1、Guidelines for Addressing Data Gaps and Recordkeeping for ASME B31.4, B31.8 and B31.8S for Pipeline Integrity ManagementPTB-12-2017ASMEPTB-12-2017 GUIDELINES FOR ADDRESSING DATA GAPS AND RECORDKEEPING FOR ASME B31.4, B31.8 AND B31.8S FOR PIPELINE INTEGRITY MANAGEMENT Prepared by: Andrew R. Lutz, P.E
2、., DNV-GL Elizabeth King, DNV-GL Dr. Thomas Bubenik, DNV-GL Dr. William Harper, DNV-GL Date of Issuance: June 28, 2017 This guideline was prepared by ASME Standards Technology, LLC (ASME ST-LLC) and sponsored by The American Society of Mechanical Engineers (ASME) Pressure Technology Codes Cant be re
3、adily seen or inspected (once installed); and are Materials dependent. Tracking requirements and practices are quite rigid within the U.S. Code of Federal Regulations (CFR) for implanted medical devices. Specifically, the medical industry requires a unique device number assigned to all medical devic
4、es implanted within patients, so the manufacturer can retrieve manuals, install dates, etc. for any of its devices for the U.S. Food and Drug Administration (FDA) within ten days of any request. 20 This level of tracking is beyond what is required for most of the pipeline industry. For example, the
5、marking and naming requirement is similar to what is required for valves 21 (where a unique id, nameplate, and body markings are required), but the requirements for how the information will be tracked after the valve is installed is currently very general. The pipeline industry could benefit from a
6、practice of uniquely tracking each component that is installed (although it would be tedious) and storing the information in a retrievable manner. This practice is more realistic as a future goal, since it may not be practical to retroactively obtain this level of detail from project records (i.e.,
7、from past or current projects). PTB-12-2017: Guidelines for Addressing Data Gaps and Recordkeeping for ASME B31.4, B31.8 and B31.8s for Pipeline Integrity Management 6 1.2.2 Nuclear Industry Recordkeeping practices were also reviewed for the nuclear industry. The nuclear industry shares the followin
8、g characteristics with the pipeline industry: Cant be readily seen or inspected (once installed); Materials dependent; and Highly critical to societys safety, environmental, and infrastructure (e.g., energy, economy) requirements. The nuclear industry in general was reviewed with respect to the reco
9、rdkeeping requirements for comparison with the pipeline industry. There were a number of key findings during this review. The nuclear industry has a substantial number of robust practices related to data and recordkeeping requirements. Quality Assurance Requirements for Nuclear Facility Applications
10、 22 prescribes requirements for: Identification of traceability of items; Authentication of records; Receipt control of records; and Maintenance of records. Some of the requirements, like “Identification of traceability of items,” specify that a heat number may be used to trace a material grade, but
11、 they dont elaborate with specific guidance on how this should be performed (e.g., within documentation). “Authentication of records” serves to set the expectations of a source record (i.e., an “authentic data source”). For example, “Documents shall be considered valid records only if stamped, initi
12、aled, or signed and dated by authorized personnel or otherwise authenticated. Corrections to documents shall be reviewed and approved by the responsible individual from the originating or authorized organization.” These criteria are similar to the types of markings that often appear in pipeline indu
13、stry construction documents. The authors of this guideline have reviewed construction and maintenance documentation from the pipeline industry and subjected it to similar criteria on a project-to-project basis. Although many operators have procedures, and forms that require signatures, dates, etc.,
14、the first requirement for all records to have such markings was PHMSAs advisory bulletin ADB-11-01 15, which required pipeline operators to have “complete” records to verify their operating pressures. The Nuclear Standard section on “receipt control of records” designates a role for receiving record
15、s, with the responsibility and organizing them in both temporary and permanent storage. A requirement for dedicated records personnel is one that many pipeline operators have begun to realize is needed. Operators have developed teams to “review” records initially, and they have maintained the teams
16、as permanent records management fixtures once the initial review is complete. The “maintenance of records” has requirements about accessibility, management of change, and version control of records, but it doesnt go into detail about how this will be completed. In the ASME Boiler and Pressure Vessel
17、 Code Section III Division 3 (BPVC-III-D3) “Containments for Transportation See Section 5). b. The authors propose a go-forward normalization approach of common minimum data forms and report templates like those found in the ASME BPVC standards for the nuclear industry. 2. Formally dedicate resource
18、s specifically to recordkeeping roles and responsibilities. 3. Provide more accessibility of the data and records to company deputies. These lessons are likely to be a continuous improvement effort, as opposed to a one-time fix, but the text in the remainder of this guideline is provided as guidance
19、 to help the industry take the next steps to address these lessons learned. The ISO standard 15489-1 would suggest the actions taken to make records more “useable” ensures “a user has the ability to access the necessary data within a reasonable time period.” 24 1.4 Recommendations for Revisions to A
20、SME B31.4, B31.8, B31.8S, and Future Work “Prior to pipeline regulations and modern evolutions of the ASME Code, there were no mandated levels of data quality, which suggests that the prevailing levels of quality in present data as a result of historical practices are no longer viewed by the public
21、or regulators as adequate. Data quality requirements set forth by the Code today are overly general and are inadequate for the future. The issue then is what can ASME do to enable an operator to evaluate and assure data quality?” 25 ASME B31.4, B31.8, and B31.8S were reviewed for potential locations
22、 for revision based on the recommendations and lessons learned described in previous sections. Current Revision Recommendations Two locations in ASME-B31.8S show direct relevance, above others, to the lessons learned of the previous section. Paragraphs 4.3 Data Sources, and 4.4 Data Collection Revie
23、w and Analysis each describe system-wide research efforts to collect and evaluate pipeline system data. Section 4.4 recommends “A plan for collecting, reviewing, and analyzing the data shall be created and in place from the conception of the data collection effort.” ASME-B31.8S has provided specific
24、 guidance based on proven industry experience collecting, reviewing, and analyzing data (and rating it for reliability). It also provides specific guidance on PTB-12-2017: Guidelines for Addressing Data Gaps and Recordkeeping for ASME B31.4, B31.8 and B31.8s for Pipeline Integrity Management 10 how
25、the data should be stored and made accessible to company Decision Makers, how they should be cross-checked and updated, and how the team in charge of maintaining this pipeline system information database should be structured. The contents in Sections 2 through 6 and Appendices A, B, and C of this gu
26、ideline have more current data collection and recordkeeping guidance than what is currently in ASME B31.8S Sections 4.3 and 4.4. The plan consists of the following (by guideline section): Section 2 - An overview of the program with roles and responsibilities. Section 3 - A description to structure t
27、he pipeline information database to optimize access to source records. Section 4 - A process to determine likely boundaries for unknown values. Section 5 - A process to determine quality and reliability of data based on attributes of the source records. Section 6 - A process for on-going data collec
28、tion and management of the records database. Appendices A, B, and C to support the main text. The most relevant location for this guidance would be as a supplementary appendix to these sections in ASME B31.8S. Sections 4.3 and 4.4, which would remain in-full and a reference to the supplementary appe
29、ndix could be added as the “recommended guidance to develop a plan for collecting, reviewing, and analyzing data.” Future Revision Recommendations The guidance within this document is a product of the authors and industrys experience over the last half-decade and was developed for MAOP verification.
30、 The focus of these efforts was typically on construction and maintenance records, which included pressure tests and material installation records. While the guidance in this document has been tested thoroughly for pipeline system materials and pressure test records, it has not been tested for some
31、other types of data that ASME B31.8S Sections 4.3 and 4.4 require (e.g., SCADA, soil resistivity/moisture levels, one-calls). It is the authors hope that the guidance and philosophies regarding accessibility and dedicated recordkeeping resources contained in this guideline could extend beyond materi
32、als and be adjusted to apply more effectively to other data types as future work. During the review, there were many locations where records requirements were “overly general” as described above. A prime example follows, where the requirement is clearly adamant about the importance of detail, but pr
33、ovides no guidance on what details are needed or how they should be stored or tracked: “Records shall be made covering all leaks discovered and repairs made. All pipeline breaks shall be reported in detail.” 26 Providing a form with minimum data requirements could provide operators with a valuable i
34、nformation gathering tool (particularly smaller operators who may not have the resources to call upon SMEs for each occurrence). Meeting the spirit of the normalization standard set by the ASME-BPVC standards for the nuclear industry would require many specialized forms and report templates with min
35、imum data requirements. Providing a recommendation on how to normalize each type of data needed for operations and maintenance and integrity and risk management practices in ASME B31.4, B31.8, and B31.8S is not possible within the scope of this guideline. Multiple subject matter experts will likely
36、be needed to meet the normalization requirements consistent with the level of the ASME BPVC standards for the nuclear industry. The remaining notable paragraphs from ASME B31.4, B31.8, and B31.8S that are candidates for normalization were itemized into tables shown in Appendix D. PTB-12-2017: Guidel
37、ines for Addressing Data Gaps and Recordkeeping for ASME B31.4, B31.8 and B31.8s for Pipeline Integrity Management 11 2 PROGRAM OVERVIEW AND TYPICAL ROLES AND RESPONSIBILITIES An operator who is interested in upgrading or maintaining a modern data and records management system as described in this g
38、uideline should include personnel and resources to fill the roles and responsibilities indicated below. These roles and responsibilities are referenced throughout the processes described within this guideline. The following roles3 will need to be delegated to the appropriate personnel upon starting
39、this process: Table 2-1: Roles and Responsibilities Role Responsibility Examples Title Database Owner Must be responsible for managing and maintaining the data within the Pipeline Database for the relevant section of pipe. Pipeline Integrity Manager Pipeline Integrity Engineer Risk Engineer Records
40、Librarian Collection, storage, organization, and manipulation of data and/or documents (a data mining expert). Must be familiar with the hard copy records and “soft” data that is (or will be) used to populate the Pipeline Database. Must provide technical support to the Research teams about source re
41、cords, their locations and formats. Pipeline Integrity Engineer Risk Engineer Administrator GIS specialist Subject Matter Expert (SME) Provides extensive knowledge about the relevant integrity practices, pipeline construction and procurement, materials, company knowledge, etc. Typically provides tec
42、hnical support about this knowledge to others in the company. Pipeline Integrity Engineer Procurement personnel Records Engineer Oversees teams of Researchers and Data Miners and performs quality assurance (including process controls and design) and quality control on their work. Pipeline Integrity
43、Engineer Risk Engineer Researcher/ Data Miner Conducts the necessary research into the background information related to records gaps or document reliability. Must be familiar with industry standards, compliance and regulator communications, and/or company information and documentation. Reviews new
44、records/information and compares them to the database. Carries out the MOC process listed within this guideline and is responsible for resolving data discrepancies. Pipeline Integrity Engineer Documents and Records Management Team GIS specialist Decision Maker Makes decisions that require the inform
45、ation from the Pipeline Database, which may include critical operations decisions (e.g., pressure reductions and fitness-for-service analysis). Company management Pipeline Integrity Engineer Risk engineers Company Management Ensures compliance of the pipeline system, which includes the records and d
46、ata management. Responsible for ensuring others on this list have the resources necessary to carry out their roles and responsibilities. VP of Engineering Compliance Manager Pipeline Integrity Manager 3 Depending on the size of the operator and the number of records to maintain, it may be appropriat
47、e for some individuals to fill multiple roles. PTB-12-2017: Guidelines for Addressing Data Gaps and Recordkeeping for ASME B31.4, B31.8 and B31.8s for Pipeline Integrity Management 12 3 COMPANY PIPELINE INFORMATION DATABASE It is recommended that each operator maintain a chief source of pipeline sys
48、tem information, so they can make auditable, repeatable, and trustworthy decisions such as those needed for fitness-for-service calculations and risk assessments. The authors of this guideline recommend a practice of maintaining digital source records directly linked to specific pipeline components
49、within an operators GIS. This recommendation is based on a philosophy of providing the operators Decision Makers easier access to the source records. This system might not fit every operators system. There may be some operators that can provide their Decision Makers ready access to all source records in a way that can be as efficient as directly linking the source records within GIS. This could be the case for a very small operator where records are always immediately retrievable for the entire syst
