Pipeline Safety Tip of the Month – July 1, 2024

I have conducted many construction inspections across gas distribution, gas transmission and hazardous liquids.  The code requirements for gas pipeline construction records include:

 

§ 192.67 Records: Material properties.

(a) For steel transmission pipelines installed after [July 1, 2020, an operator must collect or make, and retain for the life of the pipeline, records that document the physical characteristics of the pipeline, including diameter, yield strength, ultimate tensile strength, wall thickness, seam type, and chemical composition of materials for pipe in accordance with §§ 192.53 and 192.55. Records must include tests, inspections, and attributes required by the manufacturing specifications applicable at the time the pipe was manufactured or installed.

(b) For steel transmission pipelines installed on or before July 1, 2020], if operators have records that document tests, inspections, and attributes required by the manufacturing specifications applicable at the time the pipe was manufactured or installed, including diameter, yield strength, ultimate tensile strength, wall thickness, seam type, and chemical composition in accordance with §§ 192.53 and 192.55, operators must retain such records for the life of the pipeline.

(c) For steel transmission pipeline segments installed on or before July 1, 2020], if an operator does not have records necessary to establish the MAOP of a pipeline segment, the operator may be subject to the requirements of § 192.624 according to the terms of that section.

§ 192.127 Records: Pipe design.

(a) For steel transmission pipelines installed after July 1, 2020], an operator must collect or make, and retain for the life of the pipeline, records documenting that the pipe is designed to withstand anticipated external pressures and loads in accordance with § 192.103 and documenting that the determination of design pressure for the pipe is made in accordance with § 192.105.

(b) For steel transmission pipelines installed on or before July 1, 2020, if operators have records documenting pipe design and the determination of design pressure in accordance with §§ 192.103 and 192.105, operators must retain such records for the life of the pipeline.

(c) For steel transmission pipeline segments installed on or before July 1, 2020, if an operator does not have records necessary to establish the MAOP of a pipeline segment, the operator may be subject to the requirements of § 192.624 according to the terms of that section.

§ 192.205 Records: Pipeline components.

(a) For steel transmission pipelines installed after July 1, 2020, an operator must collect or make, and retain for the life of the pipeline, records documenting the manufacturing standard and pressure rating to which each valve was manufactured and tested in accordance with this subpart. Flanges, fittings, branch connections, extruded outlets, anchor forgings, and other components with material yield strength grades of 42,000 psi (X42) or greater and with nominal diameters of greater than 2 inches must have records documenting the manufacturing specification in effect at the time of manufacture, including yield strength, ultimate tensile strength, and chemical composition of materials.

(b) For steel transmission pipelines installed on or before July 1, 2020, if operators have records documenting the manufacturing standard and pressure rating for valves, flanges, fittings, branch connections, extruded outlets, anchor forgings, and other components with material yield strength grades of 42,000 psi (X42) or greater and with nominal diameters of greater than 2 inches, operators must retain such records for the life of the pipeline.

(c) For steel transmission pipeline segments installed on or before July 1, 2020, if an operator does not have records necessary to establish the MAOP of a pipeline segment, the operator may be subject to the requirements of § 192.624 according to the terms of that section.

§ 192.225 Welding procedures.

(a) Welding must be performed by a qualified welder or welding operator in accordance with welding procedures qualified under section 5, section 12, Appendix A or Appendix B of API Std 1104 (incorporated by reference, see § 192.7), or section IX of the ASME Boiler and Pressure Vessel Code (ASME BPVC) (incorporated by reference, see § 192.7) to produce welds meeting the requirements of this subpart. The quality of the test welds used to qualify welding procedures must be determined by destructive testing in accordance with the applicable welding standard(s).

(b) Each welding procedure must be recorded in detail, including the results of the qualifying tests. This record must be retained and followed whenever the procedure is used.

§ 192.227 Qualification of welders and welding operators.

(a) Except as provided in paragraph (b) of this section, each welder or welding operator must be qualified in accordance with section 6, section 12, Appendix A or Appendix B of API Std 1104 (incorporated by reference, see § 192.7), or section IX of the ASME Boiler and Pressure Vessel Code (ASME BPVC) (incorporated by reference, see § 192.7). However, a welder or welding operator qualified under an earlier edition than the listed in § 192.7 of this part may weld but may not requalify under that earlier edition.

(b) A welder may qualify to perform welding on pipe to be operated at a pressure that produces a hoop stress of less than 20 percent of SMYS by performing an acceptable test weld, for the process to be used, under the test set forth in section I of Appendix C of this part. Each welder who is to make a welded service line connection to a main must first perform an acceptable test weld under section II of Appendix C of this part as a requirement of the qualifying test.

(c) For steel transmission pipe installed after July 1, 2021, records demonstrating each individual welder qualification at the time of construction in accordance with this section must be retained for a minimum of 5 years following construction.

§ 192.229 Limitations on welders and welding operators.

(a) No welder or welding operator whose qualification is based on nondestructive testing may weld compressor station pipe and components.

(b) A welder or welding operator may not weld with a particular welding process unless, within the preceding 6 calendar months, the welder or welding operator was engaged in welding with that process. Alternatively, welders or welding operators may demonstrate they have engaged in a specific welding process if they have performed a weld with that process that was tested and found acceptable under section 6, 9, 12, or Appendix A of API Std 1104 (incorporated by reference, see § 192.7) within the preceding 71⁄2 months.

§ 192.285 Plastic pipe: Qualifying persons to make joints.

(e) For transmission pipe installed after July 1, 2021, records demonstrating each person’s plastic pipe joining qualifications at the time of construction in accordance with this section must be retained for a minimum of 5 years following construction.

§ 192.305 Inspection: General.

Each transmission line or main must be inspected to ensure that it is constructed in accordance with this part.

§ 192.319 Installation of pipe in a ditch.

(g) An operator of an onshore steel transmission pipeline must make and retain for the life of the pipeline records documenting the coating assessment findings and remedial actions performed under paragraphs (d) through (f) of this section.

 

Some of the common records issues with construction records include:

 

  • Missing Inspector qualification records.
    • Code does not specify construction inspector qualifications, but PHMSA inspects qualification records to the qualification requirements the operator has in their construction procedures.
  • No continuity records on welder requalification.  192.229 (b)
  • No destructive testing records for qualified 1104 welding procedures.
    • I have found in many cases of these missing records that the procedures were qualified awhile back and the destructive testing records have been misplaced.
  • Missing manufacturer test records (MTRs) for pipe, valves, etc.

 

I recommend that you review your construction record process to ensure that all required records are maintained.  I would be happy to help you setup a construction recordkeeping system.

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