2
Wait a minute . . .As we go through this today, you’re gonna think,
Wait a minute, here. Isn’t this the same stuff you talked about last year?Did you just recycle the same presentation and reorganize it to make it look different? And where’s that fried turkey picture?
Well, it’s right here, and the oil is getting hotter -
4
There is a lot in the works, but not moving very quickly• Gas transmission mega-rule• Valve and rupture detection rule• Miscellaneous amendments• State damage prevention enforcement• OQ, cost recovery, notifications• Safety of hazardous liquid pipelines• Excess flow valves• Standards Update• Plastic pipe
5
And not rules, yet• Class location requirements• GIS / NPMS information collection• Safety management systems• Midstream jurisdiction• Advisories
6
Gas Transmission Mega-Rule
• Expanded HCA definition – PIR, MCA• Additional IM requirements – in and out of
HCA/MCA• Anomaly response & repair criteria• More gathering lines included• EC, IC, SCC requirements• IVP – MAOP confirmation• PHMSA schedule – NPRM 1-28-2015, 60-day
comment period
7
IVP• MAOP confirmation• A process that parallels 192.619 (a) (sort of) for
vintage and other lines• Talked about it last year• You remember the proposed flowchart
10
Valve and Rupture Detection Rule
• Mandatory automated valves for HCA, Class 3 & 4 locations
• Rupture detection integrated into valve operation• Goal is rapid mitigation and enunciation of large
release events• Anticipated bias toward automatic rather than
remote operation• SCADA and alarm impacts• Likely based on two reports containing significant
misperceptions• PHMSA schedule – NPRM 5-1-2015, 90-day comment
period
11
Miscellaneous Amendments
• Rail shipment of pipe must be per API 5L1• 1.5 x MAOP test for all ASME vessels• Welder & welding operator definition and
requalification• Individual cannot inspect own work• Lateral definition impacting odorization
requirements• PHMSA schedule – Final Rule 2-4-2015
12
State Damage Prevention
Enforcement• Minimal impact to operators• Primarily a PHMSA – State issue• Allows PHMSA to enforce state laws if states
ineffective• May also include one-call requirements differing
from current• PHMSA schedule – Final Rule 2-4-2015
13
OQ, Cost Recovery, Notifications
• Expansion of OQ (new construction?)• Renewal process for special permits• More stringent incident reporting• Cost recovery for design reviews / construction
inspections• PHMSA schedule – NPRM 1-28-2015, 90-day
comment period
14
Safety of Hazardous Liquid Pipelines
• Expansion of HCA definition / assessments beyond HCAs
• Response / repair criteria in and outside HCA• Leak detection beyond HCAs• Expanding regulation and reporting of currently
exempt lines – more and smaller gathering lines• PHMSA schedule – NPRM 11-20-2014, 90-day
comment period
15
Excess Flow Valves• EFVs on all new and renewed gas service lines• EFVs on all practicable structures other than
single family dwellings• Could cover farm taps or non-LDC direct-feed
customers• PHMSA schedule – NPRM 11-3-2014, 90-day
comment period
16
Standards Update• Update IBR standards in 192, 193, 195• Addresses 22 of 60+ IBR standards• Must be available for free to the public• “On the internet” requirement eliminated• PHMSA to determine what constitutes “free to the
public”• PHMSA schedule – NPRM 8-16-2013, FR stage
17
Plastic Pipe• Authorized use of PA12 • AGA petition to raise D.F. from 0.32 to 0.40 for PE
pipe • Enhanced Tracking and traceability • Miscellaneous revisions for PE and PA11 pipelines • Additional provisions for fittings used on plastic
pipe• PHMSA schedule – NPRM stage
18
Class Location Requirements
• PLS Act requirement to study• Do IMP actions reduce the need for class
locations?• Unlikely that class location requirements will
disappear• Potential for significant reduction in class location
dependence on future pipelines• However, extensive IM would be required• PHMSA actions – Public meeting 4-16-2014• Report to Congress under review• No additional reports, publication or rulemaking
schedule
19
GIS / NPMS Information Collection• Increased positional accuracy in NPMS• ± 5 ft in HCA, ± 50 ft elsewhere• Collection of data on 31 attributes – OD, WT, Gr,
seam, age, MAOP, product, class location, HCA, valves, leak detection, throughput, etc.
• Info to help – emergency responders, local officials, risk assessments, maybe annual reports
• Extremely expensive• PHMSA schedule – Workshop in November 17,
2014Earliest effective date - 2016
20
Safety Management Systems
• NTSB recommendation P-12-17 to API to develop standard for safety management systems (arose from Enbridge failure)
• Draft API-RP-1173 balloted – 999 comments• PHMSA heavily involved and highly supportive• Structured around 10 elements• What to do, but not how to do it• Good concepts, but extremely prescriptive• PHMSA says will not be in regulations, but it will be an
“expectation” & could be enforced through Safety Orders• Several references to “regulation” at recent TPAG• PHMSA schedule – none known
21
Midstream Jurisdiction• Jurisdiction question raised about a year ago• Ad hoc group from advisory committee studying• Clarify PHMSA vs OSHA jurisdiction of facilities
for:o Dehydrationo NG processingo NGL liquids fractionationo Petrochemical operationso Storageo Terminal operations & transportation
• Goal – minimize regulatory gaps and overlaps
22
Advisories • Program evaluation and metrics• Conversion / reversal guidance• Construction notification – 60 days before
“construction related activities”, include materials purchasing, off site fabrication
• Enbridge lessons – deficiencies in IM, control center, public awareness
• Recall of some TDW repair clamps• Telephonic notification time limit – 1 hour• Reporting MAOP exceedances• Communication during emergency situations• Verification of MAOP records
23
Metrics Guidance• October 2014 – Program Evaluation & Meaningful
Metrics• Rigorous program evaluation
o Leading and lagging indicatorso Plan – do – check – act
• Goals, metrics and more metrics• 6 – 12 “meaningful” metrics – publicize
o Or maybe 100 or so
• Gas & Liquid teams developing• Finalize enforcement metrics (?)• Apparent close ties to SMS
25
Metrics Example Leading ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐Indicators‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐Lagging
Failure Mechanism Selected Process or Operational Activities for Threat Prevention or Management
Deterioration Indicators Failure or Direct Integrity Metrics
Other Third Party Damage, including vandalism, third‐party vehicle contact with facility, interferences and other intentional or unintentional acts
● ROW and patrolling program
● Line marking program
● Training and OQ tasks
● Depth of Cover survey program
● Use of Damage Information ReportingTool (DIRT) report data
● Public awareness program
● Physical protection of aboveground facilities
● No. of patrol reports that have not had necessary follow‐up completed
● Reports by law enforcement agencies and first responder agencies
● No. of pig runs with indicated damage
● No. of sites lacking security fencing and /or cameras or other features
● No. of susceptible sites lacking vehicle impact barriers
● No. of aboveground facilities hit by vehicles
● No. of vandalism incidents without a release
● Incidents of damage due to underground inference with adjacent structures, utilities, etc.
● Releases due to third party damage‐
● Releases due to prior excavation related damage‐
● Releases due to prior non excavat‐ ion‐related mechanical damage
26
Conversion & Reversal Guidance
• September 2014 PHMSA Guidance doc issued• Covers conversions, reversals, product changes• Largely follows existing regulations• Helps point out factors & changes that need to be
considered• Pressure & temperature profile changes• HCA identification• Valve and leak detection requirements• Emergency response / spill considerations
27
PG&E San Bruno • The CPUC has proposed a $1.4 billion fine – in addition
to what has already been spent on the system• U.S. DOJ has issued a superseding indictment – 28
counts• Indictment issues – Obstruction, records, threat
identification, baseline plan and assessment methods• Estimated PG&E derived gains of $281 million and
victims suffered losses of $565 million• No individual indictments – yet• PG&E appealing fine, pleading not-guilty to indictment
28
Recent GAO Report• DOT regulation has not kept pace with
transportation environment• Large gathering lines, same risk as transmission,
remain outside regulations• Recommend rulemaking to address gathering
pipeline safety• PHMSA agrees and is developing proposed
regulations
29
Web Locations• Advisory Bulletins
http://phmsa.dot.gov/pipeline/regs/advisory-bulletin
• Rulemakingshttp://phmsa.dot.gov/pipeline/regs
• Noticeshttp://phmsa.dot.gov/pipeline/regs/notices
• Final Ruleshttp://phmsa.dot.gov/pipeline/regs/rulemaking/final
• Regulatory Agendahttp://www.reginfo.gov/public/do/eAgendaMain
Top Related