On September 29, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued two Advisory Bulletins to distribution operators. One is on inside meters and regulators, and the other is on overpressure protection on low-pressure natural gas distribution systems.
The inside meter and regulator Advisory Bulletin addresses two National Transportation Safety Board (NTSB) recommendations to PHMSA that resulted from the 2016 Silver Spring, Md., incident: PHMSA to require that all new service regulators be installed outside occupied structures; and, PHMSA to require existing interior service regulators be relocated outside occupied structures whenever the gas service line, meter, or regulator is replaced.
This advisory does not directly incorporate the NTSB’s recommendation requiring operators to move inside meters and regulators outside if they are replaced. Instead, PHMSA reminds operators of the existing requirements for installation and maintenance of inside meters and regulators, including venting of customer meters and regulators. Additionally, PHMSA reminds operators of the requirement to perform threat identification and review within Distribution Integrity Management Plan (DIMP) programs.
View here.
The Advisory Bulletin on overpressure protection addresses findings from the 2018 Merrimack Valley incident and directly satisfies the NTSB recommendation to PHMSA to “issue an alert to all low-pressure natural gas distribution system operators of the possibility of a failure of overpressure protection, and the alert should recommend that operators use a failure modes and effects analysis (FEMA) or equivalent structured and systematic method to identify potential failures and take action to mitigate those identified failures.” In the advisory, PHMSA reminds operators of their obligation to comply with DIMP regulations. PHMSA then details sections within the DIMP regulations that look to reduce the risk of overpressurization events. PHMSA specifically reminds operators that “they must monitor performance measures from an established baseline to evaluate the effectiveness of DIMP” per Section 192.1007(e). PHMSA then goes on to recommend that operators develop written procedures for all activities involving new construction or replacement projects for low-pressure distribution systems. PHMSA states that those procedures should include the application of a “management of change” process among other elements.
View here.
Distribution system operators are encouraged to read both NTSB reports on
the 2016 Silver Spring incident and
the 2018 incident in Merrimack Valley.
It is important to remember that Advisory Bulletins are not intended to apply new requirements on gas systems, but instead are meant to highlight areas of existing regulations that may warrant additional attention and focus. PHMSA goes so far as to say that, “the contents of these advisory bulletins do not have the force and effect of law. They are not meant to bind the public in any way, even as pipeline owners and operators must comply with the underlying safety standards.”
For questions on this article, please contact Erin Kurilla of APGA staff by phone at 202-464-2742 or by email at
ekurilla@apga.org.