Improved integrity management principles should continue to be favored, rather than prescriptive rules, to ensure pipeline safety, the Interstate Natural Gas Association of America (INGAA) said in comments filed Wednesday on an advanced notice of proposed rulemaking (ANPR) issued by the Pipeline and Hazardous Materials Safety Administration (PHMSA) (see NGI, Aug. 25).
In the wake of the 2010 San Bruno, CA, explosion on a Pacific Gas & Electric Co. pipeline that killed eight, injured 50 and destroyed 38 homes, INGAA said its board of directors had recommended improvements to integrity management. These would include extending the current principles-based management beyond high consequence areas (HCA) to other places where people live; raising the standards of corrosion management; demonstrating that pre-regulation pipelines that went into service before 1970 (60% of U.S. pipelines) are also fit for service; and shortening pipeline isolation and response time to one hour in populated areas (see NGI, July 25).
INGAA proposes extending improved integrity management principles beyond the high population density HCAs to the protection of people living near pipelines (that is, within the potential impact radius, or PIR). This would cover about 90% of the population in the PIR area by 2020.
The pipeline group argued against installing prescriptive rules concerning mainline valves, including valve spacing and installation of remotely operated or automatically operated valves; requiring specific forms of testing, and governing the safety of gathering lines and underground gas storage facilities, as suggested in the ANPR.
“Shifting back toward a prescriptive regulatory approach would be a mistake. It would ignore the benefits of the proactive integrity management program, which helps foster innovation and continuous improvement. A prescriptive set of requirements defines a single compliance path that can stifle innovation and focus safety efforts on ‘checking the box’ rather than systemically improving practices, methods, activities and materials,” INGAA said.
“PHMSA should expand integrity management by expanding the elements to be covered in an integrity management plan and by providing more well-defined guidelines on what and how these expanded plans should evolve over time. Operators should be held accountable for these plans and their continuous improvement, and more process-oriented metrics should be developed to monitor overall safety performance.”
The group said that for instance, automatic and remotely controlled valves may be part of improving response time, but they are not the only solution, nor are they a complete solution. “Valves cannot prevent an incident, nor are they likely to reduce the number of injuries or fatalities in the unlikely event of a natural gas pipeline rupture and fire. Even with an automatic or remote controlled valve, a high-pressure natural gas pipeline can take significant time to depressurize following a rupture. Most of the human impacts from a rupture occur in the first few seconds, well before any valve technology could reduce the flow of natural gas,” INGAA said.
A better answer is incident mitigation management (IMM), which “goes beyond placing and operating isolation valves. It employs integrated planning and implementation to develop means for detecting ruptures and determining which valves to close.” IMM also calls for advance planning and coordination to cope with ruptures. “IMM is consistent with INGAA’s commitment to shorten pipeline isolation and response time to one hour in populated areas.”
INGAA also argued against requiring universal hydrostatic testing, saying it would mean high costs and lengthy outages. “Smart pig research and development ultimately will be critical to meeting the goals for pre-regulation pipelines that the National Transportation Safety Board recommended in its San Bruno report.”
That report said the probable cause of the accident was a combination of “inadequate quality assurance and quality control” in 1956 when the failed part of PG&E’s Line 132 was relocated, and a failed pipeline integrity management program that relied on inadequate and inaccurate record-keeping (see NGI, Sept. 5).
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