Operations & Safety

APGA Commitment to Pipeline Safety

On July 25, 2018 at the APGA Annual Meeting, APGA membership formalized a “Commitment to Pipeline Safety.” This document demonstrates APGA’s consistent and exhaustive dedication to the essential elements of pipeline safety: fostering a positive employee safety culture, communicating with stakeholders, implementing safe work practices, and enhancing pipeline integrity. Read it here.

Advisory Bulletins

PHMSA Issues Advisory on Corrosion Protection

The Pipeline and Hazardous Materials Safety Administration (PHMSA) issued an advisory bulletin to remind all owners and operators of hazardous liquid, carbon dioxide, and gas pipelines to consider the overall integrity of the facilities to ensure the safety of the public and operating personnel and to protect the environment. Read it here.

PHMSA Issues Advisory on Snow and Ice Impact on Distribution Systems

The Pipeline and Hazardous Materials Safety Administration (PHMSA) issued an advisory bulletin advising owners and operators of petroleum gas and natural gas facilities of the need to take the appropriate steps to prevent damage to pipeline facilities from accumulated snow or ice. Past events on natural gas distribution system facilities appear to have been related to either the stress of snow and ice or the malfunction of pressure control equipment due to ice blockage of pressure control equipment vents. This advisory reminds owners and operators of the need to take precautionary actions to prevent adverse events. A copy of the advisory can be found here.

PHMSA Advisory on Underground Storage Safety Provides Insight into California Storage Leak

The Pipeline and Hazardous Materials Safety Administration (PHMSA) has issued an advisory urging operators of underground storage facilities to have processes, procedures, mitigation measures, periodic assessments and reassessments, and emergency plans to maintain the safety and integrity of all wells and associated storage facilities whether operating, idled, or plugged. While only one or two public natural gas systems operate underground storage, the advisory contains useful information about the leak at an underground storage facility in Los Angeles that is garnering much press attention. This information may be useful to APGA members to answer questions from constituents. The advisory can be found here.

PHMSA Flooding Advisory Bulletins 

With the very heavy flooding currently occurring in some parts of the country, it is appropriate that operators maintain vigilance and awareness and be ready to take action on the risks created by major flooding to ensure safety and protect the environment.  PHMSA’s most recent advisory bulletins on flooding are here and here.

Plastic Pipe Database Committee

A group of representatives of federal and state regulatory agencies and the natural gas and plastic pipe industries have come together and formed The Plastic Pipe Data Collection Initiative. Their goal has been to create a national database of information related to the in-service performance of plastic piping materials. Members include the American Gas Association, the American Public Gas Association, the Plastics Pipe Institute (PPI), the National Association of Regulatory Commissioners, the National Association of Pipeline Safety Representatives (NAPSR), the U.S. Department of Transportation and its Office of Pipeline Safety.

Click Here to learn more: https://www.aga.org/safety/promoting-safety/plastic-pipe-database-collection-initiative/

PHMSA Initiatives

PHMSA Establishes Damage Prevention Enforcement Effectiveness Criteria

The Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a final rule establishing review criteria for state excavation damage prevention law enforcement programs. The rule is a prerequisite for PHMSA to conduct an enforcement proceeding against an excavator in the absence of an adequate enforcement program in the state where a pipeline damage prevention violation occurs.

This final rule amends the pipeline safety regulations to establish the following: criteria and procedures for determining the adequacy of state pipeline excavation damage prevention law enforcement programs; an administrative process for making state adequacy determinations; the federal requirements PHMSA will enforce in states with inadequate excavation damage prevention law enforcement programs; and, the adjudication process for administrative enforcement proceedings against excavators where federal authority is exercised. The development of the review criteria and the subsequent determination of the adequacy of state excavation damage prevention law enforcement programs is intended to encourage states to develop effective excavation damage prevention law enforcement programs to protect the public from the risk of pipeline ruptures caused by excavation damage and allow for federal administrative enforcement action in states with inadequate enforcement programs. The final rule took effect January 1, 2016. A copy of the rule can be found here.

IM Management Program Reminder

PHMSA also issued an Advisory Bulletin in the Federal Register December 5, 2012, a reminder to operators of gas transmission and hazardous liquid pipeline facilities of their responsibilities under current regulations to perform evaluations of their Integrity Management (IM) programs using meaningful performance metrics that PHMSA has developed guidance on the elements and characteristics of a mature program evaluation process that uses meaningful metrics called Guidance for Strengthening Pipeline Safety through Rigorous Program Evaluation and Meaningful Metrics.

This document provides guidance on the elements and characteristics of a mature program evaluation approach utilizing processes created to define, collect and analyze meaningful performance metrics. This guidance uses the basic requirements and processes previously developed and documented in ASME B31.8S-2004, Managing System Integrity of Gas Pipelines, API Standard 1160, Managing System Integrity for Liquid Pipelines, ANSI / GPTC Z380, Guide for Gas Transmission and Distribution Piping Systems, 2012 Edition and the Part 192 and 195 Integrity Management (IM) rules.

PHMSA Requires 60 Day Construction Notice

September 12, 2014 - PHMSA Issues Advisory on Construction Notification regarding the requirement that pipeline operators notify PHMSA 60 days prior to certain construction projects. This requirement applies to distribution operators as well as transmission pipeline operators. Specifically, 49 CFR 191.22(c) requires each operator of a gas pipeline, gas pipeline facility, LNG plant or LNG facility must notify PHMSA electronically through the National Registry of Pipeline and LNG Operators of any of the following events not later than 60 days before the event occurs:

  1. Construction or any planned rehabilitation, replacement, modification, upgrade, uprate, or update of a facility, other than a section of line pipe, that costs $10 million or more. If 60 day notice is not feasible because of an emergency, an operator must notify PHMSA as soon as practicable;
  2. Construction of 10 or more miles of a new pipeline; or
  3. Construction of a new LNG plant or LNG facility.

PHMSA wants to ensure that operators understand how the earliest possible notification to PHMSA of construction-related events is beneficial to both PHMSA and the operator. PHMSA also recognizes that the determination of whether a pipeline operator has complied with the reporting regulations in these codes must be determined on a case-by-case basis with regards to the specific facts of each project and with regards to the code language. A copy of the complete advisory bulletin can be downloaded here.