PHMSA Final Rule: Safety of Gas Transmission Pipelines Published

The Federal Register published PHMSA’s Safety of Gas Transmission Pipelines: Repair Criteria, Integrity Management Improvements, Cathodic Protection, Management of Change, and Other Related Amendments rule (a.k.a. Mega Rule RIN 2) today and can be located here. Its effective date is shorter than most PHMSA rulemakings, at nine months away on May 24, 2023. Some key topics and points covered in this rulemaking include:

Definitions

  • New definition of Distribution Center

  • Updated definition of a Transmission Line

  • Additional definitions for technology used in the rule such as Close Interval Survey and In-Line Inspection

Management of Change

  • Based on AMSE B31.8S Section 11, making it the same as the Integrity Management requirement

  • Implementation deadline of February 26, 2024

  • Does not apply to gas gathering lines

Corrosion

DCVG/ACVG Assessments of Newly Installed Pipe

  • For projects with 1,000 feet or more of contiguous backfill, a DCVG or ACVG must be performed, and any severe coating damage repaired as soon as possible, but within 6 months of placing line into service

  • Permits must be applied for within the first 6 months. If permits are required for repairs the above deadline may be extended by up to an additional 6 months

  • Records of assessment findings and remedial actions must be maintained for the life of the asset

External Corrosion Monitoring and Remediation

  • Defines specific timeframes for remediation of cathodic protection deficiencies for gas transmission lines

  • Must determine area of inadequate protection where any test station readings are below required levels

  • Investigate and remediate non-systemic issues

  • Perform CIS in both directions to identify systemic issues and remediate according to specified timeframes

  • Confirm restoration of adequate cathodic protection

Interference Currents

Where minimization of interference currents is required, the program must include:

  • Interference surveys

  • Survey results analysis to determine cause and severity (potential impacts)

  • Remedial action plan

  • Remediation timeframes

Internal Corrosion Monitoring and Mitigation

Transmission lines with corrosive constituents (CO2, hydrogen sulfide, sulfur, microbes, liquid water, etc.) must evaluate those constituents for their effect on the pipeline and develop/implement an internal corrosion monitoring and mitigation plan.

The plan must include:

  • Gas quality monitoring where corrosive contaminants enter the line

  • Mitigating technology for those contaminants

  • Annual evaluation of constituents and mitigation

  • Annual review/updates of internal corrosion program

Continuing Surveillance

Extreme weather event or natural disaster

  • Assess nature of event and inspect pipeline for potential impacts within 72 hours of safe access

  • Determine inspection method

  • Take prompt and appropriate remedial action

Analysis of Predicted Failure and Critical Strain Level

  • Provides details for PHMSA submittal request of other methods to determine remaining strength

  • Provides procedure and/or ECA details for evaluating dents and other mechanical damage

  • Provides details for submitting the ECA process for PHMSA approval

  • Details assessment interval requirements for pipe segments with anomalies that an ECA has been performed on to determine assessment intervals

Repair Criteria for Transmission Pipelines Outside of HCAs

  • Details repair timeframes for different types of anomalies

  • Repairs must be documented in accordance with Traceable, Verifiable, and Complete (TVC) requirements

  • If data required for analysis is not available (including MAOP determination), the data must be obtained through 192.607, Verification of Pipeline Material Properties and Attributes: Onshore steel transmission pipelines

  • Temporary pressure reduction requirements

  • PHMSA notification is required if remediation schedule cannot be met

  • Pressure reduction records (calculations, decisions, and actual pressures) must be kept for 5 years

  • On any repair location, in situ direct examination of crack defects is required in known locations of cracks or crack-like defects

  • Failure pressure is to be calculated in accordance with 192.712, Analysis of predicted failure pressure and critical strain level

Integrity Management

Risk Assessment

  • Integrate thirty-five (35) listed data elements starting May 24, 2023, and to be fully completed by February 26, 2024

  • Use validated data as much as possible

  • If using SME input, need consistency control measures, documentation of SMEs and qualifications of personnel approving SME inputs

  • Include a spatial relationship analysis of data

  • Include a threat interrelationship analysis

  • Must include potential consequences of an incident for each covered segment

  • Ensure method validity for incident, leak, and failure history analysis, which must align with industry benchmarks including root cause analysis or equivalent and the pipeline integrity sensitivity

  • Beginning February 26, 2024, risk assessments must evaluate:

  1. How a potential failure would impact HCAs

  2. Likelihood of failure form each threat and combination of threats

  3. Account and compensate for data uncertainty

  4. Impacts of preventive and mitigative measures on risk reduction, reduced anomaly remediation and assessment intervals

  • Includes additional threat language for plastic transmission pipelines

Direct Assessment

  • Included NACE SP0206 and enhanced language for Internal Corrosion Direct Assessment (ICDA)

  • Included NACE SP0204 and enhanced language for Stress Corrosion Cracking Direct Assessment (SCCDA)

Remediation

  • Repairs must be made and documented in accordance with TVC requirements

  • If data is not available for analysis, it must be obtained through material testing

  • Enhanced pressure reduction language and included reference to 192.712, Analysis of predicted failure pressure and critical strain level

  • Added documentation requirements to substantiate pressure reduction decisions

  • Added PHMSA notification requirements if Discovery cannot be made within 180 days

  • Updated most of the scheduled remediation criteria

  • Added requirement for in situ direct examination of crack defects using inverse wave field extrapolation (IWEX), phased array ultrasonic testing (PAUT), ultrasonic testing (UT), or equivalent technology

Preventive and Mitigative Measures (P&MMs)

  • Added a list of 15 items to include during evaluation

  • Included documentation requirement for risk analysis and preventive and mitigative measure implementation decisions

  • Enhanced language regarding leak surveys for low stress pipelines

Low Stress Reassessment

  • Enhanced indirect assessment specifics for low stress pipelines

Operators may request a one-year extension of some of these deadlines if the request is submitted to PHMSA at least ninety (90) days before the compliance deadline, the operator can provide a reasonable and justified basis, a plan for completing the requirements is provided, and a summary is included of safety status and mitigating measures to temporarily ensure safety.

If you have questions or would like to discuss a path forward on this or any other pipeline safety rulemakings, please contact Elemental Compliance for Nicole Tebow at Nicole.Tebow@ElementalCompliance.com or Lauren Tipton at Lauren.Tipton@ElementalCompliance.com.

#PipelineSafety #PipelineCompliance #GasMegaRule #PHMSA

Previous
Previous

PHMSA Periodic Standards Update II

Next
Next

Potential for Damage to Pipeline Facilities Caused by Earth Movement and Other Geological Hazards