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 & View, Volume 47 | Material Verification Intelligence

News & View, Volume 47 | Material Verification Intelligence

By:  StevenBiles and Scott Riccardella

A new program to help pipeline operators implement the Material Verification requirements in recently released pipeline regulation (Mega Rule)

On October 1, 2019, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published the long-awaited Mega-Rule  (Part 1).  One of the major new requirements identified in these amendments is when missing traceable, verifiable, and complete records, operators must implement a Material Verification (MV) (§192.607) program.  MV requires operators of natural gas transmission pipelines, to develop and implement procedures to verify the material properties and attributes of their pipeline system.  Included in the new regulation for MV are:

  • News & View, Volume 47 | Material Verification IntelligenceDevelop procedures for conducting destructive and non-destructive testing
  • Define population groupings and implement sampling programs
  • Implement and document laboratory testing
  • Complete in situ and non-destructive evaluations (NDE)
  • Expand sampling if inconsistent results based on NDE and laboratory testing
  • Document program results and preserve for the life of the pipeline asset

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News & View, Volume 43 | A Strategic Approach for Completing Engineering Critical Assessments of Oil and Gas Transmission Pipelines

News & Views, Volume 43 | A Strategic Approach for Completing Engineering Critical Assessments of Oil and Gas Transmission Pipelines

By:  Scott Riccardella and Steven Biles

Regulatory Overview
News & View, Volume 43 | A Strategic Approach for Completing Engineering Critical Assessments of Oil and Gas Transmission PipelinesIn January 2012, the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 was signed into law directing PHMSA to take steps to further assure the safety of pipeline infrastructure.  PHMSA issued the related Notice of Proposed Rulemaking (NPRM) for Safety of Gas Transmission and Gathering Pipelines on April 8, 2016.  Included in the NPRM were significant mandates regarding:

  • Verification of Pipeline Material (§192.607); and
  • Maximum Allowable Operating Pressure (MAOP) Verification or “Determination” (§192.624)

The NPRM proposes requirements for operators to verify the MAOP of a gas transmission pipeline when:

  1. The pipeline has experienced an in-service incident (as defined by §191.3) due to select causes1 in a High Consequence Area (HCA), “piggable” Moderate Consequence Area (MCA), or Class 3 or 4 location since its last successful pressure test
  2. The pipeline lacks Traceable, Verifiable, and Complete pressure test records for HCAs or Class 3 or 4 locations
  3. The pipeline MAOP was established by the grandfather clause (§192.619 (a)(3)) for HCAs, “piggable” MCAs, or Class 3 or 4 locations.

To verify the MAOP of a pipeline, the NPRM provides the following options:

  • Method 1: Pressure Test
  • Method 2: Pressure Reduction
  • Method 3: Engineering Critical Assessment (ECA)
  • Method 4: Pipe Replacement
  • Method 5: Pressure Reduction for segments with small potential impact radius (PIR) & diameter
  • Method 6: Use Alternative Technology

The ECA Approach
Per the NPRM, Method 3 (ECA) is defined as an analysis, based on fracture mechanics principles, material properties, operating history, operational environment, in-service degradation, possible failure mechanisms, initial and final defect sizes, and usage of future operating and maintenance procedures to determine maximum tolerable sizes for imperfections. 

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