We were prepared for an update to the Mega Rule…or so we thought.
Pipeline and Hazardous Materials Safety Administration (PHMSA)finally introduced new regulations in October 2019 around operators conducting integrity assessments outside of High Consequence Areas (HCA). These new areas are defined as Moderate Consequence Areas (MCA).
The new rule includes both a definition and assessment requirement:
Moderate Consequence Area: A “Moderate Consequence Area” is an onshore area that is within a potential impact circle containing either five or more buildings intended for human occupancy or any portion of the paved surface, including shoulders, of a designated interstate, freeway, or expressway, or principal arterial roadway with four or more lanes, as defined by the Federal Highway Administration.
Initial Assessment and Reassessment Interval: Operators with an onshore, steel, transmission pipeline segment with a MAOP greater than or equal to 30% SMYS located in a Class 3 or Class 4 location or a piggable MCA segment must assess these segments by July 3, 2034 and every 10 years thereafter at intervals of 126 months. Although PHMSA has allowed a 10-year schedule for reassessments, the Agency has cautioned that an operator must assess its segments earlier depending on the type of anomaly, operational, material, or environmental conditions, or as necessary to ensure public safety.
All signs pointed to the Mega rule including Occupied Sites; instead, PHMSA chose to leave these sites out.
Occupied Sites: In response to numerous comments from stakeholders, PHMSA removed ‘occupied sites’ from the definition of MCA. The inclusion of ‘occupied sites’ would have required operators to evaluate where there are outside areas or open structures within the potential impact radius that are occupied by five or more persons for at least 50 days in a 12-month period or buildings that are occupied by five or more persons on at least five days a week for 10 weeks in any 12-month period. The Agency agreed that including these areas would be unnecessarily burdensome without a comparable decrease in risk.
In anticipation of Occupied Sites being included in the new ruling, our 6.0.1 release of Gas HCA does include MCA Occupied Sites. However, after the ruling came out, you might not know that we released another version of Gas HCA. In the 6.0.2 version, all references to MCA Occupied Sites have been removed from the application.
Please contact support if you have questions or if you’re interested in upgrading.
