Developing a Cost Effective 15-year Plan to Comply with the Gas MEGA-Rule – Part 5

Article 5 of Series


Developing a Team to Manage Project Outage Clearances to Support a Gas Mega Rule Mitigation Plan

This article is the fifth 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 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 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.

Outage Clearances

If your 15-year mitigation program to comply with Part 1 of PHMSA’s Gas Mega Rule involves a lot of hydrotests, pipe replacements, in-line inspections, valve replacements and automation, then the pace of your work will likely be significantly influenced by an Operator’s ability to shut down their pipeline systems to perform the work.  This pipeline shutdown process has multiple names but for this article let’s call the process an outage clearance.  An outage clearance occurs when an operations team develops an outage plan involving a sequence of valve operations that isolates a pipeline or station and is followed by a blow down (evacuation) of the gas in the pipeline. Once the gas pipeline is blown down, construction crews can safely perform the intended work (hydrotest, pipe replacement tie-in, valve replacement tie-in, etc.)

The personnel on the team performing the outage clearance are typically very experienced and familiar with the pipeline system including any complications or nuances of the system.  Typically, this team is in house, not contracted, and may also perform routine maintenance on the pipeline system and have very little time in their schedules to perform outage clearances.  Even when outage clearances are well-planned, an emergency or other event can cause the outage clearance team to cancel a planned outage in order to respond to the more urgent event.  This schedule uncertainty can produce costly delays for the project teams implementing your 15-year plan.

It is this limited availability of experienced personnel to perform outage clearances which can greatly impact the amount of safety work an Operator can perform in any one year.  Thus, it is imperative for an Operator to begin implementing their 15-year program immediately and not wait until the deadline to perform the needed work.   However, an Operator may still lack the outage clearance resources needed even with good planning.  One best practice to reduce the number of project delays and to schedule more work involving an outage clearance is to develop outage clearance teams who are dedicated to performing project outage clearances and are not involved in the maintenance of the pipeline system or its day-to-day operation.

Developing a Team to Manage Project Outage Clearances

To develop an experienced and effective outage clearance team dedicated to project work, some operators have taken their best, most knowledgeable outage clearance personnel out of Operations and directly assigned them to a dedicated outage clearance team to support project work (15-year plan projects).  To implement this assignment of personnel to a dedicated team, may involve negotiations with a Union representing the workers or involve other HR processes, but this can be done successfully with a bit of effort.  In addition, some operators have developed a team of engineers or experienced operators to be dedicated to writing detailed outage clearance plans for each planned outage clearance.

Some of the lessons learned from implementing this best practice are:

  • The outage clearance team dedicated to project work can also support routine outage clearances during times when a project outage clearance is not occurring.
  • The Operations teams that were previously used to perform outage clearances can still support project outage clearances, but their involvement will not be counted on in case an emergency occurs, and they need to cancel their support.
  • The outage clearance team has experience and can work closely with the control room and understands system constraint.
  • The outage clearance team is also familiar with emission reductions such as the use of cross compression or flaring to help reduce the amount of gas released to atmosphere associated with pipeline blow downs.
  • The development of operating diagrams and maps of the gas transmission system make the outage clearance planning and execution much safer. It is a best practice to have an operating diagram for each regulator station and other stations (storage, terminals, meter, etc.) and an operating map for each transmission pipeline showing each key mainline valve, blowdown valves, and tap lines.

The benefits for implementing a dedicated project outage clearance team include:

  • More project work gets accomplished and increases the likelihood that your 15-year mitigation plan will be implemented prior to the deadline.
  • Lower construction costs as outages occur on time and don’t put the construction team in standby waiting on Operations to perform an outage clearance.
  • Better compliance as Operations can stay focused on compliance work and not be distracted by project work.
  • A dedicated outage clearance team is more efficient and safer at performing outage clearances.
  • A dedicated outage clearance team is more reliable at delivering successful outage clearances than maintenance/operations teams, since the maintenance team’s focus is most typically on compliance related maintenance work, or emergency responses related to pipeline operations.

Developing a dedicated project outage clearance team is a best practice your organization should consider to improve the safety and efficiency of your outage clearances, increase the likelihood that your 15-year implementation plan will be completed prior to the PHMSA deadline, and will reduce your implementation costs.   GTS is ready to help provide any guidance or gas engineering services you need to help you implement your 15-year plan and comply with the Gas Mega Rule. GTS can also help with the development of operating diagram and operating maps and clearance outage plans. Please contact Joe Medina ( for additional information.

Written by:

Ben Campbell

Vice President, GTS Area Manager –