AGA Perspectives on Current Pipeline Safety Regulations August 2014.

AGA Perspectives on Current Pipeline Safety Regulations

Augus t 2014

The American Gas Association• The American Gas Association , founded in 1918, represents

more than 200 local energy companies that deliver clean natural gas to more than 68 million Americans nationwide.

• Members deliver 94% of the natural gas in the US

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Key DOT Pipeline Safety Activities • 9 Rulemakings In Progress• 42 Legislative Mandates • Recommendations from NTSB, OIG,

GAO• Advisory Bulletins• Numerous other initiatives to improve

pipeline safety• SMS• Data Analysis Improvements• Inspection Program – Inspection Integration

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• Expected to include:• IVP: Expansion of IM + Testing

• NTSB Recommendations• Eliminate Grandfather Clause• Pressure test lines to 1.25 MAOP +

spike test• Legislation

• Confirm material strength of previously untested lines

• Located in HCAs & operating above 30% SMYS

• Repair criteria for both HCA and non-HCA areas

• Gas gathering lines & Other items• Assessment methods, corrosion control,

problematic or “legacy” pipe, etc.

Rule Status• ANPRM published

August 25, 2011• NPRM has moved

past PHMSA• Still within DOT

• Labeled a Significant rule

Safety of Gas Transmission & Gathering Lines Rule

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AGA Position on Proposed Integrity Verification Process

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• IVP Combines MAOP with TIMP expansionComplexity

• Validation is a one time activity• IVP nullifies valid MAOPs based on historical PHMSA regulations

and ASME B31.8• Lacking complete MTRs = coupon sampling program to establish

material prosperities

MAOP Foundation

• Records of historic pressure tests that currently meet code requirements should be acceptablePost Construction Pressure Test

• Introduces MCA Concept• Class 2, 3 & 4 non-HCA + Class 1 with 1 home in PIRMCA

• High Stress Line is defined as ≥ 20% SMYS• Legacy Pipe: No Common Definition• Susceptible Seam Type: No Common Definition• Engineering Critical Assessment (ECA): Not currently defined or

understood

New Definitions

• Should be situational and operational decisionSpike Test

Other Pipeline Safety Rulemakings in ProgressEFVs Beyond Single Family

HomesMiscellaneous

RuleExcavation

Damage Prevention

OQ, Cost Recovery and

Other PL Safety Proposed Changes

Plastic PipeRupture

Detection and Valves

Supportive of installation on:

-branched service lines

-Multi-family dwellings and

small commercial up to 1,000 SCFH where load is not

expected to increase

In AGA’s Commitment to

Enhancing Safety

AGA generally supports the

proposed requirements for qualifying plastic

pipe joiners

Concerns on proposed

amendments for performance of

post-construction inspectionsShould be a significant

rulemaking.

AGA encourages PHMSA to

address states that have

inadequate enforcement

AGA generally supports: Operator

Qualification for New Construction

Inclusion of special permit

renewal requirements in

regulations.

Cost recovery on design safety

reviews

AGA supports:

Increase in the design factor from 0.32 to 0.40 for PE

pipe

Incorporation of ASTM D2313-09aif not included in

the Standards Incorporated by

Reference rulemaking

AGA Members are Taking Action:

Commitment to Enhancing Safety:

Evaluate use of ASVs and RCVs on Transmission HCA

block valves

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• AGA Supports a modernization of the NPMS

• Dramatic increase in quantity of data requested

• Concerns on security of pipeline infrastructure

• Industry believes this request should be formalized in Rule Making not Information Collection

• Proposal is significant burden on many operators• PHMSA Estimated Burden = 420,516 hours

• 347 hours / respondent• Very high estimate for PHMSA• & still too low

Examples of Data Requests

National Pipeline Mapping System

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New Data Requested Includes• Narrow positional

accuracy requirements

• 5 Feet• Pipeline material and

manufacturing details• Location details on

facilities

Federal Register Notice = July 30, 2014Comments Due = September 29, 2014

Stay Tuned…

… New National Transportation Safety Board (NTSB) Incident Report

... New NTSB Safety Study on Transmission Integrity Management

... Pipeline Safety Reauthorization

… Pipeline Safety Hearings

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… Office of Inspector General Reports?

… Government Accounting Office Reports?

Erin Carmichael KurillaManager, Engineering [email protected]

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