PHMSA 192 Mega Rule and its Impact on Pipeline Safety in Gas Transmission Pipelines
Safety is such an important part of what we do in the oil and gas industry. Public safety was what sparked the United States’ concern, and it is the reason regulators began writing the Mega Rule. It all started with the San Bruno, California incident in 2010, and the Sissonville, West Virginia incident in 2012. These incidents among several other incidents were what spurred the discussion to create these rules. So, what is the Mega Rule? The Mega Rule is an amendment to the Federal Pipeline Safety Regulations. It is a huge rule change in regulations by PHMSA (Pipeline and Hazardous Materials Safety Administration) that revises how the integrity of pipeline systems are tested and it heavily emphasizes the requirement for validation of data and records. This rule, concerning Gas Transmission Pipelines which has already been released on October 1, 2019, covers:
MAOP for gas transmission lines
Verification of pipeline materials
Increasing assessments and reporting requirements of MCA’s and HCA’s
Why is MAOP important? The answer to this can be linked back to the San Bruno incident, where the pipeline pressure was built up so much from extra gas flowing through the line that the pipe ruptured and exploded. PG&E estimated that 47.6 million standard cubic feet of natural gas was released. The first rule which covers maximum allowable operating pressure (MAOP) addresses this issue. The rule requires that previously untested natural gas transmission pipelines get a reconfirmation of their MAOP. Meaning, if your pipeline doesn’t have the TVC (traceable, verifiable, and complete) documentation for MAOP; there isn’t a pressure test record available, operators must provide proof that the MAOP has been confirmed. This means that operators may need to do another pressure test and take all the necessary precautions to get their pipeline at the correct MAOP, as well as providing the documentation to support it. The rule requires operators to ensure that the MAOP is reconfirmed for 50% of applicable pipelines by July 3, 2028, and for 100% of applicable pipelines by July 2, 2035.
In addition to reconfirming MAOP, operators are also required to gather any material property records. These material property records are very important, and the idea to require them, again, came from the San Bruno incident. After the incident, investigators found that the operator had the pipe in the ground and the operator didn’t know exactly what the material of that pipe was. They had inaccurate and incomplete pipeline information and they could not accurately verify what the pipe was and what its specifications were. The integrity of pipelines is dependent on record retention of these TVC documents, and if there are any gaps in records, PHMSA will consider that as “insufficient” material property records.
A new concept that has come out of this first part of the release of the Mega Rule is the definition of what an MCA is. We all know what HCAs are (High Consequence Areas). MCAs are moderate consequence areas, and PHMSA defines them as an onshore area that is within a potential impact circle (as defined in 192.903), containing either:
Five or more buildings intended for human occupancy; or
Any portion of the paved surface, including shoulders of a designated interstate, other freeway or expressway, as well as other principal arterial roadways with 4 or more lanes.
Previously, integrity assessments were only required for pipelines in HCAs. Now, however, PHMSA is requiring all pipelines and their MCAs to be identified and documented. PHMSA has done this in response to the pipeline explosion along a highway in Sissonville, West Virginia. The explosion which resulted in a fire destroying three houses and melting part of nearby Interstate 77 in December 2012 was investigated, and the NTSB found the pipe was not within a high consequence area (HCA). Because of this, PHMSA wrote these regulations for MCAs so that operators can provide an elevated level of safety for pipelines in MCAs. The rule requires that pipelines in Class 3 locations, Class 4 locations, and in the newly defined “moderate consequence areas” (MCA) must be initially assessed within 14 years of this rule's publication date and then must be reassessed at least once every 10 years subsequently.
PHMSA has already issued a second part of the Mega Rule focusing on requirements for inspecting liquid pipelines following extreme weather events, and clarification and strengthening of integrity management assessment requirements on hazardous liquid pipelines. There are new rules on valve and rupture detection there that are more aggressive and more detailed. There is also a third part of the Mega Rule that has already been released which covers Enhanced Emergency Order Procedures, which aren’t intended to be used on an everyday basis, but they are intended only for imminent hazards.
There is going to be another part that heavily addresses integrity management improvements, cathodic protection, and management of change for gas transmission pipelines.
Gas gathering lines were previously non-regulated, but PHMSA is changing the rules to include operators of gas gathering pipelines in their new regulatory safety requirements. Gathering lines, which are the small pipelines transporting gas away from the point of production to another facility or to transmission lines, will soon be held to the same standards as liquid and gas transmission lines, with some exceptions being given of course.
Support for the Gas Mega-Rule
Does your team have a grip on record management and record retention? How does your company obtain and maintain traceable, verifiable, and complete records? Is your company developing action plans to get in compliance? If your team needs to address any of these issues, or if you are searching for a solution to solve your compliance and pipeline documentation problems, Petro IT can help.