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UPCOMING PHMSA COMPLIANCE DEADLINES & COVID-19 UPDATES

MCS CO-VID Response

MCS’s response to COVID-19 is to protect the health and safety of our employees and our clients. Our contingency plan and processes have allowed us to transition to working remotely while continuing to provide services to our clients.

 

How MCS Can Help

Complying with regulatory requirements can almost seem like a full-time job, impacting daily tasks and core operations. Our history and experience give us a detailed understanding of what regulators seek in your programs.

MCS’s team has specific business and operations knowledge and real-life project experiences. MCS is here to help solve your needs and ensure you are compliant with the new regulation issued by PHMSA.

We are currently operating using:

  • Virtual Meetings
  • Document Sharing Platforms
  • Collaboration Tools

Upcoming Compliance Deadlines

 

PHMSA Gas Transmission & Hazardous Liquids Rule

49 CODE OF FEDERAL REGULATIONS (CFR) PARTS 192: TRANSPORTATION OF NATURAL AND OTHER GAS BY PIPELINE

Part 1: Safety of Gas Transmission Pipelines
Issue Date: October, 1 2019
Effective: July 1, 2020

Following are the requirements of the new rule and the associated compliance changes that will occur. MCS can help you meet these new changes in your compliance plans and procedures.

Requirements

  • MAOP Reconfirmation
  • Verification of Pipeline Material Properties and Attributes
  • Pipeline assessment in areas outside of HCA’s
  • Reporting of MAOP exceedance
  • Considerations of seismicity as a risk factor
  • Safety features on ILI launchers and receivers
  • Record retention requirements

Compliance Changes

  • Define Moderate Consequence Area (MCA)
  • Document analytical procedure for Engineering Critical Assessments (ECA)
  • Follow IBR documents; modifications to ILI procedures
  • Modifications to IMP procedures reflecting new requirements including seismicity, cyclic fatigue, and notifications to PHMSA
  • Records retention requirements: Material properties, Pipe Design, Pipeline Components, Qualification of welders, Qualifying individuals for pipeline joining qualifications
  • Records review for compliance to TVC standard
  • Define requirements for Spike Hydrostatic Pressure Test for steel pipelines and modify procedures
  • Define requirements for verification of steel transmission pipeline material properties and attributes and develop procedure to verify un-verified information
  • Modifications to design procedures reflecting MAOP safety factor requirements
  • Develop and document MAOP re-confirmation procedures and associate methods

49 CODE OF FEDERAL REGULATIONS (CFR) PARTS 195: TRANSPORTATION OF HAZARDOUS LIQUIDS BY PIPELINE

Issue Date: October, 1 2019
Effective: July 1, 2020

Following are the requirements of the new rule and the associated compliance changes that will occur. MCS can help you meet these new changes in your compliance plans and procedures.

Requirements

  • Reporting requirements
  • Leak Detection system requirements
  • Passage of ILIs for new and replaced segments and components
  • Inspection of pipelines after extreme weather events and natural disasters
  • Pipeline Assessments
  • IM Data Analysis
  • Design Standards for ILI
  • Records review
  • Records retention requirements

Compliance Changes

  • Reporting of gravity lines
  • Regulated gathering reporting requirements
  • Leak Detection system requirements
  • Develop processes for implementing design standards to accommodate passage of ILI tools
  • Modifications to IMP procedures reflecting new requirements for IM and non-IM pipeline segments
  • Develop processes to identify relevant threats and appropriate assessment tools
  • Develop processes and procedures to verify specific risk data elements that could affect an HCA
  • Considerations of seismicity as a factor for establishing assessment schedules
  • Record inspection and actions of pipelines affected by extreme weather and natural disaster event
  • Modify process and procedures to include distribution of MSDS to On Scene Coordinators and local responders
  • Develop processes for including the integrity assessment for certain underwater pipelines located in an HCA