September 2020 Vol. 75 No. 9

Washington Watch

PHMSA ratifies industry request on MAOP

Stephen Barlas | Washington Editor

The Pipeline and Hazardous Materials Safety Administration (PHMSA) published a final rule in mid-July granting transmission pipelines the changes they had requested after publication of a final rule last October titled, “Safety of Gas Transmission Pipelines: MAOP Reconfirmation, Expansion of Assessment Requirements, and Other Related Amendments.”

After that rule was published, a number of industry groups asked the agency to reconsider a couple of key provisions, especially the one requiring companies reconfirm maximum allowable operating pressure (MAOP) in certain circumstances.

PHMSA acceded to that request on July 15 via a final rule that says operators do not have to reconfirm MAOP of pipeline segments if they have traceable, verifiable and complete pressure test records. The rule also makes it clear that the requirements on MAOP do not apply to distribution or gathering pipelines.

The October 2019 gas transmission rule focused on the actions an operator must take to reconfirm the MAOP of previously untested natural gas transmission pipelines and pipelines lacking certain material or operational records. It also required operators gather any necessary material property records, where the records needed to substantiate the MAOP are not traceable, verifiable and complete. Examples of the records necessary to confirm MAOP include pressure test records or material property records that verify the MAOP is appropriate for the class location.

On Oct. 31, 2019, the American Public Gas Association, the American Gas Association, the Interstate Natural Gas Association, and the American Petroleum Institute (the Associations) submitted a petition for reconsideration of the MAOP provisions in that rule.

Though PHMSA confirmed that distribution pipelines were not subject to the MAOP requirements, PHMSA published a separate proposed rule in June 2020, which would make changes to the Distribution Integrity Management Program (DIMP). That proposal would provide operators of farm taps originating from regulated source pipelines the flexibility to choose between inspecting pressure regulators, pursuant to their DIMP, or using pressure regulators and overpressure protection equipment to be inspected and tested at least once every three calendar years. Farm taps originating from unregulated gathering and production pipelines and master meter operators would be exempt from both DIMP and incident and annual reporting requirements.

In addition to the DIMP proposals, the proposed rule includes a provision applicable to all gas pipelines: increase of the property damage threshold associated with a reportable “incident” from the existing $50,000 to $122,000. If adopted as final, pipeline operators would no longer have to report smaller incidents that cause property damage below the threshold.

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