§195.420 Valve maintenance. Compliance Guidelines.

Valve maintenance for both hazardous liquid and gas pipelines is required to be conducted on a periodic basis.  Valves on liquid lines are inspected and maintained twice a year, gas pipelines annually.  The language of the liquid and gas regulations varies slightly, and for gas pipelines there are different requirements fro transmission and distribution valves.

The following is from the PHMSA Operations and Maintenance Guidance for Subpart F in Part 195 regarding hazardous liquid pipelines.  It provides examples of advisories and enforcement actions, as well as compliance guidance and examples of probably violations.

§195.420  Compliance  
Enforcement Guidance O&M Part 195
Revision Date 12-07-2011
Code Section §195.420
Section Title Valve Maintenance
Existing Code Language (a) Each operator shall maintain each valve that is necessary for the safe operation of its pipeline systems in good working order at all times

(b) Each operator shall, at intervals not exceeding 7 1/2 months, but at least twice each calendar year, inspect each mainline valve to determine that it is functioning properly.

(c) Each operator shall provide protection for each valve from unauthorized operation and from vandalism.

Origin of Code Original Code Document, 34 FR 15473, 10-04-1969.
Last Amendment Amdt. 195-24, 47 FR 46850, 11-22-1982.
Interpretation/Summaries  
Advisory Bulletin/Alert Notice Summaries Advisory Bulletin ADB-02-03, Gas and Hazardous Liquid Pipeline

MappingThe Research and Special Programs Administration’s (RSPA) Office of Pipeline Safety (OPS) is issuing this advisory to gas distribution, gas transmission, and hazardous liquid pipeline systems. Owners and operators should review their information and mapping systems to ensure that the operator has clear, accurate, and useable information on the location and characteristics of all pipes, valves, regulators, and other pipeline elements for use in emergency response, pipe location and marking, and pre-construction planning. This includes ensuring that construction records, maps, and operating history are readily available to appropriate operating, maintenance, and emergency response personnel.

 

RSPA urges every pipeline operator to (1) accurately locate and clearly mark on company maps and records key pipeline features and other information needed for effective emergency response; (2) keep these maps and records up-to-date as pipeline construction and modifications take place; (3) ensure that its personnel are knowledgeable about the location of abandoned pipelines and to keep data on their location in order to further eliminate confusion with active pipelines during construction or emergency response activities; and (4) communicate pipeline information and maps to appropriate operating, maintenance, and emergency response personnel. Operators are also encouraged to collaborate with the Common Ground Alliance and the Federal and State pipeline safety programs to improve all phases of underground facility damage prevention, including improved mapping standards; and to work toward developing and using, to the maximum feasible extent, consistent mapping symbols and notational systems.

 

Alert Notice ALN-89-02, Each operator should test check valves.

The purpose of this Alert Notice is to advise you of the results of an investigation conducted by OPS of a recent pipeline accident and the relevance of that investigation to the safe operation of check valves.  With this notice, OPS is alerting each gas transmission operator and hazardous liquid pipeline operator of the need to test check valves located in critical areas to assure that they close properly.

Other Reference Material& Source  
Guidance Information 1.  All mainline valves are necessary for the safe operation of a pipeline system.  In addition to mainline valves, other valves are necessary for the safe operation of a pipeline.

2.  The operator must be able to identify (list) all valves on its system that are necessary for the safe operation of their pipeline, including mainline valves.

3.  The operator must inspect and partially operate all mainline valves within the required time intervals.

4.  The operator must have records showing that all valves necessary for the safe operation of its pipeline system have been maintained.

5.  Maintenance discrepancies identified during valve inspections must be addressed and remedial actions documented.

6.  Valves installed after October 4, 1969 must have an indicator, to clearly show the valve position as required in §195.116(e).

7.  Mainline valve inspection/testing records shall identify the individual who did the valve inspection, the date the valve inspection occurred, which valve items were inspected and or tested to determine it was functioning properly, the condition of those valve items inspected and or tested, resolution of valve items found to be deficient.

8.  Some mainline valves may be equipped with a thermal relief valve from the manufacturer to protect the valve body from thermal expansion when the valve is shut in.  This relief valve must be inspected.  This inspection, per the operator’s procedures or manufacturer’s recommendations, can be done with the mainline valve inspection required here, or done on a separate inspection schedule just for the reliefs.  (See 195.428).

9.  Maintenance records for all valves necessary for the safe operation of a pipeline must show that the valve was maintained adequately, using the operators’ procedure, the manufacturer’s recommendations, or some combination thereof.

10. Procedures for maintaining all valves necessary for the safe operation of a pipeline must describe in adequate detail how valves are to be maintained.  This could be a company procedure or it could reference the manufacturer’s recommended maintenance practices.

11. Procedures for inspecting mainline valves must describe in detail how mainline valves will be inspected to ensure they are functioning properly. Procedures shall include more than just partially operating a valve, including valve maintenance items, such as dewatering and winterization of valves as appropriate.  Often part of the procedure is a checklist of specific items following the manufacturer’s recommendations to be used by personnel in performing the inspections. Dewatering and winterization of valves as appropriate

12. Procedures must address how deficiencies found during valve inspections will be handled.

13. Valves need to be in a secure area to prevent tampering and vandalism or locked.

14. An operator should determine the security requirements needed for their valves.

15. Final Order Guidance.

 

a.  BP Pipelines (North America) Inc. [3-2006-5027] (November 7, 2007) –Found that operator had valves that did not operate at the time of an inspection because of the intrusion of water that had frozen.  The operator argued at hearing that the valves had been inspected at the required intervals in accordance with their procedures, and that these valves were inoperable at the time of the inspection, but the valves were on a line that was not in-service at the time of the OPS inspection.  The Final Order found the operator in violation.  CP

 

b.  Kinder Morgan C02 Logistics Operations. L.P. [4-2006-5003] (October 12, 2010) – Found that the operator had a large number pipeline valves that did not have fencing around them. Many of the operator’s valves had pipe post and beam enclosures, which might keep cattle from rubbing against the valves and piping but would not discourage vandalism. An operator must use appropriate protective measures to prevent unauthorized operation or vandalism of their valves.  The operator alleged to have performed a security study to determine where fencing was needed but provided no documentation.  The CO required the operator to perform a security study of its valves and take appropriate actions to correct those locations the study found to have deficient valve protection.  CO

 

c.  Cenex Pipeline Company [5-2001-5003] (February 10, 2003) – Found that the operator did not have records to show that they had inspected and tested 48 mainline valves.  Operator argued that there is no clear definition in Part 195 for a mainline valve.  In the Final Order mainline valves were defined as valves integral to the safe operation of the pipeline system such as those used for station isolation, segment isolation, water crossing isolation, and lateral isolation.

 

Respondent is correct that neither the pipeline safety statute nor part 195 regulations define a “mainline” or “mainline valve.” Without a definition of a mainline valve, a common sense approach is needed.  The list in §195.260 has been interpreted as referring to examples of mainline valves.  Section 195.260 (c) uses the term mainline but only to provide that valves located on a mainline have to be located at certain points along that line. This requirement does not imply that only valves listed in §195.260 are mainline valves.

 

The examples in §195.260 are consistent with ASME/ANSI.  The ASME B31.4 Code provides that mainline valves are to be located at certain locations critical to the safe operation of a pipeline system.   Regulations must be read in entirety to ascertain the true nature of the intent and purpose sought to be accomplished. The inspection requirements of Part 195 are not based upon system design but on safety needs.

 

In this case, after further review and consideration of the purpose that the 158 valves serve to the operation of Respondent’s pipeline system, OPS has determined that there were 48 missed mainline valve inspections and not 158 as originally proposed. The valves in question are used for station isolation, segment isolation, water crossing isolation, and lateral isolation. These valves, which are integral to the safe operation of the pipeline system, should have been classified and treated as mainline valves and inspected according to the requirements of §195.420(b).  Respondent’s records do not show that inspections were conducted within the required intervals.  CP

Examples of a Probable Violation or Inadequate Procedures 1.  The lack of procedures is a violation of 195.402.

2.  The lack of records is a violation of 195.404.

3.  Operator did not identify mainline valves or other valves necessary for the safe operation.

4.  Operator did not maintain each valve that is necessary for the safe operation of its pipeline systems in good working order at all times.

5.  Mainline valve inspections were not performed at the minimum required intervals.

6.  Operator did not provide security for each valve necessary for the safe operation of its pipeline from unauthorized operation and vandalism.

7.  Operator did not follow their procedures.

8.  Valve inspection and maintenance records do not contain specificity to determine one or more of the following 1) who did inspection and maintenance, what was inspected, what maintenance was performed, and what was found.

9.  A valve necessary for the safe operation of a pipeline is observed to be inoperative regardless of the operating status of the pipeline. (CPF 3-2006-5027)

Examples of Evidence 1.  O&M Manual procedures.

2.  Operator’s personnel statements.

3.  Records identifying mainline and other valves needed for safe operation.

4.  Inspection records

5.  Maintenance records.

6.  Manufacturer’s maintenance recommendations.

7.  Photos of valves in regard to maintenance, position indicator, and security issues.

8.  Lack of procedures or records.

Other Special Notations  

All this and more including all the PHMSA Enforcement Guidance in WinDOT, The Pipeline Safety Encylopedia.

 

 

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