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Major New Pipeline Safety Program Being Readied By PHMSA
PHMSA is developing this new IVP process at the same time it is considering subjecting additional pipelines to the IM program. That has caused some confusion and concern within the interstate pipeline industry with regard to a potentially jumble of new safety requirements.
The MAOP testing requirement stems from the Pipeline Safety, Regulatory Certainty and Job Creation Act of 2011. It and recommendations from the National Transportation Safety Board (NTSB) led to the PHMSA development of the IVP. Together, these mandates and recommendations call for: removal of the existing “grandfather clause” within PHMSA’s regulations; new pressure testing requirements; integrity verification plans for pipeline segments that do not have complete records establishing their maximum operating pressures; and the conversion of all gas transmission pipelines to accommodate inspection by inline inspection (ILI) technology (i.e., smart pigs).
But any number of both interstate and intrastate companies have taken issue with many facets of the way the PHMSA plans to implement the MAOP provisions. For example, in a detailed filing submitted to the PHMSA on Oct. 9, INGAA stated: "INGAA members are concerned that the agency is retroactively imposing recordkeeping requirements. In PHMSA’s first draft IVP chart dated July 9, and in FAQs #13-16, the agency proposes that an operator must have four sets of records in order to properly verify MAOP. Even though PHMSA revised its flow chart on Sept. 10, the notes portion still indicates a similar requirement."
PHMSA published a second iteration IVP draft on Sept. 11, and INGAA praised the agency for making improvements from its original draft. But the industry still has a number of not-insignificant bones to pick with the PHMSA second draft. There are differences over how MAOP should be reconfirmed for grandfathered pipe – that it is pipeline put in the ground pre-1970, before MAOP recordkeeping requirements were in effect.
Aside from that difference on "screening," PHMSA and INGAA have different ideas on the “actions” that are required to reconfirm MAOP, such as pressure tests, de-rating, replacing or in-line inspection.
Under the new pipeline law President Obama signed in Jan. 2012, PHMSA was supposed to have published a final rule by June 2013 establishing the testing requirements for MAOP. That rule was not forthcoming and isn't likely to any time soon, because PHMSA appears to be road-testing that requirement as part of the IVP, which will not be finalized for a few years.