Operations & Maintenance Enforcement Guidance Part 192 Subparts L and M



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Enforcement Guidance

O&M Part 192




Revision Date

09-28-2011




Code Section



§192.745



Section Title

Valve Maintenance: Transmission Lines




Existing Code

Language

(a) Each transmission line valve that might be required during any emergency must be inspected and partially operated at intervals not exceeding 15 months, but at least once each calendar year.

(b) Each operator must take prompt remedial action to correct any valve found inoperable, unless the operator designates an alternative valve.



Origin of Code

Original Code Document, 35 FR 13248, 08-19-1970




Last Amendment

Amdt. 192-93, 68 FR 53895, 09-15-2003




Interpretation

Summaries




Advisory Bulletin/Alert Notice Summaries


Advisory Bulletin ADB-02-03, Gas and Hazardous Liquid Pipeline Mapping.

This bulletin is issued to gas distribution, gas transmission, and hazardous liquid pipeline systems. Owners and operators should review their information and mapping systems to ensure that the operator has clear, accurate, and useable information on the location and characteristics of all pipes, valves, regulators, and other pipeline elements for use in emergency response, pipe location and marking, and pre-construction planning. This includes ensuring that construction records, maps, and operating history are readily available to appropriate operating, maintenance, and emergency response personnel.



Alert Notice, ALN-89-02, Results of OPS-conducted investigation of San Bernardino, CA, 05-12-89 train derailment; each gas/liquid operator should test check valves.

Alerting each gas transmission and hazardous liquid operator of the need to test check valves located in critical areas to assure that they close properly.





Other Reference Material

& Source

GPTC Guide Material is available.





Guidance Information





  1. The operator must identify the valves on the pipeline system that need to be operated during an emergency situation.

  2. The operator must establish, and periodically review, a master list of emergency valves.




  1. ESD valves are emergency valves, although they may be shown on a separate list and tested and inspected as part of the ESD system.

  2. The operator must have written procedures for emergency valves.

  3. Operator must inspect and partially operate all emergency valves within the required time intervals of §192.745.

  4. Operator should use specific valve manufacturer's recommendations to develop an appropriate maintenance program.

  5. Maintenance discrepancies identified during valve inspections must be addressed and remedial actions documented.

  6. Valves should be identified with a number or tag, which should also be referenced on the appropriate maps.

  7. Facilities installed or modified after March 12, 1971 should be protected from tampering and damage (§192.179(b)(1)).

  8. Remotely operated valves must be partially operated.

  9. Regulated gathering lines may have emergency valves that are outside of the regulated area. These valves must be included on the emergency valve list.

  10. Examples of emergency valves may include: valves that are part of emergency shutdown in a compressor station; mainline valves for regulatory spacing requirements; side tap valves to isolate laterals or interconnects; blowdown valves; crossover valves; storage well side gate valves; valves that isolate stations; an inlet or outlet to measurement or regulator station.

  11. Slam shuts, check valves, and other devices used as emergency valves must be inspected per the requirements of this part.





Examples of a Probable

Violation




  1. Valves required to operate during an emergency were not included on the emergency valve list.

  2. Operator did not inspect or partially operate some or all of the valves on the emergency valve list.

  3. The operator(s) inspection interval for some or all valves was longer than required in §192.745.

  4. A valve did not operate during a field inspection.

  5. Valves not properly identified with a tag or number.

  6. Valves not secure and protected from tampering.

  7. Operator did not adequately define “partial operation” of valve in procedures.

  8. The operator did not have, or follow, written procedures for inspecting and operating emergency valves.

  9. When an emergency valve became inoperable, and it could not be repaired promptly, the operator did not designate an alternative valve.





Examples of Evidence





  1. Emergency valve list.

  2. Pipeline schematics.

  3. Station drawings.

  4. ESD records.

  5. Operator(s) O&M procedures.

  6. Documented statements from the Operator.

  7. Photographs.

  8. Manufacturer’s valve documentation.

  9. Valve maintenance and inspection records.

  10. Valve repair records.





Other Special Notations








Enforcement Guidance

O&M Part 192




Revision Date

09-28-2011




Code Section



§192.749



Section Title

Vault Maintenance




Existing Code

Language

(a) Each vault housing pressure regulating and pressure limiting equipment, and having a volumetric internal content of 200 cubic feet (5.66 cubic meters) or more, must be inspected at intervals not exceeding 15 months, but at least once each calendar year, to determine that it is in good physical condition and adequately ventilated.

(b) If gas is found in the vault, the equipment in the vault must be inspected for leaks, and any leaks found must be repaired.

(c) The ventilating equipment must also be inspected to determine that it is functioning properly.

(d) Each vault cover must be inspected to assure that it does not present a hazard to public safety.



Origin of Code

Original Code Document, 35 FR 13248, 08-19-1970




Last Amendment

Amdt. 192-85, 63 FR 37500, 07-13-1998



`

Interpretation

Summaries




Advisory Bulletin/Alert Notice Summaries





Other Reference Material

& Source

GPTC Guide Material is available.

The 1994 MOA between OSHA and DOT.

Letter to the head of the Virginia Commission regarding vaults.





Guidance Information





  1. Only relates to vaults containing pressure regulating or pressure limiting equipment. Does not apply to vaults containing other equipment.

  2. The operator must have written procedures for accessing and inspecting vaults.





Examples of a Probable

Violation




  1. The lack of procedures is a violation of §192.605.

  2. The lack of records is a violation of §192.603.

  3. The operator did not follow written procedures for inspecting vaults.

  4. Inspection of the vault is not made in the required intervals.

  5. The operator did not repair leaks that were found.

  6. The vault ventilation equipment is not functioning properly.

  7. The vault cover presented a hazard to public safety, such as no locking device to prevent unauthorized access to the vault.





Examples of Evidence





  1. Operator written procedures.

  2. Inspection records.

  3. Repair procedures.

  4. Repair records.

  5. Photographs.

  6. Vault physical dimensions.

  7. The lack of procedures or records.





Other Special Notations








Enforcement Guidance

O&M Part 192




Revision Date

09-28-2011




Code Section



§192.751



Section Title

Prevention of Accidental Ignition




Existing Code

Language

Each operator shall take steps to minimize the danger of accidental ignition of gas in any structure or area where the presence of gas constitutes a hazard of fire or explosion, including the following:

(a) When a hazardous amount of gas is being vented into open air, each potential source of ignition must be removed from the area and a fire extinguisher must be provided

(b) Gas or electric welding or cutting may not be performed on pipe or on pipe components that contain a combustible mixture of gas and air in the area of work

(c) Post warning signs, where appropriate



Origin of Code

Original Code Document, 35 FR 13248, 08-19-1970




Last Amendment




Interpretation

Summaries


Interpretation: PI-ZZ-043 Date: 05-17-1993
The following response is regarding whether the Occupational Safety and Health Administration (OSHA) had taken action in response to our letter of March 30, 1988, wherein we requested that OSHA abstain from issuing rules on certain pipeline safety operations. OSHA issued final regulations (54 FR 45894; October 31, 1989) notwithstanding our letter. However, OSHA later issued a letter of interpretation to their field offices determining that OSHA regulations in 29 CFR §§1926.651(g) (1) (iii) and 1926.651(g)(2)(i) are preempted by our pipeline safety standards. The interpretation ensued from a settlement agreement between OSHA and the American Gas Association following a petition filed in the U. S. Court of Appeals for the District of Columbia (Case No. 89-1764). A copy of the settlement agreement is enclosed.
Interpretation: PI-ZZ-044 Date: 05-17-1993
Subsection 1926.651(g)(1)(iii) of the OSHA excavation standard requires that the concentration of flammable gas be maintained below 20 percent of the lower explosive limit. This provision is intended to prevent fires and explosions that could result from explosive concentrations of flammable gases. The OPS regulation at 49 CFR §192.751 addresses the same safety problem, requiring pipeline operators to "minimize the danger at accidental ignition of gas in any structure or area where the presence of gas constitutes a hazard of fire or explosion.” This OPS regulation therefore preempts enforcement of Subsection 1926.651(g)(1)(iii) against employers who are subject to the DOT standard.


Interpretation: PI-ZZ-039 Date: 07-19-1990

(Preemption of Certain OSHA Excavation Standards)


Section 4(b)(1) of the Occupational Safety and Health Act (OSH Act) provides that OSHA does not apply to working conditions with respect to which other Federal agencies "exercise statutory authority to prescribe or enforce standards or regulations affecting occupational safety or health."
§192.751 addresses the same safety problem, requiring pipeline operators to "minimize the danger at accidental ignition of gas in any structure or area where the presence of gas constitutes a hazard of fire or explosion." This OPS regulation therefore preempts enforcement of Subsection §1926.651(g)(1)(iii) against employers who are subject to the DOT standard.
Interpretation: PI-85-002 Date: 03-20-1985
In 49 CFR Part 192, our goal is to set standards for what must be accomplished leaving the operator discretion to develop specific methods of complying that fit conditions on the pipeline and permitting the use of appropriate new, or improved technology. There are a number of guidelines which provide specific ways to remove “each potential source of ignition” as required by §192.751, including the ones cited in your letter.
Interpretation: PI-ZZ-034 Date: 01-10-1984
Knowing that the natural gas distribution system's odorant will be absorbed by the passage of natural gas through soil if a leak occurs underground, what duty does an operator have under sec. 192.751 to post warning signs to minimize the danger of accidental ignition of gas in occupied structures alongside of which an underground service line runs? For example, does the operator have a duty to warn the occupant-customer that digging near the service line might cause a leak that won't be detectable by smell?
There are no specific requirements relevant to the circumstances you describe.



Advisory Bulletin/Alert Notice Summaries





Other Reference Material & Source

GPTC Guide Material is available.




Guidance Information





  1. Applicable procedures should be reviewed during an inspection.

  2. The operator must have procedures.

  3. Typically, these procedures prohibit, restrict, and/or control the following activities where the presence of gas might constitute a fire or explosion hazard:

    1. smoking/open flames

    2. operating internal combustion engines

    3. activities that could generate static electricity or electrical arcing

    4. welding, cutting, and other hot work

    5. using non-intrinsically safe equipment, unless monitoring for the presence of a hazardous atmosphere

    6. working on compressor engine or appurtenances

    7. working inside pipeline compressor and regulator buildings

    8. the use of spark-producing hand tools; etc.

    9. the means and locations for venting of gas. E.g., the presence of overhead power lines (CPF 1-2008-1007M)

    10. purging and blow down operations

  1. Operator’s performance of procedures should be observed, if feasible.

  2. Review the operator’s hot work permit, if available.

  3. Applicable records should be reviewed to assure steps were taken to prevent accidental ignition such as:

    1. hot work/equipment permits

    2. proper grounding

    3. monitoring for presence of a hazardous atmosphere

    4. gas source isolation (positive shut-off) purge

    5. lock-out/tag-out

    6. warning signs, where appropriate

    7. written purge or blow down plans

  1. A fire extinguisher must be provided when a hazardous amount of gas is being vented.

  2. Maintenance and construction activities conducted where gas may be present should prohibit the use of tools, materials, fabrics, slings, etc. that may produce static discharge.

  3. Operator should take precautions to minimize the potential of accumulating gas.

  4. Spark-arresting techniques should be applied under certain hazardous conditions.

  5. Consideration of all sources of ignition should be included in safety plans.

  6. Operators should maintain restricted access to hazardous areas, including safety zones for vehicular and air space domains.

  7. The operator should consider environmental factors such as weather conditions and terrain when venting gas.





Examples of a Probable

Violation




  1. The lack of procedures is a violation of §192.605.

  2. The lack of records is a violation of §192.603.

  3. The operator did not follow written procedures.

  4. Appropriate warning signs are not posted.

  5. When venting gas, fire extinguishers were not present.

  6. Potential sources of ignition are not removed, or gas is not properly vented outside of a facility.

  7. Evidence that ignition took place.

  8. Use of improper tools and equipment.

  9. Failure to monitor for the presence of a hazardous atmosphere.





Examples of Evidence





  1. Operator’s written procedures.

  2. Observed or documented violation of ignition prevention procedures.

  3. Photographs.

  4. Incident reports.

  5. Hot work permits.

  6. Documented statements by operator personnel.

  7. The lack of procedures or records.





Other Special Notations





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