The Gas Pipeline Advisory Committee (GPAC) met on Wednesday, October 7, to discuss and vote on changes to the gas pipeline regulations. These changes were published as part of the Notice to Proposed Rulemaking on June 09, 2020, for review and comment. Several different provisions were discussed and voted upon. The majority of the topics were applicable to natural gas distribution operators.
First on the docket was a discussion on farm taps, and the exemption for farm taps included in a DIMP program to be exempted from prescriptive testing criteria listed in 49 CFR 192.740. This provision was unanimously approved by GPAC, with the request that PHMSA remove language regarding “service line portion of a farm tap” due to the fact that this language would have a wider impact than only the requirements in 192.740, and that PHMSA utilize the proposed Farm Tap FAQ’s to address any specific issues regarding definitions. GPAC voted unanimously to adopt with the removal of the definition.
Next up was a discussion on pressure vessel testing and the conflict between part 192 and the ASME Boiler and Pressure Vessel Code (BPVC). The edition of the BPVC which has been incorporated by reference (2001) has required pressure vessel testing to 1.3 times the maximum allowable working pressure (MAWP), while part 192 continues to require a 1.5x MAWP test requirement. PHMSA has proposed to change the rule to allow a 1.3x test factor with the requirements for test duration already stated in Subpart J. Additionally, the proposed rule would allow for an operator to use a strength test performed by the manufacturer after transportation to the installation location. GPAC voted to adopt the rule with clarification for on-location testing, requirements for relocated vessels to meet current design requirements and be retested after installation.
Following this was a discussion on a number of small amendments:
- Incident reporting criteria – PHMSA proposed to raise property damage criterion to $122,000 to account for inflation and keep remainder of rule unchanged. GPAC voted unanimously to approve the proposal and include provisions to adopt appropriate inflation adjustment at time of publication, and include a formula in part 191 for future updates.
- Master meters – PHMSA has proposed to exempt master meter operators from DIMP requirements, which GPAC voted to approve.
- Mechanical Fitting Failure (MFF) reporting – PHMSA proposed to eliminate the MFF and include that information in an incident report, as well as include a count of leaks due to MFF’s to the annual report. Industry was fully in favor, however public members of GPAC did object as they felt that adding this data would double count since leaks are already noted under other categories, and that the MFF data is valuable in identifying problems. GPAC voted 10-2 to approve the proposal as is, as PHMSA believes that a combination of incident reports and leak counts from gas distribution annual reports will provide adequate data for evaluation.
- Plastic Pipe – PHMSA proposed a number of small amendments to the plastic pipe rules, including revision of “design formula” to design “pressure”, correct minimum wall thickness for 1” CTS pipe, and clarify that pipe produced on the effective date of the rule may used revised design factor. GPAC voted to approve the proposal as stated, with a clarification to modify the minimum wall thickness table for 1” CTS pipe to 0.099-inch minimum rather than 0.101-inch minimum.
- Remote Rectifier Monitoring – PHMSA proposed to permit remote monitoring of rectifiers and clarify the specific readings that should be obtained during a rectifier inspection. Additionally, PHMSA proposed that requirements be added for physical inspection of devices if remote monitoring is being used to meet the requirements of 192.465(b). GPAC voted to approve the proposed rule, with the clarification that operators must physically inspect rectifiers once per calendar year, rather than when annual CP surveys occur.
- Atmospheric Corrosion – PHMSA proposed to extend the atmospheric corrosion inspection intervals from 3 years to 5 years for distribution service pipelines, unless atmospheric corrosion was previously identified, which would require the line to remain on a 3-year cycle. PHMSA’s proposal also included clarification of DIMP requirements to consider atmospheric corrosion as a corrosion threat. GPAC voted to approve the proposal 10-2 for the re-inspection interval on service lines, as long as the atmospheric corrosion was completely remediated. Specifically, GPAC recommended the following language be used: “If atmospheric corrosion is found, evaluated, and remediated following an inspection, and there is no evidence of systemic atmospheric corrosion due to the environment or similar factors , the operator can inspect for atmospheric corrosion on a 5-year cycle rather than the proposed 3-year cycle”
- Welding Processes – PHMSA proposed to extend the interval for “engagement in a welding process” from six months to twice per year, not to exceed 7.5 months. GPAC voted to approve as written.
- Pre-Tested Short Segments of Pipe and Fabricated Assemblies – PHMSA proposed to extend the allowance on pretested pipe and assemblies to steel pipe operating at an MAOP with hoop stress less than 30 percent but above 100 psig. GPAC voted to support PHMSA’s proposal with a recommended change to remove the hydrostatic test requirements for these lines, as code already allows for natural gas, inert gas and air as allowable test media for lines operating at a hoop stress of less than 30 percent.
The combination of both industry and public input continues to support the development of requirements that are both necessary for public safety and feasible for operator implementation. It is anticipated that the final rule which contains these changes will be published before year’s end.
For questions concerning this topic and other federal or state regulatory matters, please feel free to reach out to our Regulatory Compliance group on our website or directly via email, Wallace.McGaughey@g2-is.com or Al.Giordano@g2-is.com.