below.

CATEGORIZING LEAK DETECTION SYSTEMS There are several different types of leak detection systems utilized throughout the Nations pipeline infrastructure. Leak detection technologies can be divided into three general categories: visual inspection, instrumented monitoring of internal pipeline hydraulic conditions, and external instrumentation for detecting leaked hydrocarbons. Each category has its benefits, limitations and tradeoffs. Visual inspection is the simplest method. It involves monitoring the pipeline ROW to determine whether any leaks or spills are evident. The Federal regulations already mandate that visual inspections are performed at regular intervals throughout the year, with specific requirements dependent on the type of line. While these types of inspections are extremely reliable and the exact leak location is generally known upon inspection, there are also several limitations. Limitations include the inability to detect leaks in a timely manner, human error, and the difficulty of detecting very small leaks. Instrumented monitoring of internal pipeline hydraulic conditions is a form of leak detection that monitors the operational parameters and pressure conditions of the system to detect abnormal conditions. A change from normal operating parameters may signal a potential leak or rupture of the pipeline. These systems generally rely on SCADA systems to collect critical operating data for presentation to controllers, who then couple the data with other information to detect potential releases. This approach can range from extremely simplistic to sophisticated systems, driven by the complexity of the pipeline and the operators leak detection strategy. Each method has its own benefits and constraints. Generally speaking, the simplistic methods (volume balance, rate of pressure/flow change, etc.) are easily implemented with low costs, but unable to detect smaller leaks and will not be able to pinpoint the exact location of the leak. More sophisticated methods (mass balance, real time transient model (RTTM) and digital signal processing, etc.) are more costly to implement and maintain, but may be able to detect smaller leaks more quickly. The determination to use one method over another will depend heavily on the pipeline system and the needed capabilities. Tradeoffs between cost, reliability, sensitivity, detection speed, flexibility and ease of use play a major role in determining what approach is chosen for each system. External monitoring uses instrumentation outside of the pipeline to detect spilled/leaked hydrocarbons. Various methods may include impedance methods, sniffing methods, or other acoustic methods. External monitoring solutions are generally only used in highly sensitive or high risk areas due to the high installation and lifetime costs of these systems. The surrounding environment (water table height, soil conditions, etc.) also play a major role in how effective an external system can be. While external monitoring is often more sensitive and reliable than internal monitoring methods, retrofitting a pipeline

to include external monitoring can be incredibly expensive and in some cases not technically feasible. A more detailed discussion on all aforementioned leak detection methods/systems can be found in the 2007 PHMSA Leak Detection Technology Study. KEY CONSIDERATIONS FOR SYSTEMS LEAK DETECTION

The requirements for leak detection systems on each pipeline will vary widely amongst different pipelines. The size, length, pipeline design (i.e. entry and exit points, etc.), type of product being transported, and operating parameters will all be key determinants in what type leak detection system is most practical. There are several key considerations that should be taken into account before choosing or implementing a leak detection system. These considerations may include, but are not limited to: Rate of false alarms Instrument location, abundance and accuracy Personnel training and qualification System size and complexity Desired detection threshold parameters Response time Leak location estimation Release volume estimation Detection of pre-existing leaks Detection of leaks while the pipeline is shut-in Detection of leaks in pipelines under slack conditions Sensitivity to flow conditions Multiphase flow Robustness Availability Retrofit feasibility Testing Cost Maintenance

Each consideration should be fully understood and addressed in the leak detection system requirement. Since there is no one-size-fits-all for leak detection, different operators will look at and define these considerations differently. It is important to know and understand the pipeline constraints that the leak detection system will be deployed on. All leak detection systems have benefits and limitations. Incorporating levels of redundancy within leak detection systems can help ensure that those limitations will be accounted for and adequately addressed. Understanding the pipeline and the target leak detection threshold will help operators to better protect the public and the environment from the impact of pipeline leaks.

RELATED PHMSA ACTIONS FOR IMPROVING LEAK DETECTION SYSTEMS PHMSAs mission is to ensure the safe, reliable, and environmentally sound operation of the Nation's pipeline transportation system. Leak detection capabilities are an important part of the overall drive to maintain and improve pipeline safety for the public and the environment. As a result, PHMSA has a long history for promoting leak detection technology. 49 CFR (Code of Federal Regulations) Part 192 and 195 [8] are PHMSAs regulations for natural gas and hazardous liquids pipelines. Included in these parts are regulations that require operators to conduct leak surveys; Sections 192.706, 192.723, and 195.412. All leak surveys are required to be performed at regular time intervals dependent on the type and classification of the line. The purpose of these sections is to require operators to utilize visual inspection tools and techniques to identify any leaks that may cause a safety hazard to the public or surrounding environment. In 2000, PHMSA issued 49 CFR 195.452, Pipeline integrity management in high consequence areas. This rule improved hazardous liquid pipeline safety by accelerating the integrity assessments of pipelines that could affect High Consequence Areas (HCAs) and providing increased public assurance in pipeline safety. Leak detection is included as one of the measures operators may take to prevent and mitigate the consequences of a pipeline failure to protect HCAs along their pipeline. The rule also requires that operators have a capability to detect leaks in these areas and must perform any modifications as necessary to assure and improve this capability. The natural gas transmission integrity management rule issued in 2002, 49 CFR 192 Subpart O, Gas Transmission Pipeline Integrity Management, similarly requires operators to take additional measures beyond those already required to prevent and mitigate the consequences of a pipeline failure in an HCA. Additional measures may include, among other things, installing computerized monitoring and leak detection systems. Under the regulation, natural gas operators are required to analyze the need and use of leak detection systems within the pipeline. There are separate integrity management requirements for natural gas distribution pipelines. These requirements are in 49 CFR 192 subpart P, and were issued in 2009. These rules prescribe a leak management program. This requires operators to survey their lines for leaks and have a process by which they will manage and repair leaks that are identified. Apart from rulemakings, PHMSA has carried out a number of other actions to strengthen the Nations pipeline infrastructure using leak detection. In 2007, PHMSA issued a study on Leak Detection Technology to address the PIPES Act

mandate. The study focused on leak detection technology and how it relates to hazardous liquid pipelines. The study conceded that there is no one right solution for leak detection systems and that every pipeline system must be looked at individually. PHMSA felt that since hazardous liquid pipeline spills were on the decline, there was no need to implement stricter regulations for leak detection at that time. An Advisory Bulletin, ADB-10-01, was also issued on January 26, 2010 [9] in response to an NTSB safety study on pipeline Supervisory Control and Data Acquisition (SCADA) systems (NTSB/SS-05/02) [10]. The study found that a number of leaks between 1992 and 2004 on hazardous liquid pipelines went undetected by operators. The advisory bulletins goal was to advise and remind hazardous liquid pipeline operators of the importance of prompt and effective leak detection capability in protecting public safety and the environment. The bulletin reminded operators of the importance of leak detection and their responsibilities to determine whether a computer-based leak detection system was appropriate for their pipeline. On April 18, 2011, PHMSA held the Pipeline Safety Forum [11] to bring together pipeline safety experts, researchers, operators, regulators, and members of the public. The goal of the forum was to discuss the acceleration of rehabilitation, repair and replacement of the pipeline infrastructure. The topic of leak detection was raised several times. Leak detection was cited by industry as a technical challenge. Industry felt that leak detection instrumentation is not sensitive enough to detect all releases, and that more research and development advancements were needed in this area. Pipeline operators also spoke of issuing new regulations for leak detection capability evaluations on all regulated non-gathering lines as a means to identify opportunities for the deployment of leak detection systems. Through its Research and Development (R&D) program, PHMSA has also been fostering leak detection technology development and advancements. The program, which was formally started in 2002, has included the advancement of leak detection technology as a major program initiative since its inception. Thirteen (13) leak detection projects totaling an investment of $6.4 Million have been awarded since 2002. Five (5) of these projects are still ongoing. The project topics range from visual inspection tools such as using Unmanned Air Vehicles (UAVs) for pipeline surveillance to external monitoring tools such as fiber optic leak detection systems. The program has had notable impacts since 2002. PHMSAsponsored technology advancements have been commercialized and are being used in the industry. Examples of commercialized improvements are helicopter and fixed wing aircraft-based natural gas leak detection and internal and arealbased improvements for hazardous liquid pipelines. Additional information on past and active R&D projects concerning leak detection can be found at the program website. [12]

In order to address NTSB recommendations and a congressional mandate from the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011, PHMSA is currently conducting a leak detection technology study. The study will expand upon the aforementioned 2007 effort and will tackle both hazardous liquid and natural gas (transmission and distribution) pipelines. Specific considerations for technology maturity and constraints are currently being examined. The study is planned to be issued in late December 2012 and will discuss the technical, operational, and economic feasibility of deploying leak detection systems across the entirety of the nations pipeline infrastructure. To assist with the leak detection study, PHMSA held a public workshop March 2012 [13] that focused on how to further expand usage of leak detection systems throughout the hazardous liquid and natural gas pipeline industry. The event consisted of several panels with a focus on considerations and constraints for leak detection systems for all types of pipeline, and the capabilities of current systems that are deployed. All input will be used to help better craft the leak detection technology study and future PHMSA rulemakings. PHMSA will look at many of the issues laid out in the public workshop and study to help examine whether current leak detection regulations, for both natural gas and hazardous liquids, provide sufficient protection for the public and environment. The leak detection technology study will conclude with PHMSAs recommendations on how to improve the current regulations so that the Nation is better protected from pipeline leaks. After a review period of up to one year, certain recommendations may be enacted into the regulations if deemed appropriate through the rulemaking process. Any new rules will serve to further protect the public and environment from future pipeline leaks and spills.

pipelines operating parameters and the constraints under which the leak detection would be performing. There is no one-sizefits-all solution for leak detection systems, and while best practices from pipeline to pipeline may be the same, leak detection solutions will vary. PHMSA has been encouraging operators to use leak detection systems throughout the Nations pipeline infrastructure. This encouragement has come in the forms of regulations, advisory bulletins, reports, and research and development projects. PHMSA is committed to further fostering the use and advancement of leak detection systems to better protect the public and environment from pipeline leaks. U.S. GOVERNMENT COPYRIGHT DISCLAIMER This material is declared a work of the U.S. Government and is not subject to copyright protection in the United States. Approved for public release; distribution is unlimited. REFERENCES [1] U.S. Congress, 2002. Public Law 107355, 107th Congress. Pipeline Safety Improvement Act of 2002, http://www.gpo.gov/fdsys/pkg/PLAW-107publ355/pdf/PLAW107publ355.pdf [2] U.S. Congress, 2006. Public Law 109468, 109th Congress. Pipeline Inspection, Protection, Enforcement, and Safety Act of 2006. http://www.gpo.gov/fdsys/pkg/PLAW109publ468/pdf/PLAW-109publ468.pdf [3] U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration (US DOT PHMSA), 2007. Leak Detection Technology Study, For PIPES Act H.R.5782. http://www.phmsa.dot.gov/staticfiles/PHMSA/DownloadableFi les/S10-080623-002-Signed.pdf [4] U.S. Congress, 2012. Public Law 11290, 112th Congress. Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011. http://www.gpo.gov/fdsys/pkg/PLAW112publ90/pdf/PLAW-112publ90.pdf [5] U.S. National Transportation Safety Board (NTSB), 2011. NTSB/PAR-11/01: Pacific Gas and Electric Company Natural Gas Transmission Pipeline Rupture and Fire.. http://www.ntsb.gov/doclib/reports/2011/PAR1101.pdf [6] U.S. Environmental Protection Agency. Natural Gas STAR Program. 2011. http://www.epa.gov/gasstar/ [7] Kuprewicz, Richard B, 2007 Observations on Practical Leak Detection for Transmission Pipelines, An Experienced Perspective http://pstrust.org/library/docs/leak_detection_paper.pdf

SUMMARY The nations public, environment and economy rely heavily on a safe and robust pipeline transportation system. There is no other mode of transportation that would be able to safely supply as much of the Nations energy resources in a cost effective manner. A major component of keeping the Nations pipeline infrastructure safe and functioning is the ability to detect and repair leaks quickly. Many advocacy groups, federal agencies and law making bodies have recognized the importance of leak detection to the pipeline infrastructure and are committed to ensuring the safe and economical operation of those systems. Leak detection systems vary in types and methods. Capability and limitations differ amongst these systems and can be deployed in complimenting manners to get a broader range of protection and value. Before implementing a leak detection system, operators should have a thorough understanding of the

[8] U.S. 49 Code of Federal Regulations (CFR) Part 192 and Part 195 via Electric Code of Federal Regulations (e-CFR): http://ecfr.gpoaccess.gov/cgi/t/text/textidx?sid=6415a10221a4a3d3ed15248595469f9e&c=ecfr&tpl=/e cfrbrowse/Title49/49tab_02.tpl [9] U.S. DOT PHMSA. Advisory Bulletin ADB-10-01. Leak Detection on Hazardous Liquid Pipelines. January 26, 2010. http://www.gpo.gov/fdsys/pkg/FR-2010-01-26/pdf/20101497.pdf [10] U.S. NTSB, 2005. NTSB/SS-05/02: Supervisory Control and Data Acquisition (SCADA) in Liquid Pipelines. http://www.ntsb.gov/doclib/safetystudies/SS0502.pdf [11] U.S. DOT PHMSA, 2011. Proceedings From the National Pipeline Safety Forum, April 18, 2011. http://phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Na tional%20Pipeline%20Safety%20Forum%20Record%2004-182011.pdf [12] U.S. DOT PHMSA R&D Program https://primis.phmsa.dot.gov/rd/index.htm Website,

[13] U.S. DOT PHMSA, 2012. Improving Pipeline Leak Detection System Effectiveness and Understanding the Application of Automatic/Remote Control Valves https://primis.phmsa.dot.gov/meetings/MtgHome.mtg?mtg=75