By Carin Meyer, Regulation Compliance Program Specialist, Atmos International
To be able to operate within their regions, the onus is on pipeline operators to abide by leak detection and incident response rules. Federal regulators like the Pipeline and Hazardous Materials Safety Administration (PHMSA) regularly implement new standards as part of their renewed focus on leak detection for natural gas and hazardous liquid pipelines to ensure the people, public and environment are kept safe.
It’s important to stay current on the rules, regulations, guidance and laws for a pipeline network, especially when new and time-sensitive rulings come in which require actioning quickly. This article uses the introduction of three time-sensitive rulings with impending deadlines as examples to highlight the importance of a pipeline regulation compliance service: the Gas Mega Rule, the Safety of gas transmission pipelines regulation and the valve installation and minimum rupture detection standards.
1. Gas Mega Rule
Since the mid to late 20th century, a range of rulings have been introduced to ensure safe and compliant gas pipeline operations and they have all led up to some of the time-sensitive deadlines seen in the Gas Mega Rule today.
The natural gas pipeline safety act of 1968 started by ensuring the safe transportation of natural gas by pipelines. This was followed by the 1970 final rule which defined a “gathering line” as a pipeline that transports gas from a current production facility to a transmission line or main, with “regulated gathering line” receiving its own definition in 1992.
From the 2000s, API RP 80 was published which provided a definition of onshore gas gathering pipelines and this definition was improved throughout time. In 2020, the Gas Mega Rule, along with the PIPES Act of 2020, was introduced.
From July 2020, operators had to begin retaining records for each individual welder qualification at the time of construction for a minimum of five years following construction, per § 192.227. For transmission pipe installed after July 1, 2021, operators must begin retaining records for each person’s plastic pipe joining qualifications at the time of construction for a minimum of 5 years following construction, per § 192.285.
If subject to § 192.624, operators must develop and document procedures for completing all actions required by this section (see FAQ-12 regarding moderate consequence area identification2). These procedures must include:
Operators must modify their launchers and receivers that will be used after this date to meet the conditions of §192.750.
Three deadlines related to the Gas Mega Rule come into effect this year (2023), the first being that 2022 annual reports from Part 3 of the ruling are due in March. Part 3 of the ruling places an emphasis on data gathering to direct future regulations and will require over 400,000 gathering lines to file annual reports.
The next deadline relates to pipelines categorized as type C under 192.9. Pipelines in this group are Type A regulated gas gathering lines in a Class 1 location that have a nominal diameter of 8.625 inches or greater and are metallic with an MAOP that produces a hoop stress of 20% or more of specified minimum yield strength (SMYS) or, if the stress level is unknown, the MAOP is more than 125 psig.3 Pipelines in type C need to be fully compliant with Part 3 of the Gas Mega Rule by May 16, 2023.
Finally, Part 2 of the Gas Mega Rule is effective from May 24, 2023, and will require pipeline inspection after extreme weather events, AC and DC interference surveys, DCVG and ACDV after line backfill, an internal corrosion program and management of change.
2. Gas Gathering Breakdown
Amendments to the Safety of Gas Gathering Pipelines Regulation were published on August 24, 2022, and will be effective from May 24, 2023. The aims of these amendments have the following objectives:
While PHMSA will be exercising its inherent enforcement discretion in the nine months following the official date this ruling comes into effect from May 24, 2023, to February 24 2024,4 this only applies to operators of existing onshore gas transmission pipelines in service. For any operators whose pipeline networks don’t fit these criteria, there is a limited timeframe to fulfil these obligations before penalties are incurred from PHMSA.
3. Valve Installation Standards
In response to congressional mandates and incorporated recommendations from the National Transportation Safety Board, these proposals are necessary to reduce the consequences of large-volume, uncontrolled releases of natural gas and hazardous liquid pipeline ruptures after a number of reported incidents caused significant damage to the environment or human life.5
The standards apply to most Type A gas gathering and gas transmission lines (with limited exceptions, such as if the pipeline segment is in a Class 1 or Class 2 location and has a potential impact radius less than or equal to 150 feet).6
The standards also apply to hazardous liquid pipelines and include a small subset of rural gathering lines which cross bodies of water greater than 100 feet wide. The aim of the rule is to establish minimum safety performance standards for the identification of ruptures, pipeline segment isolation and other mitigative actions for pipelines on which rupture mitigation valves (RMVs) or alternate technology are installed.
The ruling was published on April 8, 2022, and became effective from Oct. 5, 2022. Although it is possible to request an extension of the compliance deadline based on financial, operational or technical difficulty, this is on a discretionary basis and PHMSA will require the deadline to be met eventually.7
The responsibility will always be on pipeline operators to ensure they demonstrate compliance and meet deadlines. However, sometimes time-sensitive rulings come in like the Gas Mega Rule, the Safety of Gas Gathering Pipelines regulation or the Valve Installation and Minimum Rupture standards with seemingly unachievable deadlines.
Atmos International provides a regulation compliance service that’s available for all leak detection systems, regardless of vendor. Learn more here. P&GJ
REFERENCES:
Carin Meyer, a regulatory specialist at Atmos International, helps North American customers overcome significant challenges in the interpretation of pipeline compliance regulations and supports them in becoming leak detection compliant.