On Wednesday, July 22nd, the Gas Pipeline Advisory Committee (GPAC) met to discuss the recent set of proposed rules published by PHMSA on February 6th, 2020. The intent of this proposed rule, and associated proposed rules for rupture mitigation, was to comply with congressional mandates proposed by the 2011 Pipeline Safety Act, recommendations by the National Transportation Safety Board, and recommendations by the Government Acquisition Office (GAO) to improve pipeline safety.
GPAC members discussed at length the different proposed rules and provided feedback to PHMSA from the standpoint of feasibility, reasonability, cost-effectiveness, and practicality of implementation of the proposed rules from both an industry and public standpoint.
The proposed rules cover a variety of topics, most notably the creation of “rupture mitigation” valve requirements, which, if published, would require operators to install valves under certain conditions to minimize the impacts of a rupture on life, property and the environment. This rule was recommended with -some notable modifications. One significant elimination was the prescriptive 10-minute rupture identification requirement, as it was successfully argued that the differences in leak detection systems, operator-specific equipment and locations may make the 10-minute requirement unfeasible. Rupture mitigation valves were also recommended to only apply to transmission and type A gathering lines and not type B gathering lines.
One area of discussion that will require additional clarification from PHMSA will be the applicability to multiple pipe replacements wherein the rupture valve installation requirements may be triggered, as PHMSA has defined “entirely replaced” as when two or more contiguous miles are being replaced with new pipe. GPAC debated this topic, as operators regularly replace segments of pipe, and concluded that they would recommend to PHMSA to clarify whether the two miles need be continuous, or in aggregate. Additionally, GPAC recommended to revise the language to allow for a designated crossover valve to be classified as a rupture mitigation valve.
Valve spacing and class location changes were both topics debated during the meeting, as the new rule may require an operator to install rupture mitigation valves if the class location changes when pipe is replaced to meet maximum allowable operating pressure requirements for the updated class location. GPAC debated the merit of this requirement and found that most class changes, and valve installations, occurred in Class 1 and 2 locations, largely outside of high-consequence areas. This minimizes the impact of this regulation as it would primarily affect locations re-classified to Class 3 and 4 locations. GPAC recommended acceptance of this proposed rule, with the clarification that valve installation would not be required for Class 1 and 2 locations outside of a high-consequence area, and spacing requirements would apply to replacement projects covered by the proposed transmission line valve rules in 192.179. Additionally, to minimize impacts, GPAC proposed to allow operators to automate existing valves to comply with the new requirements when pipe replacement due to class location was between 1000 feet and 2 miles.
GPAC considered proposed rules for maintenance requirements, failure investigations, and emergency response actions for gas transmission pipelines. This included clarification that lessons learned and preventative and mitigative measures were required after an incident only when reasonable and practicable, and that annual drills were only applicable to manually operated or locally-operated valves, and not automatic shutoff valves or remote control valves which may act as rupture mitigation valves. GPAC also recommended that PHMSA clarify that the requirements for general failure investigations apply to distribution lines, and specific failure investigations as provided in 192.617 (c) and (d) would only apply to transmission lines, and not distribution lines. Finally, GPAC recommended approval of revised communication rules which would require operators to contact the local public safety answering point (911) after determination of a rupture occurrence. This was to ensure that local first responders and officials were quickly aware of any hazardous situations and could ensure proper responses and use of local resources.
The final docket from GPAC, along with a recorded transcription of the teleconference, updated slides, and links to the NPRM can be found on www.regulations.gov.