In This Issue

Q&A Section

Do you have questions? RCP’s SMEs have the answers. Information will be posted here for questions we often get from clients or discussions we have with regulators, regarding interpretations and pending regulatory deadlines.

Q: If PHMSA’s maps show a liquid HCA, such as a drinking water source, in a certain location, must liquid operators assume that information is accurate when doing their “could affect” analysis?

A: PHMSA’s liquid HCA maps are based on various datasets provided by other agencies and organizations.  While they are a good starting point when identifying HCAs, they are not definitive.  Operators are required to identify any HCAs which were missed in PHMSA’s maps.  Likewise, operators may be able to demonstrate that an HCA shown on PHMSA’s maps is not currently an HCA.  If so, they can omit that HCA from their “could affect” analysis.  RCP can help operators upgrade their HCA datasets to ensure only current HCAs are included in their “could affect” analysis. 

Upcoming Deadlines:

  • April 10, 2023, is coming soon and require all new and entirely replaced gas transmission and liquids pipelines subject to PHMSA’s new RMV rule to comply from that point forward unless alternative technologies are approved by PHMSA for a particular instance. The new RMVs will have to be operational within 14 days of placing the new line or replacement segment in service.
  • The onshore gas gathering rule was published April 8, 2022. Portions became effective May 16, 2022 – Reporting of Incidents for the new Type C & R.
  • Full identification by Type and Class location was to be completed by November 16, 2022
  • For the newly identified Type C that must have the MAOP established, the deadline for boosting system pressure to take advantage of “highest actual operating pressure” as permitted by 192.619(a)(3) is coming fast – May 16, 2023
  • And as a reminder, the “Stay of Enforcement” does not mean regulators don’t expect work toward getting compliance activities in place can be ignored.

If we can help, contact Jessica Foley.