PHMSA’s Final Ruling – What’s Next for Pipeline Operators
It is important that 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. Gas Transmission operators should assess their readiness and align their current in-place integrity management programs and operating practices to meet PHMSA’s 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:
- 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.
- 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.
- 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.
- 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.
Operators who have addressed the key areas outlined above will be well prepared for any potential regulatory audit and will ensure their pipeline operation and maintenance programs are compliant with both state and federal regulators.