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Pipeline Safety Update
Christina SamesVice President, Operations & Engineering ServicesAmerican Gas Association
What I will cover:• Pipeline Safety Oversight & Influence• Executive Orders & Presidential
Memos• Pipeline Safety Regulatory Update
Pipeline Safety: Oversight and Influence
Pipeline Safety Oversight
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LegislativePipeline Safety Legislation
Every 4‐5 Years
Federal RegulatorsU.S. Dept. of Transportation’sPipeline & Hazardous Materials Safety Administration (PHMSA)National Oversight; Federal
Standards
National Transportation Safety Board (NTSB)Investigates Accidents
Issues Recommendations
State RegulatorsBeyond Federal StandardsIssue Regulations Specific
to that State
The PublicWants more data
Reactive to Incidents
Regulatory ProcessAdvance Notice of Proposed Rulemaking: Series of questions for public comment. Used when the direction of the regulation is unclear.
Notice of Proposed Rulemaking: Proposes new regulation or change to existing regulation. Open for comment.
Gas Pipeline Advisory Committee: Equal representation from government, industry and public. Last stop for all of PHMSA/Office of Pipeline Safety regulations
Final Rule: The final decisionOccasionally: Interim Final Rule – Final rule with comment period; Can change due to comments
All Published in the Federal Register5
PHMSA OST OMB Federal Register
Significant Rules can take well over a year to get from PHMSA to the Federal Register
Federal Rulemaking Process
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Significant Rule
PHMSA Federal Register
Non‐Significant Rule
Significant rules must go through the Office of the Secretary of Transportation (OST) and the Office of Management & Budget (OMB). OMB determines What Rules Are Significant
What makes a rule Significant?
• Have an annual effect on the economy of $100 million or more
• Create a serious inconsistency or with another agency• Materially alter budgetary impact of entitlements, grants, user fees, or loan programs or the rights and obligations of recipients thereof; or
• Raise novel legal or policy issues arising out of legal mandates, the President’s priorities, or the principles set forth in this Executive order.
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Executive Orders & Presidential Memoranda
Executive Orders & Presidential Memos
•Regulatory Freeze Pending Review•Reducing Regulation and Controlling Regulatory Costs ("2 for 1" order)
•Comprehensive Plan for Reorganizing the Executive Branch
•Construction of American Pipelines•Expediting Environmental Reviews & Approvals for High Priority Infrastructure Projects
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Reducing Regulation and Controlling Regulatory Costs (Two for one order)
“Unless prohibited by law, whenever an executive department or agency… promulgates a new regulation, it shall identify at least two existing regulations to be
repealed.”
“… the total incremental cost of all new regulations, including repealed regulations, to be finalized this
year shall be no greater than zero.”
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Reducing Regulation & Controlling Regulatory Costs
•Only applicable to significant rulemakings.•Exempt: Rules required by statute or court order; Independent agencies (but encouraged to follow)
•An agency can bank deregulatory actions for later use or trade across the whole department.
•With permission from OMB, one agency can use a banked deregulatory action created by another department.
•Expect: More scrutiny of “significant rules”, longer timelines, more “non‐significant rulemakings”.
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Comprehensive Plan for Reorganizing the Executive Branch
•Federal agencies to send OMB (by 9/17) a reorganization plan that describes how “to reorganize governmental functions and eliminate unnecessary agencies…, components of agencies, and agency programs.”
•OMB to invite “the public to suggest improvements in the organization and functioning of the executive branch.”
•OMB to develop a plan to reorganize executive branch, considering public comments and “relevant factors”
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Comprehensive Plan for Reorganizing the Executive Branch – Relevant Factors
•Whether the functions are appropriate for Federal Government or would be better left to State/local governments or private sector;
•Whether some or all of the functions or administrative capabilities are redundant;
•Whether the costs of operating the agency, office or program “are justified by the public benefits”; and
•The costs of shutting down or merging agencies, offices or programs, including “addressing the equities of affected agency staff.”
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Constructing American Pipelines
“The Secretary of Commerce, in consultation with all relevant executive departments and agencies, shall develop a plan under which all new pipelines,
as well as retrofitted, repaired, or expanded pipelines, inside the borders of the United States, including portions of pipelines, use materials and equipment produced in the United States, to the
maximum extent possible and to the extent permitted by law.”
Due: July 23
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Constructing American Pipelines•Comments sent to DOC (sent April 7)
•The importance of energy infrastructure, including pipelines, to the American economy.
•Quantities of oil & gas transported• Industry’s investment in infrastructure. • Jobs associated with the industry• Importance of free trade.
• ICF study by trades on feasibility & consequences of proposal – Submitted to DOC mid May.
PHMSA Rulemakings
Current and Pending Regulations• Recent Rules:
• Excess Flow Valves Beyond Single Family Homes• Operator Qualification (OQ), Cost Recovery, Accident & Incident
Notifications, and Other Pipeline Safety Proposed Changes Rule (OQ will now be a separate rulemaking)
• Natural Gas Underground Storage• Safety of Gas Transmission & Gathering Lines Rule• Plastic Pipe Rule• Valve Installation and Minimum Rupture Detection Standards• National Pipeline Mapping System• Standards Update Rule – 2015 and Beyond• We also expect: Quality Management, Public Awareness, LNG for
Small Facilities
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Excess Flow Valves (EFVs) Beyond Single Family Homes: Effective April 14, 2017
Install: EFVs on multi‐family residences & small commercial
Notice: To customers that currently do not have an EFV
Manual Service Line Shut‐off Valves: Where meter capacity exceeds 1000 SCFH, install manual curb valves or EFV.Must be installed “in such a way to allow accessibility during emergencies” and are subject to “regular scheduled maintenance, as documented by the operator and consistent with the valve manufacturer’s specification.”
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OQ, Cost Recovery, Accident & Incident Notifications, and Other Pipeline Safety Proposed Changes Rule
Effective March 23, 2017
Control Room Management: • Operators to define controller roles/responsibilities:
• During emergency, including controller's responsibility to take action & communicate with others
• Roles, responsibilities and qualifications of others with authority to direct or supersede specific technical actions of a controller.
• Training:• To provide controller working knowledge of pipeline system, especially during abnormal operating conditions
• Control room team training/exercises that include both controllers & others who would reasonably be expected to operationally collaborate with controllers (due 1/23/18)
OQ, Cost Recovery, Accident & Incident Notifications, and Other Pipeline Safety Proposed Changes Rule
Welding Procedures: Added API 1104 Appendix B for in‐service welding qualification.
Accident/Incident Notification: Within 1 hour of confirmed discovery. No requirement to estimate gas lost.
Farm Taps: Prescriptive inspection & testing requirements.• Pressure regulating/limiting/relief/automatic shutoff devices & equipment to be inspected/tested every 3 years
• Applies to service lines connected to production, gathering, or transmission pipe not operated as a part of a distribution system.
PHMSA plans a second Final Rule to address OQ in 2017.
Underground Storage Interim Final Rule
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• Incorporates into regulation 2 recommended practices (RPs): American Petroleum Institute (API) RP 1170/1171
• Issues with Interim Final Rule:• Requires plan be developed and all actions taken within 1 year• Makes all non‐mandatory portions of RPs mandatory
Safety of Gas Transmission & Gathering Lines
• Largest rule since federal pipeline safety regulations were created
• Covers over 30 major areas• Performance to prescriptive regulation
• Extends to distribution pipelines• Retroactive requirements (beyond PHMSA’s authority)
• Extensive record and material validation requirements
• Extensive testing requirements
As proposed, cost of rule will be billions of dollars. Example costs per operator:• $4.6M: Identify
moderate consequence areas (MCAs)
• $3.9M annually: Maintain MCA database
• $2.5M: Records research
• $39M: Field verification
The Plastic Pipe RuleJune 1, 2016: GPAC provided guidance and inputTracking & Traceability: Remain consistent with ASTM F2897• Phase 1: 1 Year for Manufacturers to Adhere to Marking
Standards• Phase 2: 5 Years for Operators to Implement Tracking &
TraceabilityPlastic Pipe Installation: PHMSA indicated some proposed requirements will be removed or revised for clarity: • Backfill Requirements • Trenchless Excavations of Mains & Services• Socket Fusion Diameter Restrictions
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The Plastic Pipe RuleSeemingly Retroactive RegulationsPHMSA has confirmed the seemingly retroactive requirements were only intended to be prospective, including:
• Leak clamps may not be used as a permanent repair method• Protection of electrically isolated metal alloy fittings
Design Factor, Expanded Use of PA‐11, Incorporation of PA‐12: Moving forward as proposed in the NPRM.• Additionally, PHMSA will consider retroactive application of new PE
Design Factor and other pipe diameter sizes that were not included in the NPRM.
Fusion Equipment Maintenance: PHMSA will limit to requiring operators maintain equipment in accordance with the manufacturer’s recommended practices or written procedures proven to be equivalent.
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Valve Installation and Minimum Rupture Detection Standards
Significant RuleNPRM with OST; Estimated NPRM publication 2017
Expected to cover• Rupture detection and response time metrics, including integration of ASV
and RCV placement (Objective: Improve overall incident response)
Will attempt to addressLegislation: If appropriate, require ASVs, RCVs or equivalent technology
on new or fully replaced transmission lines (where economically, technically & operationally feasible)
NTSB Recommendations: Equip SCADA systems with tools to assist in recognizing and pinpointing leaks (distribution and transmission)
AGA Members are Taking Action“Evaluate use of ASVs and RCVs on Transmission HCA block valves”
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National Pipeline Mapping SystemInformation Collection Request – Dramatically increases amount of data collected (from handful to nearly 30) and level of accuracy (500’ to 50‐100’)
First Submission: On Hold
OMB Denied PHMSA’s Proposal to Modify the NPMS. Operators to submit under existing requirements.
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Additional Pending Regulations
Safety of On‐Shore Hazardous Liquid PipelinesNonsignificant; Estimated Final Rule Publication: 2017
Standards Update Rule – 2015 and BeyondNonsignificant; Estimated NPRM Publication: 2017
State Pipeline Safety Program CertificationNonsignificant; Estimated NPRM Publication: 2017
Referenced in Gas Transmission Rule or Discussed at Workshops:
Quality ManagementPublic Awareness
LNG for Small Facilities
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One last thing…
Construction Inspection
§192.305 hasn’t gone away and still needs to be resolved.
Christina [email protected]
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Find Us Online
www.aga.org
www.truebluenaturalgas.org
http://twitter.com/naturalgasflk
www.facebook.com/naturalgas
www.linkedin.com/company/50905?trk=tyah
Additional Slides
First, a few of AGA’s Pipeline SafetyMessages
There is nothing more important to America’s natural gas utilities than the safety of the customers we serve and the communities in which we operate.
“AGA and its member companies are committed to promoting positive safety cultures among their employees throughout the natural gas distribution industry. All employees, as well as contractors and suppliers providing services to AGA members, are expected to place the highest priority on employee, customer, public and pipeline safety.”— Excerpt from AGA SafetyCulture Statement
2.5Million miles of
pipeline
Safely Transported Across the CountryNatural gas pipelines:• transport approximately
one‐fourth of the energy consumed in the U.S.
• the safest form of energy delivery in the country
Natural gas is delivered to customers through a 2.5 million‐mile underground pipeline system. This includes 2.2 million miles of local utility distribution pipelines and 300,000 miles of transmission pipelines that stretch across the country.
Modernizing InfrastructureAll natural gas utilities upgrade and modernize their infrastructure through risk‐based integrity management programs.
41 states including the District of Columbia have specific rate mechanisms that foster accelerated replacement of pipelines no longer fit for service.
41States
• Work with governors, legislators and state regulators to develop innovative models for replacing pipe no longer fit for service
• Enhances the safety and reliability of our pipeline network
• Provides natural gas access to homes and businesses across the nation
• $22 billion spend annually to help enhance the safety of natural gas distribution and transmission systems.
• Pockets of this country do not have access to natural gas
• Homes, businesses, factories and electric generators have the capacity to efficiently utilize more natural gas
• Gas utilities are working with energy planners, regulators and policymakers to bring the comfort and savings of natural gas to these new customers.
Pipelines Bring Opportunity
An interstate natural gas pipeline construction or expansion project takes an average of about three years from the time it is first announced until the new pipe is placed in service.
Regulatory ExpectationsPHMSA and State Regulators expect operators to:• Go above and beyond regulations
• Where possible, PHMSA will publicly support company efforts beyond regulations to improve pipeline safety.
• Fully embrace integrity management• Know Your System!
• Base decisions on sound data• Confirm existing data; find ways to address data gaps
• Embrace Pipeline Safety Management Systems• Plan – Do – Check ‐ Act
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PHMSA’s Regulatory ToolsRulemaking: • Advanced Notices, Notices, Final Rules
Advisory Bulletins
Guidance Documents• Inspection Protocols: Assist federal/state inspectors
in evaluating operator programs• Enforcement Guidance: Identify & summarize
precedent set by interpretations, advisory bulletins, final orders & petitions for reconsideration decisions.
• Frequently Asked Questions• Letters of Interpretation
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Safety of Gas Transmission & Gathering Lines RuleANPRM Published: August 25, 2011NPRM Published: April 8, 2016
NPRM Comments Submitted: July 7, 2016GPAC Meeting #1 Comments Submitted: April 5, 2017
PHMSA Gas Pipeline Advisory Committee to meet 3 times: January 2017, June 2017, & Fall 2017
AGA Submitted Comments on 30 Different Topics, Including:Record Retention Requirements & the Definition of “Traceable, Verifiable, & Complete”
Definition of Transmission Line & Distribution CenterMAOP Verification & Determination
Material VerificationExpansion of Pipeline Assessments Outside HCAsThe Concept of Moderate Consequence Areas
Repair Criteria for Pipeline Assessments Introduction of a Definition for “Able to accommodate inspection from an ILI”
TIMP Risk Assessments & ModelingSpike Testing & Fracture Mechanics
Corrosion Control Requirements: Internal, External, Stress Corrosion Cracking Management of Change
Gathering Lines
Other Topics Discussed at GPAC Meeting #1:TIMP Reassessment Intervals, Addressing Seismicity, Safety of Launchers & Receivers, Continuing
Surveillance after Extreme Weather Events
Finalized at GPAC Meeting #1 Preliminary Discussion at GPAC Meeting #1
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Safety of Gas Transmission & Gathering Lines Rule
Outputs from GPAC Meeting #1: Approved by GPACTIMP Reassessment Intervals: Approved as proposed‐ Industry: Also apply to low‐stress reassessments
Safety of Launchers & Receivers: Approved as proposed
Addressing Seismicity: Approved as proposed
Continuing Surveillance after Extreme Weather Events: Approved with changes‐ Clarify timeline for inspections begins after operator has made a reasonable determination that area is safe
‐ Clarify in preamble operators are encouraged to consult with pipeline safety officials
‐ Delete confusing language (“whichever is sooner”)‐ Change “infrastructure” to “facilities”
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Safety of Gas Transmission & Gathering Lines RuleOutputs from GPAC Meeting #1
Management of Change: Approved with changes‐ For non‐ IM assets, provide 2‐year phase‐in period with notification procedure for justified extensions
‐ Clarify only covers significant changes that affect safety & environment
‐ Clearly state distribution & gathering lines are exemptRecords: For Further Discussion & Comment‐ GPAC will discuss recordkeeping requirements within each topic & then determine if general‐duty recordkeeping requirement (§192.13(e)) is necessary.
‐ Industry Comment: The proposed general‐duty records requirement is unnecessary and confusing.
Preventive & Mitigative Measures: PHMSA stated there was no intent to require all P&M measures in §192.935(a)
Safety of Gas Transmission & Gathering Lines RuleOutputs from GPAC Meeting #1: For Further Discussion
TIMP Risk Modeling:• PHMSA did not intend to require probabilistic risk models• PHMSA did not intend to expand data sets for
incorporation into risk models beyond ASME B31.8S.• More discussion when MAOP Verification is discussed ‐ Industry Comments:
‐ New requirements for TIMP risk modeling should be phased in over several years.
‐ Should be avenue for operators that are missing one of the required data sets.
‐ The Associations provided a side‐by‐side comparison of requirements within ASME B31.8S and PHMSA’s proposal, highlighting the differences.
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Safety of Gas Transmission & Gathering Lines RuleOutputs from GPAC Meeting #1: For Further Discussion
Corrosion Control: PHMSA should extend deadline for post‐construction/excavation coating surveys or at least provide a justification for the proposed 3‐month timeframe.‐ Industry Comments:
‐ Remove prescriptive requirements to Subpart I & keep requirements performance based.
‐ Remove duplication (i.e., §192.478(c) & §192.477).‐ Operators should have 1‐year to perform remedial action on deficiencies found during “indirect assessments” evaluating “adequate corrosion control measures.”
‐ Internal Corrosion Incident Data provided to clarify impact this threat has on on‐shore gas transmission pipelines. Operator case study provided to explain costs associated with PHMSA’s proposal for internal corrosion control monitoring.
‐ Appendix D: Criteria for Cathodic Protection & Determination Measurements should reference full Section 6 of NACE SP0169
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Safety of Gas Transmission & Gathering Lines RuleOutputs from GPAC Meeting #1: For Further Discussion
Corrosion Preventive & Mitigative Measures‐ GPAC Discussion:
‐ Discussion on §192.935(f) & (g) on Internal Corrosion & External Corrosion P&M Measures was limited during the first meeting. It will be revisited during Meeting 2.
‐ Industry Comments: ‐ Much of the proposed additions to §192.935(f) & (g) are duplicative of sections in Subpart I that are applicable to all pipelines. PHMSA should remove these duplicative requirements.