June 2022, Vol. 249, No. 6
Government
PHMSA Finalizes New Remote Valve Requirements
By Stephen Barlas, Contributing Editor, Washington, D.C.
After more than a decade of considering whether pipelines should install automatic shut-off valves (ASVs), the Pipeline & Hazardous Materials Safety Administration (PHMSA) issued a final rule; however, it fell short of what the National Transportation Safety Board (NTSB) wanted.
Over the past decade, NTSB has repeatedly asked PHMSA to impose shut-off valve requirements following its investigation of the Sept. 9, 2010 Pacific Gas and Electric (PG&E) accident in San Bruno, Calif., in which a ruptured gas transmission pipeline caused an explosion that killed eight people.
NTSB made recommendations after its investigation and the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 required PHMSA to issue regulations requiring the use of ASVs or remote-control valves (RCVs), or equivalent technology, on newly constructed or replaced gas transmission and hazardous liquid pipeline facilities.
Eleven years later, the new PHMSA regulation affects most newly constructed and entirely replaced onshore gas transmission, Type A gas gathering, and hazardous liquid pipelines with diameters of six inches or greater after April 10, 2023.
The pipeline industry has appeared to have won most of the regulatory battles it fought over the past decade as this regulation slowly progressed through PHMSA.
“Safety is our top priority, and we are glad to see that PHMSA listened to industry’s input when finalizing the requirements that allow for faster response and help minimize the risk to the communities our members serve. The changes within the final regulation continue to help move the needle on safety, while ensuring American Gas Association’s (AGA) members are maintaining reliable and affordable natural gas service,” said Christina Sames, AGA’s senior vice president, Safety, Operations and Security.
NTSB and the Pipeline Safety Trust wanted PHMSA to apply the rule to existing pipelines, which the agency did not do. The final rule also falls short in addressing safety issues related to valve spacing and leak detection.
“PHMSA’s final rule does not meet the criteria specified in NTSB safety recommendations regarding valve and rupture detection completely,” said NTSB Chair Jennifer Homendy. “I encourage PHMSA to continue their efforts to address the identified issues from our investigation of the San Bruno, California, natural gas explosion and satisfy the NTSB safety recommendations.”
PHMSA acknowledged that NTSB recommendations included the application of the rule to existing pipelines but that such a change is beyond the scope of what it could authorize within the current regulations. PHMSA hinted it could go that route in the future but that such “an expansion may merit additional process” (e.g., a supplemental notice and solicitation of additional comments), imposing a substantial delay to a rule that is already 11 years in the making.
Further, application of the rule’s rupture-mitigation valves (RMVs) and alternative equivalent technology installation requirements to existing pipeline infrastructure would entail installation activity (e.g., blowdowns of existing pipelines prior to replacement and work in pipeline rights-of-way) that could involve significant GHG [greenhouse gas] emissions and other potential environmental harms.”
In the regulation, PHMSA requires operators to install RMVs (i.e., RCVs and ASVs), or alternative equivalent technologies, and establishes minimum performance standards for those valves’ operation to prevent or mitigate the public safety and environmental consequences of pipeline ruptures. The final rule establishes requirements for RMV spacing, maintenance and inspection, and risk analysis.
One of the issues that surfaced after PHMSA proposed explicit language in 2020 as part of its proposed rule was the definition of what constituted a “newly replaced” pipeline.
A number of pipeline trade groups, including the Interstate Natural Gas Association of America (INGAA), the American Petroleum Institute (API) and AGA, pressed for a definition, which PHMSA adopted in the final rule, that an “entirely replaced” pipeline is one that has two or more miles being replaced with new pipe within any stretch of five contiguous miles within any 24-month period.
PHMSA also adopted language proposed by the gas groups specifying that for gas transmission and Type A gas gathering pipelines the RMV or alternative equivalent technology installation requirements will not apply whether the pipeline segment is in a Class 1 or Class 2 location and has a potential impact radius (PIR) less than or equal to 150 feet (46 meters).
This final rule also establishes federal minimum safety performance standards for the identification of ruptures, pipeline segment isolation and other mitigative actions for pipelines on which RMVs or alternative equivalent technology are installed. Relevant new requirements include a definition of the term “notification of potential rupture” to identify signs of an uncontrolled release of a large volume of commodity observed by, or reported to, the operator.
This was an important provision when it was proposed, and INGAA questioned parts of the definition, one of which PHMSA changed to accommodate INGAA.
But a second, objectionable part of that definition stayed: a 10% pressure-loss-within-15-minutes threshold. PHMSA agreed to cushion the definition by permitting operators to document in their written procedures the need for alternative pressure-loss-rate thresholds because of the unique pipeline flow dynamics resulting from changes in demand.
Other new standards of note include (1) establishing written procedures for identifying and responding to a rupture, (2) responding to an identified rupture by closing RMVs or alternative equivalent technology, to provide complete valve shut-off and segment isolation as soon as practicable, but no more than 30 minutes after rupture identification; (3) performing post-event reviews of any incidents/accidents or other failure events involving the closure of RMVs or alternative equivalent technologies to ensure the performance objectives of this rule are met and to apply any lessons learned systemwide; (4) performing maintenance on RMVs and alternative equivalent technology, which includes drills for alternative equivalent technology that is manually or locally operated; and (5) implementing remediation measures for repair or replacement of inoperable RMVs and alternative equivalent technologies, including an RMV or alternative equivalent technology that cannot maintain shut-off, as soon as practicable.
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