PHMSA Rule Update. David Johnson November 14, 2018

Transcription

1 PHMSA Rule Update David Johnson November 14, 2018

2 PHMSA Active Rulemakings Gas Transmission (Mega Rule) now 3 parts o o o MAOP, Assessment requirements Repair criteria, IM improvements, CP, MOC Gas gathering Underground Storage Facilities for Natural Gas Class Location Requirements Valve Installation and Rupture Detection Standards Use of Plastic Pipe Enhanced Emergency Order Procedures Extension of 7-year interval by 6 months Gas PL Regulatory Reform Safety of Hazardous Liquid Pipelines Liquid PL Regulatory Reform Almost rulemakings? Risk Models and SMS 2

3 Gas Transmission (Mega Rule) Mega Rule progress has slowed split into 3 parts Valves and rupture detection removed to separate rulemaking Gathering delayed GPAC met 5 times on transmission sections One additional meeting planned for gathering Projected Final Rules in

4 1.1-MAOP Reconfirmation, Expansion of Assessment & Other Projected Final Rule 3/14/ month grace period for 7-year IM reassessment Incorporate seismicity into risk analysis MAOP exceedance reporting Does not apply to gathering Amendments related to Probably move (e) to (a) (f) records only onshore steel transmission and required to comply with 619 (a)-(d) Not retroactive 4

5 1.2-MAOP Reconfirmation, Expansion of Assessment & Other MAOP reconfirmation Crack consideration removed from MAOP to IM Remove definition of modern & legacy pipe / constr. Have to address if missing records less than required at time of construction Stress level consideration; < 30% may be ok Complete in 15 years or 4 years after identification Subpart J test spike for IM, not MAOP Pressure reduction lookback period increased to 5 years Fracture mech. analysis not req d for pressure reduction Revised FM methods described in new Method 5 for PIR < 150 ft 5

6 1.3-MAOP Reconfirmation, Expansion of Assessment & Other Non-HCA assessments DA only as appropriate 14 / 10 years initial assessment / reassessment Clearer differentiation of above or below 30% SMYS MCA definition Highways - 4 lanes, travel lanes & shoulders, not ROW Remove occupancy req mts & tie to HCA-type data Related record provisions Several areas pulled back to reasonable requirements 6

7 1.4-MAOP Reconfirmation, Expansion of Assessment & Other Material verification Applies to onshore steel transmission only A procedure that may be required by other sections No requirement for an overall program plan Drop list of mandatory attributes Allows operators to develop sampling plan Allows destructive or non-destructive testing Allows single, for-purpose test Drop or reduce accuracy, frequency, quadrant reqm ts Operator specifies how to deal with failures 7

8 2.1-Repair Criteria, IM Improvements, CP, MOC & Other Projected Final Rule 12/20/2019 Repair criteria HCA & non-hca not retroactive applies to non-subpart O segments Clarified pressure reductions If SMYS is needed and not known Gr. A or use OD & WT use MAOP basis or Allow ECA for many types of dents Added response timing for non-hca dents Some modification and relaxation of response to cracking Clarify preferential corrosion metal loss in welds PFP factors based on class location Longer response time in non-hca 8

9 2.2-Repair Criteria, IM Improvements, CP, MOC & Other Inspection following extreme events Period begins after operator determines safety of area Safety features on ILI launchers & receivers Relieve pressure and confirm Prevent door opening Implement before use Management of change 2-year phase in for non-im assets For significant changes affecting safety or environment Transmission, not gathering or distribution 9

10 2.3-Repair Criteria, IM Improvements, CP, MOC & Other Corrosion control New/replacement pipe coating inspections for > 1000 ft Address severe, not moderate Remedial actions within 1 year Interference surveys on susceptible lines, remediate if significant within 1 year IC monitor gas annually where corrodants can enter and other clarifications applies everywhere 10

11 2.4-Repair Criteria, IM Improvements, CP, MOC & Other IM clarifications All listed measures must be considered, not required ICDA, SCCDA & GWUT essentially as proposed Clarify operators to select appropriate assessment methods DA methods allowed where applicable no stretching Revised spike 15 min, lesser of 100% SMYS, 1.5xMAOP Strengthen assessment requirements Allow various methods besides probabilistic Establish functional requirements 3-year phase-in period 11

12 3-Gas Gathering Projected Final Rule 12/20/2019 Report gathering incidents Report gathering annual pipeline data Extend safety requirements to Type A gathering in Class 1 locations Change certain definitions 12

13 Underground Storage Facilities for Natural Gas Interim Final Rule 12/19/2016 Projected Final Rule (finalize Interim FR) 1/21/2019 Invokes API RP 1170 Design & Operation of Solution-mined Salt Caverns Used for NG Storage Invokes API RP 1171 Functional Integrity of NG Storage in Depleted HC & Aquifer Reservoirs Determined to be non-significant 13

14 Class Location Requirements Current ANPRM 7/31/ /1/2018 Analysis & NPRM next no projected date Revisiting required actions following CL changes IM measures in lieu of pipe replacement Major part of Integrity rule cost-benefit analysis Criteria for Special Permits issued June 2004 Several applications approved PHMSA became increasingly skeptical as construction and material issues surfaced c No recent approvals, but revisiting Clustering for CL boundaries? 14

15 Valve Installation & Minimum Rupture Detection Standards Projected NPRM 1/17/2019 Originally a topic in Mega Rule ANPRM Address Congressional mandates Standards for rupture identification and isolation Maintenance & inspection, spacing, risk analysis and notification (9-1-1) requirements 15

16 Use of Plastic Pipe Projected Final Rule 9/28/2018 (Let s do the time warp again) Correct errors and inconsistencies and address petitions regarding plastic pipe Tracking and traceability Design factor for PE Mechanical fittings requirements PA-11 and PA-12 use 16

17 Enhanced Emergency Order Procedures Projected Final Rule 10/24/2018 Interim Final Rule 10/14/2016 Enhance PHMSA authority to act immediately Finalize Interim Final Rule 17

18 Extension of 7-Year IM Reassessment Interval Actual notice date 11/15/2018 Comments on FAQ guidance on what constitutes justification for 6-month extension FAQ-281 How to extend Notify >180 days in advance with sufficient info FAQ-282 Sufficient info why not met, no compromise of safety, additional interim actions FAQ-207 Intervals < 7 yrs (i) based on detailed analysis or (ii) ASME B31.8S Table 3 18

19 Gas & Liquid Pipeline Regulatory Reform Projected NPRM Hazardous Liquid 2/28/2019 Projected NPRM Gas 5/10/2019 Amend regulations to ease regulatory burdens Based upon agency review,petitions for rulemaking and public comments 19

20 Safety of Hazardous Liquid Pipelines Projected Final Rule 12/28/2018 Distributed and sent to the Federal Register for publication in January 2017 Subsequently pulled back Additional comments provided by associations 20

21 Non-Rulemaking (yet) No new advisory bulletins Voluntary Information Sharing Working Group Pipeline Safety Management Systems (API RP 1173) Risk Model Work Group 21

22 Web Locations (Note: User-hostile site) Advisory Bulletins and Notices Rulemakings Public Meetings Regulatory Agenda Monthly Report on Significant Rulemakings

23 Thanks! 23