regulatory update 2019 final · • enhanced emergency order procedures • pipes act of 2016 to...

4/19/2019

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Regulatory Update

Gas Pipeline Safety

• Provides PSCWV both inspectionand enforcement authority forintrastate hazardous liquid and gasgathering and transmissionpipelines as well as gas distributionpipelines.

• Certified by PHMSA under USC§60105

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PHMSA• Gas Pipeline Safety Program

– Program has annual review includingprogress report and field inspection

– Results can be found at:https://phmsa.dot.gov/pipeline/stateprograms

/stateoversight– Grant funding based on results

• Additional funding from pipeline assessmentfees

Gas Pipeline Safety Division

• Director Mary Friend

• Manager Bob Weiford

• Four inspectors Girija Bajpayee

Ed Clarkson

David Hancock

Jim Searls

• Administrative Kay Cottle

• Three inspector vacancies

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Gas Pipeline Safety• Oversee ± 99 operators

– Ten different types of intrastate operators

– Hazardous liquid transmission and gathering,

– Gas transmission

– Gas gathering Type A, gas gathering Type B,gas gathering Type A and B

– Transmission and Type A, Transmission withType B, Transmission with Types A and B

– Gas distribution

– LP (propane) distribution

Gas Pipeline Safety• Oversee ± 99 operators

• Name changes

– Three already in 2019

– Ten in 2018

– Seventeen in 2017

• §191.22 requires notification of namechanges, acquisition or divestiture of assets

– Courtesy call always appreciated

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Gas Pipeline SafetyPSCWV REGULATED PIPELINE MILEAGE

TYPE OF PIPELINE MILES

YearHazardous

Liquid

GasTransmission

(Intrastate)

RegulatedGas

Gathering

Gas Distribution

Total

Mains Services

2018 164 168 399 10,961 2,282 13,974

2017 164 170 389 10,906 2,280 13,909

2016 230 170 403 10,883 2,262 13,948

2015 322 221 369 10,850 2,431 14, 193

2014 204 280 406 10,732 2,424 14,046

Inspections

Inspection Performance(Gas and Hazardous Liquid)

Year Inspections InspectorsInspection

Days

2019 98 (1) 4 FT 433

2018 137 (2) 2 FT, 3PT 439

2017 120 (2) 4 FT, 2 PT 547

(1) – planned program inspections(2) - includes construction inspections

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CY 2018

Gas Reportable Incidents

– No intrastate reportable incidents

– Six interstate reportable incidents

Hazardous Liquid Accidents

– One intrastate reportable accident

– One interstate reportable accident

• Girth weld

• Down slopelandmovement

• Three eventsdue to slips

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CY 2018

Safety related conditions

– One hazardous liquid,

• IM repairs

– One gas

• Land movement

Regulatory Update

PHMSA

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Interim Final RuleDecember 19, 2016

Safety of Underground Natural GasStorage Facilities

Interim regulations effective January 18,2017

Additions to Parts 191and 192

Final rule projected publication date –7/2/2019

Final RuleJanuary 23, 2017

• Remove farm taps from DIMPrequirements

• Adds requirement for farm tap regulatorand overpressure protection inspectionsevery 3 years as new §192.740

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Final RuleJanuary 23, 2017

• Farm tap FAQs issued 1/27/18

• Farm tap FAQs withdrawn 1/31/18

• Inspections completed by 12/31/19

• Exercise of EnforcementDiscretion

– March 26, 2019

Plastic Pipe Final Rule

• Issued November 20, 2018

• Effective January 22, 2019

• Added incorporated by reference documents,new design criteria, joining criteria,installation

• AGA petition for reconsideration filedDecember 20, 2018

• PHMSA response on March 11, 2019

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Plastic Pipe Final RuleRevised Compliance Deadlines

Topic SectionNew Compliance

Deadline

Joining with mechanicalcouplings

§§192.281(e)(3), (e)(4),192.283 and 192.285

April 22, 2019(90 days)

Installing service lines withcompression couplings §192.367

April 22, 2019(90 days)

CP design andimplementing corrosioncontrol for electricallyisolated fittings

§192.455April 22, 2019

(90 days)

Maintaining equipment usedfor joining §192.756

April 22, 2019(90 days)

Devices and components towithstand loads and meetspecification

§§192.143, 192.313,192.145, 192.149, 192.375,192.281(e)(3), 192.283,192.285, 192.376

April 22, 2019(90 days)

Plastic Pipe Final RuleCompliance Deadlines

Topic Section New ComplianceDeadline

Develop/implementprograms for weak links

§192.329 July 22, 2019(six months)

Develop/implementprograms for storing andhandling plastic pipe

§192.67 July 22, 2019(six months)

Develop programs formaintaining joiningequipment

§192.756 July 22, 2019(six months)

Category 1 fittingrequirements

§192.281(e)(4) January 22, 2020(one year)

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Notice Part 199Drug and Alcohol

• Issued December 11, 2018

• Minimum drug testing rate for all coveredemployees will be 50% during calendaryear 2019

• 2016, 2017 positive drug rate was >1%triggering the increase in testing

• Reminder to report contractor data toannual management information system

ADB 2019-01

• Potential for Damage to Pipeline FacilitiesCaused by Flooding, River Scour, andRiver Channel Migration

• Issued April 11, 2019

• Actions to prevent and mitigate damage topipeline facilities and ensure public andenvironmental safety in areas affected byflooding

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ADB 2019-01• 15 items for operators to consider

• Some preplanning such as using hydrologists todetermine max flow and potential for scour

• Review crossing installation information,evaluate facilities for flood potential

• Inform personnel such as control room, deploypersonnel as needed, open communication withemergency officials

• Patrolling and post flood evaluation of facilities

Class Location Change

• ANPRM – July 31, 2018• Potential safety consequences of altering

the current class location methodologyand moving to an IM-only method incertain areas

• Class location special permits

• ANPRM scheduled 11/15/2019

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Pipeline Risk Modeling

• Request for comments, August 16, 2018

• PHMSA and NTSB identified generalweakness in risk models

• Pipeline Risk Modeling Report on gas andhazardous liquid pipeline risk models indocket no. PHMSA-2018-0050

TIMP FAQ

• Request for comments, November 15,2018

• Frequently asked questions (FAQs)developed to provide guidance on whatconstitutes sufficient justification for anoperator to request a 6- month extensionto a gas pipeline's 7-year integritymanagement reassessment interval.

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Status of OtherRulemaking

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Status of Rulemakings

• Report of Significant Rulemakings

• Keep public aware of regulatory activities

• https://www.transportation.gov/regulations/report-on-significant-rulemakings

• March 2019 last report

• Outstanding NTSB and PIPES 2016issues

• Mandate of 2 for 1

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Status of Rulemakings

• Hazardous Liquid Pipelines

– NPRM – 10/2015

– Leak detection, data integration, outside forceinspections, update repair criteria

– FR published 1/13/17, withdrawn 1/24/17

– Proposed final rule publication date -6/28/2019

Status of Rulemaking

• Gas Transmission – “Mega Rule”

– NPRM – 4/8/2016

– MAOP confirmation, material verifications,grandfathered MAOP, MCA’s, risk analyses,definitions and gathering lines

– Split into 3 different sections

• Two on transmission – already had technicalcommittee meetings

• One on gathering

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– Phase 1 Transmission

• Integrity inspections outside HCAs, 6 monthextension of IM assessment intervals,testing/pressure reconfirmation of MAOP withinadequate records, MAOP exceedances, andseismicity as threat

• GPAC meetings

• Projected final rule publication -8/20/19




– Phase 2 Transmission

• Repair criteria, MOC, post event inspections,updating and bolstering corrosion control,clarification of IM assessment requirements

• GPAC meetings

• Projected final rule publication – 12/20/2019

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– Gathering Pipeline

• Reporting, regulatory requirements for certainClass 1 locations, gathering definitions

• GPAC scheduled 1/19 (postponed)

• Rescheduled for June 25, 2019

• Projected final rule publication – 12/20/2019

Gathering Pipelines

• NPRM proposed changes to endpoint of gathering– API RP80 revision

• Additional requirements for largediameter high pressure pipelines– New API RP 1182 - Safety Provisions for

Large Diameter Rural Gas GatheringLines

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• Rupture Detection and Automatic Valves

– NTSB recommendation to reduceconsequences of large volume releases

– Gas and hazardous liquids

– New or replaced pipelines

– Specific valve spacing and maintenancerequirements

– Projected NPRM– 8/7/19


• Pipeline Regulatory Reform

– Regulatory relief actions from regulatoryreview, public comments, petitions (fromNAPSR, GPTC and others)

– NPRM Projected 8/14/2019

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• Enhanced Emergency Order Procedures• PIPES Act of 2016 to establish procedures

for the issuance of emergency orders(restrictions, prohibitions) to addressunsafe conditions or practices posing animminent hazard.

• Interim rule 10/14/2016• Projected final rule publication 4/22/2019


• Repair Criteria for Hazardous LiquidPipelines– Modify repair criteria for HCA’s and develop

new repair criteria for non-HCAs

• Amendments for Liquefied Natural Gas(LNG) Facilities– Update IBR, address risks including small

LNG facilities

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Reauthorization

• PHMSA reauthorized every four years– Congress provides mandates

– Based pm NTSB and other recommendations

• PIPES Act of 2016

• Preliminary hearings

• Potential State Issues– Reduced funding

– Ex parte status

– Damage prevention enforcement

Reauthorization

• Senate bill on pipeline safety

– Solely for distribution

• Safety Management Systems (API RP1173)

• Sign off by registered engineer

• Operator Qualification

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WV Regulations

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Damage Prevention

• Damage Prevention Enforcement– Senate Bill 631 passed in March 2018

– Effective July 1, 2018

– Creates a damage prevention board to allowcivil enforcement actions against bothoperator and excavators

– 2018 PHMSA review still inadequate

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• 150 CSR 4

• Splitting pipeline safety from utilityregulations

• Preliminary discussion

Inspections

• Inspections mandated by PHMSA StateProgram Guidelines

• Unlike PHMSA, States do not performintegrated inspections

• Use IA as much as possible, but not fullydeveloped for distribution and gatheringsystems

• Difference between audit and inspection?

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Inspections

• Inspections mandated by State Programs

• Field inspections

– Standard Inspections – records/field

– Operator Qualification

– Construction

– O&M activities such as leak repairs, corrosion

Inspections

• Inspections mandated by State Programs

• Program inspections

– Integrity Management

– Control Room Management

– Public Awareness

– Operator Qualification

– Drug and Alcohol

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Inspections

• Required by state regulations to give exitinterview

• Missing records, operator has 15 days tosupply

• After 15 days, inspector will completeinspection and turn in

• If issues, 90 days to receive something inwriting

System Descriptions

• Brief descriptions of operator systems

– Units based on service areas or locations

– Share common written programs with others

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Inspection Issues

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Over pressure protection

• Copies of records when another operatoris providing over pressure protection

– Operator responsible for protectingMAOP/MOP

• HL relying on pump specifications

– Annual verification that pump or parametershas not changed

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Inspection Issues

• §192.463 – External corrosion control:Cathodic Protection

– (a) …must provide a level of CP that complieswith one or more of the applicable criteria in192 Appendix D, §195.571 (NACE SP 0169)

• Negative voltage of at least 0.85 volts (850 mv),

• Polarization voltage shift of 100 mv

• Appendix D, Section II

– Voltage (IR) drops must be considered for validinterpretation of the voltage measurement

IR DROP

• Must consider IR drop

• Readings of -850 mv probably do not meetrequired criteria

• If no established IR drop, can estimateand establish an IR drop for O&Mpurposes and action

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Inspection Issues

• Written procedures

– Detailed so someone with minimalunderstanding can follow and get reproducibleresults

– “That’s the way we have always done it”doesn’t work

Must followplans andprocedures asoutlined in theCompanyO&M andother manuals

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Inspection Issues

• §192.467 (§195.575)– Electrical Isolation

– (a) must be electrically isolated from otherunderground metallic structures, unless theyare electrically interconnected andcathodically protected as a single unit

– (d) inspection and electrical tests must bemade to assure that isolation is adequate

Electrical Isolation

• No insulators installed

• Shared facilities – no test

• Do not address isolation in O&M manual

• Distribution – could be part of integritymanagement (perhaps §192.1013?)

• Includes shorted casings – criteria todetermine if shorted?

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Inspection Intervals

• Many once per calendar year, not to exceed15 months

• Six times per year, not to exceed 2 ½months (75 days)

• Every three calendar years not to exceed39 months

• To the day

• Can do early, but not late

– Reset calendar

Inspection Issues

• § 192.459 External Corrosion – Examinationof Buried pipe– Buried pipeline exposed, examined for evidence

of external corrosion or if the coating isdeteriorated

– Investigate circumferentially and longitudinallybeyond exposed portion

• §192.475 – Internal Corrosion – General– (b) internal surface inspected for evidence of

corrosion

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Notification

• §§191.22, 195.64 – National Registry ofOperators

– Each regulated operator must have anoperator identification number (OPID)

– Notify prior for construction, flow reversal,pipeline conversion

– Notify after for name changes, acquisition ordivestiture of pipeline, change in entityresponsible for existing pipeline

Emergency Number

304-340-0486

Emergency reporting, courtesy calls,questions

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Mary Friend

[email protected]

304-340-0770

304-382-3976304-340-0486

(24-hour emergency)

regulatory update 2019 final · • enhanced emergency order procedures • pipes act of 2016 to...

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