Hydrocarbon Processing - June 2021 - GP-22

SPECIAL FOCUS: PIPELINES AND TRANSPORT
ply to idled pipelines must be issued within
2 yr.10
For many operators, this will be
a welcome addition to regulations, as they
will not only be able to classify qualifying
assets as " idle " instead of maintaining
active pipeline compliance on such lines,
but also will have more guidance on safety
practices for idle pipelines.
Large-scale LNG facilities. In late 2020,
the Government Accountability Office
(GAO), which audits agencies on behalf
of the U.S. Congress, released a report
that examined federal regulations applicable
to LNG facilities.11
The report's chief
finding was that LNG export facility regulations
belonging to multiple agencies,
including PHMSA, were out of date and
lacking " current technical standards. " 12
In the case of PHMSA, relevant regulations
were found to cite fire safety standards
dating to 2001, despite the government
recommendation that regulations
that include technical standards be reviewed
and updated accordingly every 3
yr-5 yr.13
Specifically, the report identified
that eight of nine standards relating to
Part 193 and 45 of 55 regulations applying
to natural gas facilities were outdated.14
Many critics say relevant PHMSA
regulation updates are long overdue given
a shift in the industry toward large-scale
export LNG facilities.15
-
On the heels of
these findings-and in addition to an
executive order that required PHMSA to
update 49 CFR Part 193, which had received
little attention since the 1980s16
it is no surprise that the PIPES Act now
calls for PHMSA to update federal safety
standards via a final rule for operating and
maintaining large-scale LNG facilities, except
for peakshaving facilities. This rule
must be issued within 3 yr.
Operators can likely expect more specific
regulations with stricter guidelines,
as well as updated information pertaining
to specific processes and procedures.
Onshore gas gathering lines. As recently
as October 2019, PHMSA updated
pipeline safety regulations for gas transmission
pipelines, citing incidents that
occurred over the past decade that resulted
in several fatalities.17
Meanwhile, API
issued two standards in 2020 pertaining
to the definition of gas gathering lines for
regulation application and the operational
practices for gas gathering pipelines after
recognizing the need for more robust
22 MAY/JUNE 2021 | GasProcessingNews.com
practices for gas gathering lines.18
Not as much movement as expected
has been seen on PHMSA's part to update
regulations pertaining to gas gathering
pipelines, leading the PIPES Act to direct
PHMSA to update minimum safety
standards for onshore gas gathering pipelines
as a final rule within 90 d. Operators
should expect a revised set of minimum
standards;19
however, given the deadline,
it is unlikely that PHMSA will be
requiring radical changes, translating to a
smoother updating process for operators.
Leak detection standards. Since 2003,
PHMSA has spent an estimated $15.6
MM on leak detection research, with 87%
applying to gas pipelines. Of this $13.57MM
portion, 75% applied to transmission
lines, 68% applied to distribution
lines, 59% applied to gathering lines and
3% applied to underground storage. Of
that research, more than 80% focused on
specific technologies.20
Moreover, as part of the Pipeline Safety,
Regulatory Certainty and Job Creation
Act of 2011, PHMSA was required to
provide a report of leak detection systems
(LDS) utilized by hazardous liquid pipeline
facilities and transportation-related
flowlines, along with their limitations
and practicability.21
In the same year, in
response to a fatal gas transmission pipeline
rupture and subsequent explosion,
the National Transportation Safety Board
(NTSB) issued a safety recommendation
to PHMSA that operators of natural gas
transmission and distribution lines be
required to utilize LDS to assist in recognizing
and locating leaks;22
cifically outlined in Part 195 for hazardous
liquid pipelines, the regulations for
gas pipelines are minimal. In an effort to
make such regulations more robust and to
reduce methane emissions, the PIPES Act
of 2020 requires PHMSA to release a final
rule within 1 yr that outlines more comprehensive
LDS and repair programs for
gas operators. To meet this goal, PHMSA
must provide minimum performance
standards with consideration for available
technologies.26
Operators should be prepared
for updated regulation that is more
specific as to acceptable leak detection
methods, with considerations of the type
and location of pipelines.
Additionally, while the PIPES Act refers
to " advanced leak detection technologies, "
this includes commercially available
technologies for continuous monitoring,
as well as approved periodic survey methods.
Therefore, while it is likely that CFR
Part 192 will be brought closer to the level
of specificity provided in CFR Part 195 for
hazardous liquid pipelines, with potential
regulations for computational pipeline
monitoring, operators are more likely to
find that their existing methods must be
sharpened rather than replaced altogether.
While the reauthorization of the PIPES
however, as of
March 2020, PHMSA had not yet accomplished
the provision of " a more comprehensive
and effective leak detection system
for the pipeline industry as a whole. " 23
Despite research and encouragement
by other agencies, 49 CFR Part 192,
which addresses gas transmission, distribution
and regulated onshore gathering
pipelines, makes mention of LDS only
twice. In §192.935, which addresses operators'
preventative and mitigative measures,
the regulation mentions LDS as
an additional measure,24
while §192.620
states that LDS are an acceptable method
of control for high-consequence areas for
which response time to mainline valves
exceeds 1 hour after an event is identified
in a control room.25
Compared to the LDS sections speAct
will certainly bring about change in
the industry, it is important for operators
to focus on how they can prepare for the
new requirements, as well as the reasoning
behind the updates. PHMSA regulations
are not written and released overnight,
and operators can be attentive to the development
of new regulations and anticipate
what resources will be needed to stay
in compliance. However the regulations
of the future affect them, operators must
recognize that, as technology and operations
evolve, so will the regulations that
aim to keep our industry safe. GP
LITERATURE CITED
Complete Literature Cited available online at
www.GasProcessingNews.com
WHITNEY VANDIVER is a
Compliance Specialist at NuGen
Automation LLC, where she
specializes in control room
management compliance and
assists operators with state and
federal CRM audits. Dr. Vandiver
previously worked for a pipeline operating company
in compliance-driven documentation and served
as a volunteer editor for the drafting of API MPMS
18.2. She holds a BA degree from the University of
Central Oklahoma and an MA degree and PhD,
both in linguistics, from Purdue University.
http://www.GasProcessingNews.com http://www.GasProcessingNews.com
Hydrocarbon Processing - June 2021

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