Thursday, August 25, 2011

PHMSA ANPRM: Safety of Gas Transmission Pipelines

Today the Pipeline and Hazardous Material Safety Administration (PHMSA) published an advance notice of proposed rulemaking (ANPRM) in the Federal Register (76 FR53086-53102 ) concerning changes that it is considering making to the Pipeline Safety Regulations (PSR; 49 CFR Parts 190-199). PHMSA is considering changes to rules governing safety of gas transmission pipelines, including potential changes to pipeline integrity management (IM) requirements and the definition of high consequence areas (HCAs).

Pipeline Integrity Management Changes

PHMSA notes that the current IM program has improved the safety of gas transmission pipelines in HCAs. Even with those improvements, however, fires and explosions like the San Bruno incident last year continue to occur. Additionally, during their inspections of current operator IM programs PHMSA has identified some concerns that “indicate a potential need to clarify and enhance some [IM] requirements” (76 FR 53088).

IM topics that have been identified for possible inclusion in the proposed rule include:

Modifying the definition of an HCA;
Strengthening the Integrity Management requirements in Part 192;
Modifying repair criteria;
Revising the requirements for collecting, validating, and integrating pipeline data;
 Making requirements related to the nature and application of risk models more prescriptive;
Strengthening requirements for applying knowledge gained through the IM program; and
 Strengthening requirements on the selection and use of assessment methods, including prescribing assessment methods for certain threats.

Issues Not Covered Under Current IM Rules

PHMSA has also identified some system integrity issues that are not adequately addressed by IM programs. They are considering strengthening and expanding these non-IM requirements. Some of the topics falling under this area include:

 Valve spacing and the need for remotely- or automatically-controlled valves;
 Corrosion control;
 Pipe with longitudinal weld seams with systemic integrity issues;
 Establishing requirements applicable to underground gas storage;
 Management of Change;
 Quality Management Systems (QMS);
 Exemptions applicable to1 facilities installed prior to the regulations; and
 Gathering lines.

Questions to Be Answered

As with ANPRMs this document does not generally specify proposed language that PHMSA. Rather, PHMSA provides a discussion of each of the 14 topics identified above. Along with that discussion they provide a list of questions that they would like to see answered in the public comment process. For example, under the topic concerning potential expansion of the current HCA definition, PHMSA includes (76 FR 53089) the following questions:

• Should PHMSA revise the existing criteria for identifying HCAs to expand the miles of pipeline included in HCAs?
• If so, what amendments to the criteria should PHMSA consider (e.g., increasing the number of buildings intended for human occupancy in Method 2)?
• Have improvements in assessment technology during the past few years led to changes in the cost of assessing pipelines?
• Given that most non-HCA mileage is already subjected to in-line inspection (ILI) does the contemplated expansion of HCAs represent any additional cost for conducting integrity assessments?
• If so, what are those costs?
• How would amendments to the current criteria impact state and local governments and other entities?

PHMSA is soliciting public responses to these questions as well as more general comments on the proposed changes to the PSR. These response can be submitted via the Federal eRulemaking Portal (; Docket # PHMSA-2011-0023). Responses need to be submitted by December 2nd, 2011.

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