United States: PHMSA Proposes Rules To Expand Gas Pipeline Safety Regulations

On March 17, 2016, the Pipeline and Hazardous Materials Safety Administration ("PHMSA") issued a Notice of Proposed Rulemaking ("NPRM") expanding regulations for gas transmission and gathering pipelines. Specifically, PHMSA proposes, among other things, to (1) enhance integrity management ("IM") requirements, (2) create a new clarification applicable to gas pipelines entitled "moderate consequence areas" or "MCAs," (3) require pressure testing for older pipelines that have not previously required testing, and (4) modify regulations regarding onshore gathering lines.

On August 25, 2011, PHMSA published an Advance Notice of Proposed Rulemaking ("ANPRM") seeking feedback regarding the revision of the pipeline safety regulations applicable to gas transmission and gathering pipelines. In particular, PHMSA requested comments regarding whether IM requirements should be revised and whether other issues related to system integrity should be addressed by strengthening or expanding non-IM requirements. In both the ANPRM and the NPRM, PHMSA states that the purpose of its proposed rules is to increase the level of safety for those pipelines that are not in high consequence areas ("HCAs") as well as clarifications and selected enhancements to IM requirements to improve safety in HCAs. PHMSA also states that these measures and clarifications are needed because incidents with significant consequences and various causes continue to occur on gas pipeline systems, and because PHMSA has identified concerns during inspections of gas pipeline operator programs.

In the NPRM, PHMSA proposes several revisions to IM requirements, including (1) revising IM repair criteria for pipeline segments in HCAs to address cracking defects, non-immediate corrosion metal loss anomalies, and other defects; (2) explicitly including functional requirements related to the nature and application of risk models currently invoked by reference to industry standards; (3) explicitly specifying requirements for collecting, validating, and integrating pipeline data models currently invoked by reference to industry standards; (4) strengthening requirements for applying knowledge gained through the IM Program models currently invoked by reference to industry standards; (5) strengthening requirements on the selection and use of direct assessment methods models by incorporating recently issued industry standards by reference; (6) adding requirements for monitoring gas quality and mitigating internal corrosion, and adding requirements for external corrosion management programs including above ground surveys, close interval surveys, and electrical interference surveys; and (7) explicitly including requirements for management of change currently invoked by reference to industry standards.

Regarding non-IM requirements, PHMSA does not propose to change the definition for HCAs. Instead, PHMSA proposes a new "moderate consequence area" or "MCA" classification to identify onshore non-HCA pipeline segments that are located in a "potential impact circle" containing 5 or more buildings intended for human occupancy, an occupied site, or a right-of-way for a designated interstate, freeway, expressway, and other principal 4-lane arterial roadway and that would require integrity assessments. PHMSA also proposes adding requirements for monitoring gas quality and mitigating internal corrosion; adding requirements for external corrosion management programs including above ground surveys; adding requirements for management of change, including invoking the requirements of ASME/ANSI B31.8s, Section 11; establishing repair criteria for pipeline segments located in areas not in an HCA; and adding requirements for verification of maximum allowable operating pressure ("MAOP") for certain offshore, steel, gas transmission pipelines.

In addition, PHMSA proposes modifying the regulation of onshore gas gathering lines as follows: repealing the exemption from reporting requirements for gas gathering line operations and repealing the use of API RP 80 for determining regulated onshore gathering lines while adding a definition for "onshore production facility/operation" and a revised definition for "gathering lines;" and extending certain Part 192 regulatory requirements to Type A lines in Class 1 locations for lines 8 inches or greater. PHMSA states that requirements that would apply to previously unregulated pipelines meeting these criteria would be limited to damage prevention, corrosion control (for metallic pipe), public education programs, MAOP limits, line markers, and emergency planning.

Finally, PHMSA proposes requirements for miscellaneous topics. These requirements include (1) requiring inspection by onshore pipeline operators of areas affected by an extreme weather event such as a hurricane or flood, landslide, an earthquake, a natural disaster, or other similar event; (2) revising the regulations to allow extension of the IM 7-year reassessment interval upon written notice; (3) adding a requirement to report each exceedance of the MAOP that exceeds the margin allowed for operation of pressure-limiting or control devices; (4) adding requirements to ensure consideration of seismicity of the area in identifying and evaluating all potential threats; (5) adding regulations to require safety features on launchers and receivers for in-line inspection tools, scrapers, and spheres; and (6) incorporating consensus standards into the regulations for assessing the physical condition of in-service pipelines using in-line inspection, internal corrosion direct assessment, and stress corrosion cracking direct assessment.

Comments are due within 60 days following publication in the Federal Register. A copy of the NPRM is available here.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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