Update on Proposed Safety of Gas Transmission & Gathering Pipeline Regulation

Note: The GPAC voting is based on concepts rather than specific regulatory language. Therefore, the following list represents a conceptual summary of agreements rather than specific regulatory language.

Structural 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 consists 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.

SI personnel have attended the recent GPAC meetings focused on evaluation of the proposed rule titled “Safety of Gas Transmission and Gathering Pipelines” (Notice of Proposed Rule Making April 8, 2016). The meetings produced recommendations on several elements of the proposed Rule to provide changes that are technically feasible, cost-effective, and reasonable. The following list represents some of the topics discussed at the GPAC meetings as well as key takeaways and consensus direction which may have resultant changes in the Final Rule.

SUMMARY OF DECEMBER 14-15, 2017 GPAC MEETING

On December 14-15, 2017 PHMSA conducted a GPAC meeting in Washington DC. Key items discussed during the GPAC meeting are summarized below:

Material Verification (MV) 

Proposed regulation §192.607 Verification of Pipeline Material: Onshore steel transmission pipelines was reviewed in detail. General agreement was made for eliminating several prescriptive and impractical requirements for performing MV programs. GPAC language for this specific element was approved on December 14, 2017. Included in the GPAC agreements were the following:

  • Clarify that material verification applies to onshore steel transmission lines only (and not distribution or gathering lines)
  • Delete “Applicable Locations” as proposed in §192.607(a)
  • A MV Procedure would be required to obtain missing or inadequate records as well as verify pipeline attributes if and when required by §192.624 or other code sections
  • Delete requirements for creating a MV Program Plan, but a MV Procedure would still be required
  • Keep flexibility to allow either destructive or non-destructive tests when verification is needed
  • Omit the list of mandatory attributes operators must verify, but require operators to keep records developed through this material verification method
  • Omit accuracy specifications, but retain the requirement that test methods must be validated and calibrated equipment be used
  • Omit mandatory requirements for testing multiple pipe joints within the same large excavation
  • Revisions to the statistical criteria used for MV techniques
  • Agreement to consider changing the threshold for non-line pipe components to larger than 2-inch nominal diameter rather than 2-inch and larger
  • Agreement to delete the requirement for testing when the pipe is exposed for “any other reason”
  • Reduce the number of quadrants of pipe tested (from 4 to 2 locations) where NDE testing is required
  • Alternate tools, procedures or techniques will be applicable when submitted by operator and “no objection” letter received from PHMSA within 90 days. PHMSA to notify the operator if additional review time is needed
  • Delete specific MV Program requirements and allow operators to address sampling failures through a specific company specific sampling program

 

Maximum Allowable Operating Pressure (MAOP) Determination and Reconfirmation (§192.619 and §192.624) 

The GPAC dedicated significant time discussing various important issues related to PHMSA’s proposed MAOP verification/reconfirmation requirements for transmission lines. Detailed discussion was held on the following three topics:

1. PHMSA should limit the applicability of MAOP reconfirmation to pipeline segments with MAOPs greater than 30% of Specified Minimum Yield Strength (SMYS) and eliminate Method 5 (pressure reduction for segments with small Potential Impact Radius (PIR) and diameter)

2. PHMSA should focus the MAOP reconfirmation process on one-time actions needed to confirm material strength and MAOP. Industry recommendations for revision include:

• Eliminate the requirement that operators use a spike test to reconfirm MAOP for certain segments

• Refine Engineering Critical Assessments (Method 3) to focus on inspections and analyses necessary to assess manufacturing-related features and confirm material strength

• Revise the applicability of §192.624 to exclude segments that have valid pressure test records, but have experienced a reportable incident

• Relocate the fracture mechanics modeling to a new section: §192.712

3. PHMSA should minimize changes to §192.619, which apply to all gas pipelines

 

Strengthening Potential Impact Radius (IM) Assessment Methods

An in-depth discussion took place with regards to the provisions for Internal Corrosion Direct Assessment (ICDA), Stress Corrosion Cracking Direct Assessment (SCCDA) requirements, Guided Wave Ultrasonic testing (GWUT), the passage of ILI devices along with emphasis on spike pressure test requirements in the proposed §192.506. The GPAC recognized the importance of spike testing as an assessment tool to expose significant time-dependent linear defects. There was discussion on revisions to the proposed language of this section to consider different spike test parameters and time frame associated with the spike interval. In addition, a revision to the “Method 6 Alternative Technology” notification to PHMSA and “no objection” process consistent with the recommended §192.607 procedure was approved.

SUMMARY OF MARCH 2, 2018 GPAC MEETING

On March 2nd PHMSA conducted a GPAC meeting by teleconference. Key items discussed during the GPAC teleconference are summarized below:

Strengthening IM Assessment Methods 
  • Applicability of this part will be addressed at the next GPAC meeting. Included in the details for the spike test procedure in the proposed §192.506 was the following:
  • Change spike pressure to the lesser of 100% SMYS (change from 105%) or 1.5 times MAOP
  • Industry recommended the application of spike tests only when specific crack defects are of concern (e.g., fatigue manufacturing defects, environmental crack growth, etc.)
  • Reduce spike hold time to a minimum of 15 minutes (reduced from the 30 minutes proposed in the NPRM) after the spike pressure stabilizes
  • Revise language to refer to time-dependent cracking
  • Revise proposed §192.506(g) to incorporate same “no objection” language the committee approved for §192.607 and with a timeframe of 90 days
  • Revise proposed §192.506(g)(8) to incorporate “qualified technical subject matter expert” language at the SME requirements

 

Pipeline Assessments Outside of High Consequence Areas (HCAs)

One of the fundamental revisions of the proposed Rule is the expansion of transmission pipeline integrity assessments outside of HCAs. There was significant discussion regarding the proposed 15-year initial assessment and 20-year re-assessment intervals, elevated highways as they relate to vertical Potential Impact Radius (PIRs) as well as concerns related to the proposed definition of Moderate Consequence Area (MCA), specifically related to “occupied site”. With regards to the proposed MCA definition in §192.3, the following details were discussed:

  • A recommendation was made to modify the proposed definition for MCAs to remove “5 or more persons” and the timeframe of “50 days in any twelve (12) month period” from the criteria for an occupied site. Industry expressed great concern over the practicality and feasibility to identify the number of occupants for these small occupied sites
  • Clarification that highways with 4 or more lanes are included as MCAs and a commitment to work with Federal Highway Administration (FHA) to provide operators with more clear information to be included in the Preamble of the Final Rule
  • Revise the MCA highway description to remove reference to “rights-of-way” and add language so that the highway definition consists of “any portion of the paved surface, including shoulders”
  • The preamble in the Final Rule will discuss the definition of “piggable pipeline”

 

With regards to Assessments Outside of HCAs in proposed section §192.710 the following details were discussed:

Revise the requirement for the initial assessment from 15 years as proposed to 14 years and reduce the timeframe for periodic reassessments from 20-year intervals to 10-year intervals. Assessment schedules to be prioritized based on risk and applicable to lines with an MAOP greater than or equal to 30% SMYS

Operators must select assessment methods based on the threats to which the pipeline is susceptible. Direct assessment is allowed where appropriate but may only be used to assess applicable threats

Revise the “Applicability” requirements in proposed §192.710(a) to apply only to lines with MAOP > 30% SMYS and remove low-stress assessments (<30% SMYS) as proposed in §192.710(c)(8)

Record Retention Requirements 

PHMSA proposed to clarify numerous records requirements. The GPAC meeting in March 2, 2018 addressed those record requirements for §§192.13(e), 192.67, 192.127 and 192.205 as well as Appendix A. Detailed discussions were held on the following topics:

Remove the proposed additional records requirements in §192.13(e) and the associated records requirements in Appendix A

Provide specific records requirements language in the Code rather than outside of regulatory requirements (i.e. Advisory Bulletins) or other guidance documents to better allow operators to prepare for the necessary records requirements

Clarify the records requirements for pipeline components in the proposed §192.205 apply only to components > 2 inches nominal diameter

Revise the proposed material, pipe design and pipe component requirements are not retroactive

Repair Criteria (inside and outside of HCA)

Remaining technical issues such as “response versus repair” criteria and remaining strength calculations were left for discussion at the March 26-28 GPAC meeting. The general consensus was the need for PHMSA to provide industry with additional technical data supporting metal loss with respect to predicted failure pressure calculations. The discussion among Committee members was that PHMSA was being overly conservative on this issue. Specific recommendations for “Repair Criteria” were discussed in greater detail at the March 26-28 meeting.

SUMMARY OF MARCH 26-28, 2018 GPAC MEETING

On March 26-28, 2018 PHMSA conducted a GPAC meeting in Washington, DC. Key items discussed during the GPAC teleconference are summarized below:

The Gas Transmission and Gathering Pipeline Rule will be split into three Packages to facilitate the rulemaking process

1. MAOP Reconfirmation, Expansion of Assessments and other related issues

2. Repair Criteria

3. Expansion of regulations to additional Gas Gathering Lines

Major Topics of Discussion
  1. Overview of Approach to Address Gas Gathering lines to be the primary topic on the agenda at June 12-14 GPAC Meeting
  2. MAOP Reconfirmation and related items. Continuation of discussions from December meeting:
  • Strike proposed §192.624(a)(1) and address cracks in HCAs in new §192.917(e)(6)
  • Revise language in §192.624(a)(2) to reference “Records to establish MAOP” and strike Subpart J
  • Proposed MAOP verification for grandfather pipelines to be limited to ≥ 30% SMYS PHMSA to conduct a cost-benefit analysis for Class locations 3& 4 and non-HCAs < 30% SMYS
  • Method 2- Pressure reduction; expand the “look-back” period from 18 mos. to 5 years
  • Remove FM requirements from §192.624 and place in a new §192.712. Use actual toughness values or default Charpy values proposed by Interstate Natural Gas Association of America (INGAA) study (13 ft-lb (body) and 4 ft-lb (seam) until actual values are obtained by testing
  • Method 5- Pressure reductions for small PIR and diameters revise to apply to PIR ≤ 150 ft., expand the “look-back” period for from 18 mos. to 5 years. Strike ECDA, crack assessments, odorization and remaining life calculations. Reduce patrols/ leak surveys to 4 times/year (Class 1&2) or 6 times/year (Class 3&4)
  • Subpart J pressure test records must be Interstate Natural Gas Association of America (TV&C)

1. Other Proposed Rule Amendments Related to MAOP

  • Remove text in §192.619(e) that duplicates §192.624. Move into (a)
  • PHMSA to provide guidance regarding TV&C Records in the preamble of the Final Rule
  • Increase PT factor for Class 1 location from 1.1 to 1.25
  • §192.619(f) is not retroactive and applies only to onshore, steel Gas Transmission lines
  • §192.619(a)(3) is not applicable if pipeline was pressure tested in accordance w/ §192.619(a)(2)
  • Scope of §192.607 is not applicable to distribution lines
  • Proposed changes to §192.605(b)(5) will be deleted to eliminate confusion

1. Revisions Related to Integrity Management (§192.917(e)(3) & (e)(4))

  • Revise §192.917(e)(3) & (e)(4) to incorporate language previously included in

§192.624(a)(1) and reference the new FM section (§192.712)

  • Insert a new §192.917(e)(6) to address cracking in HCAs (similar to corrosion in §192.917(e)(5)

1. New Definitions (192.3)

  • Withdraw proposed definitions for legacy construction, legacy pipe, modern pipe and electrical survey
  • Agreed on definitions for Close Interval Survey, new definition for dry gas, transmission line, in-line inspection, ILI tool, segments that can accommodate inspection by ILI tool, TV&C will be explained in the Preamble
  • Transmission line means a pipeline, or related series of pipelines, other than a gathering line, that (1) Transports gas from a gathering line or storage facility to a distribution center, storage facility, or large volume customer that is not down-stream from a distribution center; (2) has an MAOP of 20 percent or more of SMYS; transports gas within a storage field; or (4) is voluntarily designated as a transmission line by the operator. PHMSA will include a new definition for “distribution center” in the Final Rule
  1. Repair Criteria Revisions (§§192.711, 192.713 & 192.933)
  • PHMSA proposed and the GPAC voted to approve significant new repair criteria for both inside and outside of HCAs, including additional criteria over and above that proposed in the NPRM

 

Structural Integrity will attend and continue to provide client updates following the next GPAC meeting scheduled for June 12-14, 2018 in Washington, DC.

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