September 22, 2011: Gas Transmission ANPRM Extension Requested
The AGA and Interstate Natural Gas Association of America (INGAA) jointly requested that the Pipeline and Hazardous materials Safety Administration (PHMSA) grant an extension of at least 90 days to the comment period for the advance notice of proposed rulemaking (ANPRM) on Safety of Gas Transmission Pipelines. The ANPRM covers 15 separate topic areas, presents 121 questions, many of which were multi-part questions. The deadline for submitting comments is currently December 2. AGA believes an extension is warranted, but will continue to develop comments for the December deadline.
Contact Phil Bennett, pbennett@aga.org
August 26: “Pipeline Safety: Safety of Gas Transmission Pipelines”
In the August 25th Federal Register, PHMSA published an advance notice of public rulemaking (ANPRM) titled “Pipeline Safety: Safety of Gas Transmission Pipelines.” In this rulemaking, PHMSA will be revisiting the requirements in the Pipeline Safety Regulations addressing integrity management (IM) principles for Gas Transmission pipelines and additional requirements outside of IM. In particular, PHMSA will be reviewing the definition of a High Consequence Area (HCA) (including the concept of a potential impact radius), the repair criteria for both HCA and non-HCA areas, requiring the use of automatic and remote controlled shut off valves, valve spacing, and whether applying the integrity management program requirements to additional areas would mitigate the need for class location requirements. PHMSA is also considering revising requirements for new construction, corrosion control, and new requirements for gathering lines and underground storage facilities.
The OSRAC committee will develop comments on the advance notice and consider the safety recommendations that the National Transportation Safety Board will issue in their August 30, hearing on the San Bruno accident. The ANPRM, NTSB recommendations and proposed legislation are all important and AGA will develop positions for three audiences.
AGA wants broad input from the membership and will send relevant technical questions from the ANPRM and the NTSB hearing to the appropriate technical committees for discussion at the fall committee meetings. Among the specific issues PHMSA is considering concerning IM requirements is:
- whether the definition of a high consequence area (HCA) should be revised to bring additional pipeline under IM requirements;
- whether additional requirements are needed to improve operator consideration and implementation of preventive and mitigative measures to protect HCAs against incident consequences;
- whether to revise IM repair criteria for pipeline segments; whether more prescriptive requirements are needed governing collection, integration, and validation of data concerning the pipeline; whether requirements related to pipeline risk analyses should be strengthened;
- whether additional or revised requirements are needed concerning operator application of lessons learned through implementing its IM program; and
- whether additional restrictions should be placed on the use of specific pipeline assessment methods.
With respect to non-IM requirements, PHMSA is considering:
- whether revised requirements are needed on new construction or existing pipelines concerning mainline valves, including spacing and whether remotely operated (e.g., operated from a control room via SCADA system) or automatically-operated (i.e.., no human action is required) valves should be installed;
- whether requirements for corrosion control of steel pipelines should be strengthened;
- whether new regulations are needed to govern safety of underground gas storage facilities;
- whether requirements are needed to govern operator management of changes to its pipeline and operating practices; and
- whether pipeline operators should be required to implement formal quality management systems for new construction and installations as well as for post-construction operation and maintenance.
- exemptions applicable to facilities installed prior to the regulation and whether new regulations are needed to govern safety of rural gas gathering lines.
Contact Phil Bennett, pbennett@aga.org