Odorization conference announced

Clarion Technical Conferences has announced it will hold the Natural Gas Odorization International Conference & Exhibition in Houston, TX, on May 25-26, 2010.  This is the first such meeting in several years and will cover all aspects of odorization.

A “Call for Papers” was issued inviting odorization experts from around the world to submit abstracts for review.  More information can be found at http://www.clarion.org/naturalGas/naturalGas10/main.php.

Odorization requirements for gas pipelines can be found at 49 CFR 192.625.  Distribution lines are required to be continuously odorized, transmission lines have varying requirements and in many cases are not odorized at all.  Odorization is a complex operation that needs close attention to be effective.

PHMSA last amended the odorization regulations in 2003 to require odor testing be done with an instrument capable of measuring the gas-in-air concentration at which gas is readily detectable.  “Readily detectable” can vary by person, so perhaps a definition of the concept is in order.

Readily detectable odoran odor that can be discovered, determined or whose existence can be identified in a ready manner, without hesitating or much difficulty.

How do operators ensure their personnel understand this concept, so as to be able to report correctly when testing odor intensities?  Perhaps a better way of understanding this idea of readily detectable is to put it in a different perspective.  “The odor of gas should be one that a spouse, family, or member of the general public would quickly recognize, prompting them to take appropriate action.”

You can read additional information on odorization by clicking on the “Complying with odorization regulations” link to the right.

The Natural Gas Conference will explore this and all other facets of odorization from selecting an odorant, injection rates, testing and clean up.

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Pipeline Security, serious business

The TSA posted a notice in today’s Federal Register requesting comments on a new data collection requirement.  TSA will soon be publishing “Pipeline Security Guidelines” to replace the current Pipeline Security Information Circular issued on September 5, 2002.  Included in the Guidelines will be a request for security information, including an operator’s primary security contact and notification if various security events occur.  Submission is voluntary.

Recommendations from the 9/11 Commission Act of 2007 (Public Law 110-53) include provisions for the Department of Homeland Security and DOT to review review operator security plans.  The departments will work to prioritize risks and response actions and if necessary develop regulations for pipeline security.

Pipeline security is serious business.  We’ll have more information as it is made available.

Waiting for DIMP

Distribution companies are anxiously awaiting the final rule on Distribution Integrity Management as we progress through the summer.  The expectation is the rule may be released in September.  It is believed to be under review (possibly completed) at the Secretary’s office and then on its way to OMB before publication.

What changes can we expect?  Without seeing the rule itself it is impossible to know, but several presentations on DIMP have presented a glimmer of what we may see in the final rule.  The following is unofficial, obtained from TPSSC records and industry presentations.

  • Records – a reduction in the record keeping and documentation requirements.
  • Performance Through People (PTP)- removed from the rule.
  • Plastic pipe failure reporting, removed and mechanical/compression coupling failure reporting added.
  • Definition of hazardous leak added and damage further defined as excavation damage.
  • Clarification of who would approve alternative intervals for inspections (federal/state agency).
  • Master meters and LPG may have additional risk ranking requirement.
  • EFV locations further defined.

Threat identification and risk ranking are key activities in developing an operator’s DIMP.  Knowledge of the system is crucial to effectively completing these tasks.  A good comprehensive continuing surveillance program will provide much of this information, along with leak repair, corrosion control and damage prevention data.  It is not too early to start identifying these and other resources that will will needed to develop the required plan.

Pipeline safety funding increased for 2010

The House of Representatives on Thursday July 23 approved HR 3288,  Transportation, Housing and Urban Development, and Related Agencies Appropriations Act, 2010.  This bill provides funding fiscal 2010 for PHMSA’s pipeline safety programs.

The program will be funded at $105.2 million, matching the request and $12 million above 2009, for the state pipeline safety grant program. This increase will allow a 70/30 federal/local match for pipeline safety grants, which is a five percent increase in the federal match over fiscal year 2009.

PHMSA added several pipeline staff positions in 2009 and is expected to continue hiring in 2010.  The USAJOBS website  currently lists four openings for engineer and inspector positions.

NPRM to update standards, definitions

The latest Notice of Proposed Rulemaking (NPRM) PHMSA proposes to update 39 standards that are incorporated by reference in its pipeline safety regulations.  One new standard, API 5LW for transportation of line pipe will also be added to Parts 192 and 195.  The NPRM also makes some additional changes/clarifications/edits to the regulations.

PHMSA will not adopt the latest editions of 3 key ASTM standards regarding plastic pipe.  The incorporated versions of standards D2513, D2517 and F1055 will remain as is due tooncerns with marking, design factor and qualification of new materials in the current editions of these documents.  Operators were anticipating the adoption of D2513-2007 to eliminate current reference that is split between the 1987 and 1999 editions, again due to marking concerns.  (See Pipeline Safety Arena, 06 2009, Incorporating by Reference.)

A seond area where PHMSA has concerns is the adoption of NFPA 58 and 59 for LP systems.  Current regulations (192.11) state that when there is conflict between Pasrt 192 and the NFPA docs, NFPA prevails.  But no longer, PHMSA will change this regulation so Part 192 will be the requirement when there is a conflict.

We will see a change in the definitions section of 192. 3.  The definitons of active corrosion, electrical survey, and pipeline environment will be moved from their present location in 192.465 to 192.3.

Several additional changes are also proposed in 192 to clarify repair times, acceptable valves and uprating.

Corresponding changes for documents incorporated by reference are proposed in Parts 193 and 195.

The comment period runs to September 21.  You can view the NPRM in the docket .

Damage prevention enforcement may be on the way

The PIPES Act of 2006 provided for civil penalties and enforcement of violations of state damage prevention laws.  PHMSA could bring enforcement action if it is determined that a state’s enforcement is inadequate.  However without regulations in place that define the process to make this determination PHMSA cannot proceed with enforcement.

In a presentation made to the CGA Excavation Safety Conference in February 2009 and as reported in the CGA June Monthly Update, PHMSA indicated it may issue an Advanced Notice of Proposed Rulemaking (ANPRM) this year (June, July, August?) on this topic.  PHMSA will be asking for comments on procedures to be used in determining the adequacy of a state’s damage prevention enforcement program.

The requirements in the PIPES Act are a federal law and failure to use a one call, report damage or effectively respond and locate facilities is a violation of the law.  As such it is reasonable to assume that at this time action could be brought against violators through the federal judicial or prosecution process.

The Common Ground Alliance, Dig Safely and the numerous state programs place great emphasis on education as one of the the most effective means to reduce excavation caused damage.  There are multiple campaigns directed at excavators, the public, and facility owners, in other words everyone, to “Call Before  You Dig”, “Dig Safely” and to timely and accurately locate facilities.  But we know that there are those who purposely choose to ignore these admonitions, resulting in facility damages.

PHMSA should move forward with procedures for greater enforcement of  damage prevention laws.  The states themselves should also look to amending state laws where necessary to provide enforcement and penalties for those who violate state damage prevention laws.  Their is grant money available to states for improving damage prevention programs to implement the nine elements of an effective damage prevention program defined in PIPES 2006.  Approximately $1 million was recently awarded for 2009 grants and over $1.3 million was awarded in 2008.  Click here for more information on the state grant program.

The Excavation Damage Prevention Initiative can assist states in developing a consensus of damage prevention stakeholders on the 9 elements defined in the PIPES Act.  The EDPI works with CGA in developing guidance for all stakeholders and advocacy strategy for state agencies to implement modules adhering to the 9 elements.  A “Guide to the 9 Elements” was published in December 2007 and describes how to develop a 9 Element Forum.  Forums are the first step in creating awareness and understanding of the 9 elements and developing a work plan to incorporate or implement the Elements.

Damage prevention involves a multitude of stakeholders.  Joining together to develop the Best Practices, Dig Safely, the Excavation Damage Prevention Initiative and other local, state and regional initiatives has proven effective in reducing damages and will continue to show reductions.  Success will come by remembering there are two types of people who should know about damage prevention actions – those who dig and those who don’t

Proposed reporting requirements: Who reports what?

The NPRM proposes to require all reports be submitted electronically and adds or modifies reporting requirements for gas, liquid and LNG operators.

A new form for submitting safety related condition reports for both gas and liquid operators will be developed.  Currently operators use a free form report developed from the required information listed in 191.25 and 195.56.  Operators may still have to file a hard copy report with a state agency if the agency acts as an agent for PHMSA.  A new form for offshore condition reports will also be developed and will be submitted electronically.  These new reports will give PHMSA data reported in a consistent manner, allowing for better analysis to identify situations affecting pipeline safety.

Gas transmission operators will submit their integrity management performance measures (192.945 and 192.951) on the annual report required by 191.17.  This will have the benefit of reducing reporting from twice per year to just once.  However these reports are filed by state which may create some additional work for interstate operators.  They will have the option of reporting their IM performance measures by state or submitting a single report for all data.

There will be changes on the gas transmission annual report for reporting leak causes.  Currently there are seven categories for leaks.  However, in integrity management reporting operators must use the nine categories from ASME B31.8S.  These will become the new cause categories for reporting leaks on the annual report.

Additional mileage information for Type A and B gathering lines, class location by SMYS and information on volumes and types of products transported will also be required on the new transmission annual report.  With this information PHMSA can better evaluate the effectiveness of regulations on various types of pipelines and what changes may be needed.

Moving on to LNG operators, they will now be required to submit the incident, safety related condition and annual reports required by Part 191.  They have been exempt from much of this reporting and with the increased emphasis on LNG and facility development this will give PHMSA additional data on these systems.

Hazardous liquid operators will see some changes in their reporting requirements as well.  They will be required to have a procedure to calculate the volume of product released when making a telephonic notice of an accident.  Additional telephonic notices will be required if new significant information is developed during the emergency response phase of an incident.

Another action to make the pipeline regulations have parallel requirements across all types of operators will be to have liquid operators report information by state.  Unlike gas operators, liquid pipelines currently report contain on the aggregate mileage of their systems. This will further allow PHMSA to do more detailed safety analysis on the state and regional level.  And as PHMSA provides funding for state programs, this will provide information on the costs per state by mile for these programs.

Master meter operators and petroleum gas systems with less than 100 customers from a single source will retain their current exemptions.

Drafts of the new reports can be found in the docket at http://www.regulations.gov/fdmspublic/component/main?main=DocketDetail&d=PHMSA-2008-0291