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In This Issue

  1. Transportation Security Administration Releases Pipeline Physical Security Considerations
  2. PHMSA Natural Gas Distribution Infrastructure Safety and Modernization (NGDISM) Grant Program
  3. PHMSA Safety of Underground Natural Gas Storage Public Meeting
  4. PHMSA Survey of Voluntary Adoption of API RP 1173 for Gas Distribution Systems
  5. PHMSA Grants for Pipeline Safety Programs
  6. Texas Railroad Commission POC Electronic Filing
  7. Did you know?
  8. The Enforcement Corner
  9. April | National Safe Digging Month
  10. Q&A Section

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, interpretations and pending regulatory deadlines.

Q:  Must centrifugal pumps injecting liquids into a pipeline have high pressure shutdown devices?

A:  It depends on the “dead head” pressure of the pump.  If the maximum pressure developed by the pump is lower than the MOP of the pipeline, there is no need for a separate high pressure shutdown device because the pump cannot over-pressure the pipeline.  The operator should document those facts, and be aware that if the MOP of the pipeline is reduced in the future, pressure shutdowns might need to be added to the pump.  Thermal relief devices for the piping may still be required. 

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Upcoming Deadlines:

  • April 10, 2023, the Valve Rule is now fully in effect and requires 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 RMV’s 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 to be taking place.

If we can help, contact Jessica Foley.