November 2019 Vol. 74 No. 11

Washington Watch

PHMSA Issues Major Gas, Hazardous Liquid Safety Rules

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

The two very detailed, technical rules are similar to the extent they extend “integrity management” programs beyond high-consequence areas 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 inline tools, known as “pigs.” The gas rule also mandates new inspections of pre-1970-installed pipes and other segments that will need to have the maximum allowable operating pressure (MAOP) reconfirmed.

“We’re pleased that PHMSA has updated their regulations so that natural gas and liquid pipeline operators are able to facilitate the use of new technologies and processes that will help to keep their operations safe for employees, surrounding communities and the environment,” said Robin Rorick, vice President of Midstream and Industry Operations at the American Petroleum Institute.

“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.”

The Interstate Natural Gas Association of America (INGAA) had 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 had inaugurated a rulemaking on some aspects of the final rule that same year. The industry had been anxious for the final rule to be issued.

Don Santa, president and CEO of INGAA, said, “The natural gas pipeline industry is pleased to see the completion of this major update to PHMSA’s pipeline safety regulations. 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 MAOP of pipelines built before 1970, “grandfathered” pipelines operating at or above 30 percent of specified minimum yield strength (SMYS). Operators with missing records can choose one of six methods to reconfirm their MAOP and must keep the record that is generated by this exercise for the life of the pipeline. PHMSA has also created an opportunistic method by which operators with insufficient material property records can obtain such records.

The extension of integrity requirements involves pipelines in Class 3 and Class 4 locations and in the newly defined “moderate consequence areas” (MCA). Theymust be assessed initially within 14 years of this rule’s publication date and then reassessed at least once every 10 years thereafter. INGAA supported the creation of MCAs but wanted changes made, such as limiting the definition to only those pipeline segments that could be assessed through an ILI inspection and amending it to avoid ambiguity regarding residential structures.

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 pipe seam threats.

This rule also explicitly requires devices on in-line inspection (ILI) launcher or receiver facilities that can safely relieve pressure in the barrel before inserting or removing ILI tools. In addition, it 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.

While the pipeline industry eagerly awaits both final rules, gas transmission companies may be disappointed that only some of the proposals the agency has been considering since 2011 are being finalized. The agency anticipates completing a second rulemaking sometime 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.

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