In this episode of Pipeline Things, Christopher and Rhett welcome guest Brian Jimenez, Director of Pipeline Integrity – East Region at Energy Transfer. Brian and the Things tackle RIN 2 and the updated Gas Rule topics such as the term “permanently restore”, using crack calculations on metal loss calls, and the new crack response criteria. This is a great episode for our operator friends out there!
Highlights:
- Updated Gas Rule & Response Criteria from Section 714 and 933
- What is the original intent of the regulation?
- You have to be prepared when you run EMAT
- What is “wide-spread”?
Have any questions about the episode? Submit them for Rhett & Christopher to answer in an upcoming Q&A!
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Rhett Dotson
All right. On today’s edition of Pipeline Things, we try to tell one of our close friends and, and clients in the industry that he most resembles spawn. I’m not sure how he’s going to take that. If you’re not familiar with who spawn is, need to read the comment. I picked that man. More important than that, we tackle some critical things.
Of Ren two of the updated gas rule. So, if you’ve ever had questions around the words permanently restore using crack calculations on metal locks, calls, or maybe even about the new crack response criteria and want to hear, some takes and reactions to it and maybe some guidance advice for operators. This is a great episode. As we work with mister Brian Jimenez, and we think you’ll enjoy it.
Thank you very much.
All right. Hello. Welcome to today’s edition of Pipeline Things. I am your host, Rhett Dotson, and my co-host, Mr. Christopher de Leon. And I have to be honest with you, Chris, every time we do the high five, it is an intense moment of focus to make sure I don’t miss your hand because some of us call you out on us.
I’ve been called out multiple times for missing that. But it’s super exciting, man, to get this third episode, as we get, 2023 underway. If people are watching on the, the YouTube channel, you can see that we are in a restaurant surrounded by Christmas decorations. So, we’re still within the realm of the holiday season.
This is actually our first shoot coming back from the new year. So, shaking the rust off, I mean, how was your break?
Christopher de Leon
So super excited. We got to, to head down south of the border to Mexico and visit some family at the scene. And, super nice and, just lessons learned, you know, you and your traveling, you know, you had some tire issues.
I said, you know, what? It’s probably a good idea for me to do with the tires checked.
So, I go pick up the lug nuts. I go to Discount Tire.
Rhett Dotson
So, if you are only listening, Chris is now picking up a box to show us on screen
Christopher de Leon
And I handed the box over to them. I didn’t open it because I knew what it was. And so, one box had lug nuts, the other box didn’t, and they gave me this box back after the game, my tires, and they said, hey mister, do loan forgiveness, but we can’t put perishable items on your tires.
Rhett Dotson
So, wait, you gave them a box that wasn’t full of lug nuts?
Christopher de Leon
Yes. So and it turns out that our friend, the dirt merchant over at Geosyntec’s sent us chocolate. So that one was for me. One was for you. So here is your box of chocolates from Patrick Johnson.
Rhett Dotson
And if you’re listening, Thank you Alex.
Thank you, dirt merchant that you cannot indeed, attach tires to your car with chocolates.
Christopher de Leon
Yeah. So, the chocolates, I guess the techs are in a good mood, but Amanda loved them. I’m sure Morgan will as well.
Rhett Dotson
Fantastic. So, you know, it’s kind of funny you mentioned tires because I got my own tire thing going on right now, and it will tie very well into today’s episode.
So, I have had a screw in my tire for almost like a month, but I need to take the Discount Tire, must pull it out, and I keep thinking, how long can I drive around with the screw? And it’s wearing down
Christopher de Leon
and you wonder why stuff happens.
Rhett Dotson
Shut up. But I’m like, I think it’s just barely in there, but I’m not confident enough to pull it out myself.
I don’t know why. So, it kind of brings this condition, like, you know, when do you need to repair a tire?
Christopher de Leon
And I would say it’s risk management. Right? I mean that’s exactly all it is. Right. At what point do you decide it’s time to repair.
What is that response. You discovered it. You discovered it. You performed an evaluation; you’ve accepted a certain level of risk.
Rhett Dotson
So, if you all haven’t figured it out today on the show that actually we’re going to talk about we’ve been on this, this kick talk to you about the updated gas rule.
And today we are going to be talking about the updated gas rule, specifically the repair response criteria and the updated sections for 714 and 933. And you can see there’s an empty chair here in between us, because we have a special guest that we’re bringing on today. And it is time for that guest to make his way down.
I’d like to introduce Mr. Brian Jimenez, who is the director of Pipeline Integrity for Energy Transfer East. So, as he comes on. Welcome to the show.
Brian Jimenez
Thanks for having me. Awesome. You know, long time listener and excited.
Rhett Dotson
I don’t want to ask any questions because we might find out he’s not.
Brian Jimenez
I mean I might have binged them all in the last couple days. No, I’m kidding, I’m kidding. I have been listening for a while.
Christopher de Leon
Well, so in spirit of the holiday season and, we just like to give gifts. Okay, one of the most recent ones that we had was, was a Q&A session, and, and in spirit of the Q&A session and some of my personal tendencies, we brought I brought you something.
We brought just on the rent doesn’t really address box or something for both of us. So here you go. Go ahead and open it up. Let us know what you think.
Brian Jimenez
This is kind of scary. I have a feeling Rhett might like this better.
Christopher de Leon
So, one of the questions was, who would you be?
Batman and Robin. And obviously I said, you know, Batman’s one of my my favorite characters.
Rhett Dotson
So, for those who are listening, we gave we, he’s, you know, he’s totally. Chris gave Brian, a Batman versus spawn exclusive edition comic.
Christopher de Leon
So, I will not spoil this, because this is called the one shot. So, it’s not a series. Okay, so Trevor McFarlane did this with Frank Miller because I like the Dark Knight version of Batman.
Right. I think it was 93 or 94, and it was just 1 book. Okay. And so, they decided to do it again this year. And, Barnes and Nobles had a limited release. So, I don’t know, it’s just cool.
Rhett Dotson
Give it a read.
Bran Jimenez
It’s. Yeah, it’ll be fun. And share it. My son. Yeah. He’ll love it. I’m sure. So awesome. Well thank you anyways.
Rhett Dotson
So, you already know we’ve already prepared you that we’re going to be talking about, then, the new versions of the updated gas rule. And I do feel it’s worthwhile, you know, again, to let the audience know that we’re going to be talking primarily about not 192 714 and 192 933 those two sections were updated.
We’re not going to differentiate between them because, as we already mentioned, the language is identical between the two, largely when we talk about repair response materials, what are we. Let’s do it. So, 714 D and 933 D are essentially the same sections. The only division being one- and two-year conditions between non HCA locations and HCA locations.
But that’s not where I want to spend the bulk of the time on the show.
Christopher de Leon
And again, we’re talking about gas regulations. CFR 192.
Rhett Dotson
Absolutely. I also think it’s important in the interest of protecting Brian, that Brian is not speaking on behalf of energy transfer at all. So, if you were listening to this show, massive disclaimer, maybe miss Producer will put like a red traveling thing underneath.
You know, Brian speaks on behalf of his own authority. Our objective today is there are a lot of operators out there who have only maybe lightly read over this, maybe who haven’t read over it, some of it. All right. We’re asking Brian, on behalf of one of the major gas operators in the United States to offer some advice.
Christopher de Leon
and it’s not I want to jump in there a little bit.
I’ll say it a different way. You know, we reach out to our guests. because of their experience or their strong opinions. As a person in certain topics. And, and Brian holds a dear place in my heart. So, when I was an intern at the University of Houston back in the days Southern Union, Panhandle Energy, Brian was, an integrity engineer, and I learned a whole lot from him.
And then that 2007 to 2009 timeframe, you know, we were neck deep in what we’ll call IMP 1.0. Right. So, you know, we went through this cycle of their code, we’re trying to interpret it. How do you act on it. And now we have this amp we call it IMP 2.0. And so, you’ve been living this for a long time I just felt like this would be a good opportunity for you to just kind of share some of your personal experiences.
Rhett Dotson
Insight, like what would you tell somebody who maybe doesn’t have the resources of a major gas operator and hasn’t looked at it?
But again, speaking on behalf of yourself, not energy transfer. Sorry.
Brian Jimenez
And anybody that knows me knows I don’t have very strong opinions on anything. Actually, people know that I do have very strong opinions on things like this.
Rhett Dotson
All right, so, the first thing I noticed as I read through it is that I’m going to start at 192, 714. And this is actually outside of the repair response criteria before it introduces them in section D, right. It says that an operator, of this section must, you know, either remove by cutting out the pipeline material so it gives you one option or the second option, it says repaired by a method shown by technically proven engineering test and analysis that will permanently restore the pipeline.
Okay, right. My first reaction to that actually circled permanently restore. And then I went to Google and looked up the definition of permanent, which is lasting indefinitely. And I thought pipelines themselves don’t last indefinitely. So, the use of that word do pipeline,
Let me ask you, what are your thoughts on the use of the word permanent repair? Right. You have any reaction to thoughts to it.
Brian Jimenez
Yeah, I think first off, yeah. Permanent repair I mean, I think each operator is going to have to define what that means for themselves because FEMSA obviously doesn’t define that.
You know, they don’t go into the specific repair methods that that are a permanent repair. They don’t say composites are permanent repair. They don’t say compression sleeves are permanent repair. I don’t even say type B sleeves are some repairs. So, each operator is going to have to decide through their industry peers, you know, through PRCI repair manuals and other reports on what is a permanent repair.
Yeah. You know, per defect, your permanent repair over a metal loss feature in a pipe body up a permanent repair of a crack, or a preferential seam corrosion. Right. So, they’re going to have to decide what best fits that defect and what they can define as permanent.
Rhett Dotson
It’s going to be possible that a repair for one defect may be permanent for another defect may not.
Brian Jimenez
Exactly. Or you can’t apply that at all. It’s, it’s metal loss or it’s at a band. You can’t do this and that. You really got to rely back on your own, procedures rely back on the industry.
What’s been out there, other multiple reports and just even the composite types themselves, whether it’s from specific vendors, because of the manufacturers, you must decide and make sure you have that engineering testing that says this repair method is permanent for that defect.
Christopher de Leon
You know, the word that comes to my mind is, interpretation.
I feel like, you know, if we look back at IMP 1.0 and now, we, we’re dubbing this, right, we’re calling it IMP 2.0 or to move away from new gas or new mega or whatever. I feel like a big effort that we undertook in the first phase of integrity management in the late 2000 and early 2000, was interpretation, right?
And I feel like we’re in that situation again now. It’s you have language that’s written and there’s a lot of words. And we must begin to understand as an industry, what do we think it means? And then like you just brought up as an operator. So maybe one thing I’ll offer as just information is, I and we won’t speak too much about it, but I think Enga did submit a, a petition it to some parts of, of this regulation.
And I think a lot of it has to do with interpretation. So, I think, you know, one of the things we got from I guess I imp 1.0 was FAQ’s. I don’t think FAQ’s have come out for this.
Brian Jimenez
No they haven’t. You know FEMSA did put out a letter towards the end of last year, end of 2022 about having a, a, a compliance or a discretionary period of time that they’re not going to enforce the regulation to give us giving operators nine months.
But in those nine months, they said that they would be helping operators determine and interpret their code. And I was I would assume that means some FAQ’s interpretation is key. Obviously, we talked about that from subpart O from the beginning. And I’m sure beyond our time, interpretation has always been key with these regulations. And it’s not just what the industry, what an operator, but also with that individual inspector.
I mean, I don’t know how many audits you guys have been in, but an individual inspector read something or interpret something, or from an FAQ or from the regulation, and they have a different perspective than what everyone else.
Rhett Dotson
Since you all live through IMP 1.0, do you feel interpretation is less than, greater than, or approximately the same as what it was? Probably IMP 1.0?
Brian Jimenez
that’s a hard one. I mean, it’s not less.
Christopher de Leon
That’s lot I’ll give you my soapbox.
And this is lessons learned to our listeners here in our watchers. It’s again late 2000s. We’re in an inspection and we get we get dinged or there’s a finding that we don’t consider tool tolerances when we establish response criteria. And I was Integrity Engineer. We’re working on a team. And I say there’s no winning code that tells you have to add tool tolerance to every call to be more conservative.
This isn’t a data integration process, right? We have conservatism, okay? And we got to the point to where at the end of the day, we I will say this, we lost the argument because they said that there was an f a Q that provided the interpretation that that was the expectation. And our rebuttal was FAQ’s aren’t code.
And that wasn’t enough. We were still challenged and forced to change the procedures at the time. So back to this whole realm of what do I do? I think it’s important for you as an operator and even as a consultant, as part of an industry stakeholder, to really understand the dynamics of the importance of interpretation and enforcement.
Brian Jimenez
Understand the dynamics of it, for sure, but also have the robust procedures and plans in place that you can define, that you define and defend exactly define it.
Defending is better than having nothing on it at all, because then you’re defending something of an opinion or of, you know, just, oh, this is what we always assume.
Christopher de Leon
And that’s valid, right? Because at the time our procedure wasn’t, I guess so pointed towards something as an FAQ. Right? We didn’t an address at the time six right is addressed in our procedure this way.
Brian Jimenez
And so going back to the primary repair in your own manual for your repairs, here are the repairs that are for defects. They’re approved that are permanent per defect that that has to be done. I mean if you don’t have that now in your in your own manual, your SOPs, whatever you call it, you should get on that because that’s, that’s key for, for any not just for the inspections.
It’s not just getting through inspections. Right. It’s about actually applying it and getting to the people in the field, getting to the to your engineers, your project managers, they know repeatability. They know what options they have to make those repairs. So it goes beyond just inspection. I know we talk a lot about inspection, but it does. It is actually about improving the integrity of that pipeline.
Rhett Dotson
It’s I mean it’s always I never know how much question I ask is going to go. I was like, that’ll be a quick answer, man.
So you guys mentioned interpretation. And I think the language that we’re going to hone in on. So this next one is point four and again appears in both of them. And it’s obviously targeting selective seam corrosion. So they refine the regs to go after that. But they did it in such a way that again I think opens up a lot of questions that I would have for you.
So metal loss preferentially affecting so preferentially affecting is one a detected long seam two. Yep. If that long seam was formed by and gives a whole bunch of susceptible welds direct current low frequency or high frequency URW, UFW and joints with the long seam factor less than one. So again it gets all of that joint factor groups are susceptible welds right.
It says in the predicted failure pressure determined in accordance with one 9712 D. So for our audience 712 D is the new crack calculations from REN one is less than 1.25 times MLP. So let me sum it up for the audience because I just read code that makes it hard. If you find a feature that is preferentially affecting a detected long seam that has metal loss, and you run crack calculations that show it’s less than 1.25 times MAOP, you have to respond to that immediate right.
That opens up a whole host of questions for me. Yeah. And I’m curious to get your reaction. So let’s start with preferential and detected long seam what advice or just initial thoughts.
Christopher de Leon
What’s your reaction.
Brian Jimenez
Initial what’s your reaction initial thoughts is how do we get there? How do we identify and detect preferential metal loss in the scene in specific seams?
Right. You know, that goes back to, again, your definitions, your, your terms and your comfortability with your ILI vendors. You have to challenge them. Sorry, but you have to challenge their abilities to detect it, not just from the ILI perspective.
So you get to find out what’s the right tool to run, and then you have to be able to challenge their ability to properly identify it from a data analyst side, is it preferential or is it just metal loss across crossing the scene? That’s been a huge issue I think across the industry. Yeah, it’s we’re trying to attack seam corrosion here.
That’s what that means not just general corrosion or corrosion that may be touching your cross seam.
Rhett Dotson
So what happens if you end up in an audit. Right. And a guy’s like, hey, here’s an MFL, call out that it says interacts with a long serial.
Number one, you got an MFL, tool. Which is not the appropriate tool for detecting a long seam. So is that preferential.
Christopher de Leon
So I want to share maybe my initial reaction to this is it’s. I kind of applaud FEMSA for what they tried to do here.
But on this one, I actually think FEMSA did a good job of trying to communicate the intent. And that’s this in IMP 1.0 they used they incorporated by reference. We talked about this assignee B 30 18S. And it uses words like any. Which make things really complicated. It’s a poor use of resources. So any metal loss affecting a long say it was an immediate in 318s.
Rhett Dotson
We’re going to pause on that and leave a cliffhanger. So we need to come back for a break in just a moment I’m going to turn it over to Miss producer where you hear from one of our close associates. And we’ll be right back with you in a moment. Thanks.
Kara Turner
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 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 Dotson
All right. Welcome back from the break. We’re in the middle of breaking down, REM two with our guest, Brian Jimenez from Energy Transfer. And so we were in the middle of talking about repair response criteria. And I opened up, 192 714 D4. And we were talking about that particular section of code that targets seem corrosion.
And right before the break, Brian so cleverly went where I was going to go next, which is he mentioned the fact of we have in the beginning of that phrase metal loss anomalies. Paired with that section calling on 712 D, which is the crack evaluation. So there’s an obvious I’m going to say what the hell moment there, what do you do?
Or how do you handle metal loss anomalies combined with fracture mechanics rate calculations.
Brian Jimenez
I guess I understand why they did it because they don’t want us to use our standard metal loss calculations for main strength for something that is preferential to the seam in the bond line that reacts differently. We can go on and on about the metallurgy of it, right?
So we understand that they probably want to be something more conservative, maybe not even a sub 31 G is not conservative enough. So they want us to use fracture mechanics, treat it like a crack, treat it. I assume it’s a crack. Yeah. So I get that. So number one is our operators ready to do that. Operators ready to run fracture mechanics models.
Do they have the training. Do they have the people they can talk to which model to run? I know y’all talked about that previously. What’s the right model to run? On pipe body and we get to pipe body cracks a little bit. But in the scene what toughness values you have or assume the values you have from 712, which are obviously very terrible, very, very useful.
Rhett Dotson
You have to have data. So what Brian, again, is referring to is that in order to run these crack calculations, you have to understand the nature of the model you’re using. Those models require an SME to review them. So I mean we can even ask now do you have to have these review your metal loss calculations?
Christopher de Leon
Well they will in this case in 712 you get some 12 you.
Because what they’re doing right is it’s you’re not in 712. Yeah. And they pushed your metal losses crack like so they push you to say they called it by reference. And now in 712 it clearly says you have to have this reviewed by an SME.
Brian Jimenez
You have to have a review by an SME.
You have to have the data parameters, the values as you mentioned, to run it. And some models need can some models need fracture toughness and those have to be TVC or and you’ve used the default values right. And then in some cases you know operators will probably have CV ends already from pipelines from specific pipe types that they want to use.
But they have to decide, do I have enough of those samples? What kind of safety factor do I have to use? Because I pulled one sample of out of 50 miles. Well, that’s probably not TVC, right? So you have to define what is TVC. How many samples do I have to get to a significant sample size when I can, when I can use that value.
And for CVS am I using upper bound. Lower bound. You know, in the temperature range, there’s all kinds of parameters that once again goes back to writing your procedure. Put in your plan. This is what we’re doing. This is how we interpret it. This is how we’re going forward with it. That’s key is to get it all written down, go through it, have it continue to evolve.
You might want to say a one point, hey, I’m going to run mat eight everywhere. And then after a while maybe 579 is the right. So every operator has to make that decision as they go through it and continue to see the results.
Christopher de Leon
I want to throw a little bit of a curveball actually this.
But what I, what I wanted to think about was it’s, you know, training and qualification is something that I really, as a, as a consultant, it’s really something that has been a big, like, an eye opener for me, right? Is it’s, you know, one of our last podcast was about SMEs and defining them and the requirement of you have to define what tasks by names and what their qualifications are.
So kind of in that vein, again, I’m curious about your reaction to this is change your treating. You are now basically integrating fracture mechanics into your normal operations and integrity management, where prior to IMP 2.0 you weren’t doing it. It’s maybe fair to say that wasn’t common and it’s going to become common. It’s going to become common.
What is your reaction as an operator? See, as a consultant we have to be up tip top on this stuff. Sure. Right. And that’s what we get hired for. We’re supposed to help. When you call, but as an operator, not necessarily energy transfer, but in general as an operator in the community. Yeah. What’s your reaction to this idea of qualifications training, the need to close the gap.
Of we have this requirement and now crack management needs to become a standard practice. Yeah.
Brian Jimenez
For even metal. Let’s call this right I think it’s about getting your employees, your engineers, the exposure, the experience get getting them sent to training, courses, working with third party SMEs, experts, understanding who those experts are, what models they like to run.
That’s one thing. Right? But understanding that that’s something that individual operator is comfortable with and then eventually get their own employees comfortable to do them themselves, they don’t have to go and farm out every, every calculation. That’s going to be key.
Rhett Dotson
Yeah. Because I don’t think you want to format every metal loss run that they’re going to do on a pipe or long sleeve.
That’s a that’s a lot.
Brian Jimenez
That’s a lot. And so eventually you’re going to want your engineers to be able to run those calculations themselves. So you need that training in the qualification. So yeah that’s as an important thing. Once again outlining your procedures outline here. So piece in your in your in piece to make sure you have that in there and the documentation to back it up.
That was a great conversation It’s been fun. To our audience, thank you for joining us again. We’re going to continue. We got some more discussions on the updated gas rule. And again, thank you guys for listening to the Pipeline Things podcast. Will be back with you guys again in two weeks. I am your host thing and my co-host Christopher Daly on.
We’ll see you guys next time.
All right. On today’s edition of Pipeline Things, we try to tell one of our close friends and, and clients in the industry that he most resembles spawn. I’m not sure how he’s going to take that. If you’re not familiar with who spawn is, need to read the comment. I picked that man. More important than that, we tackle some critical things.
Of Ren two of the updated gas rule. So, if you’ve ever had questions around the words permanently restore using crack calculations on metal locks, calls, or maybe even about the new crack response criteria and want to hear, some takes and reactions to it and maybe some guidance advice for operators. This is a great episode. As we work with mister Brian Jimenez, and we think you’ll enjoy it.
Thank you very much.
All right. Hello. Welcome to today’s edition of Pipeline Things. I am your host, Rhett Dotson, and my co-host, Mr. Christopher de Leon. And I have to be honest with you, Chris, every time we do the high five, it is an intense moment of focus to make sure I don’t miss your hand because some of us call you out on us.
I’ve been called out multiple times for missing that. But it’s super exciting, man, to get this third episode, as we get, 2023 underway. If people are watching on the, the YouTube channel, you can see that we are in a restaurant surrounded by Christmas decorations. So, we’re still within the realm of the holiday season.
This is actually our first shoot coming back from the new year. So, shaking the rust off, I mean, how was your break?
Christopher de Leon
So super excited. We got to, to head down south of the border to Mexico and visit some family at the scene. And, super nice and, just lessons learned, you know, you and your traveling, you know, you had some tire issues.
I said, you know, what? It’s probably a good idea for me to do with the tires checked.
So, I go pick up the lug nuts. I go to Discount Tire.
Rhett Dotson
So, if you are only listening, Chris is now picking up a box to show us on screen
Christopher de Leon
And I handed the box over to them. I didn’t open it because I knew what it was. And so, one box had lug nuts, the other box didn’t, and they gave me this box back after the game, my tires, and they said, hey mister, do loan forgiveness, but we can’t put perishable items on your tires.
Rhett Dotson
So, wait, you gave them a box that wasn’t full of lug nuts?
Christopher de Leon
Yes. So and it turns out that our friend, the dirt merchant over at Geosyntec’s sent us chocolate. So that one was for me. One was for you. So here is your box of chocolates from Patrick Johnson.
Rhett Dotson
And if you’re listening, Thank you Alex.
Thank you, dirt merchant that you cannot indeed, attach tires to your car with chocolates.
Christopher de Leon
Yeah. So, the chocolates, I guess the techs are in a good mood, but Amanda loved them. I’m sure Morgan will as well.
Rhett Dotson
Fantastic. So, you know, it’s kind of funny you mentioned tires because I got my own tire thing going on right now, and it will tie very well into today’s episode.
So, I have had a screw in my tire for almost like a month, but I need to take the Discount Tire, must pull it out, and I keep thinking, how long can I drive around with the screw? And it’s wearing down
Christopher de Leon
and you wonder why stuff happens.
Rhett Dotson
Shut up. But I’m like, I think it’s just barely in there, but I’m not confident enough to pull it out myself.
I don’t know why. So, it kind of brings this condition, like, you know, when do you need to repair a tire?
Christopher de Leon
And I would say it’s risk management. Right? I mean that’s exactly all it is. Right. At what point do you decide it’s time to repair.
What is that response. You discovered it. You discovered it. You performed an evaluation; you’ve accepted a certain level of risk.
Rhett Dotson
So, if you all haven’t figured it out today on the show that actually we’re going to talk about we’ve been on this, this kick talk to you about the updated gas rule.
And today we are going to be talking about the updated gas rule, specifically the repair response criteria and the updated sections for 714 and 933. And you can see there’s an empty chair here in between us, because we have a special guest that we’re bringing on today. And it is time for that guest to make his way down.
I’d like to introduce Mr. Brian Jimenez, who is the director of Pipeline Integrity for Energy Transfer East. So, as he comes on. Welcome to the show.
Brian Jimenez
Thanks for having me. Awesome. You know, long time listener and excited.
Rhett Dotson
I don’t want to ask any questions because we might find out he’s not.
Brian Jimenez
I mean I might have binged them all in the last couple days. No, I’m kidding, I’m kidding. I have been listening for a while.
Christopher de Leon
Well, so in spirit of the holiday season and, we just like to give gifts. Okay, one of the most recent ones that we had was, was a Q&A session, and, and in spirit of the Q&A session and some of my personal tendencies, we brought I brought you something.
We brought just on the rent doesn’t really address box or something for both of us. So here you go. Go ahead and open it up. Let us know what you think.
Brian Jimenez
This is kind of scary. I have a feeling Rhett might like this better.
Christopher de Leon
So, one of the questions was, who would you be?
Batman and Robin. And obviously I said, you know, Batman’s one of my my favorite characters.
Rhett Dotson
So, for those who are listening, we gave we, he’s, you know, he’s totally. Chris gave Brian, a Batman versus spawn exclusive edition comic.
Christopher de Leon
So, I will not spoil this, because this is called the one shot. So, it’s not a series. Okay, so Trevor McFarlane did this with Frank Miller because I like the Dark Knight version of Batman.
Right. I think it was 93 or 94, and it was just 1 book. Okay. And so, they decided to do it again this year. And, Barnes and Nobles had a limited release. So, I don’t know, it’s just cool.
Rhett Dotson
Give it a read.
Bran Jimenez
It’s. Yeah, it’ll be fun. And share it. My son. Yeah. He’ll love it. I’m sure. So awesome. Well thank you anyways.
Rhett Dotson
So, you already know we’ve already prepared you that we’re going to be talking about, then, the new versions of the updated gas rule. And I do feel it’s worthwhile, you know, again, to let the audience know that we’re going to be talking primarily about not 192 714 and 192 933 those two sections were updated.
We’re not going to differentiate between them because, as we already mentioned, the language is identical between the two, largely when we talk about repair response materials, what are we. Let’s do it. So, 714 D and 933 D are essentially the same sections. The only division being one- and two-year conditions between non HCA locations and HCA locations.
But that’s not where I want to spend the bulk of the time on the show.
Christopher de Leon
And again, we’re talking about gas regulations. CFR 192.
Rhett Dotson
Absolutely. I also think it’s important in the interest of protecting Brian, that Brian is not speaking on behalf of energy transfer at all. So, if you were listening to this show, massive disclaimer, maybe miss Producer will put like a red traveling thing underneath.
You know, Brian speaks on behalf of his own authority. Our objective today is there are a lot of operators out there who have only maybe lightly read over this, maybe who haven’t read over it, some of it. All right. We’re asking Brian, on behalf of one of the major gas operators in the United States to offer some advice.
Christopher de Leon
and it’s not I want to jump in there a little bit.
I’ll say it a different way. You know, we reach out to our guests. because of their experience or their strong opinions. As a person in certain topics. And, and Brian holds a dear place in my heart. So, when I was an intern at the University of Houston back in the days Southern Union, Panhandle Energy, Brian was, an integrity engineer, and I learned a whole lot from him.
And then that 2007 to 2009 timeframe, you know, we were neck deep in what we’ll call IMP 1.0. Right. So, you know, we went through this cycle of their code, we’re trying to interpret it. How do you act on it. And now we have this amp we call it IMP 2.0. And so, you’ve been living this for a long time I just felt like this would be a good opportunity for you to just kind of share some of your personal experiences.
Rhett Dotson
Insight, like what would you tell somebody who maybe doesn’t have the resources of a major gas operator and hasn’t looked at it?
But again, speaking on behalf of yourself, not energy transfer. Sorry.
Brian Jimenez
And anybody that knows me knows I don’t have very strong opinions on anything. Actually, people know that I do have very strong opinions on things like this.
Rhett Dotson
All right, so, the first thing I noticed as I read through it is that I’m going to start at 192, 714. And this is actually outside of the repair response criteria before it introduces them in section D, right. It says that an operator, of this section must, you know, either remove by cutting out the pipeline material so it gives you one option or the second option, it says repaired by a method shown by technically proven engineering test and analysis that will permanently restore the pipeline.
Okay, right. My first reaction to that actually circled permanently restore. And then I went to Google and looked up the definition of permanent, which is lasting indefinitely. And I thought pipelines themselves don’t last indefinitely. So, the use of that word do pipeline,
Let me ask you, what are your thoughts on the use of the word permanent repair? Right. You have any reaction to thoughts to it.
Brian Jimenez
Yeah, I think first off, yeah. Permanent repair I mean, I think each operator is going to have to define what that means for themselves because FEMSA obviously doesn’t define that.
You know, they don’t go into the specific repair methods that that are a permanent repair. They don’t say composites are permanent repair. They don’t say compression sleeves are permanent repair. I don’t even say type B sleeves are some repairs. So, each operator is going to have to decide through their industry peers, you know, through PRCI repair manuals and other reports on what is a permanent repair.
Yeah. You know, per defect, your permanent repair over a metal loss feature in a pipe body up a permanent repair of a crack, or a preferential seam corrosion. Right. So, they’re going to have to decide what best fits that defect and what they can define as permanent.
Rhett Dotson
It’s going to be possible that a repair for one defect may be permanent for another defect may not.
Brian Jimenez
Exactly. Or you can’t apply that at all. It’s, it’s metal loss or it’s at a band. You can’t do this and that. You really got to rely back on your own, procedures rely back on the industry.
What’s been out there, other multiple reports and just even the composite types themselves, whether it’s from specific vendors, because of the manufacturers, you must decide and make sure you have that engineering testing that says this repair method is permanent for that defect.
Christopher de Leon
You know, the word that comes to my mind is, interpretation.
I feel like, you know, if we look back at IMP 1.0 and now, we, we’re dubbing this, right, we’re calling it IMP 2.0 or to move away from new gas or new mega or whatever. I feel like a big effort that we undertook in the first phase of integrity management in the late 2000 and early 2000, was interpretation, right?
And I feel like we’re in that situation again now. It’s you have language that’s written and there’s a lot of words. And we must begin to understand as an industry, what do we think it means? And then like you just brought up as an operator. So maybe one thing I’ll offer as just information is, I and we won’t speak too much about it, but I think Enga did submit a, a petition it to some parts of, of this regulation.
And I think a lot of it has to do with interpretation. So, I think, you know, one of the things we got from I guess I imp 1.0 was FAQ’s. I don’t think FAQ’s have come out for this.
Brian Jimenez
No they haven’t. You know FEMSA did put out a letter towards the end of last year, end of 2022 about having a, a, a compliance or a discretionary period of time that they’re not going to enforce the regulation to give us giving operators nine months.
But in those nine months, they said that they would be helping operators determine and interpret their code. And I was I would assume that means some FAQ’s interpretation is key. Obviously, we talked about that from subpart O from the beginning. And I’m sure beyond our time, interpretation has always been key with these regulations. And it’s not just what the industry, what an operator, but also with that individual inspector.
I mean, I don’t know how many audits you guys have been in, but an individual inspector read something or interpret something, or from an FAQ or from the regulation, and they have a different perspective than what everyone else.
Rhett Dotson
Since you all live through IMP 1.0, do you feel interpretation is less than, greater than, or approximately the same as what it was? Probably IMP 1.0?
Brian Jimenez
that’s a hard one. I mean, it’s not less.
Christopher de Leon
That’s lot I’ll give you my soapbox.
And this is lessons learned to our listeners here in our watchers. It’s again late 2000s. We’re in an inspection and we get we get dinged or there’s a finding that we don’t consider tool tolerances when we establish response criteria. And I was Integrity Engineer. We’re working on a team. And I say there’s no winning code that tells you have to add tool tolerance to every call to be more conservative.
This isn’t a data integration process, right? We have conservatism, okay? And we got to the point to where at the end of the day, we I will say this, we lost the argument because they said that there was an f a Q that provided the interpretation that that was the expectation. And our rebuttal was FAQ’s aren’t code.
And that wasn’t enough. We were still challenged and forced to change the procedures at the time. So back to this whole realm of what do I do? I think it’s important for you as an operator and even as a consultant, as part of an industry stakeholder, to really understand the dynamics of the importance of interpretation and enforcement.
Brian Jimenez
Understand the dynamics of it, for sure, but also have the robust procedures and plans in place that you can define, that you define and defend exactly define it.
Defending is better than having nothing on it at all, because then you’re defending something of an opinion or of, you know, just, oh, this is what we always assume.
Christopher de Leon
And that’s valid, right? Because at the time our procedure wasn’t, I guess so pointed towards something as an FAQ. Right? We didn’t an address at the time six right is addressed in our procedure this way.
Brian Jimenez
And so going back to the primary repair in your own manual for your repairs, here are the repairs that are for defects. They’re approved that are permanent per defect that that has to be done. I mean if you don’t have that now in your in your own manual, your SOPs, whatever you call it, you should get on that because that’s, that’s key for, for any not just for the inspections.
It’s not just getting through inspections. Right. It’s about actually applying it and getting to the people in the field, getting to the to your engineers, your project managers, they know repeatability. They know what options they have to make those repairs. So it goes beyond just inspection. I know we talk a lot about inspection, but it does. It is actually about improving the integrity of that pipeline.
Rhett Dotson
It’s I mean it’s always I never know how much question I ask is going to go. I was like, that’ll be a quick answer, man.
So you guys mentioned interpretation. And I think the language that we’re going to hone in on. So this next one is point four and again appears in both of them. And it’s obviously targeting selective seam corrosion. So they refine the regs to go after that. But they did it in such a way that again I think opens up a lot of questions that I would have for you.
So metal loss preferentially affecting so preferentially affecting is one a detected long seam two. Yep. If that long seam was formed by and gives a whole bunch of susceptible welds direct current low frequency or high frequency URW, UFW and joints with the long seam factor less than one. So again it gets all of that joint factor groups are susceptible welds right.
It says in the predicted failure pressure determined in accordance with one 9712 D. So for our audience 712 D is the new crack calculations from REN one is less than 1.25 times MLP. So let me sum it up for the audience because I just read code that makes it hard. If you find a feature that is preferentially affecting a detected long seam that has metal loss, and you run crack calculations that show it’s less than 1.25 times MAOP, you have to respond to that immediate right.
That opens up a whole host of questions for me. Yeah. And I’m curious to get your reaction. So let’s start with preferential and detected long seam what advice or just initial thoughts.
Christopher de Leon
What’s your reaction.
Brian Jimenez
Initial what’s your reaction initial thoughts is how do we get there? How do we identify and detect preferential metal loss in the scene in specific seams?
Right. You know, that goes back to, again, your definitions, your, your terms and your comfortability with your ILI vendors. You have to challenge them. Sorry, but you have to challenge their abilities to detect it, not just from the ILI perspective.
So you get to find out what’s the right tool to run, and then you have to be able to challenge their ability to properly identify it from a data analyst side, is it preferential or is it just metal loss across crossing the scene? That’s been a huge issue I think across the industry. Yeah, it’s we’re trying to attack seam corrosion here.
That’s what that means not just general corrosion or corrosion that may be touching your cross seam.
Rhett Dotson
So what happens if you end up in an audit. Right. And a guy’s like, hey, here’s an MFL, call out that it says interacts with a long serial.
Number one, you got an MFL, tool. Which is not the appropriate tool for detecting a long seam. So is that preferential.
Christopher de Leon
So I want to share maybe my initial reaction to this is it’s. I kind of applaud FEMSA for what they tried to do here.
But on this one, I actually think FEMSA did a good job of trying to communicate the intent. And that’s this in IMP 1.0 they used they incorporated by reference. We talked about this assignee B 30 18S. And it uses words like any. Which make things really complicated. It’s a poor use of resources. So any metal loss affecting a long say it was an immediate in 318s.
Rhett Dotson
We’re going to pause on that and leave a cliffhanger. So we need to come back for a break in just a moment I’m going to turn it over to Miss producer where you hear from one of our close associates. And we’ll be right back with you in a moment. Thanks.
Kara Turner
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Rhett Dotson
All right. Welcome back from the break. We’re in the middle of breaking down, REM two with our guest, Brian Jimenez from Energy Transfer. And so we were in the middle of talking about repair response criteria. And I opened up, 192 714 D4. And we were talking about that particular section of code that targets seem corrosion.
And right before the break, Brian so cleverly went where I was going to go next, which is he mentioned the fact of we have in the beginning of that phrase metal loss anomalies. Paired with that section calling on 712 D, which is the crack evaluation. So there’s an obvious I’m going to say what the hell moment there, what do you do?
Or how do you handle metal loss anomalies combined with fracture mechanics rate calculations.
Brian Jimenez
I guess I understand why they did it because they don’t want us to use our standard metal loss calculations for main strength for something that is preferential to the seam in the bond line that reacts differently. We can go on and on about the metallurgy of it, right?
So we understand that they probably want to be something more conservative, maybe not even a sub 31 G is not conservative enough. So they want us to use fracture mechanics, treat it like a crack, treat it. I assume it’s a crack. Yeah. So I get that. So number one is our operators ready to do that. Operators ready to run fracture mechanics models.
Do they have the training. Do they have the people they can talk to which model to run? I know y’all talked about that previously. What’s the right model to run? On pipe body and we get to pipe body cracks a little bit. But in the scene what toughness values you have or assume the values you have from 712, which are obviously very terrible, very, very useful.
Rhett Dotson
You have to have data. So what Brian, again, is referring to is that in order to run these crack calculations, you have to understand the nature of the model you’re using. Those models require an SME to review them. So I mean we can even ask now do you have to have these review your metal loss calculations?
Christopher de Leon
Well they will in this case in 712 you get some 12 you.
Because what they’re doing right is it’s you’re not in 712. Yeah. And they pushed your metal losses crack like so they push you to say they called it by reference. And now in 712 it clearly says you have to have this reviewed by an SME.
Brian Jimenez
You have to have a review by an SME.
You have to have the data parameters, the values as you mentioned, to run it. And some models need can some models need fracture toughness and those have to be TVC or and you’ve used the default values right. And then in some cases you know operators will probably have CV ends already from pipelines from specific pipe types that they want to use.
But they have to decide, do I have enough of those samples? What kind of safety factor do I have to use? Because I pulled one sample of out of 50 miles. Well, that’s probably not TVC, right? So you have to define what is TVC. How many samples do I have to get to a significant sample size when I can, when I can use that value.
And for CVS am I using upper bound. Lower bound. You know, in the temperature range, there’s all kinds of parameters that once again goes back to writing your procedure. Put in your plan. This is what we’re doing. This is how we interpret it. This is how we’re going forward with it. That’s key is to get it all written down, go through it, have it continue to evolve.
You might want to say a one point, hey, I’m going to run mat eight everywhere. And then after a while maybe 579 is the right. So every operator has to make that decision as they go through it and continue to see the results.
Christopher de Leon
I want to throw a little bit of a curveball actually this.
But what I, what I wanted to think about was it’s, you know, training and qualification is something that I really, as a, as a consultant, it’s really something that has been a big, like, an eye opener for me, right? Is it’s, you know, one of our last podcast was about SMEs and defining them and the requirement of you have to define what tasks by names and what their qualifications are.
So kind of in that vein, again, I’m curious about your reaction to this is change your treating. You are now basically integrating fracture mechanics into your normal operations and integrity management, where prior to IMP 2.0 you weren’t doing it. It’s maybe fair to say that wasn’t common and it’s going to become common. It’s going to become common.
What is your reaction as an operator? See, as a consultant we have to be up tip top on this stuff. Sure. Right. And that’s what we get hired for. We’re supposed to help. When you call, but as an operator, not necessarily energy transfer, but in general as an operator in the community. Yeah. What’s your reaction to this idea of qualifications training, the need to close the gap.
Of we have this requirement and now crack management needs to become a standard practice. Yeah.
Brian Jimenez
For even metal. Let’s call this right I think it’s about getting your employees, your engineers, the exposure, the experience get getting them sent to training, courses, working with third party SMEs, experts, understanding who those experts are, what models they like to run.
That’s one thing. Right? But understanding that that’s something that individual operator is comfortable with and then eventually get their own employees comfortable to do them themselves, they don’t have to go and farm out every, every calculation. That’s going to be key.
Rhett Dotson
Yeah. Because I don’t think you want to format every metal loss run that they’re going to do on a pipe or long sleeve.
That’s a that’s a lot.
Brian Jimenez
That’s a lot. And so eventually you’re going to want your engineers to be able to run those calculations themselves. So you need that training in the qualification. So yeah that’s as an important thing. Once again outlining your procedures outline here. So piece in your in your in piece to make sure you have that in there and the documentation to back it up.
That was a great conversation It’s been fun. To our audience, thank you for joining us again. We’re going to continue. We got some more discussions on the updated gas rule. And again, thank you guys for listening to the Pipeline Things podcast. Will be back with you guys again in two weeks. I am your host thing and my co-host Christopher Daly on.
We’ll see you guys next time.