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PHMSA Issues FAQ for RIN 2 Gas Transmission Rule

PHMSA has posted new Frequently Asked Questions (FAQ) related to “Pipeline Safety: Safety of Gas Transmission Pipelines: Repair Criteria, Integrity Management Improvements, Cathodic Protection, Management of Change, and Other Related Amendments” Rule (87 FR 52224 (Aug. 24, 2022)), as amended by 88 FR 24708 (Apr. 24, 2023) (collectively, the “2022 Gas Transmission Final Rule”). 

The FAQ addresses the following questions:

  • When evaluating a pipeline to determine if it is a “transmission line,” how should an operator consider the phrase “a connected series of pipelines” in § 192.3?
  • May an “in-line inspection” be performed using free-swimming tools?
  • What data do I consider when identifying and evaluating threats under § 192.917? What data is “pertinent”?
  • Section § 192.465 references two terms for different sources of external cathodic causes to investigate and mitigate — non-systemic and systemic causes — what’s the difference?
  • What remediation schedule should be implemented for a monitored condition under § 192.933(d)(3) with indications it “is expected to grow to dimensions” prior to the next scheduled assessment? How do I judge whether a monitored condition is expected to grow in dimensions?
  • The monitored conditions at §§ 192.714(d)(3) and 192.933(d)(3) include that “critical strain levels are not exceeded.” How should I treat a condition if the critical strain levels of my anomaly are exceeded?

Per PHMSA’s release:

“PHMSA provides FAQ to help the public understand how to comply with the regulations. FAQ are not substantive rules, do not have the force or effect of law, and do not create new legal obligations. An operator who is able to demonstrate that it is acting in accordance with FAQ is likely to be able to demonstrate compliance with the relevant regulations. If a pipeline operator chooses not to follow FAQ, the operator must be able to demonstrate the operator’s conduct complies with the regulations.”

Click here to download a copy of these FAQ.

RCP has been actively assisting our clients with developing effective programs to comply with the recently finalized gas transmission and gathering rules.  For more information, contact Jessica Foley.