The oil and gas industry has been working the past year to implement integrity management and mitigating plans in response to the Pipeline Hazardous Materials and Safety Administration’s (PHMSA) “Gas Mega Rule” which was adopted in 2019 and went into effect on July 1, 2020.

Split into the three parts, the Gas Mega Rule looks to prevent pipeline spills and deadly gas explosions by strengthening safety in more than 500,000 miles of pipelines that carry natural gas, oil, and other hazardous materials in the U.S.

“The new Gas Mega Rule essentially doubles previous regulations for onshore gas transmission, with the goal of improving pipeline safety,” writes Lightbox, a leading provider of due diligence, risk management, location intelligence, workflow solutions for the oil and gas industry. “With changing regulations for operations and increased requirements for reporting, oil & gas and engineering firms will need to ensure they are in complete compliance.”

According to oil and gas pipeline industry law firm Troutman Pepper, the Gas Mega Rule is broken into these three parts:

1.     Safety of Gas Transmission Pipelines: Maximum Allowable Operating Pressure Reconfirmation, Expansion of Assessment Requirements, and Other Related Amendments

2.     Safety of Hazardous Liquid Pipelines

3.     Enhanced Emergency Order Procedures 

“These are significant revisions to federal pipeline safety laws and will improve the safety of our nation’s energy infrastructure,” said then U.S. Transportation Secretary Elaine L. Chao.

History of the “Gas Mega Rule”

The Gas Mega Rule has been a decade in the making with the roots taking place after a massive gas explosion in San Bruno, Calif., on Sept. 9, 2010 killed 8, injured 51 while destroying 38 homes and damaging another 70 homes.

Pipeline & Gas Journal also cited “large oil spills into Michigan's Kalamazoo River in 2010 and the Yellowstone River in Montana in 2011 and 2015” as impetus to get the rules in place.

“The tremendous growth in U.S. energy production will require greater anticipation and preparation for emerging risks to public safety,” said then PHMSA Administrator Skip Elliott. “These forward-looking rules will help ensure pipeline operators invest in continuous improvements to pipeline safety and integrity management.”

The road to enactment for each of the Gas Mega Rule three parts, according to Troutman Pepper:

• Part 1 Gas Transmission Rule started with National Transportation Safety Board recommendations after the San Bruno incident as well as Pipeline Safety Act amendments of 2011 and 2016. The effective final rule was July 1, 2020.
• Part 2 Liquid Pipeline Safety Rule was initially cleared for publication in 2017 but then withdrawn with the transition from the Obama to the Trump administrations. The effective final rule was July 1, 2020.
• Part 3 Enhanced Emergency Order Procedures was mandated by the Pipeline Safety Act amendments of 2016 and became an interim final rule in October 2016. The effective final rule was Dec. 2, 2019.

The 500+ pages of new regulations have a lot of ground for oil and gas pipeline providers to cover. Some key elements include:

• Establish an Integrity Management Plan and all required procedures documented by July 1, 2021
• Verify 50 percent of pipeline mileage by July 3, 2028
• Verify 100 percent of pipeline mileage by July 2, 2035

According to LightBox and the Pipeline & Gas Journal, here is a summary of each the three parts:

Part 1 Gas Transmission Rule

The gas transmission rule requires operators to test all pipelines for Maximum Allowable Operating Pressure (MAOP) to determine the material strength of their lines, including gas transmission pipelines constructed before 1970 which were previously exempt from safety rulings. Companies must get 50 percent of the work done under the new rules within seven years and all work done by 2035.

In addition, the rule updates reporting and records retention standards for gas transmission pipelines. Companies must provide clear, traceable records and more comprehensive reporting for certain hazardous liquid gravity and rural gathering lines. Operators will have to report on exactly what they have in the ground.

There are new requirements regarding testing and sampling before something can be deemed verified. For operators without records to support what is in the ground, they will need to test and inspect pipelines and then report the findings.

Part 2 Liquid Pipeline Safety Rule

The liquid pipeline safety rule encourages operators to make better use of available data to understand safety threats and extends leak detection requirements to all non-gathering hazardous liquid pipelines. New repair requirements for High Consequence Areas (HCAs) and non-HCAs.

The rule requires operators to inspect affected pipelines within 72 hours following an extreme weather event or natural disaster, such as a hurricane, earthquake, flood, and landslide, so they may address any resulting damage.

Pipeline integrity assessments will be required at least once every 10 years. Operators will also have to install, or expand, leak detection systems, and make modifications to accommodate inline inspection tools such as “smart pigs”. 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 the pipeline cannot accommodate a leak detection system.

Part 3 Enhanced Emergency Order Procedures

The third part of the Gas Mega Rule adopts the provisions of the 2016 interim rule which established temporary emergency order procedures in accordance with a provision of the “Protecting our Infrastructure of Pipelines and Enhancing Safety Act of 2016”. An emergency order may impose emergency restrictions, prohibitions, and other safety measures on owners and operators of gas or hazardous liquid pipeline facilities.

Contact GeoCorr today to find out how our pipeline inspection technologies can meet any challenge including meeting the demands of the Gas Mega Rule.