News & View, Volume 45 | Gas Pipeline Safety Regulation Update

News & Views, Volume 45 | Gas Pipeline Safety Regulation Update

By:  Scott Riccardella. Erica Fisette, and Bruce Paskett

News & View, Volume 45 | Gas Pipeline Safety Regulation Update

Update on the Safety of Gas Transmission and Gathering Pipelines Rulemaking (known as the Mega-Rule)
Structural Integrity (SI) personnel have had significant involvement in the Gas Pipeline Advisory Group (GPAC) meetings focused on consideration of the proposed pipeline safety rule titled “Safety of Gas Transmission and Gathering Pipelines” (Notice of Proposed Rule Making April 8, 2016).  The meetings produced several recommendations to the Pipeline and Hazardous Materials Safety Administration (PHMSA) that are likely to be included in the Final Rule.  A key outcome of these meetings was that PHMSA has decided the Final Rule will be split into three sub-rule packages that will all be final rules to facilitate the rulemaking process:

  1. Maximum Allowable Operating Pressure (MAOP) reconfirmation, Material Verification, Expansion of Integrity Management Assessments Outside of High Consequence Areas (HCAs) and other related issues,
  2. Repair Criteria, Inspections Following Extreme Weather Events, Corrosion Control improvements, Management of Change; and
  3. Expansion of Part 192 regulations to include additional Gas Gathering Lines.

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News & View, Volume 44 | Update on Proposed Safety of Gas Transmission and Gathering Pipeline Regulation

News & Views, Volume 44 | Update on Proposed Safety of Gas Transmission and Gathering Pipeline Regulation

By:  Scott Riccardella, Erica Fisette, and Bruce Paskett

News & View, Volume 44 | Update on Proposed Safety of Gas Transmission and Gathering Pipeline RegulationStructural Integrity (SI) has significant depth and expertise in current pipeline safety regulations and dedicates substantial resources to ensure a comprehensive understanding of proposed pipeline safety regulations.  Using the most current insights relative to upcoming regulations, Structural Integrity guides our clients with strategic direction to best position their pipeline safety programs to comply with the new regulations.  Structural Integrity takes a proactive role in attending key Pipeline and Hazardous Materials Safety Administration (PHMSA) meetings such as the Gas Pipeline Advisory Committee (GPAC) meetings as well as supporting the rulemaking efforts of the American Gas Association (AGA), Interstate Natural Gas Association of America (INGAA), Pipeline Research Council International (PRCI) and other key associations.

The GPAC is a statutorily mandated Committee that advises PHMSA on proposed gas pipeline safety standards and regulations.  The Committee consist of members from Federal and State governments (PHMSA and National Association of Pipeline Safety Representatives or NAPSR), the regulated industry, and the general public. The Committee is responsible for reviewing the technical feasibility, reasonableness, cost-effectiveness, and practicability of proposed standards and regulations relative to pipeline safety.  The goal of the Committee is to provide recommended revisions and/or actions in response to standards and/or regulations proposed by the Federal Department of Transportation (DOT)/ PHMSA.

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News & View, Volume 43 | A Strategic Approach for Completing Engineering Critical Assessments of Oil and Gas Transmission Pipelines

News & Views, Volume 43 | A Strategic Approach for Completing Engineering Critical Assessments of Oil and Gas Transmission Pipelines

By:  Scott Riccardella and Steven Biles

Regulatory Overview
News & View, Volume 43 | A Strategic Approach for Completing Engineering Critical Assessments of Oil and Gas Transmission PipelinesIn January 2012, the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 was signed into law directing PHMSA to take steps to further assure the safety of pipeline infrastructure.  PHMSA issued the related Notice of Proposed Rulemaking (NPRM) for Safety of Gas Transmission and Gathering Pipelines on April 8, 2016.  Included in the NPRM were significant mandates regarding:

  • Verification of Pipeline Material (§192.607); and
  • Maximum Allowable Operating Pressure (MAOP) Verification or “Determination” (§192.624)

The NPRM proposes requirements for operators to verify the MAOP of a gas transmission pipeline when:

  1. The pipeline has experienced an in-service incident (as defined by §191.3) due to select causes1 in a High Consequence Area (HCA), “piggable” Moderate Consequence Area (MCA), or Class 3 or 4 location since its last successful pressure test
  2. The pipeline lacks Traceable, Verifiable, and Complete pressure test records for HCAs or Class 3 or 4 locations
  3. The pipeline MAOP was established by the grandfather clause (§192.619 (a)(3)) for HCAs, “piggable” MCAs, or Class 3 or 4 locations.

To verify the MAOP of a pipeline, the NPRM provides the following options:

  • Method 1: Pressure Test
  • Method 2: Pressure Reduction
  • Method 3: Engineering Critical Assessment (ECA)
  • Method 4: Pipe Replacement
  • Method 5: Pressure Reduction for segments with small potential impact radius (PIR) & diameter
  • Method 6: Use Alternative Technology

The ECA Approach
Per the NPRM, Method 3 (ECA) is defined as an analysis, based on fracture mechanics principles, material properties, operating history, operational environment, in-service degradation, possible failure mechanisms, initial and final defect sizes, and usage of future operating and maintenance procedures to determine maximum tolerable sizes for imperfections. 

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