Protecting Texas HCAs
Engineers Help Firm Break New
Ground With Pipeline Integrity
by Joe Killins, P.E., Pipeline Integrity Manager, Paragon Engineering Services, Inc., Houston, TX and Tom Mittler, P.E.,
Project Manager, Eastman Chemical Co., Longview, TX
This map identifies a high consequence area
with ecological impact along one of Eastman
Chemical’s pipelines in East Texas, as noted by
the black oblong circle. Eastman operates
about 750 miles of liquid pipelines which sup-
port its manufacturing operations.
n a proactive strategy to ensure
continued protection of the East
Texas environment, Eastman
Chemical Co.—supported by
Paragon Engineering Services’
Pipeline Integrity Management
Team—is breaking new ground in
its development and use of a
comprehensive pipeline integri-
30 Pipeline & Gas Journal/March 2002/pipelineandgasjournalonline.com
This map identifies two high consequence areas relating to population density along one of the com-
pany’s pipelines in East Texas. The green circle on the left specifies an “other” population area and
the orange circle on the right specifies a “high” population area.
ty management plan (IMP) for its 750-mile-
long intrastate hazardous liquid pipeline
system, which transports feedstock to its
Longview, TX chemical plant.
This IMP will meet new requirements
imposed last year by the U.S. Department
of Transportation (DOT) and the Texas
Railroad Commission. Importantly, the
challenge here is that the industry offers
very little guidance or precedents on how
to proceed in complying with these new
requirements, making the Eastman pipeline
integrity management project a significant
benchmark for pipeline operators and serv-
ice companies dealing with a complex
issue: High Consequence Areas (HCAs).
HCAs are areas with high population
density or areas near water resources or
other environmentally sensitive regions.
These locations indicate where a pipeline
spill might have significant adverse
impacts to population, the environment or
commercial navigation. In the case of
Eastman, the project team, in its final
analysis, encountered 49 HCAs in an envi-
ronmentally sensitive region that includes
Texas’ Trinity River National Wildlife
Refuge and the Sam Houston and Davy
Crockett National Forests.
The Eastman project achievement is
twofold: the development of a plan that is
meaningful and useful to the regulatory
arena in its review of the Eastman
pipeline system and associated HCAs, and
the delivery of a purposeful, comprehen-
sive, long-term pipeline integrity manage-
ment plan that Eastman can rely on for
timely monitoring and ongoing mainte-
nance/repair of its pipeline system.
The Eastman pipelines, with diameters
ranging from 4 to 12 inches, transport high-
ly volatile liquids (HVLs), including
propane, propylene and ethylene, used in
the production of a variety of chemicals and
plastics, such as oxo alcohols, polyethylene
and ethylene glycol, at the Longview plant.
In addition, the pipelines provide product
transfer between the plant and Eastman’s
salt dome storage facility at Tyler, TX.
Regulatory Arena
The new DOT Pipeline Integrity
Management in High Consequence Areas
rule (Title 49 CFR 195.452) specifies regu-
lations to assess, evaluate, repair and val-
idate through comprehensive analysis the
integrity of hazardous liquid pipeline seg-
ments that could affect HCAs.
Each operator is required to develop and
follow an integrity management program
that provides for continual assessment of
the integrity of all pipeline segments that
could impact HCAs through internal inspec-
tion, pressure testing or some other equally
effective assessment means. The federal rul-
ing specifies that HCAs include:
䡲 Unusually sensitive areas (USAs):
Locations that include drinking water and
ecological areas that are unusually sensi-
tive to environmental damage in the event
of a hazardous liquid pipeline release.
Drinking water areas of primary concern
are those that provide potable water for
domestic, commercial and industrial use.
Ecological areas of concern include criti-
cal wetlands, riverine or estuarine sys-
 Protecting Texas HCAs
tems, national parks, wildlife refuges,
wildlife preserves and critical habitat areas
for threatened and endangered species;
䡲 High population areas: As defined by the
Census Bureau, urbanized areas with 50,000
people or more and a population density of
at least 1,000 people per square mile;
䡲 Other populated areas: As defined by
the Census Bureau, locations that contain
a concentrated population, such as an
incorporated or unincorporated city, town
or village; and
䡲 Commercially navigable waterways:
Waterways with a substantial likelihood of
commercial navigation.
In addition to the federal ruling, the
State of Texas has new integrity manage-
ment rules requiring owners of all haz-
ardous liquid and gas intrastate pipelines
to develop an integrity management plan
by Feb. 1, 2002.
Eastman Plan
Paragon applied the first four phases of
its specially designed seven-phase
process to create Eastman’s custom-tai-
lored pipeline integrity management plan
for compliance with the new DOT safety
rules. The four phases include:
䡲 Initiation;
䡲 HCA Impact;
䡲 Data Management; and
䡲 Integrity Management Plan.
The DOT deadline for completing these
four phases for the liquid pipelines -cul-
minating in the generation of a written
Integrity Management Plan Framework -is
March 31, 2002.
Phase One: Initiation
The initiation phase began with a
review of regulatory guidelines, expecta-
tions for project deliverables and defini-
tion of the scope of work and data-gath-
ering requirements. This phase continued
with site visits, operations review and
interviews with key personnel, with spe-
cial attention given to HCAs, such as the
national forests and the wildlife refuge.
Phase Two: HCA Impact
During this phase, the project team iden-
tified pipeline locations and HCA locations,
applying its understanding of DOT require-
ments to effectively evaluate the impacts of
the pipeline segments upon these areas. As
part of this process, the team used digitized
aerial photography and satellite maps,
coordinated with Paragon’s in-house data-
base-driven proprietary software, the DOT
National Pipeline Mapping System data-
base and field data gathered by integrity
management teams.
The team used U.S. Geological Survey
(USGS) 7.5-minute quadrangle digital
raster graphic images for base map con-
figuration. These images are at a scale of
1:24,000, datum of NAD27, UTM Zone 15,
with the latest available editions used.
Images were ordered from the USGS web-
site at http://edc.usgs.gov/webglis.
Images are in a digital TIF format and
32 Pipeline & Gas Journal/March 2002/pipelineandgasjournalonline.com
accuracy is based on the U.S. National
Map Accuracy Standards (http://
rockyweb.cr.usgs.gov/nmpstds/nmas647.
html).
The team obtained HCA data for Texas
from the DOT National Pipeline Mapping
System (NPMS) and downloaded this data
in Geographical Information System
(GIS)/ArcView shape file format. Eastman
provided drawing files of the pipeline sys-
tem location data, which included as-built
and construction alignment sheets.
The project team then determined the
likelihood that a particular pipeline seg-
ment would affect an HCA in the event of
a spill. This work included a review of the
HCAs that the pipeline segment crosses as
well as HCAs in proximity to the segment.
When determining a potential impact
zone, the team considered the following:
䡲 Nature and characteristics of the prod-
uct transported;
䡲 Operating conditions of the pipeline
(pressure, flow rate);
䡲 Topography of the land associated
with the HCA and the pipeline segment;
䡲 Hydraulic gradient of the pipeline;
䡲 Pipeline diameter, potential release vol-
ume and distances between isolation points;
䡲 Type and characteristics of each HCA
crossed or in proximity to the segment;
䡲 Potential physical pathways between
the pipeline and the HCA;
䡲 Potential natural forces inherent to
the area (flood zones, subsidence areas);
and
䡲 Response capability (time to respond,
nature of response).
After identifying and reviewing all avail-
able information, the team prepared a for-
mal listing of all pipeline segments, with
supporting data for each pipeline segment
that could impact an HCA. Guidelines for
future evaluation and updating of the HCA
impact listing are included in the procedure
manual of the pipeline integrity manage-
ment framework.
An Eastman safety engineer considered
three effect mode scenarios or potential
hazards for each pipeline in the Eastman
HVL pipeline system:
䡲 Flash fire;
䡲 Jet fire; and
䡲 Overpressure from explosion blast.
Eastman then calculated impact distances
for each scenario and each pipeline condi-
tion using the Process Hazard Analysis
Software Tools (PHAST) Model, Version
6.00, developed by Det Norske Veritas
(DNV).
A one-pound-per-square-inch (psi)
overpressure from the explosion of a
pipeline release had the largest impact
distance when compared to flash fire and
jet fire effects. The team then used these
calculated one-psi overpressure distances
in evaluating potential effects on HCAs.
Analyses of potential impact modes
resulted in the selection of worst-case
impact distances for each pipeline size and
product combination in the Eastman sys-
tem. For each pipeline, the team plotted the
calculated impact distance on both sides of
the pipeline centerline, with the resulting
“impact zone” superimposed along the
pipeline on the USGS/HCA base maps. The
final pipeline alignment sheets showed the
presence of any HCAs within this impact
zone, resulting in the selection of pipeline
segments that could affect an HCA.
Phase Three: Data Management
In this phase, the team ranked pipeline
segments with potential impacts on HCAs
according to risk-based criteria. This phase
involved in-depth data gathering from a
variety of sources, then integration of the
data into the database for evaluation and
ranking.
Paragon engineers visited field loca-
tions and obtained available information
for the pipelines in the following areas:
I. THIRD PARTY
A. Minimum depth of cover
B. Activity level
C. One call
D. Public education
E. Rights-of-way condition
F. Patrol frequency
II. CORROSION
A. Atmospheric
1. Facilities
2. Atmosphere
3. Coating inspection
B. Internal
1. Product corrosivity
2. Internal protection
C. Buried metal
1. Cathodic protection
2. Coating condition
3. Age of system
4. AC-induced current
5. Test leads
6. Close interval survey
7. Internal inspection tool
III. DESIGN
A. Surge potential
B. System hydrostatic test
C. Soil movement
IV. OPERATIONS
A. Procedures
B. SCADA/communications
C. Drug testing
D. Safety programs
E. Surveys
F. Training
G. Mechanical error prevention
F. Maintenance
1. Documentation
2. Schedule
3. Procedures
The team prepared a list of Eastman
pipeline segments that can impact an
HCA, ranked in accordance with risk cri-
teria developed using an index-type risk
assessment method. The team then used
data gathered on each pipeline to devel-
op risk factors for each pipeline segment.
For the initial risk assessment, the team
applied the (Kent) Muhlbauer model—
using an indexing approach that considers
years of industrial experience, including
pipeline industry data—as the basis for
 Protecting Texas HCAs
assessing the relative risks of each pipeline
segment.
The Muhlbauer model scores a system to
determine the relative risks of pipeline seg-
ments within the system, utilizing a com-
prehensive variety of pipeline system data
to effectively evaluate the risk of the entire
system. This process includes applying
number values to correspond to conditions
that may lead to pipeline failure. The
Muhlbauer technique provides a broad
spectrum of pipeline failure mechanisms,
both objective and subjective, with the proj-
ect team’s efforts focused on maximum
objectivity of the data input into the model.
The Muhlbauer model score shows the risk
relating to the pipeline segment, as compared
with another scored pipeline segment, which
allows an operator to prioritize repairs and
inspection. Each factor within the model is
weighted to show pipeline integrity effects
and types of potential failures. Therefore, both
probability and consequence are inherent
within the pipeline risk score from the model.
The Muhlbauer system includes a break-
down of risk factors or conditions that might
lead to a failure. These factors are catalogued
into four indices that correspond to areas that
have historically led to pipeline failures:
䡲 Third-Party Damage Index examines
the potential of harm from activities per-
formed by someone other than the
pipeline operating personnel;
䡲 Corrosion Index examines the type of
corrosion plan in use and gives credit
based on the potential for atmospheric
corrosion, internal corrosion and buried
metal corrosion;
䡲 Design Index examines how well the
design process was performed and takes
into account whether the pipeline is oper-
ating at pressure and flows below the
design point; and
䡲 Incorrect Operations Index exam-
ines the actual operation of the pipeline
system, looking at operations, mainte-
nance, construction and the design
process. This index is the most subjec-
tive as it relies, in part, on operating
personnel judgments.
For each section of pipeline evaluated,
the project team calculated the potential
consequence using a Leak Impact Factor
that takes into consideration product char-
acteristics, location of the line pipe and the
effect a leak condition could create. Each of
the four indices listed is scored between 0
and 100 and is added to give an Index Sum.
This Index Sum is divided by the Leak
Impact Factor to arrive at a Relative Risk
score from 0 to 2000, with a lower number
indicating higher risk.
After integrating the initial data and com-
pleting the risk assessment, the team devel-
oped a baseline assessment plan specific to
Eastman’s pipeline assets. This plan consists
of an initial inspection plan, including iden-
tification of the most appropriate baseline
assessment technique(s) for each segment
and an associated schedule.
Applicable mitigating activities and
their schedules also are included. In
Pipeline & Gas Journal/March 2002/pipelineandgasjournalonline.com
addition, the document includes an
explanation and justification of the
assessment methods selected as well as
the risk factors considered in establishing
the assessment schedule.
Based on the Relative Risk scores, the
team ranked the pipeline HCA segments to
prioritize their assessment schedule, as
required by 49 CFR 195.452. This schedule
provides for inspection of 50 percent of
the highest-risk HCA segment mileage by
Sept. 30, 2004 and the remaining pipeline
segments by March 31, 2008.
Phase Four:
Integrity Management Plan
In the Integrity Management Plan phase,
the project team generated a comprehen-
sive plan framework that lays out the goals
for a comprehensive program for main-
taining the integrity of the pipeline system
throughout its life cycle. The plan includes
timelines for periodic baseline inspections
and any required remedial work.
In developing the written IMP framework,
Eastman followed the instructions of the
Final Rule, as issued in the Federal Register
on Dec. 30, 2000, “Pipeline Safety: Pipeline
Integrity Management in High Consequence
Areas (Hazardous Liquid Operators with 500
or More Miles of Pipeline.” The project team
also incorporated useful concepts, proce-
dures and guidance found in API Standard
1160, “Managing System Integrity for
Hazardous Liquid Pipelines.” As specified in
49 CFR 195.452 (f), the elements of a written
integrity management program include,
at a minimum:
䡲 A process for identifying which
pipeline segments could significantly
impact an HCA;
䡲 Analysis that integrates all available
integrity information on the entire pipeline
and the consequences of a failure (risk
assessment);
䡲 Development and implementation of a
baseline assessment plan;
䡲 Criteria for repair actions to address
integrity issues raised by the baseline
assessment and information analysis;
䡲 Continual process of assessment and
evaluation to maintain pipeline integrity;
䡲 Identification and implementation of
preventive and mitigative measures to pro-
tect the integrity of HCAs;
䡲 Methods to measure the program’s
effectiveness; and
䡲 A process for review of integrity
assessment results and information analy-
sis by qualified personnel.
To these minimum elements, the team
added the following suggested by API 1160:
䡲 Integrity management procedures
for facilities other than line pipe;
䡲 A change-management procedure;
䡲 A procedure for reviewing the IMP; and
䡲 A documentation procedure
Success Factors
Eastman has demonstrated considerable
foresight in addressing the breadth and
complexity of a labor-intensive pipeline
remediation plan to meet the new regula-
tory requirements. Paragon has supported
this effort with the rapid development of a
pipeline integrity management plan that
meets challenging regulatory deadlines
while also providing Eastman with a use-
ful tool for maintaining the integrity of its
pipeline system throughout its life cycle.
Underscoring the responsiveness of the
full team to the challenge, Eastman and
Paragon have developed a comprehen-
sive, user-friendly written plan based on a
myriad of risk-based findings.
Implementation
Eastman is developing plans to initiate
inspection of its pipelines based on the base-
line assessment plan. The company recog-
nizes that although its integrity management
program is customized to support its unique
conditions, the program will need to be con-
tinually evaluated and modified to accommo-
date changes in the pipeline design and oper-
ation, changes in the environment in which
the system operates, new operating data and
the results of initial inspections. P&GJ
Author’s Notes: Tom Mittler, P.E., is a
project manager with
Eastman Chemical
Company of Long-
view. Mittler, who
joined Eastman in
1975, has served as a
project manager for
various projects, in-
cluding three pipeline
projects of more than
500 miles of new
construction. He graduated cum laude
with a bachelor of science degree in civil
engineering from the University of
Missouri at Rolla.
Joe D. Killins, P.E.,
is manager of Pipeline
Integrity Manage-
ment with Paragon
Engineering Services,
Inc. Killins, who
joined Paragon in
2000 following an
extensive career with
ARCO, is responsible
for managing Para-
gon’s full-service capability for pipeline
integrity management, which provides a
complete systems approach. Killins has
more than 32 years of experience in
pipeline, terminal and plant engineering,
operations and staff roles. He is an expert
in DOT Pipeline Safety Regulations.
Since joining Paragon, Killins has
served as project manager for several
notable projects, including the
Williams/Transco MarketLink Expansion
Project, the TEPPCO Pasadena Pipeline
Interconnects Project and the Phillips
Alaska Field Development Screening Study.
He holds a B.Sc. degree in electrical engi-
neering from Oklahoma State University
and a master’s degree in business admin-
istration from California Coast University
at Santa Ana.