News & Views, Volume 49 | Mission Critica-nApplications to Support the Mega-Rule

News & Views, Volume 49 | Mission Critical Applications to Support the Mega-Rule

News & Views, Volume 49 | Mission Critica-nApplications to Support the Mega-RuleBy:  Scott Riccardella, Bruce Paskett, and Steven Biles

On October 1, 2019, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published amendments to 49 CFR Parts 191 and 192 in the Federal Register, issuing Part 1 of the Gas Transmission Mega-Rule.  This new regulation is commonly referred to as the Mega-Rule since it represents the most significant regulatory impact on gas transmission pipelines since the original Gas Transmission Integrity Management Program (TIMP) Regulation was issued in 2003

The original Notice of Proposed Rulemaking (NPRM) issued in April, 2016 was split into 3 Parts, with the first Part (Mega-Rule 1) including specific requirements to address congressional mandates in the 2012 Pipeline Safety Reauthorization, and other pipeline safety improvements, including:

  • Maximum Allowable Operating Pressure (MAOP) Reconfirmation (§192.624),
  • Material Verification (MV) (§192.607),
  • Engineering Critical Assessments for MAOP Reconfirmation (§192.632),
  • Analysis of Predicted Failure Pressure (§192.712),
  • Assessments Outside of High Consequence Areas (HCAs) (§192.710),
  • Additional Requirements to Evaluate Cyclic Fatigue (§192.917(e)(2)), and
  • Additional Analysis of Electric Resistance Welded (ERW) Seam Welds (§192.917(e)(4))

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News & Views, Volume 49 | Digital Elevation Modeling Support Pressure Tests Records and Reduce MAOP Reconfirmation Costs

News & Views, Volume 49 | Digital Elevation Modeling: Support Pressure Tests Records and Reduce MAOP Reconfirmation Costs

By:  Scott Riccardella, Bruce Paskett, and Eric Elder

§ 192.624(a)(1) of the Mega-Rule 1 requires MAOP Reconfirmation for steel transmission pipe segments if records necessary to establish the MAOP in accordance with § 192.619(a)(2) (e.g. pressure test), including records required by § 192.517(a), are not traceable, verifiable, and complete and the pipeline is located in a high consequence area (HCA) or a Class 3 or Class 4 location.

Part 192, Section 192.517(a) requires that natural gas pipeline operators shall make and retain, for the useful life of the pipeline, a record of the following information for any Subpart J Pressure Test (PT):

  1. The operator’s name, the name of the operator’s employee responsible for making the test, and the name of any test company used,
  2. Test medium used,
  3. Test pressur,
  4. Test duration,Pressure recording charts, or other record of pressure readings.
  5. Elevation variations, whenever significant for the particular test, and
  6. Leaks and failures noted and their disposition.

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