Developing a Cost Effective 15-year Plan to Comply with the Gas MEGA-Rule – Part 3

Article 3 of Series



Creating Asset Owners to Facilitate Decisions When Implementing a Gas Mega Rule Mitigation Plan

This article is the third 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 1400 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 a 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; and
  • Verify 100% of pipeline mileage by July 2, 2035.

Operators will need to establish a 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.

Creating Asset Owners

In the previous article in this series, we discussed problems to avoid that contribute to making projects take longer or cost more. One of the biggest contributors to costly project delays is the lack of a clear decision maker.  Many utilities have multiple departments appearing to be in charge, but each department often defers to others when a decision gets out of their area of expertise. This can increase the risk for expensive delays if a crew of ten to fifteen construction workers are idled while waiting for a decision.  Generally, timely decisions can lead to saving costs in the future.

For the many types of projects being executed under your 15-year mitigation plan, there will be numerous situations requiring timely decisions to avoid delays or save future costs.  Here are some examples: 1) During a material verification dig, you discover that an elbow with no records does not meet the specifications needed to operate at the established MOP.  Who decides whether to replace the elbow immediately or instead backfill the excavation and lower the MOP of the line?  2) During a hydrotest project, an isolation valve is found to be leaking.  Who decides whether to replace the valve during the project or instead perform a workaround and replace the valve later in a separate project? 3) During the design of a valve automation project in a station, the project engineer discovers an ILI launcher is planned in the future and the utility could save money if the station piping is modified to install a riser for the future launcher while the station is fully excavated. Who decides whether to design the project to modify the station to include the riser or instead ignore this potential savings?

To facilitate these decisions, a best practice is to appoint asset owners who are responsible for making these decisions.  Asset owners should be responsible for the safe operation of the asset and should reside in the Operations organization.  Multiple asset owners are typically assigned to their areas of expertise including pipeline, station, compression, storage, processing, and other assets.  Asset owners should seek input from the various other organizations (i.e., TIMP, Budget, Gas Control) and attempt to gain consensus, but at the end of the day must make the final decision on what should be done.  Asset owners should be involved with scope and schedule of the planned projects and should also help with what projects can be bundled. (We will discuss bundling in a future article.)  The asset owner should have a process to document and communicate all decisions so that any change is managed well.  This change management includes providing the asset owner with the ability/authority to change budget or request the change in budget to optimize the program needs.

Asset owners should make decisions based on the values of the organization.  Being consistent is important.  A good guide for asset owners is safety first, reliability second, then affordability.  Another important way to help asset owners make consistent and faster decisions is to develop decision trees for recurring issues.  Once a decision tree is developed, the asset owner should consider who else in the organization can be delegated the approval to make quicker decisions based on the decision tree.  One example is developing a decision tree for repair decisions for an anomaly found when a pipeline is excavated, with potential for a field engineer or construction manager to give the direction to proceed with the repair recommended by the decision tree.

Establishing asset owners, and the supporting decision-making and change management processes, is a best practice your organization should consider to improve decision making and reduce costly delays while implementing your 15-year mitigation plan. 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.

In the next article in this series, we will cover developing a customer outreach program to support your 15-year mitigation plan.

Written by:

Ben Campbell

Vice President, GTS Area Manager –