On August 24, 2023, PHMSA issued their notice of proposed rulemaking (NPRM) for Safety of Gas Distribution Pipelines and Other Safety Initiatives, which published to the Federal Register today. This rulemaking comes out of the Protecting our Infrastructure of Pipelines and Enhancing Safety (PIPES) Act of 2020 and the Leonel Rondon Pipeline Safety Act following the Merrimack Valley Incident. To see the rule in its entirety, click here.
If you don’t have any distribution lines here are the other safety initiatives that are part of the NPRM:
192.9 – Removal of exemptions for Type A gathering lines from some emergency response requirements
192.615 – Emergency Response Plans must additionally include:
Prompt and effective response to a notification of potential rupture or release of gas that results in one or more fatalities. Notification of 911 or emergency center includes all prompt and effective response scenarios listed under 192.615(a)(3)
For distribution systems, the following updates are expected to be met within one year of rule publication, unless otherwise noted:
191.11 – Annual reporting for distribution systems
192.18 – Adds 192.1007 (DIMP) into notification requirements for alternative technologies, etc.
192.195 – New, replaced, relocated, or changed regulator stations on low-pressure distribution systems will need to have at least two methods of overpressure protection, measures to minimize overpressurization risk by a single event, and remote monitoring of gas pressure
192.305 – New, replaced, relocated, or changed transmission lines must be inspected per the code by personnel not involved in construction of pipe. New, replaced, relocated, or changed mains must be inspected per the code by personnel performing the same construction tasks, but who did not perform that work directly, with a written justification.
192.517 – Pressure test records now need to be maintained for the life for pipelines operating below 100 psi, service lines, and plastic pipelines. Pressure tests performed following the effective date will need to include the same information required for transmission line tests.
192.605 – Include in O&M Manuals and Emergency Response Plans:
- Overpressurization procedures detailing responding to, investigation, and correcting overpressure causes.
- Management of Change process that covers at least five types of specific types of changes; ensures personnel review and certify construction plans associated with installations, modification, replacements, or system upgrades for accuracy and completeness; and ensures any hazards introduced by change are identified, analyzed, and controlled before operations begin.
192.615 – Emergency Response Plans must additionally include
- Prompt and effective response to a notification of potential rupture; release of gas that results in one or more fatalities; for distribution operators, unintentional release of gas and shutdown of gas service to 50 or more customers, or if fewer than 100 customers, 50% or more of customers; any other emergency deemed significant by the operator.
- Notification of 911 or emergency center includes all prompt and effective response scenarios listed under 192.615(a )(3)
- For distribution line operators, establish and maintain communication regarding specifics of the emergency with general public as soon as practicable during a pipeline emergency. Communications must be in English and any significant secondary languages, be in a format accessible by the population, and continue through service restoration. This includes a system and written processes for rapid communication with customers and can be a voluntary system for the public to receive notification (18 months after rule publication).
192.638 – For distribution line operators, a new section requiring records for pressure controls and TVC documents that show pipeline characteristics necessary for understanding pressure limitations, including:
- Location of regulators, valves, underground piping
- Regulator set points, capacity, and valve failure position
- Overpressure protection configuration
- Other important records
If TVC records are not available, operators must identify what is needed and develop and implement a plan for acquiring those records. Required records must be accessible to all personnel involved in design, construction, operations, and maintenance activities.
192.640 – With the exception of distribution systems with remote monitoring and shutoff capabilities, a documented evaluation of each construction project must be completed to identify potential for overpressurization before project begins, including tie-ins, abandonment, and equipment replacement. If a potential for overpressurization is identified:
- At least one qualified person must be present at the district regulatory station or alternative site during project activity.
- Pressure must be monitored by capable equipment
- Have capability to promptly shut off gas flow or control overpressurization at regulatory station
The person monitoring for overpressurization must know the location of all isolation valves, pressure controls, and have stop work authority.
192.725 – Testing before returning to service must be in accordance with Subpart J.
192.741 – Low pressure systems must monitor pressure in accordance with 192.195(c)(3) (have at least two methods of overpressure protection, measures to minimize overpressurization risk by a single event, and remote monitoring of gas pressure).
192.1003 – Excludes LPG distribution systems serving less than 100 customers from one source from D-IMP applicability
192.1005 – Title change to include (remove exemption of) small LPG operators
192.1007 – DIMP updates
- Paragraph (a ) – Updated to align with 192.638(c ).
- Paragraph (b) – Threats now include overpressurization of low-pressure distribution systems with some more specificity to existing threats as well.
- Paragraph (c ) – Risk evaluation and ranking now includes certain pipes with known issues and low-pressure distribution systems that could make any connected low-pressure equipment unsafe, including factors other than observed AOCs; potential consequences of a low-probability event; and configuration evaluation of primary and secondary overpressure protection, availability of gas pressure monitoring, and the likelihood of a single event leading to an overpressurization.
- Paragraph (d) – Now includes the requirement to identify and implement measures to reduce risks of failure, including risks associated with age, pipes with known issues, and overpressurization of low-pressure systems. Specific preventive and mitigative measures must be implemented to minimize over-pressurization risk, including specific items detailed
192.1015 – Separate requirements for small LPG operators have been removed. Small LPG operators are now subject to the entirety of this part.
For States, updates include:
198.3 – New definitions have been introduced for “Inspection person-day” and “State Inspection Calculation Tool (SICT)”
198.13 – Clarifies numbers of state inspection person-days as determined by the SICT and other factors
If your company would like assistance interpreting and implementing these new requirements, please contact Elemental Compliance at Nicole.Tebow@ElementalCompliance.com or Lauren.Tipton@ElementalCompliance.com.