In February 2020, before the U.S. was disrupted by COVID-19, the PHMSA Office of Pipeline Safety held a series of meetings in Houston to discuss recent rulemaking and the impact on pipeline operations.
One of the meetings was to discuss the implications of Part 1 of the Gas Gathering Rule that was published to the federal registry in October 2019. The meeting focused on gathering input from stakeholders and relaying the tentative plans from PHMSA for training and inspections.
For many interstate natural gas transmission operators, a significant number of assets are being brought under federal jurisdiction. This means needing to take measures to ensure compliance with PHMSA regulations. This includes the pipeline control room.
Do You Need a Pipeline Control Room?
The first question to ask is whether your operation needs to add a designated pipeline control room to support pipeline operations.
Standing up a DOT-compliant pipeline control room requires an understanding of the PHMSA Control Room Management Rule (CRM Rule). For gas operators, the specific requirements are outlined in 49 CFR Part 192 (transportation of natural and other gas by pipeline).
Within CFR 192, pipeline operators need to be aware of the requirements for each of the following critical areas of managing the control room:
- Roles & Responsibilities
- Adequate Information
- Fatigue Mitigation
- Alarm Management
- Change Management
- Lessons Learned
- Team Training
The responsibility of the pipeline operator is to ensure that internal policies and procedures align with the requirements of the external CRM Rule and relevant industry standards that are incorporated by reference. The specific requirement from PHMSA is that “each operator must have and follow written control room management procedures that implement the requirements of this section.”
This way, controllers and support personnel working in the control room can utilize the policies and procedures to monitor and control pipeline activity through the SCADA system in a manner that is compliant with the CRM Rule.
The challenge for today’s pipeline operators is how to build out a compliant control room in this era of social distancing, staggered shifts, and health concerns during COVID-19.
When taking this into account, start with the primary goal. The goal is to operate safely, strive for zero incidents, and to achieve compliance naturally in the course of control room personnel completing tasks in the control room. Now, work backward to how to achieve the goal.
- Do you need to create separate control rooms for A and B teams?
- Do you need to spread out consoles throughout the control room?
- Are you building out a 24/7 control room, which requires multiple shifts to ensure coverage?
- Do some personnel need to work from home and complete tasks remotely?
- Is your SCADA team equipped to support multiple work environments and shifts?
These are important questions to ask as you make key decisions about how to build out a DOT-compliant pipeline control room to support operations, especially in today’s environment.
Fortunately, PHMSA has recognized how challenging this period is for pipeline operators. In March, PHMSA issued a Notice of Stay of Enforcement and Notice of Enforcement Discretion for operators that may be potentially unable to comply with federal safety requirements because of COVID-19.
The notice was geared toward pipeline operations that are currently subject to PHMSA regulations. If your assets are not yet but will soon be under federal oversight, you should still consider maintaining documentation about any challenges experienced striving to achieve compliance and what measures were taken to ensure safety.
During this period of disruption, PHMSA is focused on ensuring that operators continue to comply with applicable pipeline safety regulations and “acting reasonably to use trained, non-impaired workers to perform operations, maintenance, and control room tasks.”
The next most important area of concern is how your operation will be handling leak detection.
Is Your Operation Performing Leak Detection?
The natural gas section of the CRM Rule (CFR 192) contains additional minimum requirements for “preventive and mitigative measures” that a pipeline operator must meet. This includes installing leak detection systems to help prevent a pipeline failure and to mitigate the consequences of a pipeline failure in a high consequence area (HCA).
Operators are required to base these additional measures on the threats identified for each pipeline segment. Operators are also encouraged to perform a risk assessment to identify additional measures to protect HCAs and to enhance their overall commitment to public safety.
Setting up a leak detection system includes a critical consideration of whether to install computerized pipeline modeling (CPM) to support pipeline safety. While typically associated with liquid pipelines, computerized monitoring is valuable for gas pipeline operators in the following ways:
- CPM can use statistical analysis to find patterns linked to a natural gas leak.
- CPM can perform statistical evaluation of pressure and flow in real-time.
- CPM can produce a calculation based on the inputs to help determine whether there is an actual gas leak.
Additionally, for natural gas operators of transmission lines, there is an additional requirement to perform leakage surveys. As outlined in CFR 192, PHMSA requires that leakage surveys of a transmission line be conducted “at intervals not exceeding 15 months, but at least once each calendar year.”
For transmission lines that transport gas without an odor or odorant to aid in leak detection, the requirements are more strict. In this case, leakage surveys using leak detector equipment must be conducted “at intervals not exceeding 7 1/2 months, but at least twice each calendar year” (for Class 3 locations) or “at intervals not exceeding 4 1/2 months, but at least four times each calendar year” (for Class 4 locations).
Find Support for Meeting PHMSA CRM Rule Requirements
The effective date of this portion of the Gas Gathering Rule is July 1st. While PHMSA has expressed an understanding of the difficult circumstances for pipeline operators, we still recommend taking necessary steps to drive toward compliance as your assets are brought under federal jurisdiction.
At the February meeting in Houston, PHMSA highlighted the main points of emphasis that are associated with the July 1st implementation date. View those items on Page 30 of this PHMSA presentation.
Specific to the pipeline control room, we recommend performing these critical reviews:
- Determine whether you need to stand up a new pipeline control room.
- Determine how you will support the control room to achieve compliance with the CRM Rule (Hours of Service, Alarm Management, recordkeeping, incident logging, audit preparation, etc.).
- Determine how you will perform leak detection to support pipeline safety.
EnerSys can help your operation adjust for this new operating reality. We offer a compelling combination of pipeline control room software (POEMS CRM Suite) and pipeline control room expertise to help your operation align with the PHMSA requirements for natural gas operations.
To find out more about how we can help your operation prepare for federal oversight, contact us today. We are available to help determine control room coverage given the new Gas Gathering Rule and to discuss how software can make this process easier.