Project

Critical Infrastructure Pipeline

PROJECT

Critical Infrastructure Pipeline Management Services for Regulated and Non-Regulated Pipelines

LOCATION

Freeport, Texas

Background

A large multinational, fully integrated producer and supplier of monoethyleneglycol (MEG) and diethylene glycol (DEG) operates two regulated pipelines for natural gas and ethylene on the site of its Texas Gulf Coast facility. These range from 8 to 10 inches in diameter, and both are less than 10 miles long.

This client also operates five non-regulated pipelines. Pipeline management is not core to the company’s business; as a result, leadership outsourced the regulatory compliance and integrity management tasks associated with these two assets. 

Company leaders chose ENTRUST Solutions Group and entered into an integrated pipeline management agreement to establish a comprehensive regulatory and integrity management program for both the regulated and non-regulated pipeline systems. 

Challenges

In 2019, this client contracted with ESG to develop, implement, and manage all the Texas Railroad Commission (TRRC) and Pipeline and Hazardous Materials Safety Administration (PHMSA) requirements associated with the management of its regulated and non-regulated pipelines. 

Doing this allowed the company to focus resources and budget on its core business of producing and supplying MEG and DEG. To meet immediate and long-term needs, we were challenged with developing a robust and comprehensive pipeline management solution based on the following scope of work: 

We reviewed pipeline attribute documentation, provided engineering and regulatory support for a jurisdictional determination regarding pipelines and control room status, and led engineering and advisory review of construction documentation. 

In addition, we provided pipeline management and Geographic Information System (GIS) management solutions and developed regulatory compliance manuals, operation procedures, and associated record retention forms. 

It was also crucial to integrate acquired pipeline data and link corresponding scanned record images into an industry-standard GIS database; identify, assess, model, and map potential class location and high consequence area (HCA) locations; develop and execute a pipeline cleaning plan; and develop and manage the execution of caliper tool run, including review of inspection reports. 

Solutions

The solution was extensive and included establishing a one-call ticket management system, assisting with the management and provision of a damage prevention program, and leading the development, implementation, and management of a Public Awareness Program. 

We developed and managed the overall pipeline management solution, including annual PHMSA reporting, National Pipeline Mapping System submissions, Texas Railroad Commission (TRRC) submittals, and program reviews (O&M manuals, OQ program, IMP program, etc.).

Another important part was performing a threat assessment and periodic evaluation of the integrity program, annual emergency response tabletop assessments and field exercise drills; and providing annual high consequence area (HCA), class location, and structure verification reports.

Upkeep of regulatory compliance changes was required along with management of third-party contractors for annual pipeline work activities, cathodic protection system readings, evaluations, and inspections testing, and all required leak surveys, valve operations, and maintenance.

Key Results:

As a result, the MEG/DEG supplier was able to concentrate on its core business with minimum distraction to non-core activities. We were also able to deliver:

  • A protocol to move the client from a prescriptive to a predictive maintenance and inspection program
  • Constant access to expert pipeline integrity analyses
  • A documented and established, continually improving, integrity management program that is fully integrated with operations
  • A comprehensive compliance tracker tool to document completed and upcoming compliance tasks
  • A software management database to house pipeline inspection data, records, drawings, and documents
  • Access to continually improve existing and future pipeline integrity management programs (e.g., new technology awareness, regulation changes)
  • A single source one-call management system to prevent and mitigate third-party damages

“Following an extensive review of potential service providers, company leaders recognized the unique skillsets and core strengths of ENTRUST Solutions Group.”

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