Pipeline Integrity Management: PHMSA Mega Rule – Part 2
Part 2 of Mega Rule aims to enhance gas transmission pipeline safety, improve corrosion control, strengthen integrity management (IM) practices, and mitigate risks associated with pipeline operations. It uses a proactive, risk-based approach to set higher standards for the industry to ensure the protection of communities, the environment and critical infrastructure. This section has an extended effective date from May 24, 2023 to February 24, 2024. The scope of Part 2 includes:
- IM clarifications
- Management of Change (MOC)
- Corrosion Control
- Inspections following Extreme Weather Events
- Updated Assessment Requirements
- Repair Criteria
A complete IM program begins with a framework that addresses the risk of each pipeline segment. The initial IM program must contain, at minimum, a plan for implementing the following elements:
- Threat identification
- Data collection
- Data integration
Factors such as time-dependent/independent threats, resident, and human error should all be accounted for within the scope of threat identification. The data should also include information about the year of installation, inspection reports, leak history, operating parameters, pertinent data, and other safety evaluations. As more information becomes available over time, operators must make continual improvements to the IM program based on the most significant integrity threats. Operators must consider each pipeline segment that could affect HCAs and class 3 and class 4 locations outside HCAs. PHMSA expects operators to refine their IM programs and periodically evaluate the effectiveness of their processes.
Management of Change
A MOC process should be outlined as part of an operator’s IM program. The MOC process should be comprehensive and note all technical, physical, procedural and organizational changes. These should be noted regardless of whether they are temporary or permanent changes. The MOC process should also note the reason for the changes, as well as its implications, and which authority approved the changes. Significant changes to the pipeline system may also require updating the IM program. In short, the MOC program helps ensure the IM processes are still effective when making changes to a piping system.
Note that this new requirement is expected to be completed by August 24, 2024. PHMSA states that this is reasonable, as this would be an “implementation of a procedure that operators already have in place for HCA pipeline segments”. Operators may apply for a 1-year extension with the approval of PHMSA.
Frequent incidents caused by corrosion demonstrate the ongoing need for effective regulations. PHMSA continually updates its corrosion control requirements to improve asset integrity and safety precautions. As such, PHMSA outlined several sections which propose updates to the existing regulations. These changes impact integrity assessments for newly installed pipe (>1,000-ft), internal corrosion, cathodic protection (CP) and other preventative measures. Operators must take prompt action to mitigate any potential damage to the pipeline, in which “prompt” is newly defined in the regulation. Pursuant to Section 192.935, operators must also bolster their corrosion control programs in HCAs with additional measures, such as pressure transmitters, periodic re-coatings, and additional surveys at roads, streams, and rivers, among other areas.
Extreme Weather Events
PHMSA is modifying the inspection requirements following extreme weather events, such as hurricanes, tornados, or floods. Upon determining whether the affected area can be safely accessed, operators have 72 hours to perform necessary inspections. If operators are unable to complete the inspection within the 72-hour timeframe, they must notify PHMSA as soon as possible. If an operator determines the pipeline incurred damage from the event, remedial action must be taken. Such actions include, but are not limited to:
- Reducing operation
- Performing leak tests
- Repairing or replacing damaged pipeline segments
- Performing additional inspections
- Mitigating risk in HCAs
Updated Assessment Requirements
The current corrosion assessment methods are incomplete in many areas. Some regulations do not specify the effectiveness of certain methods and others only apply to pipelines in certain environments. In the interest of wholeness, PHMSA is updating two corrosion assessment methods:
- Internal Corrosion Direct Assessment (ICDA) — only pipeline-specific data should be analyzed for indirect examinations. For direct examinations, locations are required to be analyzed based on the results of flow modeling calculations. If corrosion is found, a more detailed examination must be conducted to identify all segments (not only covered segments) within the pipeline that have internal corrosion.
- Stress Cracking Corrosion Direct Assessment (SCCDA) — at least two above-ground surveys must be conducted for indirect examinations. At least three locations must be analyzed for direct examinations based on the areas where SCC is most likely to occur. PHMSA also expanded the scope of SCC regulations to examine different pH levels, the effects of coatings and cathodic protection, and other factors associated with SCC.
Several repair updates have been made since the IM rule went into effect in 2004. Based on information gained through ongoing research and development, PHMSA proposed that operators make repairs according to a schedule that prioritizes the conditions for remediation and repair. The timeline for a repair corresponds with one of the following conditions:
- Immediate Repair Conditions
- Two-year Conditions
- Monitored Conditions
- Temporary Pressure Reduction
Of course, the complete schedule of repairs for gas transmission pipelines includes information based on specific integrity threats. Those details can be found here.
Note: Operators must notify PHMSA within 180 days following an assessment to determine if the defects present a threat to the integrity of the pipeline.
At Pond, we offer a comprehensive range of full-service support in areas such as IM, risk assessment, corrosion controls, indirect surveys, pipeline design, recommended repairs, direct examination, and field services. We are committed to helping operators comply with the expanded Mega Rule guidelines for mitigating risks and ensuring the utmost safety for the community, the environment, and nearby infrastructure. For a detailed list of Pond’s services, click here.