2016 was a busy year for the Pipeline and Hazardous Materials Safety Administration (PHMSA) and pipeline compliance with many new and proposed regulations. With the start of the New Year, we thought we'd give you a quick summary of some of the ones that stood out.
This Notice of Proposed Rule Making (NPRM) published in March, updates and enhances safety requirements for gas transmission and gathering pipelines. Key points of the proposed changes include:
- Moderate Consequence Area (MCA) - New classification for medium population density areas to be included in integrity assessment requirements; the high consequence area (HCA) definition will remain the same
- Modifying repair criteria for pipelines inside and outside of HCAs
- Providing additional direction on how to evaluate internal inspection results to identify anomalies
- Clarifying requirements for conducting risk assessment for integrity management, including addressing seismic risk
- Expanding mandatory data collection and integration requirements for integrity management, including data validation and seismicity
- Requiring additional post-construction quality inspections to address coating integrity and cathodic protection issues
- Requiring new safety features for pipeline launchers and receivers
- Requiring a systematic approach to verify a pipeline’s maximum allowable operating pressure (MAOP) and requiring operators to report MAOP exceedances
- Modifying gathering regulations by repealing API RP 80 and extending regulatory requirements to Type A lines in Class 1 locations 8 inches and greater
President Obama signed into law the Protecting our Infrastructure of Pipelines and Enhancing Safety (PIPES) Act of 2016 in June, formalizing the thirty-one provisions in this round of PHMSA’s reauthorization.
In August, PHMSA issued an Advisory Bulletin reiterating the definition of abandoned pipelines, and the operators’ responsibilities for idled versus abandoned pipelines.
Interim Final Rule for Emergency Order Authority
In October, PHMSA published this Interim Final Rule (IFR) to establish emergency order authority in accordance with the PIPES Act of 2016. The emergency order authority grants PHMSA the ability to quickly act on pipeline industry safety concerns and augments the agency's enforcement authority.
Also in October, the excess flow valves (EFVs) final rule was published pertaining to distribution lines. The rule requires EFVs on new or replaced branched lines servicing single-family residences (SFRs), multifamily residences, and commercial entities with volumes less than 1,000 standard cubic feet per housr (SCFH). It also requires curb valves for service lines greater than 1,000 SCFH. Additionally, operators are required to notify customers of their right to have EFVs installed.
This IFR, published in December, covers down-hole facilities including wells, wellbore tubing, casing, and underground natural gas storage facilities. The IFR requirements include:
- Operator Identification Designation (OPID) and reporting (annual, safety-related conditions, and incidents) with the first annual report due six months after the effective date of rule
- Underground natural gas storage facility definition
- Inclusion by reference of API RP 1170, Design and Operation of Solution-mined Salt Caverns Used for Natural Gas Storage
- Inclusion by reference of API RP 1171,Functional Integrity of Natural Gas Storage in Depleted Hydrocarbon Reservoirs and Aquifer Reservoirs
Storage facilities constructed prior to six months following the effective date must meet the requirements within 12 months of the effective date. Storage facilities constructed after 6 months following the effective date must meet the requirements upon construction and startup. This includes written procedures for operations, maintenance, and emergencies.
Leading up to the end of the year, PHMSA issued this Advisory Bulletin to reinforce the requirements for gas HCA identification. The bulletin reiterates that operators are required to have and implement HCA procedures containing:
- Tolerances or buffers to address data inaccuracies and uncertainties
- A combination of techniques to account for inaccuracies and uncertainties
- Continual improvement in accuracy for determining HCAs
- Identified site review details
- Continuing surveillance monitoring details
- Potential impact radius (PIR) calculations based on maximum allowable operating pressure (MAOP)
- Frequent data and class location review, at least annually
We know that's a lot to take in--that's why our DOT compliance specialists are here to help with a myriad of , as well as this Gas NPRM flowchart and Underground Gas Storage Facility booklet. Going into 2017 get summaries like these to keep you in the know of PHMSA’s regulatory updates and pipeline compliance news by following our Sr. DOT Compliance Specialist, Nicole Tebow, on LinkedIn.