Reconfirmation Plans and Options On October 1, 2019, the Pipeline and Hazardous Materials Safety Administration…
Implementation of Material Verification
In Support of Mega-Rule Part 1 Requirements
Operators are now required to define sampling programs and perform destructive (laboratory) or non-destructive testing to capture this information and take additional actions when inconsistent results are identified until a confidence level of 95% is achieved.
Various sections of Mega-Rule 1 require operators of natural gas transmission pipelines to ensure adequate Traceable, Verifiable, and Complete (TV&C) material records or implement a Material Verification (MV) Program to confirm specific pipeline attributes including diameter, wall thickness, seam type, and grade. Operators are now required to define sampling programs and perform destructive (laboratory) or non-destructive testing to capture this information and take additional actions when inconsistent results are identified until a confidence level of 95% is achieved. Opportunistic sampling per population is required until completion of testing of one excavation per mile (rounded up to the nearest whole number) up to 150 excavations (if the population exceeds 150 miles). Regulators have communicated an expectation that sampling locations or test sites are to be equally spaced throughout the population mileage.
To support implementation of these programs, pipeline operators must develop robust procedures to support implementation of the program including:
- Population identification and grouping,
- Sampling and test feasibility,
- Laboratory test requirements and methods for designated populations,
- In-situ test methods and protocol,
- Inconsistent results and increased sampling protocol, and
- Final verification and test completion.
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