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: We have a gas pipeline adjacent to a refining / chemical facility. How should I count the buildings in the facility when doing class location analysis?
A: Counting the buildings at an industrial facility is unlikely to exceed the nine buildings causing a Class change from Class 1 to 2. However, segments of pipelines which are within 100 yards of a building(s) where people gather in numbers exceeding 20 or more for 5 days per week during any 10 weeks of the year does make the affected segment a Class 3 per § 192.5(3)(ii).
Upcoming Deadlines:
- 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.