Citing the San Bruno, California explosion as a pivotal event driving a push for enhanced safety regulations, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published an Advance Notice of Proposed Rulemaking (ANPRM) on August 25, 2011. The ANPRM does not provide specific proposed language for the regulatory changes, but asks for public comment on 14 specific topics related to pipeline integrity management and forecasts extensive regulatory changes under consideration by the agency. 

Taken as a whole the measures being considered foretell a far more prescriptive approach than the current regulatory scheme. Many of the measures under consideration by PHMSA would expand the agency's reach and control. If adopted, the measures would require operators to make significant changes to current inspection, monitoring, data integration and recordkeeping practices.

Under consideration are measures to repeal exemptions for pre-1970 pipelines, requirements for reduction in operating pressure for certain pipelines, and prescriptive standards for assessing risks. 

Industries affected:

Natural Gas Transmission Pipelines Natural Gas Underground Storage Facilities Onshore Natural Gas Gathering lines Landfill Gas Systems

Key measures being considered by PHMSA include:

  • Changing  the definition of High Consequence Areas (HCAs) to expand the miles of pipeline included in HCAs, including:
    • Possible inclusion of all Class 3 and 4 locations
    • Increasing the width used for determining class location for pipelines over 24 inches in diameter that operate above 1000 psig
    • Increasing the number of buildings intended for human occupancy in method 2 of HCA identification
    • Oversight by state and local government of the HCA identification process
  • Additional safety measures, including those similar to Integrity Management for areas outside of HCAs.
  • Mandating additional preventive and mitigative requirements for pipeline segments in HCAs and outside HCAs including:
    • Additional line-of-sight markers
    • Depth of cover surveys
    • Close interval surveys for cathodic protection verification
    • Coating surveys
    • Recoating
    • Additional right-of-way patrols
    • Shorter in-line inspection (ILI) run intervals
    • Additional gas quality monitoring
    • Heightened standards for marking pipelines located by one-call
  • Modifying repair criteria to require additional repairs in and out of HCAs including:
    • Requiring repairs at a higher threshold
    • Aligning repair safety margins with new construction standards
    • Using more stringent repair criteria in class location change areas
    • Establishing PHMSA risk-tiering criteria
    • Shortening repair schedules for anomalies in non-HCA segments
    • Prescribing explicit ILI assessment standards for all ILI vendors and operators
    • Prescribing standards for qualification of persons interpreting ILI data and for quality and accuracy of ILI tools
  • Requiring more rigorous collection, validation and integration of pipeline data including:
    • Requiring verification of data on pipe, pipe seam type, pipe mechanical and chemical properties, mill inspection reports, hydrostatic tests reports, coating type and condition, pipe leaks and ruptures and operations and maintenance (O&M) records through in situ examinations of the pipeline
    • Making current requirements more prescriptive to improve data integration and risk assessment
  • Mandating the use of specific risk models for operator analysis of pipeline system integrity
  • Creating specific requirements for applying knowledge gained through the operator's integrity management program including:
    • Specifying a maximum period in which pipeline risk assessment must be reviewed and validated
    • Specifying data integration standards
  • Strengthening the requirements on selection and use of assessment methods including:
    • Requiring ILI assessment whenever possible
    • Adding requirements to expand modification to transmission pipelines to accommodate ILI tools
    • Establishing standards for ICDA and SCDA assessments and incorporating these into the regulations
    • Establishing remediation, hydrostatic test and replacement standards to address internal corrosion
    • Requiring a one-time pressure test to address manufacturing and construction defects
  • Changing the requirements for sectionalizing block valves including:
    • Limiting the maximum time required for an operator's crews to reach a block valve site that is not remotely controlled
    • Requiring more stringent minimum spacing of either remotely or automatically controlled valves between compressor stations
    • Requiring all sectionalized block valves to be capable of being controlled remotely
    • Adopting prescriptive decision criteria for operator evaluation of additional valves, remote closure and/or valve automation
  • Revising Subpart I to create more rigorous corrosion control including:
    • Prescribing additional requirements for post-construction surveys for coating damage or to determine the adequacy of cathodic protection
    • Requiring interference current surveys
    • Requiring additional measures to prevent internal corrosion
    • Prescribing specific practices and standards to address prevention, detection, assessment and remediation of stress corrosion cracking
    • Tightening the definition of corrosive gas stream
    • Prescribing HCAs and non-HCAs close interval survey timing intervals
    • Prescribing control measures with specific defined conditions and mitigative measures
    • Requiring that operators perform a critical analysis of all factors that influence SCC for threat analysis for every pipeline segment
    • Requiring integrity assessment using prescribed methods
    • Requiring a period analysis of operator corrosion management programs
  • Establishing federal safety standards governing underground gas storage facilities  including:
    • Inspection intervals
    • Abandonment standards â—¦Standards for internal and external corrosion monitoring
    • Welding, pressure testing and designing safety factors
    • Emergency shutdown requirements
    • Emergency response and public communication
    • O&M procedures
  • Asserting greater control over Management of Change including:
    • Requirements for IM procedures, O&M manuals, facility drawings, emergency response plans and procedures and documents to be maintained for the life of the pipeline
  • Imposing requirements related to Quality Management Systems including their design and application to control equipment and materials in new construction, and control of work product of contractors
  • Requiring pressure testing at or above 1.1 times MAOP or class location criteria for previously exempt pipelines
  • Repealing the MAOP exemption for pre-1970 pipelines •Modifying the regulation of Gas Gathering Lines including:
    • Requiring annual, incident and safety related condition reports by operator of all gathering lines
    • Amending 49 CFR 192 to change the definition of gathering line
    • Establishing new risk-based safety requirements for large-diameter, high-pressure gas gathering lines in rural locations
  • Adding regulations governing landfill gas that contains higher concentrations of hydrogen sulfide and or carbon dioxide:
    • Enhancing requirements for internal corrosion control for gathering pipelines
    • Applying Gas Integrity management Requirements to onshore gathering lines

What you should do:

The public comment period for the ANPRM ends on December 2, 2011.  Comments may be submitted using docket number PHMSA-2011-0023, and may be submitted electronically, by fax or by mail.