Regulators have become more aggressive in using API RP 1130 to hold operators accountable for maintaining their leak detection systems. In the USA, they are using the teeth in the code of regulations, 49CFR, Part 195.444, to hold operators accountable for maintaining not only the leak detection systems but also the components that support leak detection systems. The rule states the CPM systems must meet API RP 1130.
API RP1130 is a recommended practice first written by an API committee many years ago and updated several times since. Although it started life as a series of recommendations, 1130 has been incorporated by reference into the Code of Federal Regulations (49 CFR) 195.3. Section 195.444 states that computational monitoring systems must comply with API RP 1130.
Option A
Regulators can enforce any part of API RP 1130, but sections some regulators are paying particular attention to include the following:
- 5.1 – Field Instrumentation and Measurement
- 5.1.1 – Selection of Instrumentation and Measurement
- 5.2 – Communications
- 5.2.1 – Communications Medium and Error Detection
- 5.3 - SCADA
- 5.3.4 – Status processing
- 6.1.2 – CPM System credibility and review
- 6.2.1 – Testing Methods
- 6.2.2 – Initial Tests during CPM comissioning
- 6.2.3 – Periodic retesting
- 6.2.4 – Change Driven Testing
- 6.2.5 – CPM systems self testing
- 6.3.2 – Parameter changes
- 6.3.3 – Pipeline system maintenance activities.
Option B
Regulators can enforce any part of API RP 1130, but Atmos has observed a particular focus on the following sections and more precisely certain subsections:
- 5.1 – Field Instrumentation and Measurement
The selection of instrumentation and measurement and calibration and maintenance programs for this equipment - 5.2 – Communications
Communications medium and error detection - 5.3 - SCADA
It will not be long before the regulators turn to API 1175 to exact more accountability in the maintenance of leak detection systems. Are you ready?
Pipeline operators are committed to a goal of zero spills. While these operators are making significant progress to this objective, there is still always the risk of a spill. No matter how safely and efficiently a company operates their pipelines there is always the risk of a complete outsider causing an accident; third-party strikes are a typical example. Should a release occur, a strong leak detection program, using effective leak detections systems and a fast response is the best way to minimize the consequence of the spill. When the regulator calls, this same program is again your best defense.
Ideally, pipeline operators should detect a drop of oil and locate it to within meters without any false leak alarms. Currently, no technology can meet these requirements. Some performance limitations are caused by lack of instrumentation, operating conditions, or insufficient support of the leak detection systems. However, as API RP 1175 tells us, there is always scope for improvement in every leak detection system deployed.
API 1175 urges pipeline owners to set ambitious goals for the maintenance of their pipeline leak detection systems. This recommended practice was written to satisfy current pipeline regulations, and encourage pipeline operators to 'go beyond' and promote the advancement and stronger utilization of leak detection programs in hazardous liquid pipelines. It is a useful document that should increase operator confidence in leak detection systems by improving leak detection performance, and raise awareness of leak detection as a companywide obligation. Here are a few high-level suggestions for pipeline operators wondering where to begin a revamp of their leak detection program in line with API 1175:
Set key objective
- Increased operator confidence
- Meeting regulatory requirements for pipeline leak detection
- Improved reliability of leak detection systems and supporting components
- Better trained control room and field staff
- Reduction in operating risk
Key benefits
- Leak detection performance benchmarking
- Reduced degradation and unavailability of the LDS
- Improved pipeline operations and measurements
- Better understanding of the issues affecting the LDS
1. Demonstrating Continuous Improvement
Maintain the Supporting Components
Good leak detection requires robust and reliable supporting components and good operating practices. The instrumentation, equipment, and communication that support the LDS should also be well maintained. Schedule, document and track maintenance activities.
Building automated maintenance and KPI tracking tools into your leak detection systems will help you provide the documentation needed to satisfy the regulators.
Look for opportunities where changing how a pipeline is operated will improve the performance of a leak detection system. For example, increasing the operating pressure in a pipeline to eliminate vapor pockets normally allows more sensitive leak detection. Shutting in a pipeline under pressure rather than letting that pipeline drain down can enable very sensitive leak detection when the pipeline is not flowing. Elimination of drain down also allows sensitive leak detection to commence as soon as the pipeline starts pumping again.
2. Training
A good training program will reduce the consequences of a pipeline leak or rupture. Define roles and responsibilities and establish the extent and the intervals for training. The same applies for refresher training and retraining (if an employee had a prolonged absence from a position). Document the training, this is a requirement in many countries already. Consider acquiring a high-fidelity training simulator that mimics one or more of your pipelines to facilitate controller training. The Trainer system should have a controller qualification module that documents the training and testing records of each controller.
3. Test your leak detection systems
Best engineering practices recommend that pipeline leak detection systems are tested regularly. While a real product withdrawal test is preferable, this is not always practical for safety or cost reasons. When a product withdrawal is not possible, a leak detection system can be tested with historical leak or controlled product withdrawal data, simulated data, or by altering the flow or pressure readings in the SCADA or PLC to simulate a leak.
API 1175 states that leak detection systems should be tested when implemented and on a regular basis. This period should not exceed a period of 5 years. Testing should also be prompted when there has been a significant change in the pipeline operation or a physical change in the pipeline configuration. The testing process should include the requirements of LDS testing as outlined in API RP 1130. The requirements of API RP 1130 should be tailored to accommodate the unique aspects of the leak detection system and the specific assets on which the leak detection system is implemented.
The test plan should document the purpose of the test, the methods that will be employed, and the procedures that will be followed. LDS tests should be rigorous, well planned, and executed using sound engineering and technical judgment.
4. Find small changes that pay off in big gains
Identify opportunities where most improvement can be made with least effort. It may be training, adding a pressure sensor or a valve, or changing an operation on a pipeline. Set goals and document the improvements, continue to improve and monitor the progress. A good LDS vendor will provide the automated tools to track Key Performance Indicators (KPIs) for the LDS and track the reliability of the components that support the LDS; e.g. which sensors are failing, and how often.
With the technological advancement of recent years, it may be more cost effective to replace a legacy LDS with a modern system. Alternatively, complimentary leak detection methods may be the best option to ensure redundancy as well as optimized leak detection performance.
Conclusion
Since pipeline leak detection systems are engineering solutions, their performance depends on many factors. Improvements can be made in the leak detection technology deployed, instrumentation system, training, and leak detection response procedures. Closer collaboration between leak detection vendors and pipeline operators can also enhance the overall performance of leak detection systems.
Source
American Petroleum Institute. API Recommended Practice RP 1130. Computational Pipeline Monitoring for Liquids. September 2007.
Zhang, J, Twomey, M. Introduction to Pipeline Leak Detection Systems. 1st ed. Manchester England. Amazon 2017. Print American Petroleum Institute. API Recommended Practice 1175. Pipeline Leak Detection Program Management. 2015 49 CFR (Code of Federal Regulations) Part 195