The Pipeline and Hazardous Materials Safety Administration (PHMSA) has introduced a Notice of Proposed Rulemaking (NPRM) that outlines significant revisions to enhance the safety and reliability of gas distribution pipelines. The proposed changes outlined by PHMSA come in response to congressional mandates, an NTSB recommendation, and to implement lessons learned from the September 2018 incident in Merrimack Valley.
In this blog post, we will cover the key points of the proposed changes and major amendments, and examine the potential impacts on the industry.
– Enhanced DIMP requirements to identify and mitigate risks.
– Strengthened emergency response plans and communication with the public.
– On-site monitoring for construction projects with overpressurization potential.
– Redundant overpressure protection at new regulator stations.
– Expanded annual reporting requirements.
NPRM Takeaways for Gas Distribution:
PHMSA’s proposed revisions to the pipeline safety regulations for the safety of gas distribution pipelines encompass various crucial aspects. We’ve broken down the 228-page NPRM and put together a list of the key takeaways. This blog post is merely an overview so that it’s easier to digest the big picture, but we recommend reading the NPRM in full.
1. Lessons Learned from 2018 Incident:
– These revisions are a response to catastrophic incidents such as the Merrimack Valley disaster in 2018, which resulted in fatalities, injuries, property damage, and evacuations.
– The National Transportation Safety Board (NTSB) recommendation and the Leonel Rondon Pipeline Safety Act of 2020 serve as the driving forces behind these proposed changes.
2. Overpressurization Mitigation:
– Focus on reducing the risk of overpressurization in low-pressure gas distribution systems.
– Proposes new design standards and operational requirements for low-pressure gas distribution pipelines.
3. Distribution Integrity Management Program (DIMP) Updates:
– Operators must update their DIMP plans to identify and minimize risks, including materials prone to issues, overpressurization, and extreme weather.
– Emphasizes evaluating and ranking threats and potential consequences associated with low-probability events.
4. Emergency Response Enhancements:
– Improving emergency response plans for all part 192-regulated gas pipelines, including gas distribution systems.
– Operators must communicate more effectively with the public during emergencies and establish opt-in systems for customers to stay informed.
5. Operations and Maintenance Manuals:
– Proposes mandatory procedures for responding to overpressurization and a management of change (MOC) process with qualified personnel review for construction and maintenance activities.
6. Recordkeeping Requirements:
– Requires operators to maintain traceable, verifiable, and complete records regarding critical pipeline system characteristics.
– Records include details on underground piping, regulators, and overpressure protection configurations.
7. On-Site Monitoring:
– Mandates on-site monitoring by qualified personnel during construction projects that could result in overpressurization at district regulator stations.
8. Redundant Overpressure Protection:
– New regulator stations serving low-pressure gas distribution systems must have redundant technologies to avoid or mitigate overpressurization.
– Monitors gas outlet pressure for real-time notification.
9. Construction Inspections:
– Reintroduces inspection requirements for gas distribution pipelines, applicable to gas transmission and offshore gas gathering pipelines as well.
10. Test Records Clarification:
– Specific information must be recorded for tests on new, replaced, or relocated gas distribution pipelines.
– Requires disconnected service lines to be tested before reinstatement.
11. Annual Reporting:
– Expands annual reporting requirements for gas distribution operators to include additional information such as the number and miles of low-pressure service lines.
– Small LPG operators need to provide data on service lines and leak dispositions.
12. Amendments for Gas Gathering Pipelines:
– Proposes the removal of certain exceptions for part 192-regulated gas gathering pipelines to restore application of specific regulatory amendments pertaining to definitions, emergency planning, and notification protocols.
Potential Impacts on the Industry:
- Improved Safety and Reduced Risks for Gas Distribution Pipelines:
- These proposed changes are intended to enhance the safety of gas distribution pipelines by addressing vulnerabilities that can lead to catastrophic incidents. By focusing on overpressurization prevention, DIMP updates, and better emergency response, the industry can mitigate risks associated with pipeline operations. Improved design standards and operational requirements will reduce the likelihood of overpressurization incidents, ultimately ensuring a safer infrastructure.
- Enhanced Emergency Response Capabilities for All Gas Pipeline Operators:
- The NPRM’s emphasis on improving emergency response plans and communication protocols benefits both operators and the communities they serve. By establishing more effective communication with the public during emergencies and implementing opt-in systems for customer awareness, operators can respond promptly and efficiently in crisis situations. This is particularly critical in ensuring the safety of residents and minimizing the consequences of pipeline incidents.
- Increased Regulatory Compliance and Recordkeeping Obligations:
- The proposed revisions elevate regulatory compliance standards, necessitating operators to meet more stringent requirements. This includes the need to maintain traceable, verifiable, and complete records detailing critical pipeline system characteristics. While these requirements may add administrative burdens, they are crucial for ensuring the integrity and safety of gas distribution systems, aligning with PHMSA’s mission to protect people and the environment.
- Investments Required for Redundant Overpressure Protection at Regulator Stations:
- Requiring redundant overpressure protection at regulator stations introduces new design and equipment standards, which may entail significant investments for gas distribution operators. These investments aim to mitigate the risk of overpressurization, enhancing the safety of low-pressure gas distribution systems. While upfront costs may be a concern, the long-term benefits in terms of safety and public confidence are substantial.
- More Comprehensive Annual Reporting for Improved Oversight:
- The proposed expansion of annual reporting requirements adds transparency and accountability to the industry. Operators will need to provide more detailed information, including the number and miles of low-pressure service lines, and data on leaks for small LPG operators. This reporting enhances regulatory oversight and enables PHMSA to make informed decisions regarding safety and environmental concerns. While it may require additional administrative efforts, it contributes to the industry’s overall safety and risk mitigation efforts.
In conclusion, the proposed regulatory changes by PHMSA are aimed at bolstering the safety and integrity of gas distribution pipelines. These revisions are a response to past incidents and recommendations, with a focus on reducing overpressurization risks and improving emergency response capabilities. While they bring about increased responsibilities for operators, they are ultimately designed to make gas distribution pipelines safer for both the public and the environment.
Contact us now if you have questions or concerns about how these proposed changes may impact your operation.