{"operation":"document","citation":"0900006480e8d3ee","title":"U.S. DOT/RSPA - Briefing Paper on Internal Corrosion","source_type":"rulemaking","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":null,"effective_on":null,"summary":"The paper summarizes PHMSA’s plan to issue a final rule responsive to an NTSB recommendation to require that new or replaced pipelines be designed and constructed with features to mitigate internal corrosion, and outlines changes PHMSA is considering from the NPRM (including shifting focus from avoiding liquid accumulation to reducing internal corrosion risk, excepting offshore pipelines, placing requirements with other corrosion control rules, and simplifying recordkeeping). It also discusses the rationale for not adopting certain exceptions, addresses placement within the Code, and proposes a two-fold recordkeeping concept: operators must generally maintain records demonstrating compliance and may use as-built drawings or procedures with documented variances. The paper notes committee concerns and that PHMSA will not share draft final rule text with the committee. Limitations: the text","machine_formats":{"json":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e8d3ee.json","markdown":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e8d3ee.md"},"app_url":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e8d3ee","source_url":"https://downloads.regulations.gov/PHMSA-RSPA-1998-4470-0235/attachment_1.pdf","body":"<<<PAGE 1>>>\n\nB riefing Paper August 24, 2006\nDesigning and constructing gas transmission pipelines to control internal corrosion\nAdvisory Committee Action: Vote on proposed rule and cost-benefit analysis\nProject Contact: Barbara Betsock\nNTSB Recommendation:\nRevise 49 Code of Federal Regulations Part 192 to require that new or replaced\npipelines be designed and constructed with features to mitigate internal corrosion.\nAt a minimum, such pipelines should (1) be configured to reduce the opportunity\nfor liquids to accumulate, (2) be equipped with effective liquid removal features,\nand (3) be able to accommodate corrosion monitoring devices at locations with\nthe greatest potential for internal corrosion.\nPast PHMSA action and advisory committee consideration:\n• Following a briefing in June 2005, this committee generally supported the concept\nof a regulation responsive to the NTSB. Some members expressed concern that\nthe regulation not be overbroad or limit protections to high consequence areas.\n• PHMSA issued a Notice of Proposed Rulemaking (NPRM). (70 Fed Reg 74262;\nDecember 15, 2005). The NPRM proposed to:\n- Require design to avoid liquid accumulation, to include liquid removal\nequipment, and to include monitoring. Apply the design requirement\nwithout regard to the anticipated operations of the line.\n- Include offshore pipelines and gathering lines.\n- Require an operator to examine downstream portions for internal\ncorrosion impacts caused by changes to the upstream pipeline.\n- Require documentation, including engineering analysis, for every design\ndecision with respect to internal corrosion control.\n• PHMSA presented the NPRM and cost benefit analysis to the committee for\nconsideration and vote at the June 28, 2006 meeting.\n- At the meeting, PHMSA committed to clarify one concern raised by the\ncommittee with respect to a proposed requirement to analyze changes\nimpacting downstream facilities. The final rule will clarify that only\nchanges to configuration of the pipeline will require analysis.\n-The committee requested additional information and postponement of the\nvote. This paper and its attachments provide additional information for\nthe meeting and vote on August 24.\n- Committee concerns unresolved at the June 28 meeting were: whether\nthe committee was considering a proposed rule or a draft final rule; what\ntype of record-keeping should apply to the regulation; and the degree of\nenforceability of the regulation.\nThe additional information provided\n\n<<<PAGE 2>>>\n\n• This briefing paper includes a description of how PHMSA works with its advisory\ncommittees on consideration of proposed rules and cost-benefit analyses.\n• The description below of what PHMSA intends to do with the final rule outlines\nhow we intend to address the major comments to the proposed rule.\n• The attached concept paper describes how we intend to approach record-keeping.\n• The attached summary of major comments includes an expanded description of\ncomments on record-keeping, including approaches suggested by commenters.\n• The attached 5 pages of excerpts from the NTSB report on the Carlsbad, New\nMexico, accident show how NTSB developed its recommendation on design and\nconstruction of gas transmission pipeline to address internal corrosion.\nCommittee consideration of proposed rules and cost-benefit analyses\n• The pipeline safety law requires PHMSA to seek the advice of this committee on\nproposed rules and cost-benefit analyses.\n• In recent years, PHMSA has made an effort to provide this committee a summary\nof public comment on proposed rules and information about the position PHMSA\nis likely to take vis-à-vis the major comments.\n• PHMSA does not share the text of draft final rules with the committee since doing\nso could trigger a new round of public comment and delay the safety benefits of\ncompleting the rule.\nWhat PHMSA intends to do:\n• Consider carefully the comments and any advice this committee provides.\nIssue a final rule responsive to the NTSB recommendation.\n• We are considering issuing a final rule with the following changes from the\nNPRM:\n- Change focus from avoiding liquids to reducing risks of internal\ncorrosion. Simplify the section to conform more closely to the NTSB\nrecommendation. This change, which will be further explained in the\npreamble, will recognize the inability to avoid low spots in every case\nand the variety of pipeline environments. This change responds to\ncomments by INGAA, AGA, individual pipeline companies, and the\nIowa Utilities Board. Simplification will improve enforceability.\n- Except offshore pipelines from the regulation. This change responds\nto comments by INGAA and El Paso.\n- Keep the final rule with other corrosion control requirements in\nsubpart I, but add a cross-reference in a design subpart of Part 192 and\nclarify the non-retroactive impact of the rule. This maximizes the\nsafety benefit of integrated approaches to internal corrosion.\n- Simplify the recordkeeping provision. This responds to comments\nby INGAA, AGA, the Texas Pipeline Association, individual pipeline\ncompanies, and this committee.\n\n<<<PAGE 3>>>\n\nConcept for Addressing Record-keeping in Final Rule on\nDesigning and constructing gas transmission pipelines to control internal corrosion\nUse the approach developed in negotiated rulemaking for operator qualification\nregulations. This two-fold approach would:\n1. Require an operator generally to maintain records demonstrating compliance with\nthe section; and\n2. Add some specificity on the required records.\nFor the specificity, allow an operator to use as-built drawings and other construction\nrecords or written procedures. Preamble language will provide examples. One example\nis a procedure on how an operator will address design following the contour of the land in\ndesign. To avoid accumulation of liquid in the low spots, the procedure might call for\nincorporating design feature to maintain gas velocity or turbulence or to remove liquids.\nThe actual construction records or as-built drawings would show what an operator\nactually did. Another example might be a construction record showing the use of a filter\nor separator at the gate station of a distribution pipeline. Regardless of the choices in\nrecord-keeping an operator makes, the records must show circumstances justifying\nvariance based on impracticability or lack of necessity. For example, if an operator does\nnot provide features for effective liquid removal at low spots, the records must show why\nit is not necessary to do so.\n\n<<<PAGE 4>>>\n\nSummary of major comments and how we are addressing them\nRequest for exceptions from regulation based on expected operations\nMany commenters requested an exception to the design and construction requirements if\nthe operator believes liquids will not pose a problem in the line. The commenters\nsuggested several variations, including:\n• except pipeline from the requirements where an operator confirms liquids will not\npresent an uncontrolled threat (INGAA);\n• require design and construction actions only where corrosive gas is being\ntransported (AGA);\n• except pipelines in areas without a history of internal corrosion (Iowa).\nResponse: When an operator knows liquids in the pipeline are likely, relying on\noperation and maintenance actions alone to address internal corrosion misses the safety\nand economic benefit of advance planning for future needs. An operator cannot predict\nwith any certainty the absence of corrosive gas in upset conditions. Planning for these\nupset conditions when making design and construction decisions makes sense from a\nsafety perspective since it facilitates future operation and maintenance actions to address\ninternal corrosion.\nFor cost effectiveness, PHMSA is considering adding more flexibility to operators to\nselect design and construction options fitting the relative risk that the pipeline will\ntransport corrosive gas in the future.\nOther requested exceptions from regulation\nCommenters requested, without explanation, exceptions for the following pipeline\nfacilities addressed by the proposed rule:\n• gathering lines (INGAA, El Paso);\n• offshore lines (INGAA, El Paso); and\n• compressor stations (Duke).\nResponse: PHMSA agrees with an exception for offshore lines. Although these pipelines\nexperience internal corrosion, the risk they pose to people and property is considerably\nless. In addition, the design and construction options are more limited.\nGathering lines and compressor stations are different. Gathering lines are only regulated\nin populated areas. By their very nature, gathering lines regularly transport gas\ncontaining liquids. Both historically and in the new gathering line regulation, gathering\nlines are subject to the same design and corrosion regulations as transmission lines.\nCompressor stations do not operate well when there are liquids in the gas flow and liquid\nremoval may result in liquid accumulation in compressor station piping. The incident\nstatistics indicate the real risk of internal corrosion with respect to both gathering lines\nand compressor stations.\n\n<<<PAGE 5>>>\n\nPlacement within Code\nSeveral commenters suggest Subpart I- Requirements for Corrosion Control is wrong\nplace for the proposed rule. They suggest various combinations of Subpart C - Pipe\nDesign, Subpart D - Design of Pipeline Components, and Subpart G - General\nConstruction Requirements for Transmission Lines and Mains. Commenters give the\nfollowing reasons:\n• These design and construction requirements should be in the non-retroactive\nsection of the Code.\n• Subpart I requirements might be overlooked in design and construction.\nResponse: Subpart I contains other design requirements, such as pipe coating. PHMSA\nbelieves consolidating corrosion control requirements strengthens the planning aspects of\nthe regulation. To address concerns of commenters, PHMSA is considering adding\nlanguage (such as a date) that clearly points to the non-retroactive effect of the\nregulation. PHMSA is also considering adding a cross reference to subpart I in subpart D\nto alert those designing pipelines of the need to look at corrosion requirements.\nRecordkeeping\nMany commenters expressed concern about the proposed recordkeeping requirements;\nsome suggested alternative approaches:\n• As-built drawings and construction records provide sufficient information about\nan operator’s design and construction decisions in a less burdensome way. (Gas\nPiping Technology Committee)\n• Variances from specific requirements should be documented. (Duke Energy,\nNicor, Gas Piping Technology Committee) Suggested language: When an\noperator makes an exception to paragraphs (a), (b), or (c) of this section, the\noperator must document the decisions related to the exception.\n• Documenting decisions with respect to all low spots would be costly and\nunnecessary (Kinder Morgan, INGAA, El Paso, Panhandle).\n• If an internal corrosion control program is in place, documenting procedures\nshould be enough. (AGA, SoCal Gas, Southwest Gas, Paiute) Suggested\nlanguage: An operator must have written procedures to implement the provisions\nof this section.\n• Broad general language would be more appropriate and consistent with existing\nregulations. (Texas Pipeline Association) Suggested language: An operator must\nmaintain records demonstrating compliance with this section for the life of the\npipeline.\nResponse: The proposed recordkeeping requirements are overly burdensome. We are\nconsidering a general requirement to maintain records demonstrating compliance with the\nsection. As-built drawings and other construction records operators normally maintain\ntogether with some additional explanation of variances will suffice. We have developed\na concept paper discussing this.\n\n<<<PAGE 6>>>\n\nRedundancy\nSome commenters argued that other regulations on internal corrosion control make this\nproposed rule redundant. For example, commenters pointed to the requirement that new\nlines be “piggable” and hence capable of being cleaned. Others pointed to integrity\nmanagement programs (AGA) which address internal corrosion.\nResponse: The proposed rule is not redundant. Most rules cited by commenters are\noperation and maintenance requirements, not design standards, and thus do not address\nthe NTSB concern. In addition, integrity management programs directly protect only\nhigh consequence areas. The piggability requirement is a design standard, but is not\napplicable to gathering lines.","truncated":false,"body_characters":12430}