June 2020, Vol. 247, No. 6


PHMSA Proposal on Valves Proves Controversial

By Stephen Barlas, Contributing Editor, Washington, D.C.

Flack is hitting the Pipeline and Hazardous Materials Safety Administration (PHMSA) from all sides over its proposed rule to require automatic and remote shut-off valves on oil and gas pipelines. The February 2020 recommendation from PHMSA attempts to implement mandates from both the National Transportation Safety Board (NTSB) and Congress. 

The proposal requires the installation of remote-control valves (RCV) and automatic shut-off valves (ASV), or equivalent technology, on all newly constructed and fully replaced gas transmission and hazardous liquid lines. PHMSA does provide an exemption that would allow operators to install manual valves, provided operators have sufficient justification and appropriate station personnel to ensure that a manual valve can be closed within the same 40-minute timeframe.

A second part of the proposed rule establishes minimum standards for the identification and mitigation of an emergency response to ruptures, in the latter case within 10 minutes after initial notification or indication. Valves must be shut off within 40 minutes of rupture identification. The rupture provisions appear to only apply to Classes 3, 4 and high-consequence areas (HCAs). 

The Pipeline Safety Trust, which calls itself a grassroots watchdog group, formed after a pipeline accident took place in 1999 in Bellingham, Wash., argued in its comments: “If enacted in their current form, the proposed rules, nine years in the making, would not prevent or mitigate the damage caused by the failure of PG&E’s [Pacific Gas and Electric Company] pipeline in San Bruno, Calif., that led to the issuance of NTSB Safety Recommendation P-11-11.”

Gas industry trade groups, on the other hand, want additional exemptions. The American Gas Association (AGA), American Petroleum Institute (API), American Public Gas Association (APGA) and Interstate Natural Gas Association of America (INGAA) submitted joint comments. 

One of the trade group’s biggest concerns is that they will have to install automated valves in rural, Class 1 and 2 locations. 

“PHMSA should clarify that the valve automation requirements for Class 1 and 2 locations outside of high-consequence areas are opportunistic and do not require automation of upstream/downstream valves,” they wrote. The stated rationale for that position is the costs of putting RCVs/ACVs in remote areas run from $300,000 to $600,000. “These costs may be appropriate in densely developed areas, but they are not commensurate with risk in more remote areas.” 

They do not want RCVs or ACVs to be required anyplace where a pipeline has a maximum allowable operating pressure of less than 30% of specified minimum yield strength (SMYS) or a potential impact radius of less than or equal to 150 feet (46 meters) from the proposed automated valve requirements.

The NTSB complained the provisions fall short of what the safety agency has recommended over the past decade. The safety board is also unhappy the PHMSA is not proposing to require leak detection equipment on gas transmission and distribution pipelines as expansively as recommended by NTSB recommendation P-11-10. 

Instead PHMSA is requiring installation of pressure monitoring equipment at all rupture mitigation valves on both the upstream and downstream locations of the valve. 

“This requirement incorporates an aspect of NTSB Recommendation P-11-10 that will help operators to better detect ruptures, which should drive further development and installation of leak detection technology, and may help drive operators to make decisions to improve the capabilities of their current leak detection systems to detect nonrupture type events,” PHMSA explained in the proposed rule.

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