More than a decade in the making, the new Department of Transportation (DOT) mega rule— Code of Federal Regulations (CFR), Title 49, Part 191 and 192—was driven by continuing failures in pipeline systems, including the fatal 2010 gas pipeline rupture and fire in San Bruno, California, and oil leaks into rivers in Michigan and Montana.
The mega rule, which went into effect July 1, 2020, applies to more than 500,000 miles of gas and hazardous liquid pipelines in the United States. In general, the rule stipulates tougher safety regulations and more stringent reporting, and it expands integrity management requirements to gathering lines and other previously unregulated pipelines.
Requirements vary by pipeline product and type. For example, operators of gas transmission and distribution pipelines must update incomplete records, including maximum allowable operating pressure (MAOP) from the date of origin.
That’s no easy task under any circumstances. Over a pipeline’s lifetime, records can be accidentally lost or destroyed, especially if the pipeline changed ownership over the years.
But consider this: More than half of America’s pipelines were installed prior to 1970—many as far back as the 1940s, in fact—and had been protected by a lenient “grandfather clause” that permitted historical documentation to be used to establish MAOP in place of material properties. That means they lack the kind of records that meet the rule’s “verifiable, traceable, and complete” requirement. Re-establishing MAOP is the only alternative, and it’s not cheap: It’s estimated that it will cost the industry $17 to $22 billion per year when you factor in pressure tests, in-line inspection, and direct assessment to verify materials and integrity. And that’s just for pipelines outside of high consequence areas (HCAs). In all, the Pipeline Hazardous Materials and Safety Administration (PHMSA) puts the total annual costs of the rule at $31.4 million.
Aside from the considerable expense associated with it, the mega rule will generate enormous volumes of information—data that operators can use to meet regulatory tests, understand pipeline threats, and de-risk and improve their integrity management programs. The question is: what’s the best way to manage all that data so operators can maximize its value?