Mega Rule Part 1
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:
o Review of pipe and component material records per TVC requirements
o Identification of pipeline segments that do not meet material record TVC requirements
o Review of pressure test records per TVC requirements
o Identification of pipeline segments that do not meet MAOP record TVC requirements
o Procedure updates to ensure appropriate documentation is maintained going forward
o Updated filing system to identify, label, and retain required documents for the life of the asset
o Procedure creation for material testing
o Procedure creation for MAOP reconfirmation
o Material testing implementation plan
o MAOP reconfirmation testing plan
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:
o American Petroleum Institute (API) Standard 1163, In-Line Inspection Systems Qualification
o American National Standards Institute/ American Society for Nondestructive Testing (ANSI/ASNT) ILI-PQ-2005(2010), In-line Inspection Personnel Qualification and Certification
o National Association of Corrosion Engineers (NACE) Standard Practice 0102-2010, In-Line Inspection of Pipelines
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:
o Does my organization have construction projects coming up this spring or summer? If so, we recommend that new processes are established prior to project commencement to avoid mid-project process changes on July 1, 2020.
o How long will it take me to assess TVC on all the records? In order to fully establish MAOP reconfirmation procedures, you will need to know how much pipe needs testing and identify appropriate testing methodology for each segment. This is also dependent on the material records’ TVC status.
o Do my qualified personnel have enough time to address the requirements considering their existing responsibilities and compliance deadlines? A large amount of work hinges on each organization’s Integrity Management personnel. Additional help may be necessary.
o Does my organization have the appropriate, dedicated personnel to review the massive amounts of records and data? Do these personnel possess the technical ability to identify what’s required and the time to comb through these databases and files? It is critical that personnel and contractors have a pipeline background that allows them to identify and review required records.
o How will my organization differentiate between MCAs and high consequence areas (HCAs) in the IMP and affiliated procedures? The requirements are not the same and organizations should be careful to avoid accidental self-regulation.
o Is my organization ready to implement the IMP changes once they are written into programs and procedures? Consider how these changes be rolled-out to the company, develop or contract training resources or ensure items are tracked through Management of Change (MOC).
o Whose responsibility is it to ensure pressure relieving safety devices are installed on all launchers and receivers? Develop and follow a plan for implementation and documentation.
o How are these regulatory changes being managed within my organization? Is senior management involved and aware of the large undertaking these regulations require? Are there personnel designated to this effort for the long term? These requirements will apply from this time forward and will need ongoing attention.
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.
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