In This Issue

PHMSA Response to Petition for Reconsideration: Gas Transmission Rule

[Docket No. PHMSA-2011-0023; Amdt. No. 192-127]

Several trade associations jointly petitioned PHMSA on October 31, 2019 to consider amendments to the gas transmission final rule, which became effective July 1, 2020.  On July 6, 2020 PHMSA published amendments to the final rule to address this petition.  There are two main issues that are addressed in these revisions.

  1. Clarify the Applicability of the Class Location Recordkeeping Requirements in §192.5(d)
    In the Final Rule, PHMSA added §192.5(d) to require operators to have and maintain records that document the current class location of each pipeline segment. In the preamble, PHMSA stated that this requirement applies to gas transmission pipelines. However, PHMSA inadvertently omitted language in the rule’s regulatory text that would have made clear that the recordkeeping requirements applied only to gas transmission pipelines.  PHMSA granted the Associations’ request to clarify that the recordkeeping requirements in §192.5(d) only apply to gas transmission pipelines. The recordkeeping requirements apply to records that document current class location determinations and records that demonstrate how an operator arrived at such a determination for each class location.
  1. Limit the Applicability of MAOP Reconfirmation Requirements in §192.624(a)(1)
    In the Final Rule, PHMSA defined a set of pipeline segments for which operators must reconfirm the MAOP. Specifically, §192.624(a)(1) requires operators of certain gas transmission pipelines to reconfirm MAOP if, among other things, the ‘‘records necessary to establish the MAOP in accordance with §192.619(a) are not traceable, verifiable, and complete’’ (TVC). The Associations requested that PHMSA revise §192.624(a)(1) to clarify that it does not apply where an operator already has TVC pressure test records to establish MAOP under §192.619(a)(2). In the petition, the Associations stated “Without the specific reference to §192.619(a)(2), §192.624(a)(1) could be interpreted to require a pipeline to reconfirm MAOP even for pipeline segments with a TVC pressure test record.” PHMSA granted the Associations’ request to limit the applicability of the MAOP reconfirmation requirements of §192.624(a)(1) to those pipeline segments that do not have TVC pressure test records under §192.619(a)(2).  So the bottom line is if a segment has a TVC pressure test record, but not TVC design pressure records under §192.619(a)(1), MAOP reconfirmation is not required under §192.624(a)(1).

In the amendment to the final rule, PHMSA reiterated that if operators are missing material property records during anomaly evaluations and repairs, they must confirm those material properties under §§192.607 and 192.712(e) through (g). PHMSA also emphasized that if an operator uprates a segment’s MAOP, they must have TVC material and pressure test records.

For a copy of this amendment, contact Jessica Foley.