The Gas Pipeline Advisory Committee (GPAC) met June 25 – 26 to discuss the third part of the proposed gas mega-rule, Safety of Gas Gathering Pipelines. The GPAC voted on various proposals made by PHMSA in response to comments submitted to the docket for the original NPRM Safety of Gas Transmission and Gathering Pipelines. These included modifications to reporting, definitions, requirements for newly regulated gas gathering lines, and which gas gathering lines would fall within the scope of the rulemaking. A few GPAC votes of interest:
- Withdraw the proposed changes to the definition of Gas Gathering from this rulemaking, thus continuing to incorporate API RP 80 for definitions of gas gathering lines, gas treatment, gas processing and onshore gas production operations. PHMSA indicated it will monitor the outcome of the API working group’s effort to revise API RP 80 and develop API RP 1182 and may change the definition of gas gathering lines, if needed, in future rulemaking.
- Extend the deadline for determining applicability of the new rule to 2 years from the effective date. Extend the deadline for compliance with new requirements to 3 years from the effective date. Extend the deadline for compliance when a previously unregulated gas gathering pipeline becomes regulated to 2 years.
- Create a minimum set of requirements for all gas gathering lines 8-inches and larger nominal outside diameter (ex. damage prevention, line markers, public awareness, emergency plans, leakage surveys and repairs, and design, construction, inspection and testing of new lines). PHMSA will consider additional requirements for gas gathering lines greater than 12-inch nominal outside diameter that have a building intended for human occupancy located within the pipeline’s Potential Impact Radius.
To view the recorded webinar or download the presentations, click here.
Bonus: Alan Mayberry, PHMSA Associate Administrator for Pipeline Safety, announced that the draft NPRM for Valves and Rupture Detection has been submitted to OMB for their review, so keep an eye on the Federal Register and this newsletter over the next few months to see what is contained in this proposed rule.
Gas Mega-Rule Support
Are you ready for the three pending gas transmission and gathering regulations? RCP has been heavily involved throughout this rulemaking process and is ready to assist operators as they get prepared. Whether it’s a deep dive into MAOP records reconfirmation, assessing where your Moderate Consequence Areas exist, reviewing existing pipeline integrity programs, developing action plans to get into compliance, or simply providing training to your team on what’s coming, RCP can help. Visit www.rcp.com or contact Jessica Foley for more information.