In November 2021, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a new final rule designed to improve the safety of onshore gas gathering pipelines.
The long-awaited PHMSA Gas Gathering Rule expanded federal pipeline safety oversight to all U.S. onshore gas gathering pipelines, which adds up to approximately 400,000+ miles of gathering pipelines coming under federal oversight.
These are far-reaching implications that affect pipeline operations. To learn more about the overall impact on operations, we recommend listening to EnerSys CEO Russel Treat’s conversation with Keith Coyle of Babst Calland on the Pipeliners Podcast. You can also access this Pipeline Safety Alert from Babst Calland that identifies the key takeaways for operators.
At a high level, the chief concerns for operators of gathering lines include:
- Needing to identify pipe that is covered by the new regulation.
- Determining which gathering lines fall under the classification of a new Type C regulated gathering line that is 8.625” or greater and operate at higher stress levels or pressures.
- Setting up asset safety programs for the covered pipe to comply with PHMSA regulations.
Drilling down, there are specific implications for the pipeline control room. We will unpack the control room elements that gatherers need to be aware of.
PHMSA Gas Gathering Rule & the Pipeline Control Room
The central issue in regards to the pipeline control room is achieving compliance with the PHMSA Control Room Management Rule (CRM Rule). Operators of newly-regulated gathering lines will need to ensure that their control rooms comply with the CRM Rule.
For some operators, this is completely new territory. For example, if you operate gathering lines that previously were not regulated and no other types of lines, then you will need help standing up a PHMSA compliant pipeline control room from scratch.
Whereas, other operators may already have compliant pipeline control rooms for their other lines (e.g. transmission lines), and these operators just need to apply the same approach to control rooms that manage gathering lines.
Regardless, it’s important to understand or be refreshed on what is required to comply with the CRM Rule so that you can operate safely and in compliance with regulations.
CRM Rule Requirements for Federal Pipeline Assets
The CRM Rule includes control room regulations for the transportation of gas (49 CFR Part 192.631) that would affect gas gathering lines coming under federal oversight.
The regulations prescribe safety requirements that affect controllers, control rooms, and SCADA systems that are used to remotely monitor and control pipeline operations. The regulations are broken down into specific sections:
- A – General Requirements
- B – Roles & Responsibilities
- C – Adequate Information
- D – Fatigue Mitigation
- E – Alarm Management
- F – Change Management
- G – Operating Experience
- H – Training
- I – Compliance Validation
- J – Compliance & Deviations
Each section includes requirements for various aspects of control room management. For example, Section A includes a requirement that each operator must “have and follow” written control room management procedures (e.g. Control Room Management Plan or CRMP). There are multiple implications in this example:
1. You need written policies and procedures that control room personnel can follow when performing actions in the control room. However, it’s not enough to just have written procedures.
2. The other implication is that you must be able to prove that your control room personnel are following the implemented procedures. Are you doing what you said you were going to do?
This requires recordkeeping as the work is being performed in the control room. This way, you can produce the appropriate records and documentation that will satisfy a future PHMSA audit or inspection.
At EnerSys, we provide comprehensive support for policies, procedures, implementation, and recordkeeping for each section of the CRM Rule.
We can support your creation of control room policies and procedures that align with the CRM Rule, we provide implementation support to ensure that your personnel follow the policies and procedures, and we provide digital recordkeeping support through our software tools, which helps you maintain a constant state of audit readiness.
Talk to EnerSys for Control Room Management Support
Whether complying with the CRM Rule is new territory for your operation, or if you need support translating your current control room capabilities to regulated gas gathering lines, we can help.
Our team of experts will evaluate your current state and look for gaps to determine whether you are prepared for the new operating reality. We can also discuss utilizing our Control Room Operations solution that provides operators with a complete toolset of software, services, and consulting to support control room operations and compliance requirements with the CRM Rule.
By working with EnerSys, we will support your path to Natural Compliance so that you can gain confidence that you are always prepared to satisfy PHMSA requirements.
– We would appreciate the opportunity to discuss your control room needs for gathering lines. To schedule a consultation with our team, call us at 281-598-7100. Ask for EnerSys General Manager Ross Adams or VP Business Development Dale Schafer.
You can also contact us via email at firstname.lastname@example.org or complete our website contact form to get started. We look forward to supporting your control room needs achieving compliance with the new PHMSA Gas Gathering Rule requirements.