PHMSA Response to Mega Rule Part 1 Petition for Reconsideration
PHMSA has issued a response to a petition for reconsideration on Part 1 of the Gas Transmission Rule: MAOP Reconfirmation, Expansion of Assessment Requirements, and Other Related Amendments, A.K.A. the “Mega Rule” issued October 1, 2019. In the response PHMSA has agreed to two updates/clarifications:
o Under 192.5, Class locations: PHMSA has clarified that the records requirement for documenting class locations only applies to gas transmission lines
o Under 192.624, Maximum allowable operating pressure reconfirmation: Onshore steel transmission pipelines: PHMSA has limited the MAOP reconfirmation scope to pipelines missing traceable, verifiable, and complete (TVC) pressure test records, eliminating the need to also have TVC records for pipe and component specifications.
The latter point is potentially a significant change to the interpretation, expectation, and implementation of Part 1 of the Mega Rule. These changes are anticipated to be published in the Federal Register on July 6th (here). If you have questions or would like further guidance, please contact Elemental Compliance at Nicole.Tebow@ElementalCompliance.com or Lauren.Tipton@ElementalCompliance.com.