Developing a Cost Effective 15-year Plan to Comply with the Gas MEGA-Rule – Part 1

Article 1 of Series

Introduction – How to Develop a Successful and Cost-Efficient Gas Mega-Rule Mitigation Program

This article is the first in a series to help operators create a successful and cost-efficient mitigation program to implement their 15-year plans in compliance with Part 1 of PHMSA’s Gas Mega-Rule. These articles will help operators understand some of the pitfalls they may encounter when implementing their 15-year plans, and to understand some of industry’s best practices to speed the implementation of their mitigation plan while being as cost efficient as possible.

About GTS

GTS has been helping operators across the country with their gas transmission and distribution engineering for over 20 years. For the past ten years, California gas utilities have been implementing a California regulation mandate similar to the PHMSA Gas Mega-Rule. GTS has been the leading gas engineering firm involved with their mitigation plans including the design of over 1,400 miles of in-situ hydrotests, hundreds of miles of pipe replacement, ILI upgrades in both dense urban and rural locations, hundreds of valve automation upgrades, HDDs, distribution main replacement, regulator station replacements, program management, and more. GTS is also one of the leading consultants nationwide for helping operators establish compliant Records Management Systems (TVC Records) (§192.67, 205, 517), perform MAOP Reconfirmation (§192.624), and Material Verification (§192.607), and develop a 15-year mitigation plan to comply with the requirements of the Gas Mega-Rule.

Regulation Mandate

On July 1, 2020, Part 1 of PHMSA’s Gas Mega-Rule went into effect. Many of the changes in the “Mega-Rule” are intended to mitigate factors that can lead to damaging pipeline incidents in the future. The Mega-Rule requires operators to:

  • Establish an Integrity Management Plan and all required procedures documented by July 1, 2021
  • Verify 50% of pipeline mileage by July 3, 2028
  • Verify 100% of pipeline mileage by July 2, 2035

Operators will need to establish compliant Records Management Systems (TVC Records) (§§§192.67, 205, 517), perform MAOP Reconfirmation (§192.624), and Material Verification (§192.607), and develop a 15-year mitigation plan to comply with the requirements of the Gas Mega-Rule. Through best practice experiences and benchmarking, GTS believes the development of the processes, procedures, and documentation management are key components for operators to consider and perform to effectively implement these programs with long-lasting and excellent results.


For most utilities, implementing a mitigation program to meet all PHMSA’s requirements within 15 years will be a challenge. If careful upfront planning and coordination are not done and the operator attempts to manage the work using their normal cap ex and maintenance processes and programs, it is likely that the mitigation work will fall behind and require costly measures to get back on schedule to comply with PHMSA’s deadlines. To improve their chances of success, operators should consider developing several organizational best practices before fully implementing their mitigation plans. Operators will also require new skills that GTS can help with. For example, mitigation measures such as in-situ hydrostatic testing require new skills that many utilities and their contractors do not have, but will need to be successful. These new skills include pipeline cleaning, mercury mitigation, water disposal, leak detection, test certification and more.

GTS has direct experience working with the California utilities on their Pipeline Safety Enhancement Plans (PSEP) for the past ten years. GTS has helped these utilities overcome major obstacles and helped to transform these programs to be both cost-efficient and effective where they continually meet their annual mileage targets and operating budgets.

GTS will share in a series of articles the lessons learned from our experience to help operators implement a cost-efficient and successful 15-year mitigation program that complies with the PHMSA Gas Mega-Rule. In this series we will discuss:

  1. Problems to avoid when implementing your mitigation plan
  2. Getting ready – organization best practices to develop for a successful 15-year plan
    • Creating Asset Owners to facilitate decision making
    • Developing a customer outreach program
    • Developing a team to manage project outage clearances
    • Acquiring CNG and LNG support capabilities
    • Establishing an alliance contractor program
    • Establishing a PMO to manage your 15-year plan execution
  3. Implementation – planning and execution best practices
    • Selecting mitigation measures including in-situ hydrostatic testing
    • Implementing a 3-year execution process plan
    • Implementing a bundling strategy
    • Using workstream meetings to increase communication and coordination
    • Developing a robust as-built process
    • Using dashboards and metrics to monitor success and identify problems

Doing some upfront planning and organization will greatly improve the chances that your 15-year mitigation plan will be both successful and cost-efficient.  We hope you will find this series of articles useful and informative.  GTS is ready to help provide any guidance or gas engineering services you need to help you comply with the Gas Mega-Rule. Please contact Joe Medina ( for additional information.

Written by:

Ben Campbell

Vice President, GTS Area Manager –