What you need to know about the new PHMSA “Mega Rule”

July 1, 2020 marks a significant date for those responsible for manufacturing, laying, and maintaining U.S. gas transmission and gathering pipelines. Finally, the long-awaited upgrade to the Pipeline Safety Regulations will come into force.

The new regulations were first proposed in 2016 and reflect the U.S.’s significant growth of the national pipeline system. Notably, the existing pipeline infrastructure is becoming rather old, and increasing  use of natural gas is putting it under strain.

Termed the ‘Mega Rule’ because of its broad scope and sheer amount of pipeline involved, 300,000 miles of onshore gas transmission lines to be exact, the new rule places new demands on those responsible for the pipelines.

Operators will need to re-confirm the maximum operating pressure (MOAP) and specific material properties of these lines. In some cases, this will be a simple job of providing existing records. However, an estimated 168,000 miles of pipeline has never been tested and may need to be checked for the first time to establish diameter, wall thickness, seam type, grade and toughness.

Newly defined ‘Moderate Consequence Areas’ to be included in the scope

The “Mega Rule” also includes a comprehensive system of risk-based integrity assessment, repair, and validation termed ‘Integrity Management’ or IM. This enforces a proactive assessment program to assess and identify the integrity of gas transmission pipelines in a preventative maintenance approach.

Prior to July 2020, operators are required to undertake pipeline integrity assessments in High Consequence Areas (HCAs) only. Once the “Mega Rule” hits, some areas outside HCAs will be included. Pipelines in the newly defined moderate consequence areas (MCAs) and Class 3 and 4 locations will be included in the scope.

The “Mega Rule” in practice

Pipeline operators will need to routinely check the condition of pipes, valves and flanges, both above and below ground. There’s a grace period of six  months in force after the  July 1 date and reassessments will be required at intervals of no longer than seven years.

The checks will rely heavily on positive material identification (PMI) principles, and operators will need to ensure equipment is calibrated, documented and validated by a subject matter expert. Of course, this is on top of existing pipeline legislation, such as API 5L.

The mega-rule affects pipelines in the U.S. however, the EU is covered by the Gas Pressure Directive and pipeline safety is high on the agenda in China too, with new measures allowing third party access to oil and gas pipelines introduced in May 2019.


What you need to consider to comply with the “Mega Rule”

As a minimum to comply with the “Mega Rule”, each required analysis shall contain the following elements:

  1. Carbon (C), Manganese (Mg), Phosphorus (P), Sulfur (S), Chromium (Cr), Columbium [Niobium] (Nb), Copper (Cu), Molybdenum (Mo), Nickel (Ni), Silicon (Si), Titanium (Ti), and Vanadium (V).
  2. Boron (B) but if the heat analysis indicates a B content less than 0.001%, (< 10ppm) then no B determination is required for the analysis. However, it’s always an advantage if an analyzer has the capability to additionally analyze B simultaneously with the others.
  3. Any other alloying element added during steelmaking for a purpose other than deoxidation.

Equipment that’s used to uphold the different facets of the “Mega Rule” must be demonstrably accurate and precise, avoiding any future health and safety risks.

If you want to know how to comply with the “Mega Rule”, read my quick guide


We’re here to help

There’s no one PMI solution that will meet all the needs of every single company. The right PMI solution for your business depends on a number of factors, ranging all the way from the analytical capabilities of the instrument itself to the logistics of your operation.

That’s why Hitachi High-Tech offers a range of PMI analyzers for the verification of pipeline material. We believe in matching our clients to the solution that’s right for them, not trying to shoehorn their operations into a solution that might not be the best fit.

OES – PMI-Master Smart

Optical emission spectroscopy (OES) can analyse elements like phosphorous, sulfur, boron, arsenic and tin, starting at levels of less than 30 ppm. OES is also the only technology capable of measuring the carbon content of different steel grades reliably.

What you also need to consider beside the above-mentioned elements is the essential information needed to precisely calculate the CE (Carbon Equivalent), as this value defines the weldability of material. The calculation should follow the AWI or IIW suggested formula, so high precision and accuracy is required on especially carbon analysis.

The PMI-MASTER Smart from Hitachi is the only truly portable high-performance OES analyser on the market at 15kg.  It can perform up to 300 analyses with a single battery and requires no warm-up.

It comes complete with a comprehensive GRADE database with over 350,000 materials of almost all worldwide alloy configurations in circulation.  You’ll also find in the instrument library most CE calculations, so you can choose the one you need.

PMI-MASTER Smart gives you the accuracy and peace of mind of spark-OES, with the convenience of a mobile device.

XRF - X-MET8000

The handheld X-MET8000 is non-destructive, weighs only 1.5kg and has a start-up time of less than 20 seconds. Using XRF (X-ray fluorescence) technology, it can measure a wide range of elements and very low limits, and the 12 hours of battery life means that you can depend upon the X-MET when you are in the middle of nowhere.

Our products are trusted by many global oil and gas providers and inspection companies. Talk to our experts today to arrange a free demo, get more information or a quote.

Find out more about our range of NDT/PMI analyzers for the verification of pipelines.

For more information, please visit our “Mega Rule” resources page.

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About the author:

Hitachi High-Tech’s Jordan Rose is a specialist in XRF, OES, and LIBS technologies.  Jordan earned his BS in Materials Science and Engineering at the University of Connecticut and has spent almost a decade in developing applications and providing support to US customers across a wide range of industries. In his current role as Marketing Manager Americas, Jordan is based at the Hitachi High-Tech factility in Westford, MA where he’s  focused on connecting US businesses with Hitachi’s comprehensive range of solutions for quality, compliance and safety. 

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Date: 19 February 2020

Author: Jordan Rose, Marketing Manager Americas

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