November 2019, Vol. 246, No. 11


PHMSA Issues Major Gas and Hazardous Liquid Safety Rules

Years after receiving congressional directives to change pipeline safety laws – with similar suggestions coming from the National Transportation Safety Administration – the federal pipeline safety agency finally issued two major rules, one directed at interstate gas pipelines the other at hazardous liquids pipelines. 

The two very detailed, technical rules are similar in some respects to the extent they extend “integrity management” programs beyond high-consequence areas (HCA), and force a more thorough and timely effort to find leaks in both sectors.

There are also provisions on use of inspection tools, such as changes to where direct assessment can be used, and some leeway on use of inline tools, known as “pigs.” The gas rule also mandates new inspections of pre-1970-installed pipes and other segments, which will need to have maximum allowable operating pressures (MAOP) reconfirmed.

“These regulations are an important step in advancing safety, and we strongly encourage PHMSA to continue to pursue additional rulemaking that provides liquid pipeline operators the flexibility to use fit-for-purpose repair criteria based on data and sound engineering principles,” said Robin Rorick, vice president of Midstream and Industry Operations at the American Petroleum Institute (API).  

The Interstate Natural Gas Association of America (INGAA) worked with PHMSA and other stakeholders to sculpt the final gas transmission rule, which was first necessitated by a congressional pipeline safety bill passed in 2011. PHMSA itself inaugurated a rulemaking on some aspects of the final rule in 2011, too. The industry had been anxious for the final rule to be issued. 

“The natural gas pipeline industry is pleased to see the completion of this major update to PHMSA’s pipeline safety regulations,” said Don Santa, president and CEO of the INGAA. “While INGAA still needs to review the specifics of the final rule, we know that it embraces new pipeline safety technologies and engineering practices and constitutes the most significant enhancement to PHMSA natural gas transmission pipeline safety regulations since the federal code was created in 1970.”

One key provision on the gas side (distribution pipelines are not covered by the new rule) involves confirmation of MAOP for pipelines built before 1970, called “grandfathered” pipelines, operating at or above 30% of specified minimum yield strength (SMYS). 

Operators with missing records can choose one of six methods to reconfirm MAOP and must keep the record that is generated by this exercise for the life of the pipeline. PHMSA also created an opportunistic method by which operators with insufficient material property records can obtain such records.

The extension of integrity requirements brings in pipelines in Class 3 and Class 4 locations and in the newly defined “moderate consequence areas” (MCA). These must be assessed initially within 14 years of this rule’s publication and be reassessed at least once every 10 years thereafter. 

INGAA supported the creation of MCAs but wanted changes made in the initial definition proposed by the PHMSA. INGAA suggested PHMSA should limit the definition of an MCA to only those pipeline segments that could be assessed through an ILI inspection and amend the MCA definition to avoid ambiguity regarding residential structures, for example. 

PHMSA acceded to the first request allowing the use of direct assessment but denied the latter. Direct assessment in MCAs is appropriate if it is suitable for the threat being assessed but cannot be used to assess threats for which direct assessment is not suitable, such as assessing pipe seam threats.

This rule also explicitly requires devices on in-line inspection (ILI) launchers or receiver facilities that can safely relieve pressure in the barrel before inserting or removing ILI tools. It also requires the use of a device that can indicate whether the pressure has been relieved in the barrel or can otherwise prevent the barrel from being opened if the pressure is not relieved.

Though the pipeline industry eagerly awaiting both final rules, gas transmission companies may be disappointed only some of the proposals the agency has been considering since 2011 are being finalized. The agency anticipates completing a second rulemaking in the future to address repair criteria in HCAs and the creation of new repair criteria for non-HCAs, requirements for inspecting pipelines following extreme events, updates to pipeline corrosion control requirements, codification of a management of change process, clarification of certain other IM requirements, and strengthening IM assessment requirements.

A third rulemaking is expected to address requirements related to gas gathering lines that were proposed in the NPRM. P&GJ

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