In my inspections of gas integrity management and hazardous liquids integrity management, I cited several operators for preventative and mitigative measures that were not above code. For example, if a Part 192 natural gas operator’s P&M program states they will inspect valves every year which is what the code requires (See below) that is not really a preventative or mitigative measure since the O&M section of Part 192 requires this already. However, if the operator lists as a P&M measure valve inspection every 6 months when the code requires every year that is a valid P&M measure if that action is expected to reduce risk. Far below, note in the excerpt from PHMSA’s Part 192 and 195 enforcement guidance document ( available for operators to view at: FOIA Library/Electronic Reading room | PHMSA ) the notation that P&M measures must be above the requirements already in Part 192. The Part 195 enforcement guidance states this as additional actions.
- 192.745 Valve maintenance: Transmission lines.
(a) Each transmission line valve that might be required during any emergency must be inspected and partially operated at intervals not exceeding 15 months, but at least once each calendar year.
- 195.420 Valve maintenance
(b) Each operator must, at least twice each calendar year, but at intervals not exceeding 7 1/2 months, inspect each mainline valve to determine that it is functioning properly. Each rupture-mitigation valve (RMV), as defined in § 195.2 and not contained in a gathering line, or alternative equivalent technology that is installed under § 195.258(c) or § 195.418, must also be partially operated. Operators are not required to close the valve fully during the inspection; a minimum 25 percent valve closure is sufficient to demonstrate compliance, unless the operator has operational information that requires an additional closure percentage for maintaining reliability.
| Enforcement Guidance |
Part 192 Gas Transmission Pipeline Integrity Management |
| Revision Date | 12/7/2015 |
| Code Section | §192.935(a) |
| Section Title | What additional preventive and mitigative measures must an operator take? |
| Existing Code Language | (a) General requirements. An operator must take additional measures beyond those already required by Part 192 to prevent a pipeline failure and to mitigate the consequences of a pipeline failure in a high consequence area. An operator must base the additional measures on the threats the operator has identified to each pipeline segment. (See §192.917) An operator must conduct, in accordance with one of the risk assessment approaches in ASME/ANSI B31.8S (incorporated by reference, see §192.7), section 5, a risk analysis of its pipeline to identify additional measures to protect the high consequence area and enhance public safety. Such additional measures include, but are not limited to, installing Automatic Shut-off Valves or Remote Control Valves, installing computerized monitoring and leak detection systems, replacing pipe segments with pipe of heavier wall thickness, providing additional training to personnel on response procedures, conducting drills with local emergency responders and implementing additional inspection and maintenance programs. |
| Enforcement Guidance | Hazardous Liquid Integrity Management Part 195 |
| Revision Date | 12/7/2015 |
| Code Section | §195.452(i)(1) |
| Section Title | Pipeline integrity management in high consequence areas. |
| Existing Code Language | (i) What preventive and mitigative measures must an operator take to protect the high consequence area?
(1) General requirements. An operator must take measures to prevent and mitigate the consequences of a pipeline failure that could affect a high consequence area. These measures include conducting a risk analysis of the pipeline segment to identify additional actions to enhance public safety or environmental protection. Such actions may include, but are not limited to, implementing damage prevention best practices, better monitoring of cathodic protection where corrosion is a concern, establishing shorter inspection intervals, installing EFRDs on the pipeline segment, modifying the systems that monitor pressure and detect leaks, providing additional training to personnel on response procedures, conducting drills with local emergency responders and adopting other management controls. |
| Origin of Code | 195-70, 65 FR 75378, December 1, 2000 |
| Last Amendment |
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