On Wednesday, Aug. 24, 2022, PHMSA published a final rule in the Federal Register updating pipeline safety regulations for natural gas transmission pipeline operators. This new rule modified existing regulations and introduced new regulations for operators in multiple areas, including corrosion control, management of change, integrity management, and repair criteria. This is the final portion of the renowned “Mega Rule.”
Many changes were made to the integrity management portion of the rule during this iteration. One notable update is the requirement to add specific pipeline attributes to the risk analysis. PHMSA now requires operators to include all threats under ASME B31.8S, Section 2, and ensure that the evaluations include all relevant pipeline material, construction, location, operational, leak, and corrosion history. This will require operators to ensure their program is more comprehensive and validated, including the identification of personnel who review and approve data inputs as part of the risk assessment.
Operators should review the final ruling to determine what changes in the process, algorithm, or output of their threat assessment and risk assessment may be necessary. Other significant changes to integrity management include expanded requirements for using Internal Corrosion Direct Assessment (ICDA) and Stress Corrosion Cracking Direct Assessment (SCCDA). These formalize specific process requirements in the execution of surveys and the data evaluation upon completion. PHMSA also updated definitions for repair requirements for TIMP and non-HCA segments, providing further definitions for HCA and non-HCA repair requirements based on dents, wall loss, and stress corrosion cracking.
Other significant changes include updates to non-IMP pipeline segment repair criteria. PHMSA now requires operators to ensure that the pipeline’s operating pressure is less than the predicted failure pressure during repair operations as determined by 192.712. It also requires that all repairs are documented in a tracible, verifiable, and complete manner. Any found conditions must be scheduled and prioritized, providing requirements for identification and classification of immediate, two-year, and monitoring repair anomalies. This mimics the current provisions contained in the integrity management code section.
Operators should also pay special attention to the corrosion control updates as PHMSA has made significant changes. One change is the requirement for an above-ground indirect assessment promptly after backfilling to identify locations of suspected damage or anytime there is an indication that coating may be compromised. This survey is required if the backfill is over 1000’ and must be performed within six months of the backfill being performed.
Another change is the requirement that operators have a remedial action plan developed, and permits obtained, within six months of the completion of the inspection or testing. Any corrective action must be completed promptly but either within one year, not-to-exceed 15 months, or within six months after obtaining any permits, whichever is sooner.
PHMSA has identified specific requirements based on NACE SP0502 standards for severe indications on ACVG/DCVG surveys, providing a benchmark for operators to use for evaluations. They also updated the requirements for monitoring and remediation, requiring that operators now determine the extent of the area with inadequate cathodic protection based on the annual test reads. This mandates that operators perform a close-interval survey (CIS) if an inadequate test reading is discovered and requires operators to act when necessary.
Regulations have been updated to require that every operator have programs to address interference currents, monitoring requirements for internal corrosion with new definitions for dry gas, and requirements for interrupted CP systems with enhanced remedial action requirements.
There are also significant changes to the management of change requirements (MOC). PHMSA now requires transmission line operators to have a MOC process that operates per the requirements in ASME B31.8S, Section 11, to include all portions of that section. PHMSA’s goal is to expand MOC requirements currently enforced as part of the control room, operator qualifications, and IMP regulations into a full-scale, companywide MOC program.
Operators must understand which regulations will apply to their line segments, as a large portion of these items are long-term and must be incorporated into existing plans before execution. The effective date of this rule is nine months from the date of publication, with most requirements having another nine months to develop compliance solutions.
If you have any questions or need help meeting these new requirements, please call Al Giordano at 713-260-4007.