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Preparing for PHMSA’s Mega Rule by Using Technology to Improve Pipeline Operation Efficiency

After natural gas pipeline safety incidents like the one in San Bruno, California, that claimed eight lives and destroyed 38 homes, the Pipeline and Hazardous Materials Safety Administration initiated a "Mega Rule" to improve pipeline safety and better prepare emergency responders for incidents. As planned originally, the Mega Rule would have doubled the current number of pages in regulations for the pipeline industry — the reason for its "mega" nickname — but now it’s broken into three separate rules and expected to be finalized in 2019.

What is the Mega Rule?

The Mega Rule applies to gas transmission and distribution pipelines and, for the first time, interstate and intrastate pipelines. It will require pipeline owner/operators to update incomplete pipeline records dating as far back as the 1940s. With so many changes to owners’ pipeline assets over the years, paper records do not provide real-time information needed to run an efficient business. The three main parts of the Mega Rule for gas pipelines include:

  1. Intensifying risk assessment and maximum allowable operating pressure requirements
  2. Expanding integrity management program regulations to gathering lines and other previously non-regulated lines
  3. Increasing reporting requirements and safety regulations

What does the Mega Rule mean for pipeline owner/operators? 

While complying with the new rules is anticipated to be costly — requiring pipeline owner/operators to spend hundreds of millions of dollars each year — there are many positive outcomes that will come from making the investment. For starters, digitizing records will not only result in better efficiency, but also increase pipeline safety. Also, the work done to provide "reliable, traceable, verifiable and complete" records digitally will also improve the bottom line since the information can be used to perform risk-based modeling, improve integrity management planning, and determine operations and maintenance budgets.

All of the above makes it critical to approach compliance with a strong focus on technology. 

Why a strong focus on technology?

Most pipeline owner/operators have already started preparing for the Mega Rule, engaging a host of consultants to help with the formidable task of auditing records and identifying information gaps. We’ve seen and helped our clients with strategies like digitizing paper copies of records and creating an ESRI geographic information systems database that enables them to assess and rank risk, plan capital budgets and prioritize information gathering. 

Once a pipeline owner/operator launches digital platforms to host and maintain data, integrating the platforms into projects can add efficiencies by eliminating paper forms, developing automated field forms, establishing quality assurance and control steps, and facilitating real-time updates to project teams.

Many of our clients have already seen that by using technology to uncover compliance gaps, they can start mapping out solutions, including smart pigs to evaluate pipelines where possible, depressurize a line, or perform dig studies to check and record MAOPs. 

Full compliance with the Mega Rule is a daunting task, no doubt. Another strategy that we’ve seen work well is to have the entire compliance team in the same location, which sometimes means co-locating or relocating staff temporarily. We've tested this strategy with success and recommend it. Our colocated staff count with one client is about to double, enabling increased collaboration. With the right people together, decisions are made efficiently as individual compliance projects are identified. 

The Mega Rule's expanded regulations may be overwhelming at first, but by using technology to improve efficiency and recordkeeping in pipeline operations, we're all doing our part to help reduce pipeline risks and safeguard our communities. Safety is paramount as our country continues to develop and urbanize, requiring more energy resources and the pipelines to deliver them. 

Oil & Gas Pipeline Practice Lead