August 2014
AGA Perspectives on Current
Pipeline Safety Regulations
The American Gas Association
• The American Gas Association , founded in 1918, represents
more than 200 local energy companies that deliver clean
natural gas to more than 68 million Americans nationwide.
• Members deliver 94% of the natural gas in the US
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Key DOT Pipeline Safety Activities
• 9 Rulemakings In Progress
• 42 Legislative Mandates
• Recommendations from NTSB, OIG,
GAO
• Advisory Bulletins
• Numerous other initiatives to improve
pipeline safety
• SMS
• Data Analysis Improvements
• Inspection Program – Inspection Integration
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Safety of Gas Transmission &
Gathering Lines Rule
• Expected to include:
• IVP: Expansion of IM + Testing
• NTSB Recommendations
• Eliminate Grandfather Clause
• Pressure test lines to 1.25 MAOP +
spike test
• Legislation
• Confirm material strength of
previously untested lines
•
Located in HCAs & operating above 30%
SMYS
• Repair criteria for both HCA and nonHCA areas
• Gas gathering lines & Other items
• Assessment methods, corrosion control,
problematic or “legacy” pipe, etc.
Rule Status
• ANPRM published
August 25, 2011
• NPRM has moved
past PHMSA
• Still within DOT
• Labeled a
Significant rule
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AGA Position on Proposed Integrity Verification Process
Complexity
• IVP Combines MAOP with TIMP expansion
MAOP
Foundation
• Validation is a one time activity
• IVP nullifies valid MAOPs based on historical PHMSA regulations and ASME
B31.8
• Lacking complete MTRs = coupon sampling program to establish material
prosperities
Post Construction
Pressure Test
MCA
• Records of historic pressure tests that currently meet code requirements
should be acceptable
• Introduces MCA Concept
• Class 2, 3 & 4 non-HCA + Class 1 with 1 home in PIR
New
Definitions
• High Stress Line is defined as ≥ 20% SMYS
• Legacy Pipe: No Common Definition
• Susceptible Seam Type: No Common Definition
• Engineering Critical Assessment (ECA): Not currently defined or understood
Spike Test
• Should be situational and operational decision
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Other Pipeline Safety Rulemakings in Progress
EFVs Beyond
Single Family
Homes
Supportive of
installation on:
-branched service
lines
-Multi-family
dwellings and
small commercial
up to 1,000 SCFH
where load is not
expected to
increase
In AGA’s
Commitment to
Enhancing Safety
Miscellaneous
Rule
AGA generally
supports the
proposed
requirements for
qualifying plastic
pipe joiners
Concerns on
proposed
amendments for
performance of
post-construction
inspections
Should be a
significant
rulemaking.
Excavation
Damage
Prevention
AGA encourages
PHMSA to
address states
that have
inadequate
enforcement
OQ, Cost
Recovery and
Other PL Safety
Proposed
Changes
Plastic Pipe
AGA generally
AGA supports:
supports:
Operator
Increase in the
Qualification for design factor from
New Construction 0.32 to 0.40 for PE
pipe
Inclusion of
special permit
Incorporation of
renewal
ASTM D2313-09a
requirements in
if not included in
regulations.
the Standards
Incorporated by
Cost recovery on
Reference
design safety
rulemaking
reviews
Rupture
Detection and
Valves
AGA Members
are Taking Action:
Commitment to
Enhancing Safety:
Evaluate use of
ASVs and RCVs on
Transmission HCA
block valves
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National Pipeline Mapping System
• AGA Supports a modernization of the NPMS
• Dramatic increase in quantity of data requested
• Concerns on security of pipeline infrastructure
• Industry believes this request should be
formalized in Rule Making not Information
Collection
• Proposal is significant burden on many operators
• PHMSA Estimated Burden = 420,516 hours
• 347 hours / respondent
• Very high estimate for PHMSA
• & still too low
Examples of Data
Requests
New Data Requested
Includes
• Narrow positional
accuracy
requirements
• 5 Feet
• Pipeline material and
manufacturing details
• Location details on
facilities
Federal Register Notice = July 30, 2014
Comments Due = September 29, 2014
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Stay Tuned…
… New National Transportation Safety
Board (NTSB) Incident Report
... New NTSB Safety Study on Transmission
Integrity Management
... Pipeline Safety Reauthorization
… Pipeline Safety Hearings
… Office of Inspector General
Reports?
… Government Accounting Office
Reports?
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Erin Carmichael Kurilla
Manager, Engineering Services
202-824-7328
ekurilla@aga.org
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