Page 1 of 8 PRIMARY: 192.605 SECONDARY: 191.23 PURPOSE: Review guide material added by TR 2009-17 to 5.1(e) and consider restructuring the guide material under 192.605 as discussed further below. ORIGIN/RATIONALE : Member email 2/25/14 During review of TR 2009-17 for 2nd Letter Ballot (approved in LB4-2013), Editorial Section agreed that action is needed to address the format and structure of the GM under 192.605 in this area. Much of the GM added by this TR under 5.1(e) does not match with the existing titles of 5 and 5.1. Since the additional changes were outside the scope of the 2nd LB changes, it was further agreed that a new TR request would be needed. Member agreed to submit the new TR request. Restructuring discussion: - GM 5 is titled Safety-Related Condition Report -- it is recommended to consider revisions to the heading/sub-headings and then restructure the GM in this section to separately address the requirements of 192.605(d) and the O&M response to these conditions. - 192.605(d) requires the manual to include instructions enabling O&M personnel to recognize conditions that potentially may be safety-related conditions that are subject to the reporting requirements of 191.23. These should be referred to personnel for determining if a report is required and if so, to make the report. - Provide GM regarding operator response to conditions that potentially may be safety-related conditions, such as the GM added by TR 2009-17. For transmission lines that are not operated by a distribution system operator in connection with their distribution system, this may involve reference to GM 4. - GM 4 is titled Abnormal Operations and addresses 192.605(c) for certain transmission lines, the manual must include procedures to provide for safety when operating design limits have been exceeded. When TR 2009-17 was originally approved by O&M/OQ TG, TR 2012-03 was requested to look address over-pressurization issues that are categorized as abnormal operations under 192.605(c) for transmission lines. This has some overlap with the other GM discussed above this should be clarified as needed (consider cross-references). - Consider any other appropriate GM revisions related to GM 4 and 5 and the new GM structure, such as adding a new GM section if it is more appropriate than sub-headings. Section 191.5 {Editorial Note: also under review by TR 17-10} (a) Complete information is not necessary for the initial electronic or telephonic incident report to National Response Center (NRC). Refer to Guide Material Appendix G-191-1 for a sample worksheet that may be used to compile information for the incident report. The initial incident report should be made within 2 hours of discovery of the incident. Initial report information should include the following. (1) Name, address, and a 24-hour telephone number of the operator. An operator should consider providing a telephone number where more detailed information can be obtained. (2) Time and date of incident. (3) Location of incident, provided in a manner that will aid agencies in locating the site on maps. GPS coordinates, addresses and ZIP codes, and cross streets are useful. (4) Facilities involved. (5) Number of fatalities or injuries, if known. (6) Estimate of property damage. (7) Type of product gas released, and an estimate of the quantity released. For guidance on calculating gas loss from a damaged pipeline, see Guide Material Appendix G-191-5. (8) Evacuations and other emergency actions, if known.
Page 2 of 8 (9) The responsible party, if known. (10) Weather conditions at the incident site. (b)... (c)... (d)... (e) See the operator s procedures for the gathering of data needed for reporting incidents as required by 192.605. See 3.3 of the guide material under 192.605. Section 191.9 (a) (b) (c) See Guide Material Appendix G-191-2 for an index of PHMSA reporting forms. Report forms and instructions can be downloaded from the PHMSA-OPS website at www.phmsa.dot.gov/forms/pipelineforms. Additional state requirements may exist for intrastate facilities. See the operator s procedures for the gathering of data needed for reporting incidents as required by 192.605. See 3.3 of the guide material under 192.605. Section 191.15 (a) (b) (c) See Guide Material Appendix G-191-2 for an index of PHMSA reporting forms. Report forms and instructions can be downloaded from the PHMSA-OPS website at www.phmsa.dot.gov/forms/pipeline-forms. Additional state requirements may exist for intrastate facilities. See the operator s procedures for the gathering of data needed for reporting incidents as required by 192.605. See 3.3 of the guide material under 192.605. Section 191.23 (a) (b) (c) (d) For the purpose of Safety-Related Condition Reports, "in-service facilities" are those that are pressurized with gas, regardless of flow conditions. Facilities that are not "in-service" are completely depressurized and isolated from all pressurized facilities by valves or physical separation. See the operator s instructions enabling O&M personnel to recognize conditions that potentially may be safety-related conditions as required by 192.605. See Guide Material Appendix G-191-3 for a chart useful in determining if reports must be filed. See 5.4 of the guide material under 192.605 for actions to consider in response to safety-related conditions. See guide material under 192.617 for failure investigation, when applicable. If the MAOP plus the build-up allowed for operation of pressure-limiting or control devices on a transmission line is exceeded, the Pipeline Safety, Regulatory Certainty and Job Creation Act of 2011 ("Act") (Section 23(b)) states that the operator is to notify the Secretary of Transportation, and appropriate state agencies if the pipeline is subject to state regulations, on or before the fifth calendar day of the exceedance. PHMSA-OPS issued Advisory Bulletin ADB-2012-11 (77 FR 75699, Dec. 21, 2012; reference Guide Material Appendix G-192-1, Section 2) to advise owners and operators of gas transmission pipeline facilities of new reporting requirements in the Act. The Act states that exceedance is to be reported even if the condition is corrected within the reporting
Page 3 of 8 timeframe. The Advisory Bulletin requests operators to submit information comparable to that required for a safety-related condition (see Guide Material Appendix G-191-4). The operator should note that the reporting requirement for an exceedance is calendar days, as opposed to the safety-related conditions requirement of working days that does not include Saturdays, Sundays, or federal holidays. Section 192.605 1 GENERAL (a) Each procedural manual for operations, maintenance, and emergencies should include a written statement, procedure, or other document addressing each specific requirement of 192.605 that applies to the operator s pipelines. The requirements of 192.605 are included in paragraphs that cover the following topics. (1) General items related to the procedural manual ( 192.605(a)). (2) mmaintenance and normal operation of any pipeline; and the ( 192.605(b)). (3) aabnormal operations of transmission lines, other than those transmission lines operated by distribution operators in connection with a their distribution system ( 192.605(c)). (4) Safety-related condition reports ( 192.605(d)). (5) Surveillance, emergency response, and accident investigation ( 192.605(e)). The guide material under this section addresses most of the requirements of 192.605. (b) (h)... 2 TRAINING... 3 MAINTENANCE AND NORMAL OPERATIONS In addition to those items required to be in the manual under Subparts L and M as they apply to the operator s facilities, other Subparts (e.g., E, F, I, J, and K) may also require written procedures. Additional guide material can be found under individual sections. 3.1 Control of corrosion.... 3.2 Availability of construction records, maps, and operating history. 3.3 Data gathering for incidents. (a) The operator should designate personnel to gather data at the incident site and other locations where records are retained. (b) For verification and telephonic reporting that an incident has occurred on the operator s facility, the following information should be gathered as soon as possible. See Guide Material Appendix G-191-1 and guide material under 191.5. (1) Time and date of the incident. (2) Location of the incident and facilities involved. (3) Number of fatalities and personal injuries necessitating in-patient hospitalization. (4) Estimates of property damage, including and gas lost. See guide material under 191.3 and Guide Material Appendix G-191-5. (5) Type of incident: leak, rupture, other. (6) Whether there was an explosion. (7) Whether there was a fire. (8) Whether there was a curtailment or interruption of service. (9) Environmental impact.
Page 4 of 8 (10) Apparent cause and responsible party, if known. (11) Component(s) involved and material specification. (12) Pressure at the time of incident. (13) Estimated time of repair and return to service. (14) A 24-hour staffed telephone number. (c) Procedures should be established for personnel to determine if the event meets the criteria for the Part 191 definition of an "incident" and to make the telephonic report. Alternate personnel should be included in the procedures in case primary personnel are not available. If some of the information is not available, the notification should be made without that information. Any corrections or additional information may be provided later. See guide material under 191.5. (d) For post-accident drug and alcohol testing, see Part 199 Drug and Alcohol Testing and OPS Advisory Bulletin ADB-12-02 (77 FR 10666, Feb. 23, 2012; see Guide Material Appendix G-192-1, Section 2). (e) For the written Incident Report, see guide material under 192.617 and Guide Material Appendices G-191-2 and G-191-5. 3.4 Starting up and shutting down a pipeline.... 4 ABNORMAL OPERATIONS OF TRANSMISSION LINES 4.1 General. (a) The abnormal operation requirements in 192.605(c) do not apply to distribution operators that are operating transmission lines in connection with their distribution system ( 192.605(c)(5)). (b) An abnormal operation is a non-emergency event on a gas transmission facility that occurs when the operating design limits have been exceeded due to a change in pressure, flow rate, or temperature that is outside the normal limits. When an abnormal operation occurs, it does not pose an immediate threat to life or property, but could if not promptly corrected. Where applicable, the actions to be taken by the transmission operator in each situation should incorporate the current procedures. The procedures should be specific enough to ensure uniformity of action relative to the situation, such as those referenced above, while allowing sufficient flexibility to consider the particular details, material, equipment, and configurations involved. 4.2 Considerations for abnormal operations. When developing response procedures for abnormal operations, the transmission operator should consider the following. (a) Type of event. See list under 192.605(c)(1). (b) Proximity of the event to the public. (c) Potential for the event to become an emergency situation if not immediately corrected. (d) Effect of the event on the pipeline system. (e) Notification of appropriate operator personnel regarding the abnormal operation. (f) Documentation of the response actions taken. (g) Potential of the event to become a safety-related condition subject to the reporting requirements in 191.23 and 191.25. (h) If the event is an increase in pressure outside normal operating limits, the potential for MAOP plus allowable buildup to be exceeded. See 5.4(f) below and (d) of the guide material under 191.23. 4.3 Preventing recurrence of abnormal operation.
Page 5 of 8 5 POTENTIAL SAFETY-RELATED CONDITIONS, ANALYSIS, AND ACTIONS REPORT 5.1 Potential safety-related conditions. Personnel who perform O&M activities should recognize the following anomalies as potential safety-related conditions that may be subject to the reporting requirements of 191.23. (a) General corrosion that has reduced the pipe wall thickness to less than that required for the MAOP. (b) Localized corrosion pitting which has progressed to a degree where leakage might result. (c) Unintended movement or abnormal loading by environmental causes, such as an (e.g., earthquake, landslide, subsidence, or flood,) that impairs the serviceability of a pipeline segment. (d) Material defects, such as those caused in the manufacturing process, or physical damages that impair the serviceability of a pipeline segment. Sound engineering criteria should be used to determine if an observed condition involving a material defect or physical damage impairs serviceability. (e) Malfunctions or operating errors that cause the pressure of a pipeline to rise above its MAOP plus the buildup allowed for the operation of pressure limiting or control devices. If this happens, consider the following actions, which may vary depending upon the situation. (1) Initial actions. (i) Verify that an overpressure condition has occurred by performing one or more of the following. (A) Dispatch personnel for field investigation. (B) Review SCADA information. (C) Review pressure records. (ii) Isolate the malfunctioning equipment or other cause of the overpressurization, if practicable, and reduce the pressure in the pipeline to normal operating pressures. (iii) Determine whether the magnitude of overpressure warrants taking the pipeline out of service immediately. (iv) Determine the extent of possible impact (e.g., a single customer, multiple customers). (A) SCADA and pressure recorders can be used to identify overpressured segments requiring possible corrective action. (B) For low-pressure distribution systems, determine whether gas utilization equipment has been adversely affected. Notify affected customers if damage is suspected. Consider notifying emergency responders and public officials. (v) Repair or replace the malfunctioning equipment that caused the overpressurization. (2) Additional actions. (i) Perform an instrumented leak survey of the overpressured pipe. (A) Consider taking the pipeline out of service based on the nature of discovered leaks. (B) Consider examining and repairing non-hazardous leaks on overpressured piping. (ii) Determine the duration of the overpressurization. (iii) Address transmission lines as follows.
Page 6 of 8 (A) Determine the highest percentage of SMYS attributed to the overpressure event. (B) For segments subject to integrity management under 192.917(e), determine whether the overpressured pipe needs to be prioritized as a high risk segment for the baseline assessment or a subsequent reassessment. (iv) Determine the cause of the overpressurization to reduce the likelihood of a recurrence. See guide material under 192.617. (v) Assess the need for replacement of system components exposed to pressures greater than manufacturers test pressures. (vi) Determine whether a Safety-Related Condition Report is required (see Guide Material Appendix G-191-7) and if required, file a report in accordance with 191.25. (vii) In the event of an operating error, see the operator s Drug and Alcohol Testing and Operator Qualification Programs, if appropriate. (viii) Retain documentation of the event and of the corrective actions taken to continue the safe operation of the pipeline. (ix) For recordkeeping on transmission lines, see 192.709. (f) Leaks in a pipeline Pipeline leaks that constitute the need for immediate corrective action to protect the public or property. Examples include leaks occurring in residential or commercial areas in conjunction with a natural disaster; leaks where a flammable vapor is detected inside a building; and leaks that involve response by police or fire departments. While venting is done to mitigate an unsafe condition, it does not remove the unsafe condition. (g) Other known anomalies or events that could lead to an imminent hazard and cause (either directly or indirectly by remedial action of the operator) for purposes other than abandonment, a 20% or more reduction in operating pressures or shutdown of operation of the effected affected pipeline segment. 5.2 Procedures and guide material used to recognize a potential safety-related condition. Personnel who perform operating and maintenance O&M activities may use operating and maintenance O&M procedures written in compliance with Subparts I, L and M and the associated guide material and guide material appendices to recognize anomalies or events that could become safety-related conditions. Some useful sections in Subparts I, L, and M include: 192.455 192.473 192.485 192.614 192.711 192.721 192.459 192.475 192.487 192.615 192.713 192.723 192.465 192.477 192.489 192.705 192.715 192.739 192.467 192.481 192.613 192.706 192.717 5.3 Analysis and follow-up of in-line inspection (ILI). Special consideration should be given to the development of written procedures for the timely analysis of, and follow through on, information obtained through the use of an ILI tool. (a) An anomaly discovered with an ILI tool may be determined to be a safety-related condition when adequate information is available. For instance, adequate information would be available for each anomaly that is physically examined. Absent physical examination of each indicated anomaly, adequate information may be obtained when the ILI data is validated. For guidance on validation, see Guide Material Appendix G-192-14.
Page 7 of 8 (b) The date an anomaly is discovered by an operator's representative and the date the anomaly is determined by an operator's representative to be a safety-related condition are used to determine the filing deadline stated in the reporting requirements of 191.25. (c) See 192.933 and Guide Material Appendix G-192-14. 5.4 Actions in response to potential safety-related conditions. (a) Procedures should be established for personnel to determine if a potential safety-related condition meets the reporting criteria in 191.23 and to file a report in accordance with 191.25. See Guide Material Appendix G-191-3 for a chart useful in determining if reports must be filed. (b) When general corrosion is discovered that has reduced the pipe wall thickness to less than that required for the MAOP, actions should be taken to restore the pipe integrity (e.g., replace the pipe, reduce the MAOP). (c) When localized corrosion pitting is discovered that has progressed to a degree where leakage might result, actions should be taken to prevent leakage at that location such as installing a repair clamp. (d) When unintended movement or abnormal loading by environmental causes is discovered that impairs the serviceability of a pipeline segment, actions should be taken to monitor the pipeline segment until the integrity and serviceability can be restored. (e) When an observed condition involving a material defect or physical damage is determined to impair the serviceability of a pipeline segment, actions should be taken to monitor the pipeline segment until the integrity and serviceability can be restored. (f) When there are indications that the pressure of a pipeline has risen above its MAOP plus the buildup allowed for the operation of pressure limiting or control devices, consider the following actions which may vary depending upon the situation. (1) Initial actions. (i) Verify that an overpressure condition has occurred by performing one or more of the following. (A) Dispatch personnel for field investigation. (B) Review SCADA information. (C) Review pressure records. (ii) Isolate the malfunctioning equipment or other cause of the overpressurization, if practicable, and reduce the pressure in the pipeline to normal operating pressures. (iii) Determine whether the magnitude of overpressure warrants taking the pipeline out of service immediately. (iv) Determine the extent of possible impact (e.g., a single customer, multiple customers). (A) SCADA and pressure recorders can be used to identify overpressured segments requiring possible corrective action. (B) For low-pressure distribution systems, determine whether gas utilization equipment has been adversely affected. Notify affected customers if damage is suspected. Consider notifying emergency responders and public officials. (v) Repair or replace the malfunctioning equipment that caused the overpressurization. (2) Additional actions. (i) Perform an instrumented leak survey of the overpressured pipe.
Page 8 of 8 (g) (h) (A) Consider taking the pipeline out of service based on the nature of discovered leaks. (B) Consider examining and repairing non-hazardous leaks on overpressured piping. (ii) Determine the duration of the overpressurization. (iii) Address transmission lines as follows. (A) Comply with the notification requirements described in (d) of the guide material under 191.23. (B) Determine the highest percentage of SMYS attributed to the overpressure event. (C) For segments subject to integrity management under 192.917(e), determine whether the overpressured pipe needs to be prioritized as a high risk segment for the baseline assessment or a subsequent reassessment. (D) For additional information about transmission lines, see 4 above. (iv) Determine the cause of the overpressurization to reduce the likelihood of a recurrence. See guide material under 192.617. (v) Assess the need for replacement of system components exposed to pressures greater than manufacturers test pressures. (vi) In the event of an operating error, see the operator s Drug and Alcohol Testing and Operator Qualification Programs, if appropriate. (vii) Retain documentation of the event and of the corrective actions taken to continue the safe operation of the pipeline. For recordkeeping on transmission lines, see 192.709. Leaks that may constitute an emergency are responded to in accordance with the procedures required by 192.615 and 192.703. See leakage control guidelines for Grade 1 leaks in Guide Material Appendices G-192-11 and G-192-11A. Anomalies or events that could lead to an imminent hazard and cause a 20% or more reduction in operating pressures or shutdown of operation of the affected pipeline segment should be responded to in accordance with the procedures required by 192.615 and 192.703.