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PHMSA Holds GPAC Meeting on Safety of Gas Transmission & Gathering Lines Rulemaking

By Erin Kurilla posted 03-29-2018 11:57 AM

  
This week, the Pipeline and Hazardous Materials Safety Administration (PHMSA) held its fifth, and final, Gas Pipeline Advisory Committee (GPAC) meeting on The Safety of Gas Transmission & Gathering Lines Rule. While there will be one more meeting pertaining to gathering lines, this marked the end of a long journey to discuss all elements of the rule pertaining to gas transmission pipelines. A few major decisions were made and some loose ends were concluded. This week, the Pipeline and Hazardous Materials Safety Administration (PHMSA) held is fifth, and final, Gas Pipeline Advisory Committee (GPAC) meeting on The Safety of Gas Transmission & Gathering Lines Rule. While there will be one more meeting pertaining to gathering lines, this marked the end of a long journey to discuss all elements of the rule pertaining to gas transmission pipelines. A few major decisions were made and some loose ends were concluded. 

1. Three Final Rules: PHMSA will be splitting the rule into three separate Final Rules. The first will focus on regulatory changes driven by congressional mandates. The second will finalize the topics associated with gas transmission lines. The last rule will be specific to gathering lines. While there are many external factors influencing the publication of each of these rules, we do anticipate PHMSA trying to publish the first rule by the end of 2018.  

2. Distribution Center Definition: There was consensus among the GPAC members to utilize the industry proposed definition to define “distribution center.” However, PHMSA hesitated in committing to codifying a definition in this rulemaking due to concerns that establishing a definition will not fully address the confusion around the functional definition of “transmission line.” It now seems as though PHMSA is open to a two-pronged approach: (1) codify a definition in Rule 1; (2) bring together appropriate stakeholders to determine if a fresh look at the distribution/transmission demarcation is necessary. 

3. MAOP Reconfirmation: It is PHMSA’s position that new Maximum Allowable Operating Pressure (MAOP) Reconfirmation requirements should align exactly with the congressional mandates. Therefore it seems likely that the following subsets of pipelines will be required to perform MAOP Reconfirmation:
• Pipelines without records of a pressure test operating in High Consequence Areas (HCA), Class 3 or 4 Areas. 
• Pipelines utilizing the Grandfather Clause for MAOP establishment operating greater than 30 percent of specified minimum yield strength in HCAs, Class 3 & 4 areas, or Moderate Consequence Areas (MCA), if the pipeline is able to be in-line inspected using a free-swimming in-line inspection tool.

As with past GPAC meetings, APGA will be working with the other industry associations to provide comments to PHMSA on the conclusion of the meeting. In those comments, we will provide redlined code language consistent with the GPAC’s votes & conversations. 

Also, please make sure you thank Rich Worsinger the next time you see him! He has done an excellent job representing APGA members throughout the entirety of this process. For questions on this article, please contact Erin Kurilla of APGA staff by phone at 202-905-2904 or by email at ekurilla@apga.org.

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