PHMSA Proposes Integrity Management Regulations for Gas Distribution Lines

On June 25, 2008, the Pipeline and Hazardous Materials Safety Administration (PHMSA) proposed regulations that would require operators of gas distribution lines to develop and implement integrity management programs on their systems.  Comments on the proposed regulations and on other issues raised in PHMSA’s proposal are due September 23, 2008. 

Proposed Required Elements of Distribution Integrity Management Programs

PHMSA’s proposed gas distribution integrity management regulations are high-level, performance-based requirements that identify elements that all integrity management programs (except those for certain small operators) must contain.  PHMSA explains that it has not proposed prescriptive implementation methods because the diverse and complex nature of the nation’s gas distribution systems precludes a one-size-fits-all approach.  The proposed regulations would require that operators of gas distribution lines develop and implement written integrity management programs that address the following elements:

• Knowledge of infrastructure.  Based on information available from ongoing design, operations, and maintenance activities, operators must identify threats to their systems and analyze their risks.  To identify threats and risks, operators should know information about location, material composition, pipe sizes, construction methods, installation dates, soil conditions, pressures, operating experience, performance data, condition of the system, and other characteristics.  Operators are not required to engage in extensive investigations or conduct excavations to obtain information, but integrity management programs must identify the additional infrastructure information an operator needs and must provide for obtaining that knowledge over time through normal activities. 
• Identify threats.  Operators must evaluate their pipeline systems and operating environments to identify specific existing and potential threats and to determine appropriate actions to manage the threats and minimize the risk. 
• Evaluate and prioritize risk.  Operators must evaluate each applicable threat and estimate its risk to the pipeline. 
• Identify and implement measures to address risks.  Operators must identify and implement appropriate risk reduction strategies.  At a minimum, operators must implement (i) an effective leak management program, and (ii) an enhanced damage prevention program. 
• Measure performance, monitor results, and evaluate effectiveness.  Operators must develop and monitor performance measures from an established baseline to evaluate the effectiveness of their programs.  If performance measures indicate a need for improvement, operators would be required to modify their programs to improve effectiveness. 
• Periodic evaluation and improvement.  Operators must determine whether further improvements are needed based on measured performance and make necessary changes to their integrity management programs.  All operators would be required to conduct a complete program evaluation at least once every 5 years. 
• Report results.  Operators must report certain performance measures annually to PHMSA and state regulatory authorities. 

Operators of master meters and liquefied petroleum gas systems would be required to develop more limited integrity management programs that reflect the simplicity of their systems. 

Given the proposed regulation’s broad requirements, PHMSA has requested the Gas Piping Technology Committee, a standards-developing organization, to prepare guidance for operators on options for implementing the rule’s requirements.  Such guidance would be available to assist operators in developing their distribution integrity management programs, but would not be incorporated into the regulations.  A draft of this guidance is available from PHMSA. 

Excess Flow Valves

Under the Pipeline, Inspection, Protection, Enforcement, and Safety Act of 2006 (PIPES Act), distribution operators are required to install excess flow valves (EFV) on residential service lines under specified conditions after June 1, 2008.  For more information on the PIPES Act, see the Issue Alert "PHMSA Issues Advisory Bulletins Addressing the Requirement to Install Excess Flow Valves and Jurisdiction Over Direct Sales Gas Transmission Lines” (6/19/2008).   As required by the PIPES Act, PHMSA is proposing to codify the EFV requirement in the distribution integrity management regulations.  Accordingly, the proposed regulations require that operators install EFVs on new or replaced single-family residence service lines if: (1) a suitable valve is commercially available; (2) the line operates continuously at a pressure no less than 10 pounds per square inch (psi); (3) the line is not connected to a gas stream with a history of contaminants that could cause EFV malfunction and result in a loss of service; and (4) installation is not likely to cause loss of service or interfere with necessary operation or maintenance activities.

Request for Comments on Additional Issues

PHMSA also requests comments on the following: 

• Master meter and liquefied petroleum gas facilities.  PHMSA inquires whether the proposed limited integrity management requirements for these operators are appropriate, should be further limited, or even eliminated altogether.
• Very small distribution systems.  PHMSA is considering limited integrity management requirements for operators of other small, simple distribution systems that meet certain criteria.  PHMSA seeks comment on whether limited integrity management program requirements for small distribution systems is appropriate and on the appropriateness of its proposed criteria. 
• Plastic pipe issues:  PHMSA seeks comments on several plastic pipe issues:
  • Whether the Plastic Pipe Data Committee, a volunteer group administered by the American Gas Association that monitors in-service performance of plastic pipe but distributes its information only on a limited basis, should be used to evaluate and report to the industry on plastic pipe failures.
  • Whether requiring operators to report data on failures that occur in plastic pipe/fittings within 90 days is appropriate. 
  • Whether PHMSA should require permanent markings on plastic pipe and rely on the American Society of Testing and Materials to establish a revised standard for plastic pipe marking.
• Monitoring and reporting.  To monitor the effectiveness of the new regulations, PHMSA proposes to require that operators annually report the number of leaks repaired, excavation damage occurrences, one-call “tickets,” and EFVs installed.  PHMSA seeks comment on whether the paperwork burden associated with collection of the data is justified by the usefulness of the information and on whether other measures might be used to monitor effectiveness.
• Deviations from required intervals.  PHMSA is proposing to permit operators to propose alternative intervals for completing certain Part 192 requirements and to permit state regulators to approve such requests.  PHMSA seeks comments on various issues regarding this approach. 
• Prevention through people.  The proposed rule would require that operators evaluate the potential for human error in preventing and mitigating risk and address this issue in their integrity management programs.  Noting that it is developing a rulemaking for control room management, PHMSA requests comments on requirements that should be included in this or a future integrity management rulemaking and how operators are currently addressing human factors, including fatigue, in their efforts to manage system integrity. 

Implications of the Proposed Regulations

PHMSA has written the proposed gas distribution integrity management regulations broadly and without specificity in order to address the diversity and complexity of the nation’s gas distribution systems.  The lack of specificity creates potential for uncertainty while also accommodating different approaches to integrity management that reflect the needs of individual distribution systems.  Operators of gas distribution systems should analyze the issues on which the PHMSA seeks comment in order to understand whether one result or another would make a difference in their ability to develop and implement an integrity management program on their systems.  As with integrity management programs implemented on hazardous liquid and gas transmission pipelines, the key to compliance and ensuring a successful integrity management program will be establishing effective processes that implement systematic approaches to gathering and managing data and incorporating it into ongoing operation and maintenance activities.