In October 2019, PHMSA published Part 1 of the Gas Gathering Rule focused on pipeline safety: “Safety of Gas Transmission Pipelines: MAOP Reconfirmation, Expansion of Assessment Requirements, and Other Related Amendments.”
Included in the Gas Transmission Final Rule was the introduction of new terminology to help pipeline operators validate the safety of pipeline assets that are being brought under federal jurisdiction. The terminology is Traceable, Verifiable, & Complete (TVC) Records.
Background of TVC Records in Gas Gathering Rule
TVC Records was a concept introduced by NTSB in response to their investigation of the San Bruno incident that occurred in September 2010 when a natural gas pipeline owned by Pacific Gas & Electric (PG&E) exploded in a residential neighborhood.
The goal of introducing TVC Records in the Gas Gathering Rule is to create accountability of natural gas pipeline assets through proper recordkeeping to support pipeline safety measures.
Specific to the Gas Transmission Final Rule, PHMSA noted that operators need to report exceedances of the maximum allowable operating pressure (MAOP) of gas transmission pipelines. The final rule requires operators to re-confirm the MAOP of particular segments.
Operators should also gather any necessary material property records when the records needed to substantiate the MAOP are not traceable, verifiable, and complete. This includes previously untested pipelines (e.g. “grandfathered” pipelines) that operate at or above 30 percent of specified minimum yield strength (SMYS).
For operators that do not have access to records on particular segments of pipe, PHMSA created a distinction of “insufficient” material property records. This is when a pipeline’s physical material properties and attributes are not documented in traceable, verifiable, and complete records. In this case, PHMSA recommends obtaining the following physical material property and attribute records:
- Pipeline segment’s diameter
- Wall thickness
- Seam type
- Grade (minimum yield strength and ultimate tensile strength of the pipe)
- Charpy V-notch toughness values
The key for pipeline operators that do have access to records on their pipeline assets is to ensure the records are traceable, verifiable, and complete.
Identifying TVC Records of Gas Pipeline Assets
In February 2020, PHMSA held a Gas Rule Public Meeting in Houston to discuss safety issues related to gas transmission pipelines. Included in the discussion were additional clarifications on what qualifies as TVC Records.
– Traceable records can be clearly linked to original information about the pipeline segment or facility.
– Examples include pipe mill records (e.g. mechanical and chemical properties), purchase requisition, as‐built documents indicating MPYS, seam type, wall thickness, and diameter.
– PHMSA recommends paying careful attention to records transcribed from original documents as they may contain errors. Information from a transcribed document, in many cases, should be verified with complementary or supporting documents…
– Verifiable records are those in which information is confirmed by other complementary but separate documentation.
– Examples include pressure testing of a segment complemented by pressure charts or field logs, purchase order to a pipe mill with pipe specifications, and the specs verified by a metallurgical test of a coupon pulled from the same pipeline segment.
– PHMSA has clarified that, in general, the only acceptable use of an affidavit would be as a complementary document. This document would need to have been prepared and signed at the time of the test or inspection by a qualified individual who observed the test or inspection being performed.
– Complete records are finalized by evidence such as a signature, date, or other appropriate markings (e.g. corporate stamp or seal).
– Examples include a complete pressure testing record that identifies a specific segment of pipe, who conducted test, the duration of the test, medium, temperatures, accurate pressure readings, and elevation information.
– PHMSA has cautioned that a record that cannot be specifically linked to an individual pipeline segment is not a complete record for that segment. Additionally, incomplete or partial records are not an adequate basis for establishing MAOP.
Examples of TVC Records
In the Gas Transmission Final Rule published in October 2019, PHMSA cited examples of TVC records that can help pipeline operators verify their assets.
– A typical pipeline mill test report must be traceable, verifiable, and complete in the following manner.
- Traceable mill test: must be dated in the same time frame as construction or have some other link relating the mill record to the material installed in the pipeline, such as a work order or project identification.
- Verified mill test: must be confirmed by the purchase or project specification for the pipeline or the alignment sheet with consistent information. For example, verified by independent records.
- Complete mill test: must be signed, stamped, or otherwise authenticated as a genuine and true record of the material by the source of the record or information. For example, the pipe mill, supplier, or testing lab.
– A typical pressure test record must be traceable, verifiable, and complete in the following manner.
- Traceable pressure test record: must identify a specific and unique segment of pipe that was tested (such as mileposts, survey stations, etc.) or have some other link relating the pressure test to the physical location of the test segment. For example, a work order, project identification, or alignment sheet.
- Verified pressure test record: must be confirmed by the purchase or project specification for the pipeline or the alignment sheet with consistent information. For example, verified by independent records.
- Complete pressure test record: must identify a specific segment of pipe, who conducted the test, the duration of the test, the test medium, temperatures, accurate pressure readings, elevation information, and any other relevant information.
- Conversely, an incomplete record might reflect that the pressure test was initiated, failed, and restarted without conclusive indication of a successful test.
July 2020: PHMSA Response to MAOP Concerns
On July 1, 2020, PHMSA released a response to industry concerns contained in Part 1 of the Gas Gathering Rule (Gas Transmission Final Rule). The response was officially published to the federal registry on July 6.
PHMSA sought to address and clarify certain requirements for recordkeeping and the applicability of MAOP reconfirmation that were contained in the final rule.
For background on this response, four industry associations (AGA, API, APGA, and INGAA) requested that PHMSA (a) clarify that the recordkeeping requirement only applies to
transmission pipelines and (b) limit the applicability of the MAOP reconfirmation requirements to those pipeline segments that do not have a traceable, verifiable, and complete pressure test record.
PHMSA granted the requests from the associations and amended the Gas Transmission Final Rule to implement the changes.
1. PHMSA clarified that the recordkeeping requirements only apply to gas transmission pipelines. PHMSA noted that this request aligns with the final rule’s original intent, the
change requested is appropriate, and does not compromise safety.
2. PHMSA clarified that operators do not need to re-establish MAOP if they already have TVC pressure test records and were missing other records cited in the final rule.
PHMSA granted the request to limit the applicability of the MAOP reconfirmation requirements to those pipeline segments that do not have TVC pressure test records. PHMSA determined that the request from the associations to limit the applicability of the MAOP reconfirmation
requirements will not compromise safety because the availability of TVC pressure test records allows an operator to establish the MAOP for the pipeline segment without the need for reconfirmation.
In their response, PHMSA noted that the Gas Transmission Final Rule focused on the actions an operator must take to reconfirm the MAOP of previously untested natural gas transmission pipelines and pipelines lacking certain material or operational records. It also required operators to reconfirm the MAOP of those segments and gather necessary material property records in situations where the records needed to substantiate the MAOP are not traceable, verifiable, and complete.
PHMSA has clarified that if an operator has pressure test records for segments of pipe, that will suffice to meet the TVC records requirements.
Find Support With the Gas Transmission Final Rule
The Gas Transmission Final Rule contained within the Gas Gathering Rule contains specific language that operators need to be aware of when gathering together TVC Records of applicable pipeline assets.
Operators that are new to PHMSA regulations or have been challenged gathering the appropriate records in the time since the final rule was published in October 2019 may need assistance walking through this process.
Our team of experts can help fill the gap for your operation through a consultation to discuss your pipeline operation. We can help identify the application of PHMSA rulemaking to your operation and discuss the resulting implications for managing a PHMSA-compliant pipeline control room.