The U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) is issuing a final rule that expands oversight and incident reporting to all onshore gas gathering pipelines.
The requirements in the final rule are designed to prevent and detect threats to pipeline integrity, improve public awareness of pipeline safety, and improve emergency response to pipeline incidents. PHMSA expects this final rule will:
- Improve public safety.
- Reduce threats to the physical environment (including, but not limited to, greenhouse gas emissions released during natural gas gathering line incidents).
- Promote environmental justice for minority populations, low-income populations, and other underserved and disadvantaged communities.
Over 425,000 miles of gathering lines will now be covered by these regulations. Historically these lines were exempt primarily due to the rural location, smaller diameter, and smaller pressure lines. The Gas gathering lines typically transport natural gas from production facilities to interstate gas transmission pipelines. The 425,000 miles of gathering lines now exceed the approximately 300,000 miles of transmission lines.
With the increase in oil and gas production in the past decade, the volume of gas transported through gathering lines has increased significantly. Gathering lines with diameters, operating pressures, and associated risk factors similar to larger interstate transmission lines have become more common. Transmission lines are typically larger in diameter, operate under higher pressure of often run near densely populated areas.
During the hydraulic fracturing “fracking” boom in the past 15 years, often excess gas was burned at the production wells in a flare. This resulted in substantial discharges, wasteful practices, and nuisance visual and odor problems. The new rule, due to be effective on May 16, 2022, will require onshore gas gathering lines to begin filing incident reports and comprehensive annual reports. Requirements will be dependent on the proximity to dwellings - Class 1 locations are rural and sparsely populated, Class 4 locations are near densely populated areas. Some of the new requirements include:
- Corrosion control measures
- Damage prevention measures
- Public awareness programs
- Maximum allowable operating pressures
- Install and maintain mile markers
- Conduct leakage surveys
- Develop and implement emergency response plans
All of these items are typical requirements for transmission lines and now will be required for most gathering lines.
More Information on Pipeline Safety Management Systems
As an industry responsible for delivering reliable energy, the pipeline industry works hard to fulfill an obligation to protect the communities, public, and employees involved in moving liquid and natural gas to customers throughout the United States. To support continuous safety improvement across the pipeline network, industry leaders developed American Petroleum Institute’s Recommended Practice (API RP) 1173, Pipeline Safety Management System (PSMS) in 2015. The intention of the recommended practice is to achieve protect people and the environment by reaching the goal of zero incidents in the pipeline industry. API 1173 provides a systematic approach to managing the risks associated with pipeline operations. This management system is designed to be implemented and scaled for companies of any size and complexity, and with management commitment, the PSMS improves pipeline safety culture.
API has outlined the 10 key elements to assist operators in the development of sustainable pipeline safety management systems. Organizations may choose to focus on a few or all these elements, depending on their internal needs and the maturity of their system. Operators who are just starting the PSMS journey have the flexibility to start small and slowly improve over time by developing programs and processes that support their teams and align with the API 1173 framework.
- Leadership and Management Commitment
- Stakeholder Engagement
- Risk Management
- Operational Controls
- Incident Investigation, Evaluation, and Review of Lessons Learned
- Safety Assurance
- Management Review and Continuous Improvement
- Emergency Preparedness and Response
- Competence, Awareness, and Training
- Documentation and Recordkeeping
One of the essential requirements to developing a PSMS that conforms with API 1173 is leadership and management commitment. A PSMS will not work without management commitment and participation from every corner of an operation. Involving every single person and organization with a stake in the pipeline requires the managing organization to adopt safety as a core value. Elevating safety to the forefront of everything the organization does will promote the engagement required to reduce incidents and promote safe energy transportation industrywide. Each element of the PSMS holds sub-elements that are designed to boost safety performance and culture industrywide.
Planning and reassessing safety culture and processes over time helps organizations improve performance. For this reason, the Plan-Do-Check-Act approach is the cornerstone to successfully implementing and sustaining the PSMS. Pipeline companies should start their journey by evaluating their current system against the ten elements of API 1173 and planning to successfully build a system that meets or exceeds the requirements of the PSMS framework. Next, the organization will carry out the plan and check its approach by monitoring key performance indicators at regular intervals. When the plan requires adjustment, a new plan will be developed to realize continuous improvement over time.
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