In This Issue

PHMSA Released RIN 1 FAQ

PHMSA released a second set of Frequently Asked Questions (FAQ) related to the final rule entitled “Pipeline Safety: Safety of Gas Transmission Pipelines: MAOP Reconfirmation, Expansion of Assessment Requirements, and Other Related Amendments” which was published October 1, 2019. The first set of FAQ related to this rule were released December 21, 2021.

There are 25 new FAQ included and no gas asset group is missed. There are FAQ applicable to gathering, transmission, and distribution operations.

As with all published FAQ, RCP cautions users to read carefully and consider context when applying responses. For example, the new FAQ 59 states that there is no required sampling frequency, and it is applied opportunistically. While this is true as literally stated, if the data is being gathered to satisfy MAOP Reconfirmation under 192.624, the deadlines prescribed in §192.624(b) still govern.

RCP stands ready to assist with updating procedures to accurately reflect expectations generated by this new set of FAQ, assisting with implementation of the rule’s requirements and conducting pre-audit prep to assist in gauging how prepared you may be. Contact Jessica Foley for assistance.

Batch-1 and Batch-2 FAQ are published on the PHMSA website.