PHMSA’s Mega-Rule, Part 1 – It’s Here, Do You Know Where You Stand? – 

In October 2019 PHMSA published updates to 49CFR, Parts 191 and 192 issuing the first of three anticipated updates of the long-awaited Gas Transmission “Mega-Rule”. These updates reflect significant changes impacting operators of natural gas transmission assets throughout the United States. The impacts are large and broad, and operators will have to act, if they have not already done so. Let us rewind and replay just what is the Gas “Mega-Rule”?

Overview

The Pipeline Safety Improvement Act of 2002 mandated that the Department of Transportation (DOT), the Department of Energy (DOE), and the National Institute of Standards and Technology (NIST) in the Department of Commerce (DOC) “…carry out a program of research, development, demonstration and standardization to ensure the integrity of pipeline facilities.”  Unfortunately, transmission incidents continued to occur, and the 2010 San Bruno incident was an influencing factor for the creation of regulatory change. Many of the changes in the “Mega-Rule” are intended to mitigate factors that can lead to such incidents in the future. Now that changes have been published, we know the requirements to reach regulatory compliance. Below is a breakdown of the regulatory changes by some of the major topics:

1. Part 1 – MAOP Reconfirmation (validation, verification), Material Verification activities, Non-HCA Assessments activities, MAOP Exceedance Reporting, Assets Recordkeeping (establishing a Records Management System)
2. Anticipated Future Releases will impact the following areas – Transmission Repair Criteria, Inspections of Pipelines after extreme weather, updated Corrosion Controls, Strengthened Assessment requirements, Enhanced Management of Change (MOC) requirements, Updated requirements for Gas Gathering Systems

Now that Part 1 of the Gas “Mega-Rule” goes into effect rather soon, July 1, 2020, there are activities that operators can execute now to make sure their transmission assets are operating safely, reliably, and compliantly. Below are some ways that GTS can help.

GTS Activities & Support

Do you know where your company stands? Your Board of Directors and Regulators will soon be asking if they haven’t already. GTS can help operators create efficient and effective actions to ensure compliance.

Here are some ways that GTS can help.

Regulations Gap Analysis – GTS has the in-house expertise and experience needed to review and evaluate an operator’s existing gas integrity management and compliance programs, procedures, and practices. Our teams will evaluate existing programs and procedures compared to the requirements of Part 1 of the “Mega-rule”. We utilize teams with extensive experience in developing, implementing, and managing gas integrity management, pipeline safety regulatory compliance, and MAOP Reconfirmation programs for operators.

As an output of GTS’s work, we will provide the operator/client with a report outlining the results of the evaluation, including a summary of the observations, findings, and recommendations for improvement. Additionally, GTS can provide tactical actions, and assist with implementing these tactical actions, to close identified gaps.

As future anticipated regulatory publications are made, GTS will expand its Gas Transmission Regulations Compliance Matrix™ and incorporate required activities for compliance.

Records Management Systems (TVC Records) (§§§192.67, 205, 517) – It is imperative that records for operators’ assets and tests on these assets are managed for the entire life cycle of the assets. Records Management principles must be considered in creating a sustainable Records Management System (processes, technology, and trained people). In addition, the upstream processes of creating Issued for Construction packages (i.e. design) and Construction As-Builts creation must be improved and managed to ensure that excellent records are able to enter the Records Management System.

GTS has the experience in developing and implementing sustainable Records Management Systems for legacy and new records. GTS is able to ensure that operators are able to be confident that their asset records are properly secured, managed and are available for use as needed.

MAOP Reconfirmation (§192.624) – GTS has been providing MAOP Reconfirmation (validation, verification) services to operators throughout the United States since 2011. GTS has performed this work on thousands of miles of pipelines and hundreds of stations. The GTS MAOP Reconfirmation Method™ incorporates key foundational activities – from Records Review through Issues Analysis and Mitigation – to establish a comprehensive, efficient, and documented MAOP program. These foundational activities include rationale documentation, processes, templates, prioritization and assessment schemes, calculations, and tracking methods. Additionally, the GTS MAOP Reconfirmation Method™ ensures that available records are typed, attributed, graded, and properly stored for system-to-system reference and ease of retrieval for use.

Material Verification (§192.607) – Material verification is required when asset knowledge is lacking. To ensure that clients have confidence in technology and methods, GTS has performed Material Verification technology assessments, developed technical guidelines and procedural steps to complete material testing (NDT and DT) and proprietary tools that allow for data reconciliation and asset sample size determinations. These items are the foundation for a sound Material Verification Program to allow the operation to move forward in establishing new TVC records of material on a sustained basis.