July 2019, Vol. 246, No. 7


Pipeline Companies Oppose Some Proposed Mapping Requirements

By Stephen Barlas, Contributing Editor

WASHINGTON — The proposal from the PHMSA to force transmission and distribution pipelines to submit additional geospatial data to the National Pipeline Mapping System (NPMS) could cost the industry tens of millions of dollars in added expenses. 

Arick Sears, senior regulatory attorney, MidAmerican Energy Company, said the new reporting mandates for pipelines, if finalized, will cost his company $1 million. MidAmerican owns 12,860 miles of natural gas distribution main, 678,350 gas services, 688 miles of natural gas transmission pipeline and three Liquefied Natural Gas plants.

Paiute Pipeline Company, in its comments to the Pipeline and Hazardous Materials Safety Administration (PHMSA), said the new data collection requirements would substantially increase the number of pipeline attributes collected from four to nineteen.

“In Paiute’s case, the requested attributes reside in multiple databases/platforms outside of its Geographic Information System (GIS) and would require substantial data integration to provide the information requested in the geospatial formats specified by PHMSA,” wrote Mark Litwin, vice president and general manager of Paiute. “It is estimated this data integration activity will take several years to complete at a cost upward of $1 million.” 

The Pipeline Safety Act directs operators of pipeline facilities (except distribution and gathering pipelines) to submit geospatial data and technical data, such as design and material specifications, to PHMSA for use in the NPMS. PHMSA has collected data for the NPMS since 1998.  

The revised information collection described in PHMSA’s April 11, notice was first proposed in 2014 and modified in 2016. 

The first tranche of new data would be collected a year after whatever the PHMSA effective date becomes, if in fact the new data requirements are approved by the White House. Phase II information would be collected in the second year. 

Phase III would kick in in 2024 and transmission pipelines would have to submit positional accuracy of +/- 50 feet accuracy for all segments in: 1) Class 2, Class 3, or Class 4 areas; 2) within an HCA; 3) where there are one or more buildings intended for human occupancy or an identified site within the potential impact radius (PIR). All other gas pipeline segments must be mapped to a positional accuracy of +/- 100 feet.

MidAmerican’s Sears told the PHMSA in comments “the most efficient and cost-effective method of bringing data elements into compliance with the proposed standard is to update centerlines during scheduled in-line inspection runs. 

“Absent a critical emergency, MidAmerican finds it difficult to justify passing the additional expense on to its ratepayers,” Sears wrote in comments dated May 11.  “Accordingly, MidAmerican recommends that the data collection standard reinstate the original seven-year deadline for Phase-3 reporting.”

While the Phase III deadline is problematic for both transmission and liquid lines – the latter would have to submit data with a positional accuracy of +/− 50 feet – some elements in all three phases are controversial, including in-line inspection capability, which would be a Phase 1 requirement. 

On the one hand, Paiute said it has no problem submitting pipe diameter, wall thickness, pipe material, pipe grade, seam type, decade of installation, coated (yes/no), onshore/offshore, class location, and abandoned pipelines.

On the other hand, Paiute does not currently track in-line inspection capability in its GIS system. That is a Phase I requirement. 

“It is unclear how this attribute influences risk evaluation; the implication that a pipe segment that is “piggable” is less risky is not founded,” Paiute wrote to the agency. “To incorporate the geospatially referenced attribute for in-line inspection data capability for all transmission pipelines will be burdensome, costly, and time-consuming. The inline inspection capability would provide minimal practical utility, does not improve pipeline safety, or insight to pipeline risk and therefore does not justify the burden.” P&GJ

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