With any change to standards, lots of questions arise. Atmos has collated the key answers to some common questions relating to API RP 1175.
1. Why should my company implement API RP 1175?
Answer: While leak detection cannot prevent a leak, a good leak detection program will help to minimize the consequence of leak. RP 1175 focuses pipeline operators on selecting the right leak detection methods, maintaining the leak detection systems and their supporting components and on making sure the systems are optimized. This will help to minimize the impact of releases on people, the environment and property, and drive the industry toward a goal of zero releases. Implementing 1175 provides guidance to develop a Leak Detection program, measure its performance and the performance of the systems used to detect leaks and to set goals for ongoing improvement.
2. Is 1175 mandated by the regulators in the US or Canada?
Answer: The API and the Association of Oil Pipelines issued RP 1175 in response to the US Department of Transportation Pipeline and Hazardous Materials Safety Administration (PHMSA) appeal to provide guidance to the Operators for developing, maintaining, and sustaining an active, comprehensive leak detection program. While the RP is not mandated by PHMSA in the US or by the National Energy Board in Canada, as previous API documents addressing pipeline leak detection are frequently cited or even adopted by numerous regulating authorities around the world to set pipeline leak detection standards, it is likely that this new RP will also influence leak detection regulation around the world.
3. What if senior management does not believe leak detection works?
Answer: Some managers lack confidence in Computation Pipeline Monitoring systems (CPM) because too many leak detection systems failed to detect leaks in the past. However, those systems failed mainly for one of the following reasons; • the wrong leak detection system was selected for the pipeline where it was applied • the leak detection system supporting components such as instrumentation and communications were ill-maintained the controllers were inadequately trained in the leak detection system 1175 addresses these issues with recommendations on selecting leak detection methods, setting up a maintenance program, checking performance and a training personnel. Establishing a strong leak detection program and culture will assure that more leaks are detected.
4. How is this different from other API leak detection guidance (i.e. API RP 1130 or API TR 1149)?
Answer: 1175 is considered an umbrella document that covers leak detection program management, whereas, 1130 and 1149 are specific to Computation Pipeline Monitoring systems (CPM). RP 1175 includes any technique for leak detection (third-part surveillance, hydro-testing, In-line inspection, Cameras, SCADA monitoring, CPM, etc.) that can be implemented as part of an overall leak detection strategy. It is intended to encourage Operators to embrace leak detection as part of their operations, adopt industry best practices, and continuously improve their program management.
5. Is a pipeline operator required to comply with all the components contained in 1175?
Answer: While it is advised to follow the entire RP, each operator should utilize the parts of 1175 that align with its goals, and risk tolerances. Leak detection programs and systems rely on people, processes and technology. A deficiency in any one category can reduce the effectiveness of the other two.
6. Can an operator deploy API RP 1175 in a fit-for-purpose manner to meet the company’s needs? If so how should this be done?
Answer: Yes. If a company program is already sufficient, it may just require formal documentation of current company practices to manage and reduce the risks of leaks. In other cases, a company may need to strengthen its program by adding process, procedure, and/or technology to close gaps identified in the API RP 1175 Gap Analysis.
7. Does following 1175 require purchasing new equipment and technologies?
Answer 7: Not necessarily. Overall, 1175 focuses on developing a culture where all levels of a company from the top down is committed to leak detection and a strategy that uses people, processes and technology to develop an overall leak detection program that is measurable, effective and continuously improved.
8. What are the first few things to focus on?
Answer: build strong leadership support and the right culture. The rest of the RP may take time to implement and will be much more difficult if the first two elements are missing.
9. What is the difference between an LD Strategy and LD Program?
Answer: The LD Strategy is a part of the over leak detection program. The strategy includes the long-term goals for the pipeline operator. The LD Program includes identifying the KPIs, setting up methods to measure the results, and monitoring the performance over time.
10. Are there recommended metric values that indicate whether an LD system is good or bad?
Answer 10: No, determining whether an LD system is good or bad is left to the discretion of the individual Operators. An LD system may perform differently, based on how the Operator applies it and the parameters about the specific pipeline system where it is being used.
11. Does API RP 1175 include suggested KPIs?
Answer 11: Yes, KPIs are recommended. Each Operator will decide which KPIs are appropriate for their needs, applications, and risks. So far, the biggest challenge in this area has been to find KPIs that effectively measure improvements in intangibles such as company culture. In comparison, KPIs for leak detection system performance are easier.
12. Is the purchase of API RP 1175 required to gain access to the Gap Analysis Tool?
Answer: No. Although the Gap Analysis Tool is designed to adequately address each element of API RP 1175, it does not replace the need for each Operator to read and understand the information that is contained in API RP 1175. The purchase of the RP is recommended to assure a complete understanding of its contents.
13. Is the use of the API RP 1175 Gap Analysis Tool required, or will another instrument suffice?
Answer: Use of the API RP 1175 Gap Analysis Tool is left to the discretion of each Operator; however, the gap analysis tool can save time in the evaluation of your program. The tool makes a good starting point and may help when responding to questions during audits of the LD program.
14. What is considered a “good” gap analysis score?
Answer: A good score is left to the Operator to interpret based on their specific risks. However, the closer the average score is to 1 for each element of API RP 1175, the better the score.
15. What resources, besides the Gap Analysis Tool, are provided to help each Operator deploy API RP 1175?
Answer: There are slide decks on the API website on each of the chapters that summarize the chapters.
The API RP 1175 includes examples of:
- A Risk Assessment
- A List of Selection Criteria - Factors Affecting Performance
- Performance Metrics and Targets - Roles in the Use of the
- LDS Training Plan
16. Where can I get more information about API RP 1175?
Answer: PipelineLDP@api.org
17. What is the timeframe to deploy API RP 1175?
Answer: That is left to the discretion of each Operator. The API RP 1175 Implementation Team suggests the following paced deployment of API 1175:
- Quarter 1 of 2017 Complete the API 1175 Gap Analysis
- 2017 Close your highest priority gaps that were identified in your gap analysis.
- 2018 Conduct a follow-up gap assessment of your program and finish closing your operator's remaining gaps.
Source: API RP 1175 Implementation Team