NAPSR meets for pipeline safety

The National Association of Pipeline Safety Representatives (NAPSR) held their annual meeting in Indianapolis during the week of September 14. Pipeline safety activities of all types were discussed, ranging from federal and state programs and regulations, to damage prevention, new technology and congressional legislation.

NAPSR is an organization of state agency pipeline safety managers who are responsible for the administration of their state's Pipeline Safety Programs. It represents 52 state agencies whose duties include operator inspections, compliance and enforcement, training and safety, accident investigation, and record maintenance and reporting.

The following synopsis covers the updates on proposed and current regulations presented at the meeting. Distribution Integrity Management was submitted to the Office of Management and Budget (OMB) in early August and OMB has 90 days to clear the rule for publication. Reporting of plastic pipe failures will likely be replaced by reporting of mechanical coupling failures. Prevention through People is also not expected to be in the final rule. The implementation time frame is anticipated to be 18 months after publication of the final rule.

PHMSA has additional work to do as well as the operators to prepare for DIMP.  They are developing revised annual reports to include the reporting provisions of DIMP.  An inspection form and guidelines are under development as well. PHMSA will also have criteria that state agencies can use to review and accept alternate timeframes for deviation from periodic inspections and tests as provided for in the rule.

The Control Room Management regulation was also submitted to OMB in August. It is expected to be on the same timetable as DIMP; however, there was no further information on what form the final rule might take. There are API technical standards for control rooms, alarm management and SCADA displays being considered by PHMSA for incorporation by reference once the final rule is in place.

Part 195 regulations were extended to hazardous liquid low-stress pipelines 8-5/8 inch and larger in June 2008. PHMSA calls this Phase 1 of low-stress pipeline regulation.  Phase 2 will consider extending the regulations to low stress pipelines of smaller diameters. A cost-benefit study is underway on various scenarios with an NPRM to follow.

The ASME B31Q Pipeline Personnel Qualification Standard was not adopted by PHMSA when first published due to 13 areas of concern identified by operators. This standard is reported to be in revision and 12 of 13 issues are potentially resolved. This may be sufficient for PHMSA to again consider incorporating this standard into the regulations.

A current project at PHMSA is a Gap Analysis of Parts 192 and 195. This review will attempt to answer the questions:

•   What are the major differences and why?

•   What differences should be eliminated?

•   What holes exist in the regulations, i.e., what should be in the regulations that are not currently in the regulations?

•   What holes should be fixed?

Answering these questions will allow PHMSA to be better able to answer questions from Congress and others regarding pipeline safety differences between operations and what future actions may be proposed.

Anomaly assessments of cased crossings present another challenge. Operators must complete their baseline integrity management assessments for all pipelines by December 17, 2012 and for many the crossings are the most difficult piece. A Casing Inspection Quality Action Team has been working to address the inspection process. One result of their work will be a Cased Crossing Guidance document, possibly published this fall.

A critical piece of pipeline safety and damage prevention are the requirements in the PIPES Act for use of one-call, following facility location markings and damage notification. These can be enforced at the federal level if a state’s enforcement is inadequate. n

 

David Bull is manager of ViaData LP, publisher of WinDOT, The Pipeline Safety Encyclopedia.