After years of planning and waiting the Gas Mega Rule is officially here. Looking towards the effective date of this final rule as July 1, 2020, we are providing a multi-part blog series that lets us summarize how we got to this point and how SSP can help assist with the logical next steps.
The link below provides all the details of the expanded rulemaking and there are many different parts to the mega rule. This first blog, as part of a mega rule series, we will be focusing on maximum allowable operating pressure attribution through document verification.
Following the well-known San Bruno incident and identification of a need for more thorough records, congress mandated through the initial regulations that all pipeline operators conduct a records review for segments in HCAs and Class 3 and 4 locations. These findings had to be reported to PHMSA through annual reporting. The verification is and was intended to ensure that pipeline operators have records (MTRs, As-Builts, etc) that accurately reflect the physical and operational characteristics of the transmission pipeline assets. Each document or set of documents identifies the key attributes to support the MAOP calculation and the pressure in which the individual segment, fitting or valve can be operated at.
This process often identified a number of areas across the pipeline system that had inadequate records even outside of HCAs, Class 3 or Class 4 locations. Due to the identification of so many areas, the new proposed rule amends the original regulations to address the testing & pressure reconfirmation of all un-known locations. This plus other changes are provided in the following summary:
This rulemaking amends the pipeline safety regulations to address the testing and pressure reconfirmation of certain previously untested gas transmission pipelines and certain gas transmission pipelines with inadequate records, require operators incorporate seismicity into their risk analysis and data integration, require the reporting of maximum allowable operating pressure exceedances, allow a 6-month extension of integrity management reassessment intervals with notice, and expand integrity assessments outside of high consequence areas to other populated areas.
Since the original rulemaking in 2011, GIS has evolved to the point where we can use it for a true system of record. GIS isn’t just a map any more and handles complex modeling or integrations for the spatial location, attribution and document linking/management. When the rule first came out, pipeline GIS systems couldn’t handle every data set, integration or continual maintenance need. Yet as the technology has evolved, GIS has become THE centralized repository and an integral technology for system knowledge supporting regulatory requirements, analytics and continual maintenance.
SSP’s pipeline team has worked with over 40+ transmission pipeline operators and our experiences has shown that there is some work to do in order to meet the new regulations. Even for the few companies that have scanned, integrated and stored every historical document…we have opportunities to innovate. That will include new field data collection, capital design/ordering, tighter asset management integrations, document management linking and upgrades to the latest GIS tools to manage the asset’s lifecycle. For other companies, the planning phase is over and it’s time to get all documents scanned, captured and linked into our GIS system of record. How can SSP help you get to next July and beyond? Lets start with the documents.
Document Collection, Integration and Linking
SSP’s data and project teams have supported numerous pipeline operators and utilities with scanning, categorizing and entering data from historical as-builts, current workorder backlogs, original documents and through continual data support (data clean-up, edits, etc). Having scanned or entered 100s of thousands of documents, the onshore SSP data team is experienced at interpreting your documentation while also understanding GIS data editing and reconciliation within the enterprise system of record. Having invested in physical scanners, our experience team will come on-site, work with your document experts and get every document into a digital format. But the work doesn’t stop there. Once in a digital format, we can work within your current document management system to categorize and add metadata to each digital file. Getting everything scanned and organized primes us for the next steps…getting the data into the GIS.
During a typical project, SSP next works with your organization to define a document collection and asset attribution ‘rules of engagement’. This provides the hierarchy and document ranking to understand where we should get the MAOP attribution, how to link the source documents and where/how to derive the spatial locations. Our focus is not only on the attributes because the spatial representation is equally important. Knowing that a foot difference could affect the HCA, MCA or Class location analysis, we work with the historical documents and the operator to ensure that we capture the best-known spatial representation. Often times this is derived from historical stationing, reconciled between multiple sources or (in the best case) generated from X/Y data.
Loading data and linking documents can be accomplished in a number of ways and typically depends on your current system’s maturity and/or desired 3rd party system access. In most cases, SSP’s data team will work directly within your GIS to post the new attributes, assets or information. This allows for existing integrations to remain intact and to facilitate editing through current workflows, QA/QC and data management tools.
For other operators, the sheer amount of data requires another approach. Due to the need to integrate massive data collection efforts, SSP developed a process called SSP Replay. As the diagram shows below, SSP Replay first takes a physical copy of your versioned production database. Our data team then restores that backup and works independently of your production environment to collect, update, load, migrates and integrate the required data.
Through agreed upon project loading intervals, SSP coordinates a migration of the delta data through SSP Replay. All adds, updates or deletes in the backup/copy are replayed into your production GIS environment. The key here is that this doesn’t just write to DEFAULT, Replay writes to a set of versions within our production GIS below the production/DEFAULT version. Each version is then QA/QCd, often by a separate SSP data group, before reconciling and posting to your DEFAULT. In this scenario, SSP can work in an independent backup and path while coordinating replays of MAOP documents/data into your GIS. The proven and successful process is an ideal path for operators who are just starting out with the federal document collection requirements.
Knowing your system, getting the data in and creating a digital twin in GIS is only half of the process. We then must have a way to conduct further analytics, innovate through digital collection techniques, edit and maintain your data for the life of the assets.
Collection of the documents and integrated into a system of record is a massive effort, but without the right repositories, databases or management tools…the data can become stale. The new regulations require operators to continue management of the asset for its entire lifecycle while retaining historical references and documents. In order to satisfy these requirements we need to look beyond document and data management. It is time to look at the entire ecosystem and how your organization generates work (construction, inspections, etc), gathers data from field work (direct digital integration, work order posting, GIS editing) and overall system knowledge/reporting.
Part II of this series will take a deeper dive into these next steps. Keep an eye out for how SSP can help:
- Create a repository for your Mega Rule data
- Best practices for continual maintenance
- Run your High Consequence/Moderate Consequence Analysis & Class Location
- Create an automated and managed regulatory reporting environment
It may seem daunting now that the rules are here but know that SSP’s pipeline and data teams are here to support your efforts. Reach out directly to [email protected] or visit us at an upcoming conference. Our next event is at Esri’s GeoConX where SSP will be out in force. Check out the link to find us there or to schedule a meeting at the booth!
What do you think?