Hard spots: a misunderstood zombie or a 21st century baseball technique? Join Christopher and Rhett on this episode of Pipeline Things as they talk about RIN 2’s definition of hard spots and what that means for operators while breaking down the NTSB report for Danville Kentucky. You don’t want to miss this episode.
Highlights:
- Thou must play soccer
- RIN 2 defines hard spots – what does this mean for operators?
- What is a hard spot?
- NTSB Report for Danville Kentucky
Have any questions about the episode? Submit them for Rhett & Christopher to answer in an upcoming Q&A!
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Thank you for joining us on today’s episode of Pipeline Things. Today, we find out that Chris is in a bit of a hard spot with his kids. They don’t want to play soccer. Dad played soccer. Thou must play soccer if you were a member of the De Leon Family. But no, we tie that back to REN2, the definition of hard spots. And we talk a little bit about the NTSP failure report for Danville, Kentucky. And so thank you for joining us and we hope you enjoy it. And remember, your kids should play soccer.
[MUSIC]
Rhett
Welcome to today’s edition of pipeline things I am your host Rhett Dotson my co -host Christopher De Leon and we want to thank you guys for joining us today I um I gotta say I think I’m gonna like the way this episode episode’s gonna go I never know exactly when I start but I like what we have planned for you today.
Chris
I feel like that’s what you feel about me sometimes. You’re not sure how the interactions are gonna go.
Rhett
Chris, no, I always, I always, sometimes I don’t know where you’re going to go but I trust you enough to know it’s gonna end up at a good spot, most of the time. Most of the time.
Rhett
You have to be comfortable with managing change, right? Yeah, absolutely. So hey man, What activities are your kids about to get into? We’re hitting spring now, weather’s coming up. What are the De Leon kids up to? So what we’re managing right now is it’s spring soccer is about start and so we’ve got all three of our kids signed up now for outdoor. I thought only one of them actually liked soccer.
Chris
Oh no that’s not true.
Rhett
Is it a requirement in the De Leon household that you must in order to be a member of the De Leon family you must play soccer and how many years do they have to play soccer for?
Chris
Let’s just say that uh there are no there are considerable incentives or bribing to get your kid to play soccer and if they score goals it like it’s the the benefits are exponential
Rhett
so it’s a performance driven family to
Chris
incentive based
Rhett
No consequences
Chris
to do the things that dad wants.
Rhett
Wow to do the things that dad wants, that’s great.
Chris
So we’re playing soccer, it’s fun, so we’re pretty active, right? So we have planned activities, extracurricular money through Thursday, so when you bring all of them into a new activity, we’re just—
Rhett
Are you coaching? I’ve asked you before, are you coaching any of the soccer?
Chris
Not yet.
Rhett
Why not?
Chris
Not yet, because I wanna be dad.
Rhett
Okay.
Chris
I wanna be dad for a little while.
Rhett
I liked being dad and coaching, it was fun.
Chris
Two of my kids have asked for me to be coached so the two—
Rhett
I feel like you’d be so good
Chris
Yeah, so Juliet and Gemma have both asked me to coach, but I just I just like being dad I like encouraging them. I like cheering them on.
Rhett
There’s a component of that. I’ll be real with you. Let me ask you a question.
Chris
What’s up?
Rhett
So when you played soccer because you played soccer pretty and I think most of the audience Yeah, you played it a lot. How much has the game or the techniques in the game changed that you see in your kids.
Chris
It’s huge.
Rhett
Give me an example.
Chris
It’s huge. So I would say parents are…
Rhett
Not related to parents. I want to talk about the physical of actual the game itself. So I would say the action, the training.
Chris
I would say my kids aren’t there yet, but I would say there is a significantly more…
Rhett
Really?
Chris
Yeah. I would say that now as kids are getting in their teens, I would say strength and conditioning is becoming a much more important part of the development of a player whereas before with when I was growing up It was all about skill and talent. It was less about physical conditioning So now you have to be stronger you have to be more agile more NFL -ish more football -ish.
Rhett
It’s funny The reason I’m asking you obviously I coached Caleb’s baseball for years the first year He’s not playing but I have a nephew now who is starting to play and so my sister’s asked me like hey Will you come coach And I’m like yeah, and they sent me a video and I’m immediately like oh, yeah We need to break this down. He’s not watching the ball. He’s not doing this Hey when he throws turn his shoulders um and a lot of things I didn’t play a lot when I was young Yeah, my older brother did and when I started teaching Caleb I started watching some videos even off YouTube so not that old about the throwing motion which is down comes back You make the snake bite come around and when I brought him to a coach the coach was like we don’t teach throwing like that anymore. I mean this throwing is essential to baseball you start in the beginning and he’s like no whenever you want to throw you actually just go we’ll go straight back because this motion is better it’s not how it’s but he’s like it’s this throwing motion has been improved has been shown to generate less injuries it produces faster time to the ball all these things that I mean we just taught us the essential weight even up through the YouTube age of how to throw a baseball and you kind of people just accepted it as the norm without ever you know it it changed slowly so I was wondering—
Chris
You know I just want to render this because I mean obviously we like to talk about pipelines and pipeline integrity is it’s it sounds like there’s there’s this balance of discipline the discipline component of being an athlete or a sport or professional but then also the coaching right just the just how we do things, which is performance, in my opinion. So again, my reference was it was a lot more around performance, not discipline. When I was playing soccer growing up, it was a lot about can you strike the ball the right way and put it where we want you to.
Rhett
Has the right way to strike the ball changed in 20 years?
Chris
That’s where coaches change. Different coaches have different styles. So for me, I was less impacted by one coach wanting me to strike the ball a certain way, it was more around hit it right, put it where I need you to put it all the time. Now I feel like there’s a big influence on strength and conditioning, which is significant. That’s around performance, right? There’s a lot more weights involved, a lot more strategic agility drills, whereas in your reference—
Rhett
You know, baseball’s seen a lot of that too.
Chris
Exactly, where I think what you’re seeing is more coaching tactic, right? That’s more about my opinion.
Rhett
It’s like form, though. It’s like basic—
Chris
Yeah, that’s discipline, right? That’s about doing it this way versus do it that way so but yeah so all that is to say I think we see that a lot in what we do as professionals to be honest
Rhett
Yeah no doubt right so you can pretty clearly see where I was going with segue right that a lot of times we do something a certain way as we say this is how you should throw a baseball yeah and there’s no other way to throw a baseball or this is how you should hit a baseball or this is the proper way to strike a ball and then when we’re confronted with information of hey did you know that throwing that way actually leads to more injuries you’re like whoa I have to yeah I have to train a different way I have to teach my kids how to throw a different way
Chris
Your procedures your discipline
Rhett
Yeah everything and that is I think in a lot of ways very applicable to our industry because today we’re gonna be talking about hard spots and I think hard spots out there I think are probably one of the what word would I used to describe hard spots. If corrosion is the most mature threat—
Chris
It’s another zombie.
Rhett
Is it a zombie?
Chris
I feel like it’s on the horizon, and it’s becoming more relevant, and you’re gonna have to do something to prepare for it. And if you’re not, you’re probably behind the ball. It’s one of those things where it’s like, it’s at the horizon, it’s coming, you’re gonna have to cross that horizon.
Rhett
See, I wonder if operators realize that it’s coming so interesting like I just did a presentation this weekend covering Dents and Geo hazards Most people felt reasonably comfortable dents. Yeah, Geo hazards very uncomfortable.
Chris
Yeah, it’s another zombie
Rhett
I felt like a lot of people put yes pretty uncomfortable. Yeah But focus on this arc Chris what the reason we’re bringing up hard spots today isn’t just because we wanted it’s because that was something very Important in in RIN2.
Chris
I think it’s important.
Rhett
You think it’s important.
Chris
I think it’s important. If we look at some of the last episodes that we’ve done, you know, one of the sayings that we’ve said is define and defend.
Rhett
Yep. Well, in this case, RIN2 define hard spot for us. So you can defend your own definition, but it’s probably pretty good if you use PHMSA’s.
Chris
No, we can defend our position, right? So it may be defined, but you need to have procedures in place to defend your position.
Rhett
So lets talk about this. So in RIN 2, I’m going to read the definition for you. They actually added a section of code underneath the definitions, which is 192 .3 if I’m not mistaken. And they added the definition of a hard spot. And this is what they defined it as. Steel pipe material with a minimum dimension greater than two inches in any direction with hardness greater than or equal to Rockwell 35C Burnell 327 or Vickers 345 HP 10. So we see PHMSA endeavoring to give us an explicit definition of hardspots. Now, it’s interesting Chris that is The only place within RIN 2 that hardspots are mentioned and I thought it was kind of funny I told you before the episode. It’s funny. We defined hardspots on RIN 2 But there was actually a lot more conversation in RIN 1 around hardspots
Chris
But there’s a trend on that right so we’ve also talked about that RIN 1 for example introduced 712, where you’re establishing predictive failure pressures, but it didn’t tell you what to repair. And now in RIN 2, we see the requirements for repair.
Rhett
So we understand why they really wanted to release it all at once, and I understand, you know, one of the regulators comments to us was, you know, you would have understood a lot of this if all three parts had come out at the same time. Yeah. And so what we see here is the definition of hard spots, but again, we don’t want to get back into REN 1 right now, but it’s worthwhile to to mention that hardspots appear in multiple locations, including MCAs, the M .A .O .P. Reconformation section, it’s called out as a threat that operators need to address, particularly with regards to ILI. So topic number one, obviously, is we’re going to cover hardspots today for the audience, and there’s something else that you wanted to bring out that surprised you.
Chris
Yeah, it’s the so what of that, right? I always like to think of, okay, so Why is this now defined? And what does it mean for me? Okay, so they’ve defined hard spots. So what, right? And so as I continue to read RIN2, I feel like there’s always a story there, right? That’s why I like the preamble, right? We like reading the preambles, we like being engaged in industry, ’cause it kind of tells the full story. You don’t wanna look at one pixel on the TV, you wanna look at all the pixels so you can see the picture. And what we also found is that they also introduced 192, 13, I think it’s paragraph D, might have to check me on that, but it’s MOC, Management of Change. And I started thinking, I was like, I wonder if there’s a correlation there, right? And what we do know is that incidents, significant incidents in our industry, normally are big drivers for new regulation. And while we think that, you know, or we find that San Bruno is often referenced, right, in a lot of these preamble statements. I would say there’s another incident out there that might have had something to do with the basis for defining hard spots and also this push towards having MOC being a more broader paragraph in code versus it being embedded as it is now, like inside a subpart O, which is specific to
Rhett
So, I think for the audience, we’re going to have to take you through that journey. So the question that Chris is mentioning specifically or the point is related to 192 .13. You’re correct. And it says that each operator of an onshore gas transmission pipeline must evaluate and mitigate as necessary significant changes that pose a risk to the safety or the environment through a management of change process. Each operator of an onshore gas transmission pipeline must develop and follow a management of change process. I was outlined in ASME B318S section 11 and then they go through. It’s interesting that you reference the incident because the incident that you’re referring to is the Danville, Kentucky incident. To catch the audience up on that, what we’re talking about here is Enbridge operated a 30 -inch natural, I’m reading specifically from the NTSB’s report. So for our audience out there, you can actually search the NTSB failure investigation, go to pipelines and find this material. It says that Enbridge’s 30 -inch natural gas transmission pipeline ruptured in Danville, Kentucky, releasing about 100 million cubic feet of natural gas that ignited. The accident resulted in one fatality, six injuries, and the evacuation of over 75 people. five residences were destroyed by the resulting structural fires and an additional 14 were damaged, a nearby railroad track was also damaged and over 30 acres of land were burned. As you go through and read that report, they attributed the failure to a hard spot that interacted with cracking.
Chris
Yeah and just to set the background guys, the intent is not necessarily to to walk through or dissect that report in particular, it’s rather just tying that back to potentially why we find some of the things we find in RIN2. It’s normally attributed to significant incidents. There was a fatality. It’s a threat that the NTSB and PHMSA felt maybe needed some more attention and so what do you do? They define it. They say, “Hey guys, we need to be aware of this stuff.”
Rhett
It’s interesting to note that again, this incident occurred and it wasn’t the first hard spot related incident not on that line but I do think that it gathered a lot of attention for a couple of reasons so I’m gonna give you some of the the key points from that and then I want you to help us take us through how does this actually relate to what we see in code. So I think key point number one and I think where a lot of operators find themselves is that hard spots are considered a manufacturing threat.
Chris
Exactly right.
Rhett
which we consider stable so in general again I want to take our listeners back through that yeah there are a number of threats that when we identify them as stable we don’t take further action on them is that fair to say
Chris
I would I would say procedurally they’re probably considered as monitored monitored right which could take you down another path of if they’re monitored how are you monitoring them right but again In most cases, category one is it’s they’re stable and two, under continuous evaluation, you’re always looking to see have any of those conditions changed.
Rhett
And so there’s a number of threats that fall into this. We talk about seam weld flaws fall into this in natural gas pipelines, maybe wrinkle bends fall into this under natural gas pipelines, hard spots, even certain girth welds might be considered vintage manufacturing defects that are stable.
Chris
But there’s a caveat there, right? That’s under the basis of a hydro test, right? So just a little caveat there, right? Not just because you have them means they’re stable, right? They’ve been tested for fitness through your hydro test. Now that’s where the whole idea of well, how long was the test? Do you have records? Can you, you know, do you have TVC records for it, etc., but we won’t get into that.
Rhett
And even REN1 again, touch space on the subpart J hydro test on 1 .25 in order to, for crack -like flaws to be considered stable. And I want to read here because then in that report they referenced the fact that Enbridge had considered it stable. And it said they also referenced a PHMSA 2017 advisory bulletin on manufacturing defects. And it says that according to the 2017 advisory bulletin manufacturing threats are stable threats that become active. That is require reassessment, huge language, right? So they’re giving us the manufacturing, the requirements under which manufacturing threats can become active, at least per that 2017 bulletin. When any of the following occur, the operating pressure increases above the highest operating pressure in the past five years, the MAOP is increased, or stresses are increased that lead to cyclic fatigue, and it says in 2007 -11, sorry, Spectra and later Enbridge considered hard spots as eliminated as a threat on line 15, valve section four, after one line line inspection, four excavations, and one repair on the pipeline segment. –
Chris
Yeah, so again, we’re using this NTSB report just as a basis for discussion, guys, right? Again, the intent is not to dissect it and understand right or wrong or to draw a position. Absolutely. So I think what I want to highlight there is it’s when you look at the NTSB advisory bulletin, those don’t necessarily correlate and that’s a segment for you to mention more about the NCB report is it’s none of those were the drivers that we believe to be what caused the incident. Absolutely. Right. So the basis could have been a hard spot, but change would have had to happen. Something would have had to have made that an active integrity threat.
Rhett
And it’s interesting because in the report they go through and they identify that the change you’re speaking of was a line reversal in this particular case. And they specifically say that line reversals don’t fall under any type of management of change process.
Chris
Yeah. However, we would say that an operator would consider that a management change process and there were advisory bulletins around flow reversals and service changes, right?
Rhett
The opposite, I’m going to say, I have heard of, obviously, when an operator reverses the line, I’m very familiar with how they address the integrity threat of SCC, because everybody recognizes that, hey, when you reverse a line, you increase the threat of SCC near the section section. But I don’t think I’ve ever heard anyone mention the threat of hard spots changing with regards to a line reversal. I feel like that’s new information that I don’t think—
Chris
I think and again it goes back to our opening right it’s I think it’s more about PHMSA wanting to highlight the importance of managing change specific to the analysis process that you would want to attribute to like a safety management mentality right where you’re thinking hey I’m inducing change on this pipeline, this is fair for me to look at my baseline assessment program and reevaluate what threats I think are active and which ones are stable. And so would necessarily, and again, I want to pull a little bit away from Danville in this case and saying, was it important that, is the message to take away from this that there was a full reverse on heart spots? I would say no. I think it’s more around thinking through a process of change management of your integrity management program is based on processes and procedures. And your process should be continuous evaluation. And it’s important for you to say, okay, what are my active threats and what are my stable threats? And redefine them so that you can defend them again, right? I think that’s the point. So it’s a little bit pulling away from the Danville scenario and saying, I think that’s the nugget, right? Because if we look at the NTSV report again, again, I don’t think we can correlate the fact that the flow was reversed entirely too, why we think-
Rhett
No, it’s just to consider your factor, right? And they say that, combined with some other things, led to it becoming a reactivated threat, which is very interesting. And so the net brings us to our next topic, which is, again, they considered the hard spots eliminated after one inline inspection. And it’s worth talking about that inline inspection. But here’s where I’m going to put a cliffhanger for our audience because we’re going to take a break.
And if you want to hear what I have to say on the ILI, you’re going to have to come back after a brief word from one of our friends.
Kara:
Hi, I’m Kara Turner. I am the managing director and co -founder of ADV Marketing. We get the honor of working with Rhett and Christopher to produce this crazy podcast and also work with them on any other initiatives that they have when it comes to marketing. And if you know them or are listening to this podcast, you know that it gets pretty crazy around here. So we have a lot of fun with them. ADV Marketing is a full service business to business marketing agency. We specialize in service companies and technology companies. So if you are enjoying listening to this podcast and the fun that they’re having, reach out to us and see how we can make your marketing fun.
Rhett
All right, welcome back to Pipeline Things. As Chris dooly pointed out during the break, he was unhappy with my presentation of the, my summarization of the cause of the failure in the Danville, Kentucky. So I wanna revisit that briefly, so I wanna keep you happy, Chris. That’s my primary goal.
Chris
It’s important for the audience to know what’s going on.
Rhett
– Yes. So the hard spot was the cause of failure, but it was a hard spot interacting with the threat. So I’m just gonna read directly what the ENTSB says, right? It says the probable cause and resulting fire was due to a combination of a preexisting hard spot, and they put in parentheses a manufacturing defect, degraded coating and ineffective cathodic protection applied following a 2014gas reversal project which resulted in hydrogen -induced cracking at the outer surface of line 15. Now so that’s why I had already mentioned the gas reversal and I wantto go back again because they do mention it as a contributing factor. They say contributing to the accident was the 2014 gas flow reversal project which increased external corrosion and hydrogen evolution. So again manufacturing or I’m sorry hard spots which are a manufacturing threat are happy as long as nothing changes. Right in this particular case we had increased external corrosion and hydrogen migration that happened as a result of what the NTSB says is line reversal. And so that was the role that the line reversal played there. But going back again I think the whole point there was that I feel there’s there is a lesson to be learned there and it’s not the point of the show which is that the line reversal, most people wouldn’t have thought that would have contributed to the reactivation of a hard spot threat. I was like, man, I think that that, that in of itself is a key learning apart from this show. But the reasons why they considered the hard spot stable, I mentioned before was that they had one inspection for excavations and one repair. The inspection that they mentioned was based on a 2011 technology.
Chris
So ILI, right?
Rhett
ILI, correct.
Chris
Inline inspection, not direct examination.
Rhett
And I want to read what the NTSB report says. It says, “NTSB reviewed the performance specification for the tool used during the 2011 hard spot MFL run and found that the report provided to Perspectra did not contain a statement regarding minimum detection capabilities of the tool. Further, the specifications were not complete. They did not clearly state if the probability of detection, location accuracy and sizing accuracy applied to hard spots, metal loss anomalies, or both. In addition, it says specialized ILI tools, such as hard spot NFL tools, rely on proprietary processes for data analysis and interpretation. Spectra relied on the ILI vendor’s contractual requirements and confirmation using the vendor’s quality checks for validation of data coverage and quality.
Chris
Man, thanks for doing that. Now the audience doesn’t have to go read the report.
Rhett
Wait, it got to set the stage. And I don’t want– since you’ve already harped on me once and said that apparently I didn’t do a good job like paraphrasing something, I’m terrified. But as a paraphrase now, just read the darn report.
Chris
Yeah, so a couple of things that we get from that, you know, me getting back to the so what, is I think it’s important for us to take a moment to talk about Why they say MFL technology, right?
Rhett
Hard spot MFL. Yep, specifically.
Chris
Yeah, but it’s MFL technology Yes, so can can MFL technology be used to detect identifying size hard spots? I Think the answer is yeah, we think so right?
Rhett
Yes.
Chris
So how does that work?
Rhett
I wasn’t sure how to answer because you give me this look And I’m like what am I supposed to answer yes or no here? I’m actually not sure we’re trying to get yeah
Chris
No, no again. We’re relatively confident in that right and so Usually it’s a two MFL based system, so one where’s a higher MFL magnetic circuit where you’ll have, let’s call it, greater than 10 ,000 kA per meter saturation in the pipe wall, and then you’ll have something that’s different than that, traditionally on the lower side. Some tools will try to use a trailing MFL sensor where it’s some distance in the high field magnetic MFL where it’s some distance and it doesn’t have another magnetic circuit, a component or a magnetic circuit, it just has MFL sensors trailing. Another one is it’s a calibrated low field MFL.
Rhett
So there are variations inn the applications of MFL for the detection of hard spots.
Chris
Yeah, so are they all the same?
Rhett
No.
Chris
I think that’s one of the big takeaways, right? Is it’s like all technologies, it’s really important for you as an operator to understand what’s the measurement principle, how was the performance specification established, what’s the historical performance of it, what is that tool going to be able to do for you?
Rhett
Are we talking about hard spots still? Because I feel like you’re talking about cracks all of a sudden. I feel like you just jumped straight from hard spots to EMAT. I feel like after I’ve been listening to you talk about EMAT for the last three months, I feel like you’re saying the same thing that you say for EMAT.
Chris
It’s process, procedure, right? it’s it’s it’s highlight tool selection and the neat thing about this and and and I think the NTSB report highlights this is it’s in RIN 1 of the new gas rig we see that api standard 1163 is now also incorporated by reference
Rhett
Yeah i’m chomping at the bit here chris because if we work for a vendor We we we saw this aspect of things what I mean is The questions we received most times on a specification We’re around the images for depth and length Not the other language in the specification. Yeah, and I’m just and that’s a guy honest And I wonder how many how many people would still find themselves Not aware of the finer details or points of a performance specification Yeah today
Chris
So Man that could be a whole other episode. I mean if I were to have an episode on qualifying I like
Rhett
what’s the qualification of an I like technology for detecting metal loss and dents. What’s the qualifications for an ILA technology differentiating seam well defects? I mean, there’s, in detection, within different types of seam well, there’s a lot of questions you could run down here related to performance specifications, Chris, that I think are fair. Because I think, I want to defend the operators, but here I don’t always feel like the performance specifications are written in a manner that’s always easy to understand.
Chris
I would also say though, but again,
Rhett
Or if you’re not used to looking at them Maybe you don’t even know what questions to ask
Chris
And and maybe that’s it, right? So I’ll tie into part of again something that I think is important and it’s you know in in the gas rag presently There is language that operators should lean on right so 192 .911 paragraph O It’s pretty specific. It’s you have to have written procedures Right, You have to have written procedures that ensure pipeline integrity for environmental safety, public safety. I mean, you have to have written procedures for your activity associated with integrity assessments.
Rhett
So an operator listens to this podcast, Chris, and jumps in and says, “Oh my gosh, I’m going to go read their specifications.” And they start reading the specifications and they have questions, what should they do?
Chris
Talk to their ILI Vender. And I would say before they do that, they should probably read 1163, which it’s not a fun read, but a big takeaway that I would give you is this is it’s one you need to understand what the tool is going to be able to do for you for the specific threat you’re looking for you need to understand how the mfo how the excuse me how the performance specification was established because 1163 doesn’t tell you what a standard is from a minimum performance perspective it just says define it and then establish a spec and the ILI vendors gets establish what that bar is they have to meet, right? So who dictates that you need a POD of 90 % and or a POD of greater than 50 % for a specific threat, right? And that’s where really operators need to hone in and say when I read these specs I need to understand number one is it’s what are they trying to tell me? Two, how did they establish it? And three, what’s their historical performance? You can tell me this all day long, but how are you substantiating that the tool can perform accordingly? Let’s get back to the NTSB report And that’s highlighted there, right?
Rhett
It is, and I think that’s a big takeaway for vendors is really our operators, I’m sorry, maybe operators and vendors both, is dig into your performance specification and understand it, not just the picture that states what the detection capabilities are. And if you have questions, you should talk to your ILI vendor, absolutely. And you should dig into understanding how it was validated. Again, ’cause I think that, you know, the NTSB honed in on that. It’s also interesting, Chris, and this is where you’re going to bring up the last point. In that data set that they collected in 2011, and there were seven integrity assessments, as a result of this incident, they went back and re -evaluated the data set. And I don’t know, this really stood out to me, so I’m just going to read it again. It says, “In August of 2019, the vendor used the raw data from 2011 to conduct a re -analysis that showed a total of 441 hard spots in the segment. Of these 441 identified hard spots, nine were located in the pipeline joint that ruptured, including two at the rupture origin, with predictus hardness values of 241 Brunel and 245 Brunel.
Chris
So what?
Rhett
It’s significant. Let me take so what? During the 2011 inspection, there were no hard spots identified in this region that failed. So even had Enbridge gone back and said, “Hey, we’re reversing flow, we need to reassess hard spots.” If they had just done it based on the data that they had, it wouldn’t have triggered anything in this joint. They go back though and they rerun it, they find 441, nine of which are in this joint, two of which who have 241 and 245 Brunel. Now the surprising thing there to me is that again, 241 and 245, Brunell aren’t high enough to have made an operator jump up and do anything.
Chris
And it’s also less than the 327 that is now in the definition for hard spots.
Rhett
Yes.
Chris
Getting back to the so what?
Rhett
So that, it’s interesting to me. So clearly there’s still a gap there, but I think the reanalysis is a bit—
Chris
It’s great.
Rhett
What do you mean great?
Chris
It’s great.
Rhett
I was gonna say you say great. I was thinking alarming.
Chris
It’s not alarming, right? It’s all about perspective I mean we want I like technology to improve Right. And so what this demonstrated is is that I like technology works, right? And that’s why that’s why I think we see the G pack as as rent as the new gas rule and and PHMSA and the DOT they’re really they’re really pushing towards the use of ILI in continuous improvement technology development for ILI, right? The technology back in 2011 had the capability to detect it. However, as we see in the report, there was not what I would call an API 1163 compliant or consistent performance spec for hard spots with that ILI system. Fast forward, say, plus or minus, I mean, roughly eight years, what happens? New computational technology, more experience, they know what They’re looking for the ILI system is better understood and now they surface 400 plus features and in that specific joint nine candidate features. And we got to be careful here, right? Because we need to appreciate that you don’t, there’s always this analysis requirement of thresholding, right? And you don’t want to say, oh, we’ll report everything you see because then you really are finding a needle in the haystack, right?
Rhett
But then here is my challenge right so and I want to I want to ask you for what recommendation she would have her if you run yeah an ILI spec tech spec
Chris
start over yeah try that again
Rhett
um can we edit that out miss producer I don’t know by the way it’s so good to see miss producer back by the way congratulations to miss producer she’s got a new name now so if you search her up on LinkedIn she’s totally different now you should continue searching for that old person though because we don’t want anybody to take her amen she’s fabulous. So, but going back, if an operator runs a technology for a stable threat, and let’s say they run your traps down on 1163 and the procedure’s qualified, how or what advice do you give an operator to reconsider that technology as it continues to progress?
Chris
So let me make sure I understand this. So you ran it before, do you need to go back to realize?
Rhett
Let’s say an operator today ran EMAT for the justification of their CMAT flaws, showed that all their CMAT flaws are stable. They’re like, hey, it’s cool. And wait. Today, let’s say they ran it right now. Let’s say they ran it today and finished it up. And we know EMAT’s going to continue to change. I’m just using EMAT as an example, because I know it’s always on your mind. Yep.
Chris
I like hardspots, but OK.
Rhett
Let’s say Gen4. Let’s say EMAT ultra, ultra plus, Hashtag awesome comes out in 10 years. –
Chris
Sure.
Rhett
Does an operator go back and reevaluate a segment with the new technology updates? I mean, how do you do that?
Chris
It always depends. Right? I would say that as part of integrity management.
Rhett
Well, can you hold that operator?
Chris
Look, you asked me a question. I’m saying it’s a culture.
Rhett
I’m asking you a question. I want to keep asking.
Chris
It’s okay. As an integrity engineer, ’cause I still think of myself as an integrity engineer. We don’t work for an operator.
Rhett
That’s so sweet.
Chris
Yeah. But as a consultant, I would say you’re always managing your pipeline. You’re always integrating data. You’re always integrating the information from the field that you’re learning at conferences, that you’re learning potentially from our podcast. And you’re always thinking about your assets and saying, Hey, I know on this segment, it’s been in the ground for this long. I know these challenges. I know the coding type. I haven’t found it yet, but we have other different threats. So in this case, if I’m not mistaken, Danva was EFW pipe. Yeah, pipe. So we’ve now learned that EFW pipe has a propensity to have hard spots in it. So if you have EFW pipe, specifically 30 inches, like in this case, and you haven’t thought about the threat of heart spots,
Rhett
But they had. They did in 2011.
Chris
Yeah, we’re not here just to talk about this scenario. What I’m saying is it’s the concept of…
Rhett
So like once a decade you should kick the tires on technology and see what happens? I mean…
Chris
Yeah, I think it depends.
Rhett
I think, that’s what I’m saying. I feel like that’s a challenge.
Chris
I think it depends, right? And that’s the whole concept of continuous improvement.
Rhett
And learning in education. I think what I liked what you were saying is that I do think as you go to conference and you listen to what some of the vendors claim they can do, it’s worth paying attention when something new comes on the scene.
Chris
Absolutely.
Rhett
And evaluating how it might change your baseline assessment.
Chris
But equally, and I’ll look at the camera on this one, it is incumbent on the operator for you to qualify that technology. Not so much that the vendor is qualifying their specification. That’s step one. Step one is for a technology to be vetted by the technology company for them to have a commercialization process and to be transparent as required by API 1163 to communicate a performance spec and how is it established. And you can audit that process. You can talk to your vendor and say, how did you establish the spec? Show me your process, show me what you achieved. But then it’s incumbent on you as an operator to say, will this tool meet the requirements or the goals of the inspection that I have? And what are you gonna do to ensure that it’s gonna be able to give you the characteristic data or the information you need to give you that comfort to say, you know what, I feel good. And back to these guys, they went and did digs.
Rhett
They did.
Chris
It’s really hard to say they did something wrong. If the vendor doesn’t report it, how is the operator supposed to respond?
Rhett
And that was my question, there you go.
Chris
And that’s a challenge, right? I mean, again, you said it earlier, this pipeline had seven integrity assessments on it across the span of say, let’s just call it eight to 10 years. I don’t remember the exact dates, but this wasn’t a baseline assessment. So they knew the threat of it. They tried to assess it. They went and did digs. They did at least what some would you could be a level one or a level two validation of the ILI.
Rhett
Yeah, the NTSB specifically said it wasn’t statistical, that they agree they did do some validation.
Chris
So the point is it’s kind of hard to, I’ll be honest with you, you kind of feel, in my perspective, if I’m the integrity engineer on the job, I’m kind of feeling bad for them a little bit. I can’t say they necessarily did anything wrong other than recognize looking back to hindsight 2020 and saying, there wasn’t an ILI specification that you could have held the vendor to, we could question how was that spec established and what was the historical performance and could there have been more done? The reality is, man, that’s kind of hard.
Rhett
That may be, again, because we’re going to run out of time here, and I do think each of these topics, Kelly, could have been separate, but as it pertains to hard spots and their inclusion and definition in REN2, I think where I want to try and get to a recommendation if if an operator’s listened to this, is that if, and let’s limit it to hard spots for now, is that you need to understand the specification how it’s qualified. And I’m gonna add a caveat to that. Whether you’re performing an inspection today or you performed an inspection 10 years ago. ‘Cause there’s probably some operators out there who evaluated what they would have considered to be susceptible segments based on that information at the time.
Chris
With a technology back then.
Rhett
With a technology that’s 10 years old.
Chris
So, and that’s why, again, when we were thinking about what to highlight in REN2, ’cause this kind of wraps up our REN2 arc, it was, you know, we just got off this co -idea of define and defend, right? PHMSA has defined something. And so now it’s, and operators are constantly defending their integrity management programs and their decisions. And some operators have improved and say, you know what, I know I might’ve had an issue with hard spots, I ran hard spot tools, I’m gonna pick something 10 years ago, I’m picking something arbitrarily, right? 10 years ago and I feel good about it and I’ve never found anything in the field. We would just say because of this incident that happened, it’s healthy for you to read through it and learn and say, man, you know what?
Rhett
What can I learn here?
Chris
What do I need to do here, right? And so my recommendation is this, is to recognize that technology and ILI is evolving. And 1163 focuses on the ILI system, which just isn’t the tool, the manager of the physical components. It’s not just a centauric technology. It’s also the algorithms that are applied, the procedures for evaluation, the personnel qualifications, it’s all of that.
Rhett
Yep, and I think what we have seen lately again is we have seen, ’cause we’ve watched presentations from the NTSB where they have parked on the fact that, hey, operators aren’t learning from other operators and we’re seeing the same mistakes and I think that that is a key learning here. Know your specification and if you ran it historically go back and revisit that specification at least as it pertains to hard spot.
Chris
And if you’re gonna run a new technology. So again same thing ASME /B3 /8S is incorporated by reference. We see that in in section 12 under quality management controls. I mean, it’s pretty explicit, right? I don’t remember the verbatim, but it basically says, if you are using outside resources to conduct integrity related activities, and it even says, I think, for example, pigging, you are still responsible for the quality management of that process. And so again, I even think the NTSB report in this case says that the operator relied on the vendor’s quality process. So if I was to try to picture that a little bit to see if you can see what I’m saying is it’s the operator needs to be careful about trusting third -party quality management systems and processes. You define them and they have to prove or qualify against your quality management system. I think the interview even said that for standard processes like MFL and Caliper, You know, the operator had predefined processes, but for this one, they didn’t, right? And I think that’s just what I wanted to state is it’s, you know, we have all these resources, right? Lean on your standards, lean on your recommended practices, lean on industry lessons learned and own that quality management.
Rhett
All right. Man, that’s really good stuff. So I’m going to wrap up this episode and say, you know, that If you get a chance to take a look at the NTSB value report, it actually is a good read. There’s a lot that can be gleaned there. And I think we’re coming up now, we’re gonna be wrapping up this, we have one more episode left, which is our Q &A episode. So I’d like to highlight that if you have questions for Christopher or I, we always take a mix of fun and a mix of serious. So you can give them to a Miss Producer, you can give them to us on LinkedIn, You can email them to us. I think we’ve gotten a few to info @d2integrity .com through the website.
Chris
Yeah, info@d2integrity.
Rhett
Feel free. We can keep it anonymous or we can mention you. It’s up to you. And again, sometimes we may pull, as you saw in the last episode, we may pull that question out and ask an operator directly if it’s good enough. So Chris, anything else you wanna leave them with?
Chris
Yeah, I would just say hard spots kind of seems to be a hot topic. I would say ask for help right there’s a lot going on with hard spots. There’s a lot of lessons learned There’s a lot of activities whether it’s integrity assessments whether it’s integrity management or It’s understanding. ILI technology ask for help Like we say phone calls are free gives a call
Rhett
Can the audience expect updates on your kids soccer progress? Can we get statistics number of goals short scores? Scott you know passes landed shots taken number of minutes setting the bench number of minutes requested to sit at the bench
Chris
Yeah, let’s just say again right now. I’m still in the phase of we’re doing it for fun. We’re not competitive yet I don’t need them to pay for college through soccer yet.
Rhett
Yeah, I’m just if you’re paying your kids to play soccer It’s probably competitive, but that’s just me. So we hope you enjoyed this episode of pipeline things Thank you for joining us. Remember, submit your questions. It’s been a pleasure being with you. I am your host, Rhett Dotson, my co -host Christopher De Leon, and we’ll see you again in two weeks.