UPCOMING PHMSA COMPLIANCE DEADLINES & COVID-19 UPDATES

MCS COVID-19 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