Last week, the Pipeline Hazardous Materials Safety Administration (“PHMSA”) has been conducting a public meeting of the Gas Pipeline Technical Advisory Committee to discuss the recently passed natural gas pipeline “mega” rule. Jones Day Publication published an article in June of 2016 that provides an excellent overview of the rule.
Key impacts on the control room include the following:
• Newly defined “moderate consequence areas” which add special provisions.
• Requirement to track MAOP exceedances.
• Requirement to perform risk assessments, and modify pipeline operations as a result of findings.
• Expansion of the regulation of gas gathering lines.
Likewise, PHMSA is in process on a Liquids Mega Rule (ANPRM 75 FR 63774, October 18, 2010. Docket No. PHMSA-2010-0229). While the original Advanced Notice of Proposed Rule Making (“ANPRM”) dates back to 2010, the Notice of Proposed Rule (“NOPR”) public comment period was closed in January 2016. The liquids “mega” rule also has a number of new requirements that will impact the control room including:
• All liquid gathering lines are required to meet all 49 CRR Part 195 reporting requirements.
• All liquid lines, including all gathering lines, are required to have leak detection.
• Significantly expanded information analysis requirements.
It is expected that the liquid mega rule will be published in the first half of 2017. So what does this mean? Ultimately, pipeline operators are going to be expected to create more records and to use those records to manage their risk of operations.