Proposed Changes to the Annual Gas Transmission DOT Report Concerning MAOP Verification NGA Fall Operations Conference October 4, 2012 Mary Holzmann
National Grid In the US, we serve 3.4 million customers over a network of nearly 32,000 miles of pipe throughout New York, Massachusetts, Rhode Island. We have just recently sold our New Hampshire Assets. 2
Background Just in case anyone is not that closely involved in with the Annual Report for Gas Transmission and Gathering Systems, Operators went through some major Transmission report changes that PHMSA made to the 2010 Reports. PHMSA combined the Annual Reports with the Transmission Integrity Management Program Reports while also requiring Operators to include far greater detail in the combined report on pipe inventories by class location and %SMYS and additional Integrity inspection and repair details. PHMSA implemented a switch over to using their new Portal process which requires users to obtain Portal access in order to file reports. PHMSA had extended the 2010 Report deadline to August 2011 due to the extent of the changes and switching to their new computer system. The 2011 reports were due March 15, 2012 (as usual, but this resulted in a shortened time frame between the 2010 and 2011 reports. The changes to be discussed here are NEW CHANGES impacting the next Annual Reports which cover 2012 pipeline data and the MAOP verifications as well as pipeline piggability. Operators need to be aware of how this new data needs to be broken down so proper data is collected for submission to DOT/PHMSA. 3
Update on Annual DOT Report as of 9/21/2012 On April 13, 2012, (77 FR 22387) PHMSA proposed a number of revisions to the Annual Report for Gas Transmission and Gathering Systems (PHMSA F 7100.2-1) some minor, some quite significant. The initial comment period ended 6/12/2012 PHMSA received 12 comments in response to that notice. Operators: Alliance Pipeline, Energy Transfer, National Grid, Paiute, SCANA Corporation, and Southwest Gas Trade Associations: NGA, AGA, INGAA, API, AOPL and Texas Pipeline Association 1 Public commenter 4
Update on Annual DOT Report as of 9/21/2012 Just recently, on 9/21/2012 PHMSA published the 30- day Notice (77 FR 58616) in response to the comments, and provides the public with an additional 30 days to comment on their modified revisions to the forms and the instructions, and to announce that the revised Information Collections will be submitted to the Office of Management and Budget (OMB) for approval. PHMSA s current work on the annual report should be considered as complete. The comments from this thirty day notice go directly to the OMB. 5
Update on Annual DOT Report as of 9/21/2012 Operators should consider these forms to be final because OMB is unlikely to change the forms unless critical changes are deemed necessary. All prior comments and PHMSA s amended Annual Report form and instructions in response to those comments can be found on the docket at: http://www.regulations.gov Docket number PHMSA-2012-0024 Operators should use the revised Report form and instructions to finalize their plans for submitting MAOP verification data (and in preparation for the 2012 Reports). 6
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There are Other Changes, however. This presentation covers those areas involving the MAOP verifications only. I have provided NGA with the entire Annual Report changes and Instructions. These will be available through NGA after this conference. NGA will discuss if any further comments should be submitted before the deadline (October 19) regarding the new changes in an upcoming conference call. 8
Highlights of the DOT Report Changes and MAOP Verification PHMSA Administrator Quarterman looking on as President Obama signs the Pipeline Safety, Regulatory Certainty, and Job Creation Act in January 2012
Highlights of the DOT Report Changes and MAOP Verification PHMSA has determined that the most appropriate method to collect MAOP verification information is through the next Gas Transmission Annual Report. Owners or operators must submit the required MAOP verification information using the new Parts Q and R of the revised Annual Report. At this time, PHMSA has decided not to extend the Report deadline of March 15, 2013 regardless of the many comments received on the issue. PHMSA is taking this approach to ensure that owners or operators comply with the requirement to submit the data not later than 18 months as per the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011(before July 2013). 10
Highlights of the DOT Report Changes and MAOP Verification PHMSA has determined that mileage for records reviews that are not complete should be identified as mileage without records to avoid confusion and comply with the reporting requirements. Therefore, PHMSA has revised the instructions to specify that pipeline segments that have not been verified be reported under the appropriate w/out Recds column. After the March deadline, operators can submit Supplemental Reports if necessary to update their MAOP verification data previously submitted to PHMSA. 11
Major Changes to the Forms and Instructions involving MAOP are as Follows: PHMSA intends for operators to report mileage under the single code section heading used to establish the MAOP. In some scenarios, 49 CFR 192.619(a)(1) through (4) may all have been considered when establishing MAOP, PHMSA expects the mileage to be reported under the single heading for the final methodology that was used to determine the MAOP value. PHMSA has revised the instructions to include this clarification. 12
Where in the Annual Gas Transmission DOT Report do Operators Record the Miles by Method Used to Determine MAOP Verifications? What Changes Were Made or Amended Concerning the Report? Brand new Part Q Gas Transmission Miles by 192.619 MAOP Determination Method
Part Q Gas Transmission Miles by 192.619 MAOP Determination Method In the April 13, 2012 (77 FR 22387) Federal Register notice for this information collection revision, PHMSA expressed intent to collect Part Q data only for Class 1 and 2 HCAs and all Class 3 and 4 locations. All of the Class 1 and 2 not in HCA rows should have been blacked-out in the w/out Recds column. PHMSA has revised the report form and instructions to not collect the reporting of mileage without complete records in Class 1 and 2 locations which are not within HCAs. 14
Part Q The Amended Version 9/21/2012 15
PART Q Gas Transmission Miles by 192.619 MAOP Determination Method Amended Instructions In the Total columns, operators report transmission pipeline miles by the subsection of 192.619 serving as the limiting factor for establishing MAOP and by each combination of class location and HCA. A short explanation of each 192.619 subsection for MAOP determination methodology [follows] 16
192.619 Methodology Description Given in Part Q Instructions 17
Review of Class Location and HCA definitions are Given in Part Q Instructions 18
Part Q - Instruction Detail Transmission miles may only be entered under a single subsection of 192.619. In some scenarios, 192.619(a)(1) through (4) may all have been considered when establishing MAOP, but PHMSA expects that one value is lower than the others and was used to establish MAOP. In other scenarios, 192.619(c) could be used to set MAOP, regardless of the values in 192.619(a)(1) through (4). For each combination of class location and HCA shown on the form, report the miles in each MAOP category. The sum of all Total columns for 192.619 subsections and Other for each class location must be consistent with the class location data reported in Part K. If miles are entered in the Other column, enter text describing the Other method(s) used to establish MAOP. 19
Part Q Instruction detail continued For each combination of class location and HCA, except Classes 1 and 2 outside HCAs, report the transmission miles for which the operator lacks complete records to verify the MAOP in the w/out Recds column. The value in the w/out Recds column must be less than or equal to the value in the Total column for each combination of class location and HCA. For the purpose of this part, verification records are records that can be used to validate the MAOP for the subject pipelines such as: as-built drawings, alignment sheets, specifications, and all design, construction, inspection, testing, maintenance, manufacturer, or other related documents. These records should be traceable, verifiable, and complete. For miles of transmission pipeline for which the operator has not completed the records review, include these miles in the w/out Recds column. See PHMSA Advisory Bulletin (ADB) 2012-06 for additional details: http://www.phmsa.dot.gov/staticfiles/phmsa/downloadablefiles/pi peline/regulations/advisorybulletins/ad-12-06.pdf 20
Reporting of miles MAOP using 192.619 (d) When reporting transmission miles for which 192.619(d) was used to establish MAOP, include miles of pipeline installed pursuant to a PHMSA special permit allowing operation up to 80% SMYS in Class 1 areas. From 2006 through 2010, PHMSA issued fifteen of these special permits with conditions equivalent to pipeline installed under 192.619(d). 21
Where in the Annual Gas Transmission DOT Report do Operators Record the Miles Pressure Tested? What Changes Were Made or Amended Concerning the Report? Brand new Part R - Gas Transmission Miles by Pressure Test (PT) Range & Ability to use Internal Inspection Tools
Part R - Gas Transmission Miles by Pressure Test (PT) Range and Internal Inspection PHMSA agrees with the commenters and has expanded Part R to collect data about the mileage of pipe in three bands of pressure tests; miles tested to more than 1.25 times the MAOP, miles tested to less than 1.25 times the MAOP but greater than or equal to 1.1 times the MAOP, and miles with a pressure test less than 1.1 times the MAOP or no pressure test. PHMSA also agrees that the test medium is irrelevant and has amended the form and instructions accordingly. 23
Part R continued Operators are required to report in each pressure test band the number of miles able to accommodate internal inspection and the number of miles not able to accommodate internal inspection. PHMSA has amended the form and instructions for Part R in response to comments to clarify the phrase not able to accommodate the passage of instrumented internal inspection devices. As a result, PHMSA has revised Part R to collect Miles Internal Inspection ABLE and Miles Internal Inspection NOT ABLE. The instructions include the following definition for Internal Inspection ABLE A length of pipeline through which commercially available devices can travel, inspect the entire circumference and wall thickness of the pipe, and record or transmit inspection data in sufficient detail for further evaluation of anomalies. 24
Part R - Amended version 9/21/2012 25
Part R Amended Instruction Details 9/21/2012 For Part R, enter miles of gas transmission pipe in each of the three pressure test ranges with each range divided into miles able to be internally inspected and miles unable to be internally inspected. All gas transmission miles must be reported in this part. The miles entered for each class location must be consistent with the class location data entered in Part K. If an operator is uncertain whether a gas transmission pipeline has been subjected to a post-construction pressure test, report the miles in the PT < 1.1 or No PT section. 26
Part R Amended Definition for Clarification Miles Internal Inspection ABLE means a length of pipeline through which commercially available devices can travel, inspect the entire circumference and wall thickness of the pipe, and record or transmit inspection data in sufficient detail for further evaluation of anomalies. If an operator is uncertain whether a gas transmission pipeline is able to be internally inspected, report the miles in the Miles Internal Inspection NOT ABLE column. 27
Older Versions of Sections Q & R as Proposed in June 2012 Notice have been Changed Be Sure to use the Revised Format and Amended Instructions to Ensure Proper Data is Collected for DOT Reports due March 2013
Part Q originally proposed - since revised. Be sure to use newest version 29
Part R originally proposed - since revised. Be sure to use newest version 30
Questions? Comments? Discussion? 31