Date: November 26, 2008

Summary of AGA Supplemental Gas Committee Project

LNG Safety Valve Inspection and Testing Frequency Study

Background Information:
The Supplemental Gas Committee (SGC) first discussed in 2000 members concerns about the annual
testing frequency for LNG facility safety relief valves (SVs) required by DOT in 49 CFR 193. The consensus of
the Committee was that a data collection would be the SGCs first step in building a case for reducing the
frequency, to present to the regulatory agencies for their consideration. Since that initial discussion, LNG
Benchmarking surveys gathered safety relief valve testing information in 2001, and each year from 2003-2006.
Each years benchmarking was slightly revised, with the goal to refine the questions to gather the most productive
data. Several SGC members analyzed the benchmarking data, reported survey results to SGC members at Spring
and Fall SGC meetings, and researched various codes and standards (NFPA 58, NFPA 59, NFPA 59A, ASME,
API, 49 CFR 192, 49 CFR 195, etc.) for safety valve testing requirements and guidelines.
After a couple years of discussion and analysis of benchmarking data, the SGC determined that the
committees efforts should be identified as a SGC Project in 2005. The 2008 SGC Project Report defined the
safety valve project as follows:
SGC members will utilize existing LNG Safety Valve Benchmarking data and develop additional data that
can be presented to PHMSA to consider relaxing the annual testing frequency of LNG safety valves. This project
will address the issue of over burdensome annual testing with the goal to align more with other industries SV
testing practices

Executive Summary:
Based on the quality and content of the data collected, a consensus decision by the SGC members at the
Spring 2008 committee meeting in Phoenix, AZ, was made to table the project, until such a time that (i) a more
consistent picture of LNG facility SV testing could be assembled through detailed analysis of available data, and
(ii) the regulatory environment would be more open to the SGC appeal to PHMSA, giving it a higher probability of
success. It is the intention of the SGC to retain all the survey results and research collected. The SGC intends to
monitor the regulatory environment for developments that suggest that the SGC should reactivate
the project.
A more detailed summary of the LNG Benchmarking results, committee member comments, and general
industry guidelines is provided below.

Detailed Data Collection Results and Committee Comments:

1. 2006 SV Benchmarking Result Highlights:
o 20 companies participated
o 25 facilities were reported
o Average number of SVs tested - 126
o Average cost per facility to test - $34,600
o 10% of all valves tested did not meet ASME test criteria (releasing within set tolerance; reseating)
o 5% of all valves tested did not meet DOT test criteria (with tolerance 10%)
o Only one respondent indicated that the failure of a SV caused a release which caused a plant shutdown.
Research into this reported occurrence determined that the valve did not fail to release, but operated at its
design pressure set point. The operation of the SV was caused by an actual over pressurization of a system
due to a control system logic error.
o No respondents reported a SV ever causing an injury to an employee
2. Benchmarking data had inconsistencies. Survey responses in 2006 were received on 25 facilities, of the nearly 110
LNG facilities country wide. Not all survey questions were answered by every respondent, and several questions
produced conflicting answers by the respondents.
3. Some Benchmarking participants reported a high rate of failures during the testing of safety valves as defined by
the ASME and DOT criteria listed in the Benchmarking surveys. Although 10% of the SVs reported failed to
meet ASME criteria without adjustment, and 5% did not meet DOT criteria, it is important to recognize that the

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 SVs may have failed to open within the +/- lifting set point criteria, may have failed to open at all, or may have failed
to reseat fully . More precise information on testing methods, testing results, and circumstances will be needed to go
forward.
4. A question of whether SRVs ever caused plant incidents was never cleanly answered; more detail is needed in a
future survey or questionnaire.
5. Several SGC members made the point that the 49 CFR 192 and 49 CFR 195 requirements for annual testing apply to
facilities and pipelines that are located in areas accessible to the public. Therefore, if over-pressurization and failure
of the pipeline were to occur, the general public safety would be at risk. However, LNG facilities are secure, fenced
facilities that must meet siting requirements in 49 CFR 193 to prevent any flammable gas concentrations (in excess
of one half of the LFL or 2.5% gas in air mixture) from going beyond the plant boundary. Because of these plant
siting requirements, there should be no risk to general public safety, making the annual SV testing requirements
currently in 49 CFR 193 unnecessarily burdensome, compared to the consensus requirements in NFPA 59A (5 year
testing intervals for process SVs and 2 years for storage tank, tank top relief valves).
6. The PHMSA incident report file was examined but no SV problems relating to LNG facilities were located.
7. Research indicated that some valve manufacturers and some standards recommend choosing SV testing frequency
depending on ambient conditions, prior test results, etc., for each valve, rather than using fixed intervals.
8. Regulators and standards organizations are beginning to discuss risk-based decision-making for LNG facilities.
Excellent recordkeeping and precise documentation of historical and current SV test and performance data would be
essential to establish a valid baseline for consideration.
9. The SGC members believed that, based on the inconsistent data collected thus far, AGA would have a difficult task
in convincing PHMSA to relax the annual testing requirement at this time.
10. The SGCs current committee project workload reduced ability to commit resources to proceed with this project.
11. If personnel or funds were available, 1 a consultant could be engaged to develop an optimum questionnaire, and to
work interactively with SGC members as needed to obtain data that would definitively document the relevant factors.
That individual could then analyze the results of member companies findings, in search of any patterns or
circumstances for which persuasive data suggest an initial focus, in building the case to regulators for lengthening SV
testing intervals.
12. Alternatively, several members suggested that while the evidence may not support AGAs approaching PHMSA at
this time to modify the testing frequency, an individual company could decide to make a proposal to its AHJ, or
request a formal waiver, to lengthen the annual testing interval for some or all of its SVs, based on a detail-intensive
justification that would satisfy the AHJ.

Respectfully submitted,

Margaret H. Sanfilippo Kevin Ritz

__________________________ _____________________
Manager, Regulatory Compliance Engineering Analyst
Distrigas of Massachusetts LLC BGE
Member AGA SGC Member AGA SGC and Immediate Past Chair
Member NFPA 59A Technical Committee (AGA Rep)

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A DOT inspector recently informed a member that the Technical Assistance Grants to Communities program, authorized by the PIPES
Act of 2006, makes available engineering and technical assistance related to pipeline safety, and may be a resource.
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 Table 1. Safety Relief Valve Maintenance Testing Interval Requirements

Reg/Standard Title Requirements Interval

49 CFR 192.743 Transportation of Natural (Pressure limiting and regulating stations: Capacity of relief devices) 15 mo
and Other Gas by Pipeline: [determine capacity at intervals not exceeding 15 months]
Minimum Federal Safety
Standards
49 CFR 192.745 " (a) (Valve maintenance: Transmission lines) Each transmission line that 15 mo
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.
49 CFR 192.747 " (a) (Valve maintenance: Distribution systems) Each valve, the use of 15 mo
which may be necessary for the safe operation of a distribution system,
must be checked and serviced at intervals not exceeding 15 months, but
at least once each calendar year.
49 CFR 193.2619 Liquefied Natural Gas (Maintenance - Control systems) Inspect and test once each calendar 15 mo
Facilities: Federal Safety year, not exceeding 15 months, except seasonal (before season), fire
Standards protection (not to exceed 6 months)
49 CFR 195.420 Transportation of (Valve maintenance) (a) Each operator shall maintain each valve that is 7.5 mo
Hazardous Liquid by necessary for the safe operation of its pipeline systems in good working
Pipeline order at all times. (b) Each operator shall, at intervals not exceeding 7.5
months, but at least twice each calendar year, inspect each mainline
valve to determine that it is functioning properly.
49 CFR " (Overpressure safety devices and overfill protection systems) (a) [each 7.5 mo/
195.428(a) calendar year not exceeding 15 months; highly volatile liquids twice 15 mo
each calendar year not exceeding 7.5 months]
49 CFR " [relief valves on breakout tanks containing highly volatile liquids - not 5 yr
195.428(b) exceeding 5 years]
NFPA 30 Flammable and 7.7.7 (Wharves) Relief devices shall be tested at least annually to annually
Combustible Liquids Code determine that they function satisfactorily at their set pressure.
NFPA 54 National Fuel Gas Code B.3 (Maintenance of Gas Equipment) "should be examined at frequently
frequent regular intervals"
NFPA 58 Liquefied Petroleum Gas E.2.3 (Pressure Relief Valve Testing) Frequent testing is not considered ~10 yr
Code necessary. Test PRVs on containers >2,000 gal water capacity at
approximately 10 year intervals.
NFPA 59 Utility-LP Gas Plant Code 10.1.4 (Testing Relief Devices) Relief devices, other than hydrostatic 5 yr
relief valves, shall be tested for proper operation at intervals not
exceeding 5 years.
NFPA 59A Standard for the 11.5.5.1(e) Stationary LNG tank relief valves shall be inspected and set- 2 CY/
Production, Storage, and point tested at least once every 2 calendar years, not exceeding 30 5 yr
Handling of Liquefied months. All other relief valves protecting hazardous fluid components
Natural Gas (LNG) shall be randomly inspected and set-point tested at intervals not
exceeding 5 years + 3 months.
29 CFR 1910.178 [liquid fuels - per NPFA 30; liquefied petroleum gas fuel per NFPA 58]
ASME B31.3 Process Piping, 2002 322.6.3 (Pressure Relieving Devices) Devices shall be in accordance -
with BPV Code, Sec. VIII, Div. 1.
ASME B31.8 Gas Transmission and 853.31(b)(2) (Maintenance of Pressure Limiting and Pressure 1x/CY
Distribution Piping Regulating Stations) At least once each calendar year, a review shall be
Systems, 1999 made to ensure that the combined capacity of the relief devices on a
piping system is adequate to limit the pressure at all times to values
prescribed by the Code.
853.41 (Valve maintenance) Pipeline valves that would be required to
be operated during an emergency shall be inspected periodically and
partially operated at least once a year to provide safe and proper
operating conditions.
ASME B31.8S Managing System Integrity 6.3 (Pressure Testing) ASME B31.8 contains details on conducting -
of Gas Pipelines, 2001 pressure tests.

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Reg/Standard Title Requirements Interval
ASME BPV Code, Sec. VII, C2.430 (Safety Valves) Check periodically to see that the safety valves periodically/
Recommended Guidelines are free to operate and are not leaking. 1 yr/
for the Care of Power C4.110 (Appurtenances - Safety Valves) Testing, inspection, and repair 2 yr
Boilers, 7/03 should be performed at a regular frequency determined by the valve's
maintenance history. The application characteristics can vary for each
valve on a multi-valve system and create a different cycle for each
valve. The normal cycle time is 1 year.
C4.220(c) (Safety Relief Valve/Relief Valve Inspection and
Maintenance) Corrosiveness of media, application, and trim component
metallurgy are primary elements that determine frequency of testing
and maintenance. Can be as short as 6 months or as long as 2 years for
an individual safety relief or relief valve, based on operating and
maintenance experience.
ASME BPV Code, Sec. VIII, Div [no field maintenance info] -
I, 2001, Unfired Pressure
Vessels
API 510 Pressure Vessel Inspection 4.3 (Inspection Intervals) Interval determined by performance of device 10 yr
Code, 3/92 in its particular service; maximum 10 years.
API 574 Inspection Practices for Sec. 7 (guidelines to determine inspection frequency) Depends on -
Piping System consequences of a failure, degree of risk, amount of corrosion
Components allowance remaining, historical data available, regulatory requirements.
API RP 576 Inspection of Pressure- 6.4 (Inspection Frequency) Varies widely with various operating [ 10 yr]
Relieving Devices conditions and environments to which relief devices are subjected;
more frequent when corrosion, fouling, leakage problems occur.
Historical records of tests and service for each device guide
establishment of safe and economical inspection frequencies. Establish
a definite interval for each device, depending on operating experiences;
revise as justified by test records and consistency of results. API 510
says max. 10 yr. Investigate regulators' frequency requirements to
avoid conflict. Visual on-stream inspections 5 yr.
API 620 Design and Construction of [Appendix N (Installation of Pressure-Relieving Devices) N.1 Pressure- -
Large, Welded, Low- relieving devices shall be installed so that they are readily accessible for
Pressure Storage Tanks, inspection and removable for repairs.]
2/02, 6/04
API 2000 Venting Atmospheric and 4.5.6 (Maintenance of Venting Devices) For recommended -
Low-Pressure Storage maintenance and inspection procedures, see API Bulletin 2521 and API
Tanks, 4/98 Recommended Practice 576.
API 2510 Design and Construction of 9.7.4 (Pressure-Relieving Devices) Refer to API 520, Parts I and II, for -
Liquefied Petroleum Gas proper design of pressure-relieving devices and systems for process
(LPG) Installations, 4/89 equipment used in liquefaction and vaporization facilities.
API 2510A Fire-Protection 2.10.4.1 (Relief Valve Testing) It is important that all pressure relief -
Considerations for the valves be shop tested on a periodic basis to ensure their continuing
Design and Operation of reliability. The API Guide for Inspection of Refinery Equipment,
Liquefied Petroleum Gas Chapter XVI, provides information on testing procedures as well as a
(LPG) Storage Facilities, basis for establishing test frequencies.
4/89
API 2521 [does not appear on API web site 10/10/06]
API Guide for Inspection of [does not appear on API web site 10/10/06]
Refinery Equipment
LPGA Code of Practice, 2000 CoP 1, part 3, A.1.1 (Examination Intervals, vessel fittings, pressure 10 yr
relief valves) At 5 years. For internal valves or external valves to CoP
15 Part I with stainless steel springs, frequency may be increased to
maximum of 10 years in accordance with manufacturer's guaranteed
service life, or where sufficient service performance data is available to
satisfy the competent person that the longer service life is justified.

Resources;
AGA LNG Benchmarking 2001, 2003-2006
Codes and Standards listed in table
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