Successful HSD Process Audit by PHMSA Provides Clarity in Mega Rule Compliance
The newly updated PHMSA mega rule for onshore gas transmission pipeline systems poses a challenge to pipeline operators as the best practices to achieve regulatory compliance are still being discussed by the industry.
If operators do not already have the proper technology and inspection systems to comply with the new mega rule, they take on the risk of accruing significant expenses and wasted resources.
Fortunately, a recent trial audit of MMT’s material verification technology resulted in “no objection” from PHMSA, providing operators some clarity in how to effectively comply with the PHMSA mega rule and protect pipeline integrity.
Specifically, MMT’s HSD tester and MMTConnect technology can be used in NDE inspections to verify material properties and attributes in accordance with §192.607 of the PHMSA mega rule. The process documents the required physical pipeline characteristics— including diameter, wall thickness, seam type, and grade—with calibrated equipment that conservatively accounts for uncertainty, just as the mega rule requires.
The inspections performed in situ follow established testing procedures and include a complete dataset through MMTConnect, allowing operators to progress towards traceable, verifiable, and complete (TVC) records. In addition, the reporting includes additional data on the steel microstructure and chemical composition which provides insights on the steel quality and vintage.
Once the expected properties of a line segment are verified with MMT’s HSD tester, operators can use those values when reconfirming maximum allowable operating pressure (MAOP) through §192.624, in lieu of the conservative default values specified in §192.712 of the mega rule. Using these more realistic values justifies less conservative MAOP calculations, and provides more informed results for integrity management decision-making.
MMT continues to develop methods to maximize the benefits of material verification data for operators to minimize unnecessary digs and prioritize the right repairs with alternative sampling plans. As a result, operators can build efficient and comprehensive integrity management programs that minimize costs and reduces risk for pipeline systems.
This article appeared in News & Views: MMT’s Q3 Newsletter. Subscribe today to receive these quarterly newsletters straight to your inbox.
