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On Tuesday, June 9, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published the Gas Pipeline Regulatory Reform Notice of Proposed Rulemaking. This proposed rule is in response to the President’s January 30, 2017, Executive Order (EO) “Reducing Regulation and Controlling Costs” and the two 2017 Department of Transportation requests for public comment on regulations that (1) are obstacles to transportation infrastructure projects or (2) could be repealed, replaced, suspended or modified without compromising safety.

APGA submitted comments to the second notice supporting the broad comments submitted by the pipeline industry trade associations and provided additional specific comments on atmospheric corrosion checks and public awareness effectiveness requirements. To view those comments, please go to community.apga.org/2017-PHMSA-Comments.

PHMSA has now requested comment on ten proposed amendments to 49 CFR Parts 191 and 192:

1. Provide flexibility in the inspection requirements for farm taps;
2. Repeal distribution integrity management program (DIMP) requirements for master meter operators;
3. Repeal submission requirements for the mechanical fitting failure (MFF) reports;
4. Adjust the monetary damage threshold for reporting incidents for inflation;
5. Allow remote monitoring of rectifier stations;
6. Revise the inspection interval for monitoring atmospheric corrosion on gas distribution service pipelines;
7. Update the design standard for polyethylene (PE) pipe and raise the maximum diameter limit;
8. Revise test requirements for pressure vessels consistent with American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME BPVC);
9. Revise welder requalification requirements to provide scheduling flexibility; and
10. Extend the allowance for pre-tested short segments of pipe and fabricated units to pipelines operating at a hoop stress less than 30 percent of the specified minimum yield strength (SMYS) and above 100 pounds per square inch (psi).

The proposals of particular interest to APGA membership are:

• Mechanical Fitting Failure Reports: PHMSA is proposing to eliminate the requirement for operators to submit mechanical fitting failure (MFF) reports. Operators would still be required to submit incident reports, which include almost all of the information on the MFF form, for releases from mechanical fittings that meeting the definition of incident. The MFF form has largely become duplicative of the incident form.
• Atmospheric Corrosion Inspections: PHMSA agreed with APGA’s recommendation to establish a separate atmospheric corrosion reassessment interval for gas distribution service pipelines. PHMSA proposes a maximum inspection interval for service lines of once every 5 calendar years, not to exceed 63 months unless atmospheric corrosion was identified on the last inspection. If there is observed corrosion, the interval for the subsequent inspection would be once every 3 years, not to exceed 39 months. An operator could revert to the longer interval if no atmospheric corrosion is identified on the next inspection. PHMSA would expect, however, operators of service lines in high-corrosion environments to consider atmospheric corrosion in their evaluation of risks under DIMP and conduct atmospheric corrosion inspections more frequently than the minimum requirements.

Comments are due in early August 2020. APGA draft comments will be shared with the Operations & Safety Committee for review and approval. It is our hope to work with the other gas pipeline industry trade associations on filing comments to this proposed rule.

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.