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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.

Hazardous Liquids operators that have facilities that, in the event of a failure, could affect a High Consequence Area are not required to conduct integrity assessments, as these requirements only apply to line pipe or “Right of Way pipe.” Under §195.452, Pipeline Integrity Management in High Consequence Areas, operators of “could affect” facilities are required to:

  • Integrate data and conduct a Risk Analysis
  • Evaluate the necessity of additional Preventive and Mitigative Measures

Refer to PHMSA FAQ 2.1 for additional information:

Q:  FAQ 2.1 Does the rule apply to more than line pipe?

A:  Yes. The continual evaluation and information analysis requirements of the rule apply to pipelines as defined in 49 CFR 195.2. This includes, but is not limited to, line pipe, valves and other appurtenances connected to line pipe, metering and delivery stations, pump stations, storage field facilities, and breakout tanks. The baseline integrity assessment and periodic re-assessment requirements apply only to line pipe.

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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 can be ignored.

If we can help, contact Jessica Foley.