On July 8, 2022, PHMSA issued a notice that it intends to exercise limited enforcement actions for Type C gas gathering lines with nominal outer diameters greater than and equal to 8” and less than or equal to 12”. On November 15, 2021, PHMSA published a Final Rule Safety of Gas Gathering Pipelines: Extension of Reporting Requirements, Regulation of Large, High-Pressure Lines, and Other Related Amendments. The Final Rule requires that Type C gas gathering pipelines meet the requirements of §192.9 requirements by May 16, 2023. The July 8, 2022 Notice indicates that PHMSA does not intend to take enforcement action for Type C gas gathering pipelines, related to §192.9 compliance until May 17, 2024 for those lines with nominal outer diameters greater than and equal to 8” and less than or equal to 12”. After May 17, 2024 PHMSA states they will begin inspection of these pipelines, with an emphasis on those lines with buildings intended for human occupancy located within the pipeline’s Potential Impact Radius. PHMSA recommends that State partners also adopt this limited enforcement discretion, but there is no mandate for States to do so. PHMSA also reminded operators that this limited enforcement discretion does not apply to the other provisions of the Final Rule and those enforcement dates will remain in effect (ex. Part 191 reporting provisions for Type C & R gas gathering, classification of Type C lines by November 16, 2022, and §192.9 compliance for Type C lines with nominal outside diameters greater than 12”).
For a copy of this Notice or to find out how RCP can assist operators correctly classifying their gas gathering pipelines and assist with compliance efforts, contact Jessica Foley.