On July 1, 2020, after roughly 8 years of going through the proper procedures for recommendations and reviews, the Pipeline Hazardous Materials and Safety Administration’s (PHMSA) new Gas Mega Rule finally went into effect. The new Gas Mega Rule essentially doubles previous regulations for onshore gas transmission, with the goal of improving pipeline safety. With changing regulations for operations and increased requirements for reporting, oil & gas and engineering firms will need to ensure they are in complete compliance.
We’ve put together a guide providing an overview of the new PHMSA Gas Mega Rule, the expected impact on oil & gas and engineering firms, and how to leverage GIS tools to ensure changes required for compliance happen as smoothly and easily as possible.
The PHMSA Gas Mega Rule explained
Pipe failures are relatively uncommon, but when they do occur, they are high-impact events with devastating consequences for the local environment and population. According to the Significant Incident Consequences Summary released by PHMSA, pipeline incidents between 2005-2017 resulted in 168 fatalities, 592 injuries, and over $5.4 billion in total costs. Additionally, these events require rapid mobilization of local resources, such as police and fire departments, as well as medical personnel. The Gas Mega Rule is expected to greatly improve safety and help prevent future incidents.
The rule is split into three parts. Two of the rules focus on changes to safety standards that apply to gas pipelines and hazardous liquid pipelines. The third rule changes the procedures required to issue emergency orders. A brief summary of the three rules is below.
Part 1 of the PHMSA Gas Mega Rule
Part 1 contains changes to the regulations for gas transmission lines and new requirements for the verification of pipeline materials. This part of the rule aims to improve safety with transportation and operation of onshore gas transmission pipelines.
Operators will have to test all pipelines for Maximum Allowable Operating Pressure (MAOP) to ensure their safety, including lines that had been exempted from previous safety rulings. Companies will have 14 years to comply with this new measure, but 50% of the work must be done within the first seven years. All companies must provide clear, traceable records and more comprehensive reporting is required for certain hazardous liquid gravity and rural gathering lines.
Pipeline operators will have to know and report on exactly what they have in the ground. There are new requirements for how much sampling and testing must be done to call something verified. If operators do not have records to support what’s in the ground, they must test and inspect pipelines and then report findings to PHMSA.
Part 2 of the PHMSA Gas Mega Rule
Part 2 of the Gas Mega Rule contains new repair requirements for High Consequence Areas (HCAs) and non-HCAs. The rule also states operators must inspect pipelines within 72 hours of extreme weather events and natural disasters, such as hurricanes, floods, earthquakes, and landslides. Additionally, pipeline integrity assessments will be required at least once every 10 years.
Operators will also have to install or expand on leak detection systems, and modifications to accommodate inline inspection tools. Leak detection requirements extend to all non-gathering hazardous liquid pipelines. Pipelines located in HCAs must be compliant within 20 years unless the basic construction of a pipeline cannot accommodate a leak detection system.
Part 3 of the PHMSA Gas Mega Rule
Part 3 of the PHMSA Gas Mega rule focuses on issues related to gas gathering lines and includes new requirements for emergencies that provide PHMSA with the authority to issue emergency orders. This will more easily allow PHMSA to address imminent hazards that could impact the industry, such as unsafe conditions or faulty components used on a pipe. For liquids, PHMSA’s final rule encourages pipeline operators to “make better use of all available data to understand pipeline safety threats.” Additionally, the rule states that they must review HCAs as well as Moderate Consequence Areas (MCAs).
How has COVID-19 impacted the PHMSA Gas Mega Rule?
The PHMSA Gas Mega Rule was drafted well before anyone knew that COVID-19 was about to disrupt the world. As a result, some accommodations needed to be made.
Many employees in the oil & gas industry are considered essential, particularly those who ensure pipeline safety. Workers inspecting oil pipelines, repairing leaks, and maintaining and operating special equipment were already facing challenges due to the pandemic, and the Mega Rule puts added stress and pressure onto the workforce. Proponents of the new PHMSA Gas Mega Rule argued that inspections and safety were weak to begin with and are concerned that the COVID-19 pandemic continues to delay operational safety. They question whether it’s best to shut down the riskiest oil pipelines that clearly fall far short of the new guidelines, but this has not been called for yet.
The bulk of the Rule went into effect on July 1, 2020, and PHMSA reportedly received complaints from oil & gas pipeline operators. PHMSA decided to suspend enforcement actions and is encouraging maximum regulatory flexibility during the pandemic, which is considered a national emergency. Due to constrained resources resulting from the COVID-19 pandemic, PHMSA announced a six-month stay of enforcement of initial compliance deadlines. This provides operators with additional time to fully incorporate new procedures into their management of changes process.
Limitations to the stay include the hazardous liquid rule, which must proceed on the original timeline. PHMSA also makes it clear that they can rescind the stay if they determine a safety issue warrants doing so. Plus, anyone taking advantage of the stay will need to keep records proving justification for needing it.
How oil & gas and engineering companies can manage risk and maintain compliance
GIS/location technology will play a major role in supporting oil & gas companies and engineering firms as they transition into the new requirements set forth by PHMSA. Spatial intelligence and location technology provide the geospatial data integration and storage necessary to transition into new compliance standards as seamlessly as possible.
Location technology delivers hundreds of data points relating to parcels of land. This information is continually updated for accuracy. Location intelligence solutions feature map-ready content making it easier to illustrate complex data points, analyze data to predict potential problems, and track and manage data for reporting. Check out some examples below.
Tracking pipeline location
Upload pipeline locations into a digital map, where you’ll be able to see where pipes are currently located overlaid with information like population and hazard data. You can also review historic data of those areas to see how they’ve changed over time and whether those changes could impact pipeline integrity.
Deliver proper reporting
Much of the PHMSA Gas Mega Rule calls for improved, consistent reporting. A location intelligence solution like LandVision™ provides dynamic reporting tools that can be included with reports to PHMSA, such as timestamped maps with notations. Your pipeline data report can be easily pulled up and created within minutes.
Additionally, location intelligence helps identify HCAs and MCAs, as well as any changes that have occurred in those areas. The new rules require companies to determine the factors in the original HCA analysis and identify whether any of those factors have changed, and then how changes could affect segment identification. Companies must maintain these records, and they must be traceable, verifiable, and complete (TVC).
Risk modeling is a huge factor in the Gas Mega Rule. Location technology provides access to hazard data and will be essential for remaining in compliance with the Weather Related Event (WRE). This rule calls for inspections within 72 hours of a weather event or other type of natural disaster. Oil & gas and engineering firms will have to look for pipeline damage caused by scouring or movement of surrounding soil that can result from tropical storms, floods, landslides, hurricanes, or earthquakes. PHMSA must be notified if there is evidence of a problem, such as corrosion, and the resolution must also be reported.
Location technology makes it easier to track and report on which pipelines are at greatest risk from WREs, and can also track seismicity, geology, and soil stability.
Analyze location data to mitigate risk
Access to hazard data, both current and historic, allows gas & oil companies to analyze information that can help mitigate risk. PHMSA states in the new rule that pipeline operators will have to identify where the higher risk pipelines are, so they can test those first and then fix them if needed. Location intelligence makes it faster and easier to identify those higher risk areas.
Additionally, if an accident were to occur or maintenance were required, a location platform with owner information makes it easy to contact affected property owners—including printing out labels needed for mailers. Quick contact with owners will help reduce harm in the event of an accident.
Easy collaboration between remote teams
Oil & gas and engineering companies are typically working with multiple remote teams and workers. Whether you’re in the office or in the field, a location intelligence platform can make collaboration easier by updating data across users in real-time. This ensures everyone can remain consistent using the same data points, and no one is working off of outdated information. Reporting and updates are saved in the system, and authorized users will be able to access the information they need anytime and from any place.
Simple integration into your existing workflow
Our North American parcel database, makes it easy to integrate location data into your existing workflow. You don’t have to change how you work. Instead, you integrate the data you need into your platform or software in the way that makes the most sense for you.
LightBox is the trusted GIS solution for oil & gas and engineering companies
LightBox offers solutions to update and maintain georeference asset maps and records of pipelines. Our platform helps oil & gas and engineering companies develop, update, and maintain pipeline assets.