Notice of Proposed Rulemaking (NPRM)

Huy Nguyen Western Region

Topics • Rulemaking Process

• Safety of Hazardous Liquid Pipelines (PHMSA-2010-0229) • Safety of Gas Transmission Pipelines (PHMSA-2011-0023) • Amendments to Parts 192 and 195 to Require Valve Installation and Minimum Rupture Detection Standards (PHMSA-2013-0255) • Operator Qualification (PHMSA-2013-0163) • Plastic Pipe Rule (PHMSA-2014-0006)

Rulemaking Process

• Advance Notice of Proposed Rulemaking (ANPRM) - Used to gather information (non-mandatory) • Notice of Proposed Rulemaking (NPRM) - Almost always required – Defines intent and scope • Supplemental Notice of Proposed Rulemaking (SNPRM)

Rulemaking Process

• Final Rule (FR) – Implementation date, 30 – 90 days depending on significance of regulation • Direct Final Rule (DFR) – Used for non-controversial issues

NPRM PHMSA-2010-0229

Safety of Hazardous Liquid Pipelines • Extend reporting requirements to all gravity and rural

hazardous liquid gathering lines – Add §195.1(a)(5) for submitting the reports

• Require inspections of pipelines in areas affected by extreme weather, natural disasters, and other similar events

• Require periodic assessments of pipelines that are not already covered under the IM program requirements – Add new §195.416 for assessing non-HCA pipeline

segments

NPRM PHMSA-2010-0229 Safety of Hazardous Liquid Pipelines • Modify the IM repair criteria and apply those

same criteria to any pipeline where the operator has identified repair conditions – Modify criteria in §195.452(h) for IM repairs – Amend §195.422 for performing non-IM repairs

• Expand the use of leak detection systems for all hazardous liquid pipelines – Amend §195.134 – Modify §195.444

• Accommodation of in-line inspection tools

NPRM PHMSA-2010-0229

Safety of Hazardous Liquid Pipelines • Clarify Other Requirements

– Develop a written IM Program for new pipeline – Information Analysis – Verify Segment Identification on an annual basis – IM Program for the facility – Seismicity of the area

• Next Milestone: OMB Approval • Congressional Mandate: PSA2011 Sec 5(IM), 8 (Leak Detection); Sec 29 (Seismicity); Sec

14 (Biofuels) • NTSB/OIG/GAO: NTSB P-12-03 (Discovery of Condition); NTSB P-12-04 (Assessments);

GAO 12-388 (Data Collection)

NPRM PHMSA-2011-0023 Safety of Gas Transmission Pipelines • Require periodic integrity assessments for Non-HCA

- Initial assessment within 15 years - Periodic reassessment every 20 years thereafter

• Strengthen repair criteria for HCA and Non-HCA - Modify criteria for IM repairs in an HCA - Add 80% metal loss, corrosion near seam, selective seam corrosion (SSC) and significant stress corrosion cracking (SCC) for immediate repair conditions in an HCA - Add additional dent criteria and all other SCC and crack-like defects for one-year repair conditions in an HCA - Include criteria for non-IM repairs - Same immediate repair criteria in an HCA for non-HCA - One-year repair conditions in an HCA would require a two- year repair conditions in non-HCA

NPRM PHMSA-2011-0023 Safety of Gas Transmission Pipelines • Strengthen requirements for Assessment Methods -Clarify selection and conduct of ILI per new mandatory reference to NACE, API, and ASNT standards -Clarify consideration of uncertainties in ILI reported results. • Clarify requirements for validating & integrating

pipeline data -Clarify that data be verified and validated -Clarify requirements for integrated analysis of data & information -Establish minimum pipeline attributes that must be included

NPRM PHMSA-2011-0023 Safety of Gas Transmission Pipelines • Clarify functional requirements for risk assessments -Add a new definition for “quantitative risk assessment” that adequately evaluates the effects of:

– Interacting threats – Identify the contribution to risk of each risk factor – Account for uncertainties in the risk model and data used

• Clarify requirement to apply knowledge gained through IM

-Clarify expectation that operators use knowledge from risk assessments to establish and implement adequate Preventive & Mitigative (P&M) measures -Provide more explicit examples of the type of P&M measures to be evaluated

NPRM PHMSA-2011-0023

Safety of Gas Transmission Pipelines • Strengthen corrosion control requirements -Expansion of corrosion controls required in Subpart I -Specific Preventive and Mitigative (P&M) measures for HCAs to address both external and internal corrosion

– Similar to measures required for pipe segments operating under the alternate MAOP rule per 192.619

• Add requirements for selecting Preventive & Mitigative (P&M) measures in HCAs to address internal corrosion and external corrosion

-Enhance internal & external corrosion control programs in HCAs to provide additional protection from corrosion commensurate with Alt MAOP pipelines

NPRM PHMSA-2011-0023

Safety of Gas Transmission Pipelines • Management of change -Codify the specific attributes of the Management of Change process from ASME/ANSI B31.8S, Section 11 (already incorporated by reference). -Require operators to develop and follow a Management of Change process and address risk as part of the general requirements of Part 192. • Require pipeline inspection following extreme external

events • Include 6 month grace period (w/notice) to 7-yr

reassessment interval (Act § 5(e)) • Require reporting of MAOP exceedance (Act § 23)

NPRM PHMSA-2011-0023

Safety of Gas Transmission Pipelines • Incorporate provisions to address seismicity (Act § 29) • Add requirement for safety features on launchers and receivers • Gathering lines - Require reporting for all & some regulatory

requirements -Repeal exemption for all gas gathering line operators to report incidents, safety related conditions, & annual pipeline data -Repeal use of API RP 80 for determining gathering lines and add a new definition for “production facility or production operation” and a revised definition for “gathering line” -Extend regulatory safety requirements to Type A lines in Class 1 locations (8” or greater)

• Integrity Verification Process (IVP) • Next Milestone: OMB Approval • Congressional Mandate: PSA2011 Sec 5(IM), 23 (MAOP); Sec 29 (Seismicity) • NTSB/OIG/GAO: NTSB P-11-14 (Grandfather Clause); NTSB P-11-15 (Seam Stability); NTSB P-14-1

(Roadways); NTSB P-15-18 (In-line Inspection); NTSB P15-20 (In-line Inspection Tools); NTSB P-15-21 (Direct Assessment); NTSB P-15-22 (Data Integration); GAO 12-388 (Data Collection)

Integrity Verification Process (IVP)

NPRM PHMSA-2013-0255

Rupture Detection and Valve Rule • Mandatory installation of automatic shutoff

valves (ASVs), remote controlled valves (RCVs), or equivalent technology (Act § 4)

• Establish performance based meaningful metrics for rupture detection for gas and liquid transmission pipelines (Act § 8)

• Locations: High Consequence Areas (HCA) for Hazardous Liquid and HCA, Class 3 and 4 for Natural Gas

NPRM PHMSA-2013-0255

Rupture Detection and Valve Rule • Goals:

– Improve rupture mitigation (response) – Shorten pipeline segment isolation times in HCAs and

select non-HCAs – Address Congressional mandates – Incorporate NTSB and GAO recommendations

• Next Milestone: OST Concurrence • Congressional Mandate: PSA 2011 Sec 4(RCV), 8 (Leak Detection) • NTSB/OIG/GAO: NTSB P-11-9 (911 Notification by Control Room); NTSB P-11-10 (Leak

Detection); NTSB P-11-11 (ASVs/RCVs); GAO 13-168 (Valves)

NPRM PHMSA-2013-0163

Operator Qualification (OQ) • Expand the scope of OQ requirements to

cover new construction and certain previously excluded operation and maintenance tasks

• Extend the OQ requirements to three (3) additional pipeline categories – Type A gas gathering lines in Class 2 locations – Type B onshore gas gathering lines – Regulated rural hazardous liquid gathering lines

NPRM PHMSA-2013-0163

Operator Qualification (OQ) • Change the scope of OQ rule so that the method

of determining a “covered task” is changed to a technically justified method instead of negotiated “4-part test” originally in the rule

• Standardization of the format used in OQ • Complete a review of the effectiveness of their

OQ program

NPRM PHMSA-2013-0163

Operator Qualification (OQ) • Incorporate the record requirements that would

address evaluators and program effectiveness • Address Management of Change and the

communication of those changes • Next Milestone: Publication (NPRM) • NTSB/OIG/GAO: NTSB P-12-8 (Operator Qualification); NTSB P-12-7 (Control

Center Staff)

NPRM PHMSA-2014-0006

Plastic Pipeline • Traceability and Tracking

-Revise § 192.3 by adding definitions for ‘‘traceability information’’ and ‘‘tracking information’’ -Revise § 192.63 to require operators to adopt the tracking and traceability requirements in ASTM F2897–11a, ‘‘Standard Specification for Tracking and Traceability Encoding System of Natural Gas Distribution Components (Pipe, Tubing, Fittings, Valves, and Appurtenances)’’

• Design Factor for Polyethylene (PE) -Increase the design factor for PE pipe from 0.32 to 0.40 in § 192.121

NPRM PHMSA-2014-0006

Plastic Pipeline • Expanded Use of Polyamide-11 (PA-11)

-Allow PA–11 pipe (PA32316) for pressures up to 250 psi, diameters up to 6 inches, and additional limitations on wall thickness as listed in the petition

• Incorporation of PA-12 -Same as PA-11

• Risers -Add the requirements for the design (§ 192.204) and construction of risers (§§ 192.321(j) and 192.375(a)(2)) associated with plastic pipe

NPRM PHMSA-2014-0006 Plastic Pipeline • Fittings

-Incorporate a requirement to use only mechanical fittings or joints that are designed and tested to provide a seal plus resistance to lateral forces so that a large force on the connection would cause the pipe to yield before the joint does - Add a new paragraph (g) to require such fittings used within plastic pipelines be cathodically protected and monitored in accordance with §§ 192.455 and 192.465(a)

NPRM PHMSA-2014-0006 Plastic Pipeline • Repairs

-Include a requirement for all plastic pipe and or components to be replaced if they have a scratch or gouge exceeding 10 percent of the wall thickness -Incorporate a new section (§ 192.720) to prohibit the use of leak-repair clamps as a means for permanent repair on gas pipe used in distribution service

• Next Milestone: Advisory Committee Vote

Questions?

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