On November 5, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued two interpretation letters in response to questions posed by state pipeline safety program offices. One request focused on the actions an operator must take when identifying corrosion on an unprotected steel distribution pipeline, while the other interpretation was specific to the treatment of farm taps in Kentucky.
APGA is closely reviewing both of these interpretations and coordinating with other industry stakeholders to determine what subsequent actions might be necessary. Unfortunately, PHMSA’s interpretation process provides no opportunity for public comment as it is technically not providing a new regulatory requirement. However, it is well known that many times these interpretations deviate from previous common practices.
Regarding the Cathodic Protection (CP) on “Hot Spot” Locations, PHMSA concludes that if an operator experiences a corrosion leak on an unprotected steel distribution pipeline and installs a leak clamp, an anode must be installed. Additionally, PHMSA states that the adequacy of the CP provided by that anode must be tested at least once each calendar year, not to exceed 15 months, unless those tests are impractical. After the initial evaluation, operators must reevaluate the CP every three years not to exceed 39 months. The same requirements apply if the operator identified external corrosion, but no leak, and recoats the pipe and installs an anode.
Regarding the Statutory Farm Taps, in Kentucky producers and gatherers were historically required to offer natural gas service to owners of property located within one-half mile of its wells or gathering facilities. All equipment and material required to transfer natural gas from the tap to the customer’s premises are owned by the customer and defined as a “customer line.” PHMSA states that a “service line” ends at the connection to customer owned piping, or the outlet of a meter, whichever is further downstream. Therefore, in this situation, neither the customer nor the operator are required by federal regulation to maintain a customer owned regulator on a customer fuel line in accordance with the new Farm Tap inspection requirements.
For questions on this article, please contact Erin Kurilla of APGA staff by phone at 202-464-2742 or by email at
ekurilla@apga.org.