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.
On December 14-15, 2017 PHMSA conducted a GPAC meeting in Washington DC. Key items discussed during the GPAC meeting are summarized below:
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:
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
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.
On March 2nd PHMSA conducted a GPAC meeting by teleconference. Key items discussed during the GPAC teleconference are summarized below:
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:
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)
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
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.
On March 26-28, 2018 PHMSA conducted a GPAC meeting in Washington, DC. Key items discussed during the GPAC teleconference are summarized below:
1. MAOP Reconfirmation, Expansion of Assessments and other related issues
2. Repair Criteria
3. Expansion of regulations to additional Gas Gathering Lines
1. Other Proposed Rule Amendments Related to MAOP
1. Revisions Related to Integrity Management (§192.917(e)(3) & (e)(4))
§192.624(a)(1) and reference the new FM section (§192.712)
1. New Definitions (192.3)
Structural Integrity will attend and continue to provide client updates following the next GPAC meeting scheduled for June 12-14, 2018 in Washington, DC.