In This Issue

Gas Transmission Rulemaking Draft FAQ’s Released

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 (

  • 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