Learn more about the PHMSA final rule for gas transmission pipelines

1. PHMSA Final Rule for Gas Transmission Pipelines
August 2021
PIPELINE INTEGRITY
WEBINAR SERIES:

2. TODAY’S SPEAKER
Bryan Louque has over 25 years of
experience in the pipeline industry. He
has been involved with the design,
construction, and O&M of pipeline
systems with an emphasis on corrosion
control, pipeline integrity and
regulatory compliance programs on
hazardous liquids (Part 195) and
natural gas (Part 192) pipeline systems.
Bryan Louque, P.E.
Vice President of Asset Integrity and Corrosion
Audubon Companies

3. Agenda
 When is the Gas Transmission Rule Effective?
 What’s in the Gas Transmission Rule?
 What’s not in the Gas Transmission Rule?
 What’s Next?
 Q&A
WHY AM I HERE?
September 2010 October 2019

4. WHEN IS THE RULE EFFECTIVE?
Effective Date – July 1, 2020
TICK
TOCK

5.  March 20, 2020 - Enacted
 May 26, 2021 - Terminated
§ 191, § 192 & § 195 Stay Due to COVID 19
ENFORCEMENT UPDATE

6. WHAT’S IN THE RULE?
§ 191.23 & 191.25 Reporting Safety-Related Conditions
What’s New?
 Clarifies the SRC reporting requirement for pipeline
operational pressures that exceed MAOP (plus buildup)
• Required information
• Reporting timeframes
• Contact information
Key Exceptions
 Gathering Lines
 Distribution lines
 LNG facilities

7. WHAT’S IN THE RULE?
What is the Impact?
 The impact is LOW
 Modify O&M manual to reflect reporting requirements
§ 191.23 & 191.25 Reporting Safety-Related Conditions

8. WHAT’S IN THE RULE?
§ 192.3 Definitions
What’s New?
 Adds definitions for:
• Engineering Critical Assessment (ECA)
• Moderate Consequence Area (MCA)
Key Exceptions
 Traceable, Verifiable and Complete (TVC) definition not
included rule
 Defined in the preamble to the rule
 Examples given

9. WHAT’S IN THE RULE?
§ 192.3 Definitions (cont.)
Engineering Critical Assessment (ECA)
 A documented analytical procedure based on
• Fracture mechanics principles
• Relevant material properties (mechanical and fracture
resistance properties)
• Operating history, operational environment and in-service
degradation
• Possible failure mechanisms
• Initial and final defect sizes
• Usage of future operating and maintenance
procedures to determine the maximum tolerable
sizes for imperfections based upon the
pipeline segment MAOP

10. WHAT’S IN THE RULE?
§ 192.3 Definitions (cont.)
Moderate Consequence Area (MCA)
 An onshore area that is within a potential impact radius (PIR),
as defined in § 192.903, containing either
• Five or more buildings intended for human occupancy; or
• A principal, arterial roadway with 4 or more lanes,
including any portion of the paved surface, including
shoulders, of a designated interstate, other freeway, or
expressway (National Highway System).
December 2012

11. WHAT’S IN THE RULE?
What is the Impact?
 The Impact is MODERATE
 Review ECA process to determine if beneficial to use
 Define pipeline moderate consequence areas
§ 192.3 Definitions

12. WHAT’S IN THE RULE?
§ 192.7 What documents are incorporated by reference partly or
wholly in this part?
What’s New?
 Incorporated by reference
• ANSI/ASNT ILI-PQ-2005(2010), “In-line Inspection
Personnel Qualification and Certification”
• AGA, Pipeline Research Committee Project
PR-3-805, (R-STRENG)
Key Exceptions
 None

13. WHAT’S IN THE RULE?
• What is the Impact?
 The Impact is LOW
 Modify ILI procedures to reflect new requirements
§ 192.7 What documents are incorporated by reference partly or
wholly in this part?

14. § 192.9 What requirements apply to gathering lines?
What’s New?
 Specifically exempts gathering lines from the requirements
enacted as part of this rule
Key Exceptions
 192.67 – Materials; Record collection and record maintenance
 192.127 – Pipe Design and § 192.205 - Pipeline Components
 192.619 – MAOP
 192.227 – Qualification of Welders (Type A Only)
 192.517 – Records: Tests
 192.750 – Launcher and receiver safety
WHAT’S IN THE RULE?

15. What is the Impact?
 The Impact is MODERATE
 Gathering line requirements to be addressed
in future rules
WHAT’S IN THE RULE?
§ 192.9 What requirements apply to gathering lines?

16. § 192.18 How to notify PHMSA (New Section)
What’s New?
 Provides contact information to notify PHMSA
• Requires a 90-day advance notification if the operator
intends to employ an alternate integrity assessment
method, analytical method, sampling approach, or
technique (i.e., “other technology”)
• Operator may proceed with the proposed other
technology unless notified otherwise by PHMSA
Key Exceptions
 None
WHAT’S IN THE RULE?

17. What is the Impact?
 The Impact is LOW
 Modify O&M manual to reflect new requirements
 Modify IMP to reflect new requirements
WHAT’S IN THE RULE?
§ 192.18 How to notify PHMSA (New Section)

18. § 192.67 Records: Material Properties (New Section)
What’s New?
 Steel transmission pipelines installed
• After July 1, 2020 - Retain all records for the life of the pipeline
• Prior to July 1, 2020 - Retain any such records for the life of the
pipeline
 Record requirements
• Document the physical characteristics of the steel transmission
pipeline, including diameter, yield, UTS, wall thickness, seam
type, and chemical composition
 Includes all tests, inspections, and attributes required at the time
the pipe was manufactured.
Key Exceptions
 None
WHAT’S IN THE RULE?

19. What is the Impact?
 The impact is MODERATE
 Update record retention practices to reflect new
requirements
 Modify GIS schema to reflect TVC requirements
WHAT’S IN THE RULE?
§ 192.67 Records: Material Properties (New Section)

20. § 192.127 Records: Pipe Design (New Section)
What’s New?
 Steel transmission pipelines installed
• After July 1, 2020 - Retain records for the life of the
pipeline
• Prior to July 1, 2020 - Retain any such records for the life of
the pipeline
 External pressure and loads
• 192.103 Pipe Design – General
 Design pressure
• 192.105 Design Formula
Key Exceptions
 None
WHAT’S IN THE RULE?

21. What is the Impact?
 The Impact is MODERATE
 Update record retention practices to reflect new
requirements
WHAT’S IN THE RULE?
§ 192.127 Records: Pipe Design (New Section)

22. § 192.205 Records: Pipeline Components (New Section)
What’s New?
 Steel transmission pipelines installed
• After July 1, 2020 - Retain records for the life of the
pipeline
• Prior to July 1, 2020 - Retain any such records for the life of
the pipeline
 Valve manufacturing and pressure rating records
 Applies to flanges, fittings, branch connections, extruded
outlets, anchor forgings, and other components where
• SMYS ≥ 40 ksi and Diameter > 2 inches
Key Exceptions
 None
WHAT’S IN THE RULE?

23. What is the Impact?
 The Impact is MODERATE
 Update record retention practices to reflect new
requirements
 Modify GIS schema to reflect TVC requirements
WHAT’S IN THE RULE?
§ 192.205 Records: Pipeline Components (New Section)

24. § 192.150 Passage of Internal Inspection Devices
What’s New?
 NACE SP0102, In-Line Inspection of Pipelines, incorporated by
reference
Key Exceptions
 None
WHAT’S IN THE RULE?

25. What is the Impact?
 The Impact is LOW
 Review and compare NACE SP0102 with existing ILI
procedures
 Modify ILI procedures to reflect new requirements
WHAT’S IN THE RULE?
§ 192.150 Passage of Internal Inspection Devices

26. § 192.227 Qualification of Welders
What’s New?
 Steel pipelines
• Maintain individual welder qualifications for a minimum of
5 years post construction
• Will also apply to Type A gathering systems
 Effective July 1, 2021
Key Exceptions
 None
WHAT’S IN THE RULE?

27. What is the Impact?
 The Impact is LOW
 Update record retention practices to reflect new
requirements
WHAT’S IN THE RULE?
§ 192.227 Qualification of Welders

28. § 192.285 Plastic Pipe: Qualifying Persons to Make Joints
What’s New?
 Non-metallic pipelines
• Maintain individual pipeline joining qualifications for a
minimum of 5 years post construction
 Effective July 1, 2021
Key Exceptions
 None
WHAT’S IN THE RULE?

29. What is the Impact?
 The Impact is LOW
 Update record retention practices to reflect new
requirements
WHAT’S IN THE RULE?
§ 192.285 Plastic Pipe: Qualifying Persons to Make Joints

30. § 192.493 In-Line Inspection of Pipelines (New Section)
What’s New?
 Incorporated by reference
• API 1163, In-Line Inspection Systems Qualification
Standard
• ANSI/ASNT ILI-PQ, In-Line Inspection Personnel
Qualification and Certification
• NACE SP0102, In-Line Inspection of Pipelines
Key Exceptions
 None
WHAT’S IN THE RULE?

31. What is the Impact?
 The Impact is MODERATE
 Review and compare standards with existing ILI procedures
 Modify ILI procedures to reflect new requirements
(validation)
WHAT’S IN THE RULE?
§ 192.493 In-Line Inspection of Pipelines (New Section)

32. § 192.506 Transmission lines: Spike Hydrostatic Pressure Test
(New Section Added)
What’s New?
 Defines the requirements steel pipeline spike hydrostatic test
• SMYS ≥ 30%
• Test medium = Water
• Test duration = 8 hours min
• Spike test pressure to lesser of 1.5 times MAOP or 100%
SMYS and hold for 15 minutes (within first two hours of
test)
Key Exceptions
 None
WHAT’S IN THE RULE?

33. What is the Impact?
 The Impact is LOW
 Review and compare standards with existing hydro
procedures
 Modify hydro procedures to reflect new requirements
WHAT’S IN THE RULE?
§ 192.506 Transmission lines: Spike Hydrostatic Pressure Test
(New Section Added)

34. § 192.619 Maximum Allowable Operating Pressure:
Steel or Plastic Pipelines (Records)
What’s New?
 Steel transmission pipelines installed
• After July 1, 2020 - Retain records for the life of the
pipeline
• Prior to July 1, 2020 - Retain any such records for the life
of the pipeline
 (a)(4) MAOP reconfirmation (§ 192.624) required to address
record retention gaps
Key Exceptions
 None
WHAT’S IN THE RULE?

35. What is the Impact?
 The Impact is HIGH
 Identify all pipeline sections where MAOP verification gaps
exists
 Review records for compliance to TVC standard
 Link TVC records to GIS segments
WHAT’S IN THE RULE?
§ 192.619 Maximum Allowable Operating Pressure:
Steel or Plastic Pipelines (Records)

36. § 192.607 Verification of Pipeline Material Properties and
Attributes: Onshore Steel Transmission Pipelines (New Section)
What’s New?
 In and of itself, § 192.607 adds no new requirements
• Only required for § 192.619 MAOP re-confirmation
 Defines requirements for verification of steel transmission
pipeline material properties and attributes
• Maintain records for life of pipeline
• Records must be traceable, verifiable, complete (TVC)
• Develop procedure to verify incomplete records via
destructive or non-destructive tests
WHAT’S IN THE RULE?

37. § 192.607 Verification of Pipeline Material Properties and
Attributes: Onshore Steel Transmission Pipelines. (New Section)
What’s New?
 Testing may be performed at opportune times
• Anomaly direct examination
• In Situ evaluations
• Repairs, remediations & maintenance digs
• Excavations associated with replacements or relocations
 Non-destructive and destructive test requirements
• Minimum Yield Strength (SMYS)
• Ultimate Tensile Strength (UTS)
WHAT’S IN THE RULE?

38. § 192.607 Verification of Pipeline Material Properties and
Attributes: Onshore Steel Transmission Pipelines (New Section)
What’s New?
 Sampling program for pipeline sections where information is
incomplete
• Populations of common characteristics & age (FAQ-18)
• Tests required per population is 1 per mile or 150 total,
whichever is less
• Prior tests may be utilized
• Unexpected or non-confirmatory results
• Expanded sampling program @ 95% confidence level
WHAT’S IN THE RULE?

39. § 192.607 Verification of Pipeline Material Properties and
Attributes: Onshore Steel Transmission Pipelines (New Section)
What’s New?
 Component material verification
• Required for
◦ Diameter > 2”
◦ SMYS ≥ 42 ksi
◦ Cannot be isolated from pipeline
• Not required for
◦ Compressor, meter & regulator stations
◦ Separators
◦ River crossing headers
◦ MLV’s and valve operator piping
◦ Cross-connection isolation valves
• Verify ANSI pressure ratings
WHAT’S IN THE RULE?

40. § 192.607 Verification of Pipeline Material Properties and
Attributes: Onshore Steel Transmission Pipelines (New Section)
Key Exceptions
 None
What is the Impact?
 The Impact VARIES
 Depends on presence or absence of TVC records
 Develop sampling program for unexpected results
 How many digs are sufficient to comply?
WHAT’S IN THE RULE?

41. § 192.619 Maximum Allowable Operating Pressure:
Steel or Plastic Pipelines
What’s New?
 MAOP modifications
• Class 1 safety factor raised from 1.1 to 1.25 for pipe
installed after effective date
• Applies to Type A & Type B gathering lines
• MAOP established under§ 192.619 (a)(4) must account for
the material property requirements under § 192.607
• May be required to re-confirm the MAOP of the pipeline
under the new section § 192.624
• Comply with new MAOP record retention requirements
Key Exceptions
 None
WHAT’S IN THE RULE?

42. What is the Impact?
 The Impact is MODERATE
 Modify design procedures to reflect new safety factor
requirements
 May be required to reconfirm MAOP due to incomplete TVC
records
WHAT’S IN THE RULE?
§ 192.619 Maximum Allowable Operating Pressure:
Steel or Plastic Pipelines

43. § 192.624 Maximum Allowable Operating Pressure Re-Confirmation:
Onshore Steel Transmission Pipelines (New Section)
What’s New?
 Steel pipeline MAOP reconfirmation required for
• § 192.619(a) MAOP establishment – Incomplete TVC records
and pipeline is located in:
◦ A High Consequence Area (HCA); or
◦ A Class 3 or Class 4 location
• § 192.619(c) MAOP establishment (grandfather clause) - SMYS
≥ 30% and pipeline is located in
◦ A High Consequence Area (HCA); or
◦ A Class 3 or Class 4 location; or
◦ A Moderate Consequence Area (MCA), if piggable
WHAT’S IN THE RULE?

44. What’s New?
 MAOP re-confirmation compliance deadlines
• July 1, 2021 - Develop MAOP re-confirmation procedures
• July 3, 2028 - Complete 50% of re-confirmations
• July 2, 2035 – Complete 100% of re-confirmations
• 4 years maximum post pipeline segment category change
or pipeline segment falls into category requiring MAOP
re-confirmation
WHAT’S IN THE RULE?
§ 192.624 Maximum Allowable Operating Pressure Re-Confirmation:
Onshore Steel Transmission Pipelines (New Section)

45. What’s New?
 MAOP re-confirmation methods
• Pressure test and TVC records for diameter, wall thickness,
seam type and grade (Design Calc)
• Pressure reduction – 5 year lookback with safety factor
applied
◦ Highest operating pressure
◦ Low Stress Pipelines - Highest operating pressure
combined with periodic patrol and leak survey
• § 192.632 Engineering Critical Assessment
• Pipe replacement
• Alternative technology
WHAT’S IN THE RULE?
§ 192.624 Maximum Allowable Operating Pressure Re-Confirmation:
Onshore Steel Transmission Pipelines (New Section)

46. Key Exceptions
 None
What is the Impact?
 The Impact is HIGH
 Develop MAOP re-confirmation process
• Review all pipeline records from one end to the other
• For entire pipeline, not just required area
• Update GIS data base
 Verify MAOP re-confirmation methods comply with
allowable methods
WHAT’S IN THE RULE?
§ 192.624 Maximum Allowable Operating Pressure Re-Confirmation:
Onshore Steel Transmission Pipelines (New Section)

47. § 192.632 Engineering Critical Assessment for Maximum Allowable
Operating Pressure Re-Confirmation:
Onshore Steel Transmission Pipelines (New Section)
What’s New?
 New MAOP confirmation method - ECA
• Conservative assumptions used for missing TVC values
• Analyze & determine defect predicted failure pressure
• MAOP is determined by lowest predicted failure pressure
with safety factor applied
Key Exceptions
 None
 “Path” to utilize where hydro records are incomplete
WHAT’S IN THE RULE?

48. What is the Impact?
 Identify any segments that require cyclic fatigue or crack /
crack like defect threat analysis.
WHAT’S IN THE RULE?
§ 192.632 Engineering Critical Assessment for Maximum Allowable
Operating Pressure Re-Confirmation:
Onshore Steel Transmission Pipelines (New Section)

49. § 192.710 Transmission lines: Assessments Outside of High
Consequence Areas (New Section)
What’s New?
 Assessment outside HCA’s where:
• SMYS ≥ 30%
• Class 3 or Class 4 areas
• MCA, if piggable
 Deadline - July 3, 2034 or 10 years post segment categorization
 Reassessment interval – 10 years
 Methods - ILI, hydro, spike hydro, direct examination,
DA, and GWUT
Key Exceptions
 None
WHAT’S IN THE RULE?

50. What is the Impact?
 The Impact is HIGH
 Modify O&M to reflect new requirements (Not part of
Subpart O)
 Define pipeline moderate consequence areas
WHAT’S IN THE RULE?
§ 192.710 Transmission lines: Assessments Outside of High
Consequence Areas (New Section)

51. § 192.712 Analysis of Predicted Failures (New Section)
What’s New?
 Defect failure pressure analysis
• Corrosion - ASME/ANSI B31G or R-STRENG
• Cracks and Crack Like Defects - Models
 Crack growth models
• TVC records include CVN data (§ 192.607)
• Defect stability
• Remaining life
• Precision / accuracy of assessment data
• Conservative assumptions until assessed
Key Exceptions
 None
WHAT’S IN THE RULE?

52. What is the Impact?
 The Impact is MEDIUM
 Determine susceptibility to cracks and crack like defects
 Modify O&M procedures to incorporate new requirements
WHAT’S IN THE RULE?
§ 192.712 Analysis of Predicted Failures (New Section)

53. § 192.750 Launcher and Receiver Safety (New Section)
What’s New?
 July 1, 2021 – Launchers and receivers equipped with pressure
relief device
Key Exceptions
 None
What is the Impact?
 The Impact is LOW
 Verify all ILI launchers and receivers comply with new safety
standards
WHAT’S IN THE RULE?

54. § 192.909 How Can an Operator Change its Integrity
Management Program?
What’s New?
 Revised to reference PHMSA notification requirements under
the new section § 192.18
Key Exceptions
 None
What is the Impact?
 The Impact is LOW
 Modify IMP manual to reflect new requirements
WHAT’S IN THE RULE?

55. § 192.917 How Does an Operator Identify Potential Threats to Pipeline
Integrity and Use the Threat Identification in its Integrity Program?
What’s New?
 Seismicity, geology and soil stability
 Emphasis
 Cyclic fatigue analysis (7 year interval)
 Manufacturing defect stability
 Prove it by pressure test
 ERW pipe section reference § 192.712 (Failure Pressure
Analysis)
 Cracks and crack like defects (New Section)
Key Exceptions
 None
WHAT’S IN THE RULE?

56. What is the Impact?
 The Impact is MODERATE
 Document why some threats are not or have not been
considered
 Modify IMP manual to reflect new requirements
WHAT’S IN THE RULE?
§ 192.917 How Does an Operator Identify Potential Threats to Pipeline
Integrity and Use the Threat Identification in its Integrity Program?

57. § 192.921 How is the Baseline Assessment to be Conducted?
What’s New?
 ILI assessment requirements
 New section
 Assessments Added
 Spike hydro pressure test
 Excavation and in-situ
 Guided wave
 MAOP re-confirmation
Key Exceptions
 None
WHAT’S IN THE RULE?

58. What is the Impact?
 The Impact is MODERATE
 Review IMP with regard to manufacturing defects, time
dependent threats, cyclic fatigue threats, and crack & crack
like defect threats
WHAT’S IN THE RULE?
§ 192.921 How is the Baseline Assessment to be Conducted?

59. § 192.935 What Additional Preventive and Mitigative Measures
Must an Operator Take?
What’s New?
 Outside force damage
 Emphasis
 Includes loading, longitudinal / lateral forces and seismicity of
the area
Key Exceptions
 None
WHAT’S IN THE RULE?

60. What is the Impact?
 The Impact is LOW
 Modify IMP manual to reflect new requirements
 Modify risk model to reflect new requirements
WHAT’S IN THE RULE?
§ 192.935 What Additional Preventive and Mitigative Measures
Must an Operator Take?

61. § 192.937 What is a Continual Process of Evaluation and
Assessment to Maintain a Pipeline's Integrity?
What’s New?
 Aligned with Threats (§ 192.917)
 Assessments Added
• Excavation and in-situ
• Guided wave
• MAOP re-confirmation
Key Exceptions
 None
WHAT’S IN THE RULE?

62. What is the Impact?
 The Impact is LOW
 Modify IMP manual to reflect new requirements
WHAT’S IN THE RULE?
§ 192.937 What is a Continual Process of Evaluation and
Assessment to Maintain a Pipeline's Integrity?

63. § 192.939 What are the Required Reassessment Intervals?
What’s New?
 Revised to reference PHMSA notification requirements under
the new section § 192.18
Key Exceptions
 None
WHAT’S IN THE RULE?

64. What is the Impact?
 The Impact is LOW
 Modify IMP manual to reflect new requirements
WHAT’S IN THE RULE?
§ 192.939 What are the Required Reassessment Intervals?

65. § 192.949 How does an Operator Notify PHMSA [Removed and
Reserved]
What’s New?
 Removed and replaced with new section § 192.18
Key Exceptions
 None
WHAT’S IN THE RULE?

66. WHAT’S IN THE RULE?
What is the Impact?
 The Impact is LOW
 Modify IMP manual to reflect new requirements
§ 192.949 How does an Operator Notify PHMSA [Removed and
Reserved]

67. § Appendix F to Part 192–Criteria for Conducting Integrity Assessments
Using Guided Wave Ultrasonic Testing (GWUT) (New Section)
What’s New?
 Added Appendix F for GWUT assessment
Key Exceptions
 None
WHAT’S IN THE RULE?

68. What is the Impact?
 The Impact is LOW
 No longer an alternative technology that requires approval
 Modify IMP manual to reflect new requirements
WHAT’S IN THE RULE?
§ Appendix F to Part 192–Criteria for Conducting Integrity Assessments
Using Guided Wave Ultrasonic Testing (GWUT) (New Section)

69. Future Rules: The Rule does not include many changes to Parts 191
and 192 that PHMSA proposed at earlier points in the proceedings
and will be included in future rules:
WHAT’S NOT IN THE RULE?
Mega Rule Part 2:
 Repair criteria in HCAs
 Creation of new repair criteria for non-HCAs
 Requirements for inspecting pipelines following extreme events
 Updates to pipeline corrosion control requirements
 Codification of a management of change process
 Clarification of certain other IMP requirements
 Strengthening IMP assessment requirements

70. Mega Rule Part 3:
Requirements related to gas gathering lines that
were proposed in the NPRM
WHAT’S NOT IN THE RULE?
Future Rules: The Rule does not include many changes to Parts 191 and
192 that PHMSA proposed at earlier points in the proceedings and will
be included in future rules:

71. Bryan Louque, P.E.
Vice President, Asset Integrity & Corrosion
D: 918.514.5879 C: 913.221.3446
blouque@auduboncompanies.com
auduboncompanies.com
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