PHMSA Mega Rule: Your Guide to Compliance Through Integrity Management, Cathodic Protection, Pipeline Mapping, and More.
If you work in natural gas, you’ve likely heard plenty about the PHMSA Mega Rule over the past decade. As new regulations begin to roll out, it’s key to assess how they’ll impact your operations and what steps you’ll need to take to be in compliance.
It’s called the “Mega” Rule for a reason. It is the most comprehensive and sweeping change in regulations the gas pipeline industry has seen since 49-CFR 192 was introduced. It’s so large, in fact, it had to be broken into three parts. Part One went into effect in 2020 focusing largely on material verification, expansion of assessments and new record keeping requirements. Part Three expands PHMSA’s jurisdiction of onshore gathering lines and was entered into the Federal Register on November 15, 2021, with an effective date of May 16, 2022. Part Two is in the process of being finalized.
Whether you’re catching up on the details or starting to research next steps for your natural gas assets, check out our guide to complying with the PHMSA Mega Rule.
Mega Rule Part Three
We’ll start with an overview of Part Three as it is the most recent rule to go into effect. Part One is discussed next as it went into effect with some 2021 deadlines. Finally, we’ll discuss Part Two which has yet to become effective, but you should be aware of its content.
Mega Rule Part Three Part Three focuses on PHMSA’s oversight reach. Previously their authority covered transmission and some 11,661 miles of onshore gathering pipeline, but this new regulation will extend coverage practically to the first valve off the production facility, bringing an estimated additional 426,000 miles of gas pipeline under PHMSA’s jurisdiction. Of this mileage, PHMSA estimates 90,863 miles will classify as Type C gathering, which qualifies for more stringent regulatory treatment.
Part Three final rule was a bit of a surprise to the industry.
Most pundits expected Part Two to be effective in 2021 with Part Three finalized sometime in 2022. However, Part Three was published on November 15, 2021 with an effective date of May 16, 2022.
According to the executive summary of the final rule, the driver behind accelerating Part Three enforcement is due to new drilling technologies, surging gas production and a corresponding increase in volume transported by gathering lines.
PHMSA further noted that “Large diameter, high-pressure gathering lines are susceptible to the same types of integrity threats as transmission pipelines, including corrosion, excavation damage, and construction defects. The exemption of these pipelines from the safety requirements of the Federal Pipeline Safety Regulations failed to consider the present risks that now exist.”
Part Three puts a significant new reporting burden on operators with new guidelines for classification of gathering lines and a corresponding incident tracking and reporting requirements.
Mega Rule Part Three Key Dates
|November 15, 2021||Publication Date|
|May 16, 2022||Effective Date|
|November 16, 2022||Identification of Type C lines|
|March 31, 2023||2022 Annual Report Due with new classifications|
|May 16, 2023||Full compliance with 192.9|
Achieving Part Three Compliance
If you are new to PHMSA, reaching full compliance under Part Three can be overwhelming.
We’ll start with a jurisdictional determination study, reviewing your system design, operating and location conditions to determine if your previously unregulated pipe is now subject to federal or state regulations. If we find you have pipe that is now regulated, then you have new annual reporting and performance requirements.
We can help start or expand your compliance program by leveraging our mobile data CartoPac Enterprise solution to digitize your entire pipeline system. We’ll map center lines and everything you need to be compliant.
Next, we’ll use our proprietary Gas Class Location software to identify the class location, reporting, and pipe characteristics needed for gathering Type determinations. Work product deliverables include a geodatabase with centerline attribution and a comprehensive report that explains the methods, assumptions and data sources used in the study – a critical artifact for your inevitable PHMSA audit.
Our flagship integrity management software, Risk Intelligence Platform (RIPL) can then be used to identify and manage the corrosion, excavation damage, and construction defect threats also identified in Part Three.
With a comprehensive approach to identifying, assessing, providing expertise, hardware and software, and providing mitigation and other hands-on services, American Innovations and Bass Engineering are here to help.
Mega Rule Part One
Part One of the Mega Rule covers a variety of new regulations including Maximum Allowable Operating Pressure (MAOP) verification and the identification of new extended covered segments of pipelines called Moderate Consequence Areas (MCA). Here are three key points to ensure your gas pipeline is on its way toward compliance:
- Pipeline Records: All material pipeline records must be traceable, verifiable, and complete.
- MAOP Testing: Operators must confirm MAOP for qualifying pipelines, using a variety of methods. 50% of your pipeline’s MAOP must be confirmed in the first seven years of the ruling, so it’s crucial to track and document your progress. Depending on the documentation you already have, you may also need to run pressure tests and/or run lab tests on your pipe to ensure its material integrity.
- Identifying MCA: Prior to the Mega Rule, pipeline operators were required to identify segments of their pipe that have higher consequences in the event of a failure. Part One expands this regulation to cover Moderate Consequence Areas. MCAs are areas that are not classified as HCAs but contain five or more people or dwellings intended for human occupation or congregation, including major roadways. Pipeline operators must comply with additional regulations for these areas like assessment and corrosion protection to mitigate hazards.
Mega Rule Part One Key Dates
The roll-out of Part One spans 15 years. Here are the key dates you should know:
|July 1, 2020||Rule went into effect|
|December 30, 2020||Rule is officially enforced|
|July 1, 2021||Companies need a plan in place to verify MAOP and identify MCAs|
|July 3, 2028||50% of MAOP verification must be complete|
|July 2, 2035||100% of MAOP verification must be complete; must have plan in place to regularly assess MCAs|
Part One requires a long-term, focused effort to achieve compliance by 2035 and beyond. The best path forward is to use a software package like RIPL; which can be used to manage the traceable, verifiable, and completeness of the records you’ll need to comply.
In addition, our experienced GIS staff can also help identify your HCAs and MCAs through our proprietary geospatial gas Class Location software scaled to analyze every foot of thousands of miles of pipe.
Never worry again about the format, content, or completeness of your annual reports. The team behind RIPL at American Innovations and Bass Engineering can take the stress out of reporting and ensure your filing is compliant.
Mega Rule Part Two
Part Two of the Mega Rule focuses on improving pipeline integrity management best practices. While it is not yet in effect, you will need to plan ahead for what will most certainly be significant required changes to your integrity, operating and compliance procedures:
- Cathodic Protection: Gas pipeline operators must have an external corrosion management plan in place to limit the effect of electrical interference through surveying and assessment. They must then make efforts to mitigate this corrosion in a comprehensive manner alongside other test results.
- Close Interval Surveying & Assessment: If any pipe to soil measurements indicate that cathodic protection is below appropriate levels, the pipeline operator must conduct close interval surveys approximately every five feet in the affected area and remediate any issues within 12 calendar months.
- AC Interference Monitoring: Previously pipeline operators had to “consider” a recurring or continuous AC interference program to control and monitor accelerated corrosion due to power lines. Part Two now solidifies this request for “consideration” into a true requirement within 6 calendar months.
- Internal Corrosion: Pipeline operators must establish a continuous program to monitor and mitigate internal corrosion. If they find that the pipeline is actively transporting corrosive gas, they must check the affected areas at least twice annually using coupons or other relevant methods.
Achieving Part Two Compliance
There are a number of moving parts and pieces in Part Two of the Mega-Rule that must be addressed by pipeline operators.
If you’re not sure where to start, we can help you review your operations and best practices for cathodic protection. With our expertise and suite of hardware and software solutions like RIPL and PCS, you can easily update, document and manage your records.
We can also help you develop a comprehensive AC or DC Interference monitoring program. With our risk modeling software, you can assess risks and plan mitigation efforts with confidence.
When it comes to internal corrosion, many pipeline operators have no current program in place. If you’re not sure what your program should look like, what factors you may need to consider, or how and when to monitor your pipeline, we can answer these questions and develop a tailor-made continuous program based our mobile data collection solution CartoPac Enterprise.
With CartoPac Cathodic Protection, we can help you perform close interval surveys and gather data on your current cathodic protection needs. Then, we can help you and your team form a plan of action.