As we approach the invocation of the new gas transmission rules – changes to 49CFR, Part 192 – GTS recognizes that compliance with the numerous and major changes may seem overwhelming, unnecessary and impossible to implement. Below are the various activities that must occur to reach the end state for pipeline operators to have excellent asset knowledge, gas delivery systems with reduced risk, higher safety and continue to offer the societal benefits that they have for over a century.

MAOP Validation
Fundamental to operating safe and reliable pipelines is to rigorously ensure that asset records accurately depict the operating assets and thus allow for correct pipeline design and test calculations. Recognizing that the availability of records for in-situ pipelines may sometimes be a challenge, GTS has developed methods to ensure MAOP Validation is always performed correctly, and conservatively when records are not available.

MAOP Validation Dataset Usage
Many times, operators do not start MAOP Validation with the end state in mind and discover that after datamining the asset records and calculating MAOP for pipe sections, that not all features have been tallied nor other valuable data has been mined. A well-structured Pipeline Features List (PFL) template will allow for comprehensive data collection thus allowing operators optimum optics for prioritization of post-MAOP Validation activities. Once activities are prioritized, compliance action can occur to ensure operator-regulator alignment. After alignment is achieved, the path forward to rehabilitating pipelines, retrofitting them to accommodate ILI tools or to meet the desired MAOP are clear.

Assessment Data Usage
One of the new requirements will be to assess new pipelines after installation to verify coating integrity. This activity will reduce corrosion cell developments, which will improve the safety and life of the pipeline. In addition, newly retrofitted pipelines will open a new world of valuable data regarding pipelines that have been in operation for decades. This data will have to be acted upon and will lead to pipeline direct assessments and, if necessary, repairs. Coordination of the myriad of activities from the time new assets are installed, through coating check, direct assessment check and repair can be a challenge. The employment of a work management system that is asset based and coordinated with the GIS will be beneficial, if not a necessity for operators.

Post Asset Installation
The use of the MAOP Validation Dataset can facilitate the performance of a Pipeline Centerline Survey. This type of survey acquires a survey-grade location of the pipeline centerline. If properly planned, the survey can also acquire other beneficial data such as main depth, adjacent vertical penetrations, right-of-way obstructions, harmful vegetation, etc. More important, if the PFL features can be geospatially aligned on the new centerline in GIS, operators will have a robust and accurate GIS. This activity is not easy to accomplish when there are competing priorities and budget constraints, but the outcome can be worthwhile and rewarding.

Please contact Joe Medina ( for additional information.