PHMSA, Mega Rule Part 1 deadlines are days away

It may seem like only yesterday that PHMSA finally issued Part 1 of the Mega Rule.  On September 30 of 2019, PHMSA issued the Final Rule – Pipeline Safety: Safety of Gas Transmission Pipelines: MAOP Reconfirmation, Expansion of Assessment Requirements, and Other Related Amendments.  It became effective a year ago on July 1, 2020.  This long-anticipated rulemaking addresses gaps in MAOP determination and follows the significant pipeline incident in 2010 at San Bruno, California.

The rulemaking was extensive with 78 pages of background, analysis, and revisions to 49CFR192.  Of particular note is a deadline that is upon us – July 1, 2021:

  • 192.227 Qualification of welders – “for steel transmission pipe installed after July 1, 2021, records demonstrating each individual welder qualification at the time of construction in accordance with this section must be retained for a minimum of 5 years following construction.”
  • 192.285 Plastic Pipe: Qualifying person to make joints – Though rare, the record retention period for plastic fusion on transmission pipe installed after July 1, 2021 is also a minimum of 5 years.
  • 192.624 Maximum allowable operating pressure reconfirmation: Onshore steel transmission pipelines – “Operators of a pipeline subject to this section must develop and document procedures for completing all actions required by this section by July 1, 2021. These procedures must include a process for reconfirming MAOP for any pipelines that meet a condition of §192.624(a), and for performing a spike test or material verification in accordance with §§ 192.506 and 192.607, if applicable.”
  • 192.750 Launcher and receiver safety – “Any launcher or receiver used after July 1, 2021, must be equipped with a device capable of safely relieving pressure in the barrel before removal or opening of the launcher or receiver barrel closure or flange and insertion or removal of in-line inspection tools, scrapers, or spheres. An operator must use a device to either: indicate that pressure has been relieved in the barrel; or alternatively prevent opening of the barrel closure or flange when pressurized, or insertion or removal of in line devices, if pressure has not been relieved.”

Are your procedures for completing all actions associated with MAOP reconfirmation, spike tests and material verification complete and comprehensive?  It may be beneficial to conduct a gap analysis of these written procedures to ensure they are sufficient and that you are ready for future PHMSA or State audits.  GTS, a Kleinfelder Company, has completed such plans for many operators as well as gap analysis of Operator’s plans.  We would be happy to help in any way necessary; you may reach out to us at