What is the New Valve Rule?

 

PHMSA's New Valve Rule Has Hints of PSMS in it.  

It might be my imagination, but as I reviewed the valve rule I began to see various elements or concepts from API RP-1173 – Pipeline Safety Management Systems (PSMS) that found their way into this new rule. 

What is the new valve rule?

Starting from October 5, 2022, the "Valve Rule" by PHMSA went into effect.

Officially known as the "Pipeline Safety Requirement of Valve Installation and Minimum Rupture Detection Standards." This comprehensive rule encompasses various design and performance standards that pertain to the installation, operation, maintenance, and spacing of rupture-mitigation valves (RMVs) or alternative equivalent technologies. It specifically applies to newly constructed or completely replaced onshore pipelines of large diameter gas transmission, Type A gathering, and hazardous liquid pipelines.

How Does the New Valve Rule Relate to PSMS?

As I delved into the details of the valve rule, I couldn't overlook the striking resemblance between certain elements and concepts found in API RP-1173 - Pipeline Safety Management Systems (PSMS).

The new valve rule demonstrates a clear connection to Pipeline Safety Management Systems (PSMS). Upon closer examination, it becomes apparent that the valve rule incorporates key principles and concepts from PSMS. These include considerations for risk management, operational controls, maintenance procedures, and overall safety practices.

"This approach feels right to me. It is driven by risk, it is not overwhelming, and it is not terribly controversial."

Let's explore these requirements in a more cohesive manner:

OPERATING PROCEDURES

Under the new rule, operators are mandated to:

• Respond promptly to identified ruptures by closing RMVs for complete shut-off and segment isolation within a maximum of 30 minutes after rupture identification.
• Implement emergency operations, including emergency shutdown procedures.

EMERGENCY PREPAREDNESS AND RESPONSE

The rule necessitates operators to:

• Revise their emergency plans to establish immediate and direct communication with 9-1-1 emergency call centers or coordinating government officials upon notification of potential ruptures.
• Identify response resources and interfaces, ensuring effective coordination with local emergency responders.

INCIDENT INVESTIGATION, EVALUATION, AND LESSONS LEARNED

Operators are obligated to:

• Conduct thorough investigations and reviews following ruptures.
• Incorporate the insights gained from these investigations into their practices and procedures.
• Review their personnel training and qualification programs related to design, construction, testing, maintenance, operations, and emergency procedures.
• Perform post-event reviews of incidents, accidents, or failures involving RMV closures to ensure compliance with the rule's performance objectives and to apply lessons learned throughout their systems.

By addressing these areas comprehensively, the new valve rule promotes enhanced safety, efficient emergency response, and continuous improvement within the pipeline industry.

 

How does this help?

By aligning with PSMS, the valve rule emphasizes a holistic approach to pipeline safety management.

It recognizes the importance of implementing comprehensive systems and protocols to prevent ruptures and ensure the integrity of pipeline operations.

In conclusion, the adoption of PSMS principles in the valve rule promotes consistency and harmonization within the industry. It establishes a common framework for pipeline operators to follow, fostering a culture of safety and standardization.

I think we may see other PSMS elements or concepts being codified in this manner. We have seen Management of Change (MOC) revisions by way of the Transmission Rule. We will also be seeing MOC mandates for distribution operators by way of the PIPES Act.

While it may be a mere coincidence, it is fascinating to witness the evident influence of PSMS in shaping this new rule. As presented above, I do see bits and pieces of PSMS being embodied in new pipeline regulations, however. This approach feels right to me. It is driven by risk, it is not overwhelming, and it is not terribly controversial.

Coincidence? Perhaps!