In This Issue

Gas Transmission Advanced Notice of Proposed Rulemaking (ANPRM)

On August 25th, PHMSA published in the Federal Register an ANPRM titled “Pipeline Safety: Safety of Gas Transmission Pipelines.” In this ANPRM PHMSA is considering whether changes are needed to the regulations governing the safety of gas transmission pipelines. In particular, PHMSA is considering whether integrity management (IM) requirements should be changed, including increasing prescriptiveness in some areas, and whether other issues related to system integrity should be addressed by strengthening or expanding non-IM requirements. Among the specific issues PHMSA is considering concerning IM requirements is whether:

  • the definition of a high consequence area (HCA) should be revised to bring additional pipeline under IM requirements;
  • additional requirements are needed to improve operator consideration and implementation of preventive and mitigative measures to protect HCAs against incident consequences;
  • to revise IM repair criteria for pipeline segments; whether more prescriptive requirements are needed governing collection, integration, and validation of data concerning the pipeline; whether requirements related to pipeline risk analyses should be strengthened;
  • additional or revised requirements are needed concerning operator application of lessons learned through implementing its IM program; and
  • whether additional restrictions should be placed on the use of specific pipeline assessment methods.

With respect to non-IM requirements, PHMSA is considering whether:

  • revised requirements are needed on new construction or existing pipelines concerning mainline valves, including spacing and whether remotely operated (e.g., operated from a control room via SCADA system) or automatically-operated (i.e., no human action is required) valves should be installed;
  • requirements for corrosion control of steel pipelines should be strengthened;
  • new regulations are needed to govern safety of underground gas storage facilities;
  • requirements are needed to govern operator management of changes to its pipeline and operating practices; and
  • whether pipeline operators should be required to implement formal quality management systems for new construction and installations as well as for post-construction operation and maintenance.
  • exemptions applicable to facilities installed prior to the regulation and whether new regulations are needed to govern safety of rural gas gathering lines. These exemptions relate to allowable maximum operating pressure for pipelines that were in service before the initial gas pipeline safety regulations were published. These pipelines are commonly known as “grandfathered” pipelines.

The comment period for this ANPRM ends on December 2, 2011. For a copy of the ANPRM, please contact Jessica Roger.