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: When discovering an immediate repair anomaly do I have to take a pressure reduction if I am operating below the calculated safe pressure per RSTRENG to take 20% pressure reduction in operating pressure and is this considered a safety-related condition?
A: Yes. The pressure reduction is still required by 20% of highest pressure within the previous 60 days and a Safety Related Condition (SRC) report is required within 5 days of determining the reduction.
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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 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 or that the rule can be ignored.
If we can help, contact Jessica Foley.