Accurate Data Is Essential for Natural Gas Pipeline Safety

49 CFR Part 192, Transportation of Natural and Other Gases by Pipeline: Minimum Federal Safety Standards, as promulgated by Pipeline and Hazardous Material Safety Administration (PHMSA), contains the prescriptive regulatory compliance requirements for natural gas pipeline system operators. Subparts A through P of Part 192 outline requirements for materials, construction, operations, maintenance, operator qualification, and integrity management. The standard applies to transmission, distribution, and gathering systems and many other facets.

Subparts O and P of Part 192, specifically outline vital practices for the integrity management of gas pipelines; Subpart O deals with transmission gas pipelines, while Subpart P focuses on distribution gas pipelines. Integrity management requirements are in addition to the operational and maintenance aspects of Part 192 and apply to distribution pipelines per §192.1003 and “covered” pipeline segments (which is segments of gas transmission pipeline located in a high consequence area, or HCA).

Central to these regulations is the emphasis on maintaining traceable, verifiable and complete (TVC) data. This article explores the requirements of 49 CFR Part 192 and underscores why accurate data is critical for compliance and safety, and how a geographic information system (GIS) can help manage and maintain that data.

Overview of Current Regulations and Potential Changes

49 CFR Part 192 governs the minimum federal safety standards for the operation of natural gas (and other gas) pipelines, and is enforced by PHMSA, along with most state regulatory commissions. A few states share joint jurisdiction with PHMSA over interstate pipelines, while many more enforce rules for intrastate pipelines.

One of the key requirements include the development and implementation of Integrity Management Programs (IMPs) essential for assessing and managing risks for transmission pipelines that may affect HCAs or for distribution pipelines per §192.1003. Operators must collect, integrate, and analyze data on pipeline integrity, monitor potential threats, and evaluate the effectiveness of preventive and mitigation measures. Regular inspections and maintenance are mandated to identify and address potential issues before they can escalate.

Due to some catastrophic pipeline rupture events, PHMSA has developed and recently incorporated changes in the regulations focused on safety and prevention, including more accountability in recordkeeping and data accuracy (among many other changes). This has initially been implemented into the transmission pipelines space through several published final rules, collectively known as the Mega Rule. Some of these same requirements potentially would be applicable to distribution pipelines in the very near future per the Notice of Proposed Rule Making (NPRM) that was issued Sept. 7, 2023, Pipeline Safety: Safety of Gas Distribution Pipelines and Other Pipeline Safety Initiatives. One of the major aspects of RIN2 of the Mega Rule focuses on improving a pipeline operator’s risk analyses to include accounting for additional pipeline attributes. In addition, operators are required to integrate analyzed information into their IMPs (requiring that data to be verified and validated) and taking into consideration interacting threats, potential failures, and worst-case incident scenarios from the initial failure to incident termination.

Examples of what the final rule for gas distribution pipelines might include (per the NPRM) related to data keeping and data integration include:

1. Identifying and minimizing risks to their systems from specific threats, such as extreme weather and other geohazards. This is similar to what is seen for transmission pipelines, integrating third-party geohazards data into their GIS and risk models to account for the risks from geohazards.
2. Identifying and maintaining TVC maps and records for their systems. This requirement may differ from the transmission pipeline requirements as it may be established on a more opportunistic basis (i.e., through normal operations, maintenance and emergency response activities). Where the operator may not have TVC records, they must identify and document which records are needed and develop and implement procedures for generating or collecting those records.
3. Expanding annual reporting requirements. Additional information may be collected by PHMSA to support more regulatory oversight of the safety of those systems. This may require additional data to be stored for the distribution pipeline systems that may not be readily available.

How GIS Can Support Data Needs

Having accurate data is extremely important to both Part 192 Subparts O and P, but the ability to integrate and utilize that data to its fullest is fundamental to effectively implementing integrity management and risk assessment efforts detailed in those subparts. The best way to allow for that data integration and utilization is through an effective GIS. A GIS enables enhanced risk assessment and management by providing a detailed spatial representation of pipeline networks, including their locations, characteristics and surrounding environments. This information is crucial for identifying potential risks, such as proximity to populated areas, identifying potential threats, and for predicting and mitigating hazards. Regulatory compliance also hinges on clean GIS data, ensuring that documentation and reporting on pipeline conditions, operations and maintenance activities are precise and up to date. The GIS data also helps facilitate efficient responses in the event of pipeline materials recalls.

Furthermore, accurate GIS data supports efficient maintenance and emergency response by allowing operators to quickly locate pipelines, understand their characteristics and plan activities effectively. In emergencies, precise data facilitates rapid response and decision-making, minimizing the impact of incidents. Additionally, well-maintained GIS data enhances operational efficiency by streamlining data management processes, eliminating redundancies, and improving analysis accuracy, leading to cost savings and increased safety. Clear and accurate GIS data also fosters effective communication with stakeholders, including regulatory agencies, local communities and emergency responders, building trust and cooperation essential for effective pipeline management.

Challenges in Maintaining GIS Data

Despite its benefits, maintaining clean GIS data presents challenges. Common issues include data entry errors, which can introduce inaccuracies into databases and affect decision-making and compliance. Keeping GIS data current as pipeline infrastructure evolves requires continuous effort and resources. Integrating GIS data with other operational systems used for regular maintenance and tasks, such as one-call data and cathodic protection survey data, can also be complex and prone to errors, adding another layer of difficulty to data management.

GIS Data Assessments and Reviews

To address these challenges, conducting regular GIS data assessments and reviews is crucial to maintaining good GIS data health. These assessments evaluate the accuracy, completeness and overall quality of the data. The process begins with data validation, where GIS data is verified against physical inspections or other reliable sources to check for discrepancies in location, attributes and data consistency. Following this, data cleaning is performed to identify and correct errors or inconsistencies, which may involve removing duplicate records, correcting erroneous entries and updating outdated information.

Engaging with users and stakeholders who interact with GIS data is important for gathering feedback on data quality and usability. This feedback can provide valuable insights into areas needing improvement and help prioritize data management efforts. Additionally, reviewing and updating data management procedures and standards aligns with current best practices and regulatory requirements.

Best Practices for Data Quality

To maintain and continue to manage clean and accurate GIS data, operators should follow best practices in GIS data management. Conducting regular data audits is essential for verifying the accuracy and completeness of GIS data. Consistency and reliability are the outcomes when standardized procedures for data entry and maintenance are implemented. Training staff on proper data handling and the importance of data quality is crucial. Leveraging advanced technologies and software tools can significantly enhance data accuracy and streamline management processes.

Conclusion

49 CFR Part 192 details the minimum requirements necessary to maintain the safety and integrity of natural gas pipelines. Accurate GIS data plays a vital role in helping pipeline operators meet these regulatory requirements, manage risks and maintain operational efficiency. By prioritizing data quality, conducting regular GIS data assessments and adhering to best practices, operators can improve compliance, enhance safety and contribute to more effective pipeline asset management. In doing so, they not only meet regulatory mandates but also support the overall reliability and safety of the pipeline infrastructure.