On January 11 and 12, the Technical Pipeline Safety Standards Committee (TPSSC) met in Arlington, Va., to review the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) proposed changes to transmission regulations. The TPSSC is a congressionally-mandated peer review committee composed of industry, government and public pipeline safety experts that advises PHMSA so its rules are reasonable, practicable, technically feasible and cost-effective. Rich Worsinger of Rocky Mount, N.C., represents public natural gas on this committee.
The proposed rule covers 136 Federal Register pages and proposed many complex and interrelated changes. Even though the rule was listed as a transmission rule, some of the proposed changes would affect distribution operators. For example, PHMSA proposed to amend Appendix D that deals with criteria for cathodic protection, to require an “instant off” measurement of pipe to soil potential, requiring the cathodic protection system to be turned off just before the reading is taken. This could require significant costs for distribution systems that typically use galvanic anodes physically connected to the pipe for cathodic protection. APGA’s comments pointed out that such costs would provide little benefit as only three out of 592 distribution reportable incidents since 2010 occurred on pipe under cathodic protection, and none of those three incidents caused any injury or property loss to the public. The only cost was to the operator to repair the pipe.
The committee approved some of the less controversial aspects of PHMSA’s massive proposal, including flexibility in transmission integrity management reassessment intervals, requirements for safe design of pig launchers and receivers and addressing seismicity in integrity management. There was significant concern expressed by the committee about PHMSA’s proposed recordkeeping requirements, in particular it’s placement in a portion of regulations that would make it retroactive. The committee also expressed APGA’s concern about changes to corrosion control requirements. The TPSSC’s views carry great weight; however, PHMSA is not legally bound to accept every committee recommendation.
The TPSSC will meet twice more in the coming months to complete a review of the remainder of PHMSA’s proposed changes. For questions on this article, please contact John Erickson of APGA staff by phone at 202-464-2742 or by email at jerickson@apga.org.