How is your organization doing with tackling Part 1 of the Gas Transmission Rule: MAOP Reconfirmation, Expansion of Assessment Requirements, and Other Related Amendments, a.k.a the “Mega Rule” issued October 1, 2019 by the Pipeline and Hazardous Materials Safety Administration (PHMSA)? This part of the “Mega Rule” addresses traceable, verifiable, and complete (TVC) records, material testing, maximum allowable operating pressure (MAOP) reconfirmation, and moderate consequence areas (MCAs), all large topics for the natural gas industry. Keep in mind as you wrestle with these new requirements that there are several aspects to consider, often simultaneously. Let’s break them down.
The TVC material records and MAOP reconfirmation are best considered in separate but interacting process streams. The first is pipe and component material records and verification. The second is pressure test records and MAOP reconfirmation. These are different sets of documents that operators must have for each pipeline segment. Additionally, the MAOP record set is dependent on completion of the material record set. Analyzing the current state of records for each pipeline segment will help define an organization’s process moving forward. Operators must also update procedures in tandem with the records review process to fully address the new requirements.
Elemental Compliance experts have developed this quick reference list as potential topics to address in order to comply with the new rule:
Once operators have a good handle on material records, they can turn their attention to the additional Integrity Management Program (IMP) requirements. Each organization’s IMP and associated procedures will need to be updated to account for MCAs, additional assessment requirements, cyclic fatigue and cracking considerations, remaining strength determinations, and the inclusion of three in-line inspection (ILI) best practices:
By July 1, 2020 relevant programs and procedures must be updated (with the exception of MAOP reconfirmation procedures), and organizations must be ready to implement. Additionally, by July 2021 each organization must have pressure relieving safety devices installed on all launchers and receivers and have the MAOP reconfirmation procedure(s) and plan in place.
Key questions to ask include:
PHMSA will be inspecting on these subjects beginning July 1, 2021 and Part 2 of the “Mega Rule” is fast approaching, so no matter where you start in this process, it’s important to begin now. If you are feeling overwhelmed, if you are not sure where to begin, or if you are just in need of some extra hands, contact us at Nicole.Tebow@ElementalCompliance.com or Lauren.Tipton@ElementalCompliance.com and we will assist your organization with moving forward.
Stay tuned to Elemental Compliance’s LinkedIn page and Blog for further regulatory updates.
For updates on the above topics and other state and federal regulatory initiatives, follow Elemental Compliance on LinkedIn, or watch for our blogs at www.ElementalCompliance.com.