Preparing for PHMSA’s Mega Rule – Plan & Procedures Due July 1, 2021
It is important that prudent gas transmission pipeline operators review the changes to 49 CFR Parts 191 and 192 and adjust integrity programs as necessary to achieve continued regulatory compliance. The final rule, which came into effect on July 1, 2020, gas transmission operators should assess their readiness and align their current in-place integrity management programs and operating practices to meet new regulations, the deadline for process and procedures due July 1st, 2021. At a minimum, an operator should develop a “Mega Rule Response Plan” that includes four key focus areas outlined as follows:
1. Ensures that systems are in place to calculate and identify both HCAs and MCAs on an on-going basis, along with the supporting processes to capture and align pipeline right-of-way adjacent structures along with other pipeline attribute information.
2. Determines those pipeline asset segments that meet the applicability requirements of (§192.624) and develop processes and procedures to perform MAOP reconfirmation by July 1, 2021. In addition, operators should develop a MAOP reconfirmation plan, including a. Evaluation of optimum pipeline segment MAOP reconfirmation methods, and; b. The data management practices that will be used to capture and integrate MAOP reconfirmation information.
3. Determines pipeline segments that require material verification according to §192.607 and develop procedures for material verification in conjunction with analysis of predicted failure pressure during pipeline assessments §192.712. In addition, an operator should review the data management practices that will be used to capture and integrate material property information.
4. Ensures reporting and data management systems are in place to integrate data and perform analysis as a basis to confirm reliability, define and mitigate potential risks, and demonstrate compliance to the regulations.
The PHMSA Mega Rule: what’s at Stake?
Since PHMSA officially published the Gas Mega Rule in October 2019, it is critical for gas transmission pipeline operators to advance their knowledge of the impending mandates and determine the best approach with how they will address these with their existing integrity management programs. Massive resources will be required to replace pipe or conduct other material integrity activities on pipelines that are fit-for-service. Given the limited cost structure of the industry, it is critical every dollar spent goes toward improving pipeline safety and reliability performance.
Effective Pipeline Integrity Support
Dynamic Risk has 25+ years industry expertise with providing support and facilitating the development of pipeline integrity programs and practices that provide operators with the tools necessary to effectively and efficiently implement Gas Mega Rule requirements and class change provisions through a dedicated, consistent approach. Key service offerings include the following:
Ø Pipeline Regulatory Compliance Support
Dynamic Risk provides industry leading regulatory support to pipeline operators in which our services and applications have supported over 100 audits at the Federal, State and Provincial level.
Ø Fitness for Service
Dynamic Risk offers a comprehensive analysis of a pipeline’s current state of integrity. The data and analysis derived uncovers key threats and conditions to support the development of an effective Integrity Management Program and ensure the operator addresses key regulatory mandates for safe and efficient pipeline operations and maintenance programs.
Ø ILI Data Calibration, Alignment, Integration & Analysis
Dynamic Risk provides our clients with ILI data expertise, a solid technical understanding of ILI analysis, management and efficient data assurance and validation.
Ø Integrity Data Management Services
Dynamic Risk has a strong technical understanding of pipeline integrity data. Our team comprises experienced integrity data analysts with a deep understanding and focus on engineering, ILI, GIS, from the wellhead to big-inch cross country transmission pipelines.
Ø Engineering Assessments
Whether your needs relate to the management of existing infrastructure or new pipeline construction projects, we have the technology and engineering expertise to assist you with risk-based decision making.
Ø Incident Investigation
Our experts have active relationships with regulators and stakeholders, providing external credibility and appropriate support.
To learn more about how Dynamic Risk can support your organization with effectively managing and adhering to PHMSA’s Gas Mega Rule by July 1, 2021, please Contact Us to be put in touch with one of our industry experts.