Part 2 of the Gas Mega Rule added new requirements for data integration into IM programs, including analyzing potential failures and interacting threats. While the amended 49 CFR Part 192 doesn’t explicitly mention risk modeling, the incorporation of ASME B31.8S and amendments to §192.917 seem to make risk modeling prescriptive.

The purpose of this white paper is to perform a comparative analysis of the new regulatory requirements pertaining to data analysis, data integration, threat identification, risk assessment, and risk modeling recommendations, both issued by PHMSA, to evaluate potential conflicts that may complicate regulatory implementation.

Date Published: May 29, 2023