Four trade associations jointly submitted a Petition for Reconsideration to PHMSA for the recently published final rule Safety of Gas Transmission Pipelines: MAOP Reconfirmation, Expansion of Assessment Requirements, and Other Related Amendments. There are two issues in the new regulation that The Associations found to be in conflict with approved language voted on by the Gas Piping Advisory Committee.
- The Associations request that PHMSA revise § 192.624(a)(1) to adopt the GPAC-endorsed language indicating that § 192.624(a)(1) does not apply where an operator has “records necessary to establish maximum allowable operating pressure in accordance with § 192.619(a)(2)”, pressure test records. Without the specific reference to § 192.619(a)(2), it is unclear whether an operator must reconfirm MAOP when a pipeline segment already has a traceable, verifiable, and complete pressure test record.
- The Associations request reconsideration of § 192.5(d), which codifies the requirement for pipeline operators to have records documenting the current class location of each pipeline segment. Section 192.5(d) does not limit the recordkeeping requirement to transmission pipelines. This deviates from the intent and scope of the NPRM, which stated that the recordkeeping requirements for establishing class location only applied to transmission pipelines, not distribution or gathering pipelines.
For a copy of the petition for reconsideration, click here.
Gas Mega-Rule Support
Are you ready for the recently published and 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.