AGA/NTSB Correspondence - AGA Request for Clarification of NTSB Recommendations P-10-1 through P-10-4 - June 2011
On June 14, 2011, AGA sent a letter to NTSB Chairman Deborah Hersman in an effort to gain clarity around four recommendations that the NTSB issued to PHMSA and Pacfific Gas and Electric Company (PG&E).
AGA White Paper - Industry Guidance on Records Review for Re-affirming Transmission Pipeline MAOP - October 2011
The intent of this document is to provide general guidance to pipeline operators who are undertaking a process to review their records for the purpose of re-affirming their maximum allowable operating pressures (MAOPs) for existing transmission pipelines. The guidelines are simply a suggestion of practices which can be considered by operators who are developing a plan, in response to recommendations made by the National Transportation Safety Board and the advisory bulletin issued by DOT’s Pipeline Hazardous Materials Safety Administration (PHMSA) on January 10, 2011.
AGA Response - AGA Response to NTSB Safety Recommendation P-11-32 on Inline Inspection - March 2012
On March 26 the American Gas Association and the Interstate Gas Association of American (INGAA) met with NTSB Board members to review the progress the trade associations have made in completing Safety Recommendation P-11-32 from the San Bruno investigation. The recommendation states:
Report to the National Transportation Safety Board on your progress to develop and introduce advanced in-line inspection platforms for use in gas transmission pipelines not currently accessible to existing in-line inspection platforms, including a timeline for implementation of these advanced platforms. (P-11-32)
The trades worked with various pipeline research entities to create the report. Similar to the computer industry, internal inspection of pipelines to find minute flaws in pipe has achieved dramatic improvement over the last two decades. There are still limits to the technology and research and development continues.
PHMSA Advisory Bulletin - Verification of Records - May 2012
On May 7, 2012 PHMSA issued an Advisory Bulletin (AB) to remind operators of gas and hazardous liquid pipeline facilities to verify their records relating to operating specifications for maximum allowable operating pressure (MAOP) required by 49 CFR 192.517 Records and maximum operating pressure (MOP) required by 49 CFR 195.310 Records. This AB provided guidance and definitions for the terms traceable, verifiable and complete. PHMSA provided guidance and examples to clarify what constitutes as sufficient supplemental support to validate a pipeline's MAOP. The AB also notifies operators of PHMSA s intent to amend 192.619(a)(3), the MAOP grandfather clause, after receiving operator data submitted for the year 2012. AGA had been in discussions with PHMSA since the advisory was issued and had received verbal confirmation that a single record that contained the needed information to confirm a pipeline s MAOP would be acceptable. In June 2012, AGA submitted an official request for interpretation to PHMSA and subsequently received the confirmation below.
AGA Letter - MAOP Records Verification: Request for Clarification of Advisory - June 2012
Following review of Advisory Bulletin (ADB-12-06, Docket No. PHMSA-2012-0068) issued by the Pipeline and Hazardous Materials Safety Administration (PHMSA) in the May 7, 2012 Federal Register regarding Pipeline Safety: Verification of Records, AGA received questions and concerns from its members regarding the Advisory Bulletin and is therefore seeking clarification.
PHMSA Response - PHMSA's confirmation that a Single Record is Acceptable for Establishing MAOP - July 2012
On June 28th, PHMSA responded to AGA's Letter (above) regarding the the number of records needed to establish MAOP
AGA Position Paper - Interim Actions for Insufficient MAOP Records on Transmission Pipelines - June 2013
The Pipeline Safety, Regulatory Certainty and Job Creation Act of 2011 Section 23.a.1 states that,
“(1) IN GENERAL – The Secretary of Transportation shall require each owner or operator of a pipeline facility to conduct not later than 6 months after the date of enactment of this section, a verification of the records of the owner or operator relating to interstate and intrastate gas transmission pipelines of the owner or operator in class 3 and class 4 locations and class 1 and class 2 high‐consequence areas.
(2) Purpose – the purpose of the verification shall be to ensure that the records accurately reflect the physical and operational characteristics of the pipelines described in paragraph (1) and confirm the established maximum allowable operating pressure of the pipelines.
(3) Elements – the verification process under this subsection shall include such elements as the Secretary considers appropriate.”
In response to the congressional mandate in Section 23.a.1, PHMSA added a new section, Part Q, to the Gas Transmission and Gathering Annual Report. This section requires operators to evaluate and report by June 15, 2013 the method(s) used for determining transmission pipeline MAOPs for those lines in the class locations and HCAs as identified in the Act. There are approximately 300,000 miles of natural gas transmission pipelines in the United States and a significant portion of these lines were installed prior to federal pipeline safety regulations being codified in 1970. Therefore, it is anticipated that there will be some gaps in the MAOP records. AGA’s issue paper Understanding the MAOP Record Verification Process explains the principle that incomplete records for reporting does not equate to insufficient data for confirmation of MAOP
AGA Comments - AGA Comments on Class Location Requirements - November 2013
Section 5 of the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 requires the Secretary of Transportation to evaluate and issue a report on whether Integrity Management Program (IMP) requirements, or elements thereof, should be expanded beyond High Consequence Areas (HCAs) and whether such expansion would mitigate the need for class location requirements. AGA submitted comments to the docket today. Due to the integral role of Class Location-related risk factors in the regulations, AGA does not support the revision, replacement or complete removal of the use of Class Location-driven requirements for gas transmission pipelines, nor does it support adding additional Class Locations or revising the currently specified factors as their use throughout Part 192 is an integral part of pipeline safety. AGA encouraged PHMSA to continue to allow the use existing Class Location-related factors as currently prescribed in Part 192 for the design, construction, operation and maintenance of natural gas transmission pipelines. AGA supports the investigation and development of a second and parallel methodology for transmission pipelines that experience a change in Class Location outside of the original design and pressure testing which potentially affects the MAOP. This methodology would utilize a PIR approach and incorporate elements of transmission integrity management program. AGA believes that regardless whether an operator uses PIR or Class Location the change-out criteria should be modified to acknowledge that if certain integrity management criteria are met perfectly good pipe should not have to be replaced because of an increase in the population density.