In summing up this rapidly changing regulatory environment, all signs suggest that PHMSA’s gas mega rule will lead to more regulations affecting many more miles of pipeline. Among the big changes will be greater regulation of pipelines built before 1970, new regulations for pipelines that could affect MCAs, and expansion of regulation to the gathering system. The changes that result from these and other aspects of the mega rule will be far-reaching and costly for the industry.
But how can operators prepare for these potential regulatory changes? The best approach is to take proactive steps to conduct gap analyses of gathering systems and determine what is required to develop more complete material verification records.
The industry is also encouraging regulators to consider a range of cost-effective options that will enable operators to obtain compliance. To date, PHMSA’s rulemaking has focused on direct testing methods to determine and verify pipeline materials. If carried out on such a large scale under the proposed mega rule, testing approaches of this kind could prove costly and impractical.
Proposed regulations and the gathering pipeline system
Regulators will require the implementation of integrity management programmes on gas gathering lines, specifically those of high yield strength in HCAs.
Implementing these programmes will be an important step in the battle to manage internal corrosion – the biggest threat to gathering pipelines. Crude oil and natural gas in many of these lines are still untreated, causing pipes to corrode at a faster rate than in transmission pipelines.
Nalco Champion has taken a close look at the different approaches needed to address the mega rule. Depending on the age of the pipelines and construction practices used, transforming this infrastructure to be piggable will involve significant effort and costs. To start, extensive retrofits will need to be made to reconfigure countless valves, fittings, welds, overhead spans and tight radius bends to allow the smooth passage of inspection pigs. In addition, companies will need to extensively clean the lines for inspection and possibly install liquid handling and recovery systems, such as slug catchers.
Operators of gathering systems will also need to apply the right set of chemistries and pigging technologies that allow each pipeline to be easily cleaned and inspected. After the pipelines have been hydrostatically tested to determine MAOP, it will be essential to safely dispose or treat water collected during cleaning.
Once these inspections and treatment have been completed, operators will be required to implement appropriate preventative programmes, such as water sampling and system monitoring, which will allow them to manage critical risks over the life of their pipeline systems.
As the mega rule goes into effect, there will ultimately be increased costs and staffing needs in response to growing reporting and compliance requirements. Companies may find it more efficient and cost-effective to outsource this function to an experienced maintenance partner that can provide the tools that will need to be in place to respond to new regulations.
PHMSA’s proposed gas mega rule must receive final government authorisation before it can go into effect. It is safe to say the scope and complexity of compliance management will expand exponentially for pipeline operators. In some cases, the rules will involve changes that operators can make immediately. But other improvements, such as expanding regulations to gas gathering lines, could take decades to complete.
In this changing regulatory environment, successful companies will be the ones that take proactive, prudent action. Already, some are taking action to collect data on their pipeline systems and identify gaps, and others are investing in changes to make their gathering systems piggable in anticipation of future regulations.
It is clear that pipeline operators will need to think carefully about ways to cost-effectively respond to the new mega rule. Working closely with experienced service providers, pipeline operators can gain a valuable advantage by anticipating and meeting the new regulatory requirements.
Read the article online at: https://www.worldpipelines.com/special-reports/29122017/preparing-for-waves-of-regulatory-change-part-2/
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