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PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION UNITED STATES DEPARTMENT OF TRANSPORTATION
WASHINGTON, DC
Docket No. PHMSA-‐2011-‐0023 Notice of Proposed Rulemaking
Pipeline Safety: Safety of Gas Transmission and Gathering Pipelines
COMMENTS OF THE PLASTICS PIPE INSTITUTE
The Plastics Pipe Institute (PPI) is the leading trade association representing more than 300 members and associates involved in the use of plastic pipe in our nation’s infrastructure including: plastic piping system manufacturers, resin producers, and plastic equipment manufacturers. Many of the members produce plastic pipe, fittings, and components used in our nation’s natural gas distribution network, and for a wide range of oil & gas gathering applications. Today polyethylene (PE) and polyamide (PA) piping represents more than 95% of all newly installed gas distribution piping. HDPE, PA and advanced spoolable composite piping represent a large portion of the oil & gas gathering market in North America. The manufacturers and products represented by PPI have a long, proven history of successful service in oil and gas gathering applications and provide the following advantages:
• No corrosion -‐ Corrosion in steel pipelines is becoming a more common problem for many operators with even greater environmental and cost consequences. HDPE, PA, and Spoolable composite pipelines are much less susceptible to corrosion.
• Rapid Installation -‐ Unlike conventional steel piping systems that are assembled at location from large quantities of straight lengths that must be short enough to fit on a truck bed, PE, PA, and spoolable composite pipe is manufactured in long lengths that result in rapid installation and completion.
• Improved Safety -‐ Pipe coils are lightweight and require little handling at the location. The reduction of connections means little time spent in the ditch. With the reduced manpower requirement and rapid completion, operators see vastly reduced safety risks.
• Heat fused or drastically reduced number of connections – PE and PA pipe may be joined by heat fusion providing a reliable, leak-‐free connection. With spoolable composites lengths up to 5,000 ft there are often no connectors, and for longer lengths relatively few connections are required virtually eliminating the potential for these types of leaks.
• Improved Flow Characteristics -‐ thermoplastic materials provide better flow characteristics than new steel pipe. Thermoplastics do not deteriorate in service, retaining these flow characteristics for the life of the pipe, unlike steel where typically designers have to allow for degrading flow characteristics in service.
• Remediation of Leaking Existing Pipelines – HDPE, PA, and spooled composite pipe is frequently pulled into existing pipelines as a rapid, low cost method for returning a line to full or even
increased operating pressure. There is minimal ground or right of way disturbance, and no reliance on the structural integrity of the existing failed line, which is used only as a convenient conduit. Many miles of failed pipeline have been remediated and returned to full service by this technique.
PPI opposes any changes to the 49 C.F.R. part 192 that may hinder or eliminate the use of PE, PA, or spoolable composite piping, thereby, reducing the overall safety of the gas gathering systems and discourage the use of new technologies.
PPI supports the efforts of PHMSA to update CFR 49 part 192 to reflect changes in gas transmission and gathering included in this notice of proposed rulemaking (NPRM), but the NPRM is overly ambitious, lacks proper industry involvement, and does not adequately address associated costs to the industry. PPI encourage PHMSA to consider finalizing only those portions of the NPRM that are not controversial, and then continue to work with the regulated community and the public on addressing the more difficult proposed changes, or withdraw those that do not meet industry standards.
Many areas of the NPRM require further clarification, and PPI provides suggested language where necessary. The following comments are submitted on behalf of PPI.
§ 192.3 Definitions
PPI believes that API RP 80 is a useful recommended practice developed through a consensus American National Standards Institute (ANSI)-‐accredited standards process. PPI respectfully requests that PHMSA continue to utilize API RP 80 for the purpose of establishing where production ends and where gathering begins and ends.
§ 192.8 How are onshore gathering lines and regulated onshore gathering lines determined?
PPI strongly opposes the extension of existing regulatory requirements for Type B gathering lines to Type A, Area 2 gathering lines in Class 1 locations, if the nominal diameter of the line is 8” or greater for non-‐metallic materials. This proposed extension of the regulations is arbitrary, conflicts with other portions of 49 CFR Part 192, and creates onerous requirements for gas gathering operators.
New Type A, Area 2 classification is Arbitrary
The selection of 8 inches as the cutoff for large diameter is arbitrary. No justification is provided for selecting this dimension as the cutoff point. HDPE up to 36 inches in diameter is used in gas gathering applications. In fact, more than 60% of the HDPE used in class 1 gas gathering applications is 8 inches or larger. HDPE is designed on a standard dimension ratio to ensure that its’ properties are consistent across dimensions. The dimension used to define the cutoff between small dimension and large dimension requires additional study.
Conflicts with other sections of the Code
The proposed Type A, Area 2 gathering lines applies to pipe 8 inch in diameter or greater, operating at 125 psig or higher. The proposed changes would make certain class 1 applications regulated thereby invoking current design rules (intended for class 3 and 4 gas distribution) and limitations on plastic piping that are in conflict.
-‐ §192.123 limits the maximum operating pressure for PE to 125 psi while the new regulation is applies to non-‐metallic operating at 125 psi or higher. This effectively means that no PE of 8 inches in diameter or greater could be used in Type A, Area 2
-‐ Currently PA-‐11 is limited in size to 4 inches in diameter in §192.123 so the new regulations would not apply to these products
-‐ Spoolable composite pipes are considered non-‐metallic. These products are commonly used in class 1 gathering applications, but are not currently recognized in 49 CFR Part 192 for regulated applications.
Requirements are unduly onerous
This rule would effectively limit the use of PE over 8 inches in diameter to gas gathering applications with a maximum operating pressure of less than 125 psig or require the use of larger diameter pipe to provide the same gas flow at the lower pressures. Many (50% of the total HDPE gathering market) large dimension PE gas gathering systems in operation today operate successfully at pressures above 125 psig designed using the design equation with a design factor of 0.63.
PPI believes the proposed rule to regulate Onshore Gathering Lines Type A, Non-‐Metallic, Area 2 (class 1 locations with a nominal diameter of 8 inches or greater) with an MAOP more than 125 psig will have a dramatic cost impact to gas gathering pipeline operators. PPI estimates that the design pressure limitation annual compliance cost to the industry to be approximately $140 MM.
By regulating Type A, Area 2, class1 non-‐metallic materials Section §192.59 is invoked and states that rework or regrind material is not allowed in plastic pipe produced after March 6, 2015. It is a common industry practice in the gas gathering to use HDPE with up to 30% clean rework material. The imposition of no rework or regrind material in gas distribution has already caused significantly increased costs for manufacturers. Extension of those requirements in gas gathering would have a large financial impact to manufacturers, hence operators, and would be done with no technical justification. PPI estimates that this rulemaking would increase costs by more than $37 MM annually due to the restriction on rework. (See analysis in Appendix A).
Overall more than 1,000 miles of 8 inch and larger PE pipe is installed for gas gathering applications annually. We estimate the total annual compliance costs for the industry to be over $177 million. This is above the $100 million threshold and we believe would pose undue burden on industry operators and
would require further regulatory review by Office of Management and Budget (OMB). The costs were determined based on PPI statistical data for gas gathering pipelines with the following assumptions:
·∙ We estimate the newly regulated lines to be at least 30% of the total industry reported energy piping sales. We estimate that at least 50% of the gathering pipes are designed with an MAOP equal to the maximum design pressure based on PE4710 design factor (DF) of 0.63
·∙ To achieve equivalent gas flow with the 125 psig design pressure limitation for regulated thermoplastic pipes, the NPRM will require PE pipes currently designed to SDR 13.5 or lower to be upsized or switched to other more expensive materials
·∙ The total cost of eliminating rework is at least $0.30/lb which will be passed through to industry operators
·∙ Industry cost for eliminating rework is based on the large volume of rework that will have to be sold in lower resin cost markets and to scrap recyclers
The additional engineering, procurement, and construction costs associated with these newly regulated lines are not part of this analysis. Therefore, it is anticipated that the total annual compliance costs for the industry will far exceed the $177 million.
As noted in the NPRM preamble, the GAO released a report (GAO Report 14-‐667) to address the increased risk posed by new gathering pipeline construction in shale development areas. GAO recommended that a rulemaking be pursued for gathering pipeline safety that addresses the risks of larger-‐diameter, higher-‐pressure gathering pipelines, including subjecting such pipelines to emergency response planning requirements that currently do not apply. The intent of this code change was to regulate larger diameter, high-‐pressure gathering lines, not to eliminate a widely used material from those applications. While onerous, we can agree that the requirement to develop procedures, training, notifications, and carry out emergency plans as described in § 192.615 may improve safety, but the GAO report recommendation had no intention of limiting the materials used in gas gathering.
Based on the argument that this proposed extension of the regulations is arbitrary, conflicts with other portions of 49 CFR Part 192, and creates onerous requirements for gas gathering operators, PPI recommends striking the requirement for non-‐ metallic materials in Type A, Area 2 as shown below:
Type Feature Area Safety buffer A —Metallic and the
MAOP produces a hoop stress of 20 percent or more of SMYS. If the stress level is unknown, an operator must determine the stress level according to the applicable provisions in subpart C of this part. —Non-metallic and the MAOP is more than 125 psig
Area 1. Class 2, 3, or 4 location (see § 192.5). Area 2. Class 1 location with a nominal diameter of 8 inches or greater.
None –metallic
Until such time that PHMSA adopts the relevant standards and applies the proper design formula and assess the necessary design limitations for plastic gas gathering, non-‐metallic materials should be struck from the proposed rulemaking.
Alternative Proposal
In this NPRM PHMSA has not taken any steps to adopt by reference the most recent standards relating to non-‐metallic pipelines now commonly used in oil & gas gathering systems including API 15S and ASTM F2619-‐13. As a result of this apparent omission, the NPRM as structured would indefinitely prohibit the use of widely used non-‐metallic pipelines in gathering operations as these type of lines are not intended to meet all the current requirements of Part 192. If PHMSA intends to move forward with the new Type A, Area 2 designation for non-‐metallic materials operating above 125 psi with a diameter of 8 inches or greater, PPI recommends the following additions to other parts of 49 CFR Part 192 to account for the new regulated gas gathering requirements (new sections are shown in red text):
§192.7 What documents are incorporated by reference partly or wholly in this part?
(5) API Specification 15S, “Spoolable Reinforced Plastic Line Pipe”, 2nd edition, March 2016
(20) ASTM/ ANSI F2619-‐13, “Standard Specification for High-‐Density Polyethylene (PE) Line Pipe ,“ (ASTM F2619013), IBR approved § 192.121(c)
§192.9 What requirements apply to gathering lines?
(f) For a plastic pipeline that becomes regulated after [insert effective date] the maximum allowable operating pressure is determined in accordance with the design equation in §Part 191.121,
(1) the operator shall monitor the class locations along the pipeline as required by §192.613. If an increase in population density indicates a change in class location to a Class 3 or 4 the operator shall confirm or revise the maximum allowable operating pressure in accordance with §192.121(b) and §192.121(c).
§192.59 Plastic pipe
(d) Rework and/or regrind material is not allowed in plastic pipe produced after March 6, 2015 used under this part.
(1) paragraph (d) of this section does not apply to plastic pipe used for gas gathering in class 1 or 2 locations
§ 192.63 Marking of Materials.
(2) Except as provided in paragraph (f) of this section, plastic pipe and components manufactured after [INSERT EFFECTIVE DATE OF FINAL RULE], must be marked in accordance with ASTM F2897 (incorporated by reference, see § 192.7) in addition to the listed specification.
(f) Paragraph (e)(2) of this section does not apply to pipe produced to ASTM F2619-‐13 used as gas gathering lines in class 1 or 2 locations.
§192.121 Design of Plastic Pipe (Combined with section §192.123 as proposed in PHMSA-‐2014-‐0098)
(c)(2) For PE pipe produced after [INSERT EFFECTIVE DATE], a DF of 0.40 may be used in the design formula, provided:
(i) The design pressure for plastic pipe may not exceed the pressure as determined by the design equation in §192.121(a);
(ii) The material designation code is PE2708 or PE4710;
(iii) The pipe has a nominal size (IPS or CTS) of 24 inches or less; and
(iv) The wall thickness for a given outside diameter is not less than that listed in the following table:
(d) (2) For PA pipe produced after [INSERT EFFECTIVE DATE], a DF of 0.40 may be used in the design formula, provided:
(i) The design pressure for plastic pipe may not exceed the pressure as determined by the design equation in §192.121(a)
(3) For PE pipe produced after [INSERT EFFECTIVE DATE] used in gas gathering lines in class 1 or 2 locations, a design factor of
(ii) 0.63 for PE 4710 (dry gas), or
(iii) 0.50 for PE 4710 (when more than 2% liquid hydrocarbons are present)
may be used, provided:
(1) The design pressure does not exceed the pressure determined in §192.121 design equation
(2) Plastic pipe may not be used where operating temperatures of the pipe will be:
(ii) Below −29 °F (−20 °C), or −40 °F (−40 °C) if all pipe and pipeline components whose operating temperature will be below −29 °C (−20 °F) have a temperature rating by the manufacturer consistent with that operating temperature; or
(iii) Above the temperature at which the HDB used in the design formula under §192.121(b) is determined.
(3) The material is a PE 4710 as specified within ASTM F2619-‐13 (incorporated by reference, see §192.7)
Operators have used non-‐metallic materials in constructing gathering lines for decades, and have used HDPE in these applications for 60 years. As the technology has improved, non-‐metallic lines have been utilized in larger diameters and at higher pressures in a variety of operating scenarios, particularly in Class 1 locations.
Plastic gathering lines are far more corrosion resistant to water-‐borne hydrogen sulfide, CO2, organic acid components of oils and erosion by produced solids than nearly any steel alloy lines. Given that corrosion, erosion and abrasion are causes of a majority of oilfield equipment damage, these products are some of the best corrosion preventative solutions to prevent leaks, spills and gathering line failures. In addition, plastic pipelines also sharply reduce cost by rapid deployment of spooled lines via surface, plowed or trenched installation. These pipelines can be laid in a fraction of line, decreasing construction disturbances of urban and wildlife areas.
Issue with Repair of Existing Lines
Despite the benefits of plastic pipe for gathering lines, as a result of this proposal, previously installed non-‐metallic material pipe will become functionally obsolete to the extent there is ever a need to repair them. For example, they will not be able to meet the corrosion requirements found in Subpart I, given that the
very nature of the material(s) used is not susceptible to corrosion. This could cause a ripple effect through the gathering industry, causing operators to cease the use of non-‐metallics in pipelines that are 8-‐inches or greater, and possibly smaller. This will impact operators, manufacturers and product suppliers, both directly and indirectly, including increasing the costs of gathering projects going forward simply due to the use of steel over the more economic and, by all measure, safe, non-‐metallic materials.
§ 192.285 Plastic pipe: Qualifying persons to make joints
PHMSA has determined that compliance requires that pipeline qualification records are complete and accurate. The proposed rule would add a new paragraph § 192.285(e) to require each operator of transmission pipelines to make and retain for the life of the pipeline records demonstrating plastic pipe joining qualifications in accordance with this section.
(e) For transmission pipelines, records demonstrating plastic pipe joining qualifications in accordance with this section must be retained for the life of the pipeline.
This wording is unclear. Proposed new wording …
(e) For transmission pipelines, records demonstrating the qualifications of persons joining plastic pipe at the time of making those joints in accordance with this section must be retained for the life of the pipeline.
PPI appreciates the opportunity to comment on the above-‐referenced Notice of Proposed Rulemaking and looks forward to receiving the requested information, and updates to the final rule.
Should you have any questions regarding these comments or about the PPI in general, please do not hesitate to call me at 763-‐691-‐3312 or [email protected].
Respectfully submitted,
Randall Knapp
Director of Engineering -‐ EPSD