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Recording as found and as left pressures as well as setpoints during pressure relief valve testing is required by PHMSA for both gas and hazardous liquids. If you look at the code below (red), these records are not specified in code. However, enforcement history like the example copied below (blue) is used by PHMSA to justify their position that this data is necessary to demonstrate adequate compliance with the code. In other words, their enforcement of requiring as found and as left pressures has been tested in the courts and upheld allowing PHMSA to continue this requirement.
195.402 Procedural manual for operations, maintenance, and emergencies.
(c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations:
Enhanced Content – Paragraph Tools
(3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part.
- 195.428 Overpressure safety devices and overfill protection systems.
(a) Except as provided in paragraph (b) of this section, each operator shall, at intervals not exceeding 15 months, but at least once each calendar year, or in the case of pipelines used to carry highly volatile liquids, at intervals not to exceed 71⁄2 months, but at least twice each calendar year, inspect and test each pressure limiting device, relief valve, pressure regulator, or other item of pressure control equipment to determine that it is functioning properly, is in good mechanical condition, and is adequate from the standpoint of capacity and reliability of operation for the service in which it is used.
- 192.605 Procedural manual for operations, maintenance, and emergencies
(b) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following, if applicable, to provide safety during maintenance and operations.
(1) Operating, maintaining, and repairing the pipeline in accordance with each of the requirements of this subpart and Subpart M of this part.
- 192.739 Pressure limiting and regulating stations: Inspection and testing.
(a) Each pressure limiting station, relief device (except rupture discs), and Pressure regulating station and its equipment must be subjected at intervals not exceeding 15 months, but at least once each calendar year, to inspections and tests to determine that it is-
(1) In good mechanical condition;
(2) Adequate from the standpoint of capacity and reliability of operation for the service in which it is employed;
(3) Except as provided in paragraph (b) of this section, set to control or relieve at the correct pressure consistent with the pressure limits of §192.201(a); and
(4) Properly installed and protected from dirt, liquids, or other conditions that might prevent proper operation.
NOTICE OF AMENDMENT
December 14, 2017
Mr. Stanley Chapman III President, US Gas Pipelines Columbia Midstream Group, LLC 700 Louisiana Street, Suite 700
Houston, TX 77002
Dear Mr. Chapman:
CPF 1-2017-6008M
From April 24-28, 2017, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected the procedures and records of Columbia Midstream Group, LLC, a subsidiary of TransCanada (TransCanada), at its pipeline facility located in Leetonia, Ohio.
On the basis of the inspection, PHMSA has identified the apparent inadequacy found within TransCanada’s plans or procedures, as described below:
§ 195.402(c)(3)
(C) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations:
(3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart Hof this part.
TransCanada’s procedures for operating, maintaining and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart Hof Part 195 were inadequate for overpressure safety devices. Specifically, TransCanada’s procedures failed to provide sufficient guidance on how to conduct and document relief valve inspections, per§ l 95.428(a).
Section 195.428(a) states:
“(a) Except as provided in paragraph (b) of this section, each operator shall, at intervals not
exceeding 15 months, but at least once each calendar year or in the case of pipelines used to carry highly volatile liquids, at intervals not to exceed 7½ months, but at least twice each calendar year, inspect and test each pressure limiting device, relief valve, pressure regulator, or other item of pressure control equipment to determine that it is functioning properly, is in good mechanical condition, and is adequate from the standpoint of capacity and reliability of operation for the service in which it is used.”
During the inspection, the PHMSA inspector reviewed TransCanada’s “Liquid Overpressure Safety Devices and Overfill Protection Plan”, dated 8/30/16 (Plan), “Liquid Pipeline Relief Valve Setpoint Test/Capacity Review Procedure”, dated 6/10/16 (Procedure), and relief valve inspection records (Record). TransCanada’s Plan and Procedure did not provide sufficient guidance on conducting and documenting a relief valve inspection.
To ensure that a relief valve will relieve at the specified set pressure when needed, data is needed on the condition of the valve prior to the inspection (“as found”), as well as on the condition of the valve after the inspection is completed (“as left”). Information typically documented includes:
- Toe relief pressure of the valve in the •’as found” condition
- The relief pressure of the valve in the “as left;’ condition
- The “set point”
TransCanada’s Plan and Procedure did not include sufficient guidance and criteria for capturing either the “as found” or “as left” pressure of a relief device, as the terms are not defined. The Plan states in Section 3:
“Documentation:
Equipment maintenance records for mechanical pressure relief valves (thermal relief and pressure relief valves) records should include:
- As found and as left set point pressure of the device.”
The Procedure provides guidance for documenting various pressure reading values during the performance of a relief valve inspection. None of the values required by the Procedure are stated to be the “as found” or “as left” relief pressure required to be documented per the Plan.
The Records reviewed demonstrated’ inconsistency with the Plan, as no fields were defined for ‘·As Found” or “As Left” relief pressure.
In addition, the Plan/Procedure lacked details such as, but not limited to:
- The criteria for determining acceptable “as-found” / “as left” relief pressures
- The actions that must be taken if the relief valve “as-found” pressure does not meet the criteria
- The definition and criteria for determining “popping pressure”, “popping point”, “reseat pressure”, “set pressure”.
Therefore, TransCanada failed to provide sufficient guidance on how to conduct and document relief valve inspections, per the requirements of§ 195.428(a).