Record keeping

The US National Transportation Safety Board has issued another press release on the the San Bruno failure.  It includes seven recommendations, most of them urgent.  I’ll highlight a couple:

To PG&E (the pipeline owner):  “Aggressively and diligently search for all as-built drawings, alignment sheets, and specifications, and all design, construction, inspection, testing, maintenance, and other related records, including those records in locations controlled by personnel or firms other than PG&E, relating to pipeline system components, such as pipe segments, valves, fittings, and weld seams for (certain PG&E pipelines) that have not had a maximum allowable operating pressure established through prior hydrostatic testing. These records should be traceable, verifiable, and complete.

To the California Public Utilities Commission:  “… ensure, through adequate oversight, that PG&E has aggressively and diligently searched documents and records ...”

These recommendations appear to have been made because PG&E believed that the pipe which failed was seamless but it in fact very clearly contained seam welds, some of which seemed to be of dubious quality.  So PG&E’s record keeping was not up to scratch.

Concurrently, I’ve been reviewing a committee draft of the forthcoming new edition of AS 2885.3.  The section on records management caught my eye, partly because it is very comprehensive and partly in the light of the NTSB recommendations above.  (You can get a copy of the public comment draft here for anyone interested; see Section 10.  Note that public comment closed a long time ago.)

One can perhaps be just a tiny bit forgiving of PG&E not having good records of a pipeline built in 1956 since practices have changed markedly since then.  Nevertheless it’s a salutary illustration for anyone who feels that documentation, change management, etc are onerous.

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2 Responses to Record keeping

  1. Michael Malavazos says:

    Now you can see why some of us Regulators get very annal about records and dosiers being kept on all testing etc

  2. Mark Coates says:

    To add to this, I would like to remind everyone of the importance to also retain copies of the relevant design and material codes (eg AS2885.1 – 2007 and API 5L Edition 44) for instances such as these, or whenever an asset is to be modified, reviewed, re-rated, etc.

    In my time I have undertaken several reviews on assets built in the 1970’s and earlier, and the design and materials codes used then are very different to what we have today. This information is useful when trying to determine what was used and why – especially if the original design calculations are not available. Accurate inspection history is also invaluable.

    Organisations such as Standards Australia can make these earlier publications available if required. Sometimes they have published a Miscellaneous Standard which covers the history of material development.

    With today’s systems, electronic copies should be kept with the asset’s history files.

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