Valve Rule Analysis
On April 8, 2022, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published the Requirement of Valve Installation and Minimum Rupture Detection Standards Final Rule (Valve Rule) in the Federal Register with an effective date October 5, 2022. This Rule applies to new or replaced segments totaling two (2) miles or more in an area of a contiguous five (5) miles in length for the following pipeline types on or after April 10, 2023:
Natural gas transmission lines with a diameter of 6-inches or larger
Type A gas gathering lines
Hazardous liquid line with a diameter of 6-inches or larger
The Valve Rule includes Rupture Mitigation Valve (RMV) or equivalent technology spacing and location requirements as follows:
Natural Gas RMV spacing:
Class 4 locations - Every four (4) miles; shutoff segments no greater than eight (8) miles between valves
Class 3 locations – Every seven-and-a-half (7 ½) miles; shutoff segments no greater than fifteen (15) miles between valves
Class 1 and 2 locations with a PIR greater than one hundred fifty (150) feet – Every ten (10) miles; shutoff segments no greater than twenty (20) miles between valves
Class 1 and 2 locations with a PIR equal to or less than one hundred fifty (150) feet are exempt
Hazardous Liquid RMV spacing and locations:
Pipelines that could affect HCAs – Every fifteen (15) miles, not to exceed seven-and-a-half (7 ½) miles for the endpoints of the shutoff segment
Pipelines that could not affect HCAs – Every twenty (20) miles
Maximum distance of seven-and-a-half (7 ½) miles from could affect segment endpoints
On HVL pipelines within an HPA or OPA with a maximum spacing of seven-and-a-half (7 ½) miles
On the suction and discharge of a pump station
On each pipeline entering or leaving a breakout out tank storage area
On pipelines in a manner that will minimize or prevent safety risks, property damage, or environmental harm
In locations determined by the integrity management preventive and mitigative measure process
On laterals which permits shutdown of lateral without impacting mainline flow
On each side of water crossings greater than on hundred (100) feet wide at the high-water mark
Maximum one (1) mile intervals for water crossings
On each side of a reservoir used for drinking water
Natural Gas and Hazardous Liquid operators are required to update procedures in to include:
Specific actions for controllers
Identification of a potential rupture with specific criteria
Incident investigation including sending failed pipe or components for testing
Incorporation of lessons learned into design, construction, testing, maintenance, operations, and emergency response manuals as well as training programs
Analysis of rupture and valve shut-off responses
Incident summary within ninety (90) days
Establish and maintain liaison with 911 and LEPC (if applicable) immediately upon notification of a potential rupture
Receiving, identifying, classifying notices of events that need immediate response
RMVs must meet the following requirements and capabilities:
RMVs must be operational within fourteen (14) days of installing or replacing the pipe unless operators can demonstrate that it would be economically, technically, or operationally infeasible
If manual valves are employed as alternative equivalent technology, procedures must designate nearby personnel to ensure shut down within thirty (30) minutes
Definition of Notification of a potential rupture
Operator must fully close RMVs or alternative equivalent technologies within thirty (30) minutes of rupture identification
RMVs must:
Be capable of being fully closed within thirty (30) minutes of rupture identification
Be capable of being operated remotely or by onsite personnel
Be able to be monitored for status
Have a backup power source to maintain communications
Be monitored for valve response status
Have flow modeling performed
Maintenance requirements for RMVs include:
Point-to-point verifications in accordance with control room requirements
If manual valves are employed drills must be completed to ensure closure time of thirty (30) minutes as well as post-drill follow-up, including training and procedure updates.
Inspection:
For natural gas automatic shut-off valves (ASVs) functioning as RMVs – Annually, not to exceed fifteen (15) months
For hazardous liquid RMVs and emergency flow restricting devices (EFRDs) – Twice a year, not to exceed seven-and-a-half (7 ½) months
Valve remediation of any valve found to be inoperable:
Repair or replace as soon as possible but within twelve (12) months
Designate an alternative acting RMV within seven (7) calendar days
Integrity management and risk analysis requirements regarding RMVs include:
If it is determined an RMV would mitigate risk in a High Consequence Area (HCA), the RMV must be installed (includes ASVs for natural gas and EFRDs for hazardous liquids)
For natural gas pipelines - Risk assessments must be reviewed and certified by a senior executive of the company annually and within three (3) months following an incident or safety-related condition
For hazardous liquids – EFRD analysis must be performed prior to placing the pipeline into service
If you have questions or would like to discuss a path forward on this or any other pipeline safety rulemakings, please contact Elemental Compliance at Nicole.Tebow@ElementalCompliance or Lauren.Tipton@ElementalCompliance.com.
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