PHMSA has released a draft of “Batch 2” Frequently Asked Questions (FAQ) related to the final rule “Pipeline Safety: Safety of Gas Transmission Pipelines: MAOP Reconfirmation, Expansion of Assessment Requirements, and Other Related Amendments,” originally published October 1, 2019. Batch 1 (Mega Rule FAQs – RCP Inc.) was finalized and released on September 15, 2020. Comments can be made to PHMSA by going to the docket PHMSA-2019-0225-0031. Once PHMSA has had the opportunity to review these comments, they will respond, similarly to Batch 1, with a final set of Batch 2 FAQ’s. Our understanding is there is a 3rd Batch draft in progress and should be released soon. In this draft Batch 2, there are numerous FAQ’s with PHMSA responses. The following topics are addressed. For a copy of these FAQ’s or to inquire about RCP services, please contact Jessica Foley (jfoley@rcp.com).
- Safety-Related Condition Reports
- Operator Qualification reporting
- MAOP of Type A and B gathering pipelines
- Applicability to distribution lines
- Material verification for pipeline components
- Anomaly investigation of grandfathered pipe
- Welder qualification records
- Moderate Consequence Areas
- Spike hydrostatic testing
- Material verification
- Maximum Allowable Operating Pressure establishment and reconfirmation
- Assessments outside of High Consequence Areas