BY MICHEL OLIVER
I plan to resume my thoughts on Control Room Management (CRM) after addressing a more-timely matter.
PHMSA has finally taken the next step toward publishing the long-awaited Gas Pipeline Safety Rule – also known as the “Gas Mega Rule” – and, as it seems that the first installment of the new Rule could be published within the next couple months, I thought it prudent to at least attempt to discuss it now.
So – what’s in this new rule?
While the initial rule focused on gas transmission pipelines, it has since been expanded to include gathering lines to address outstanding mandates from the 2011 and 2016 Pipeline Safety Act reauthorizations.
If published as proposed, the new rule will double the size of the current Part 192 regulations. For this and a few other reasons, PHMSA has decided to issue the new rule in three parts.
It appears that the first part of the rule – which is currently awaiting OMB approval – will focus on those outstanding mandates, on new MAOP reconfirmation requirements and on an expansion of existing pipeline integrity assessment requirements – including some more prescriptive language, a redefinition of high-consequence area (HCA) and the introduction of a new category of “moderate-consequence area” (MCA).
It will also include provisions for material verification, incorporation of seismicity into data integration and risk analyses; an extension of reassessment intervals; and MAOP exceedance reporting.
We should expect the new MAOP reconfirmation and remediation requirements to be phased in, allowing operators one year to develop their plans and several years to complete their testing and/or replacement.
The second part of the rule will likely expand gas transmission integrity management program (IMP) requirements and should be expected by the end of this year. Provisions will include adjustments to pipeline repair criteria, inspections following extreme weather events, launcher/receiver safety features, increased assessment requirements, additional corrosion control requirements; and management of change elements.
The third part of the rule should address gathering pipelines and can be expected sometime next year. It will include new regulations for lines in Class I locations, new reporting requirements and a few new definitions.
So – are you asking yourself if you are ready for the new Gas Mega Rule – or, if not, what you should do to get ready?
Have you proactively reviewed and reconfirmed your MAOP, conducted additional risk analyses and testing, reviewed your records, identified your gaps and determined additional pipeline pressure and/or material testing requirements? Or – are you waiting to see what is published and what it will mean for you?
While the time for waiting may be running out, I think you can rest assured that you are not alone, that there is a lot of available help, and that together, we will get through this.
Note: This is the third in a series of blog entries on gas and hazardous liquid pipeline operations and regulatory compliance. If you have any questions or comments about this blog or would just like to talk about anything related – please feel free to reach out to me at: firstname.lastname@example.org