Tad Nowicki, Christopher DeLeon, and Rhett Dotson, ROSEN USA, explain how new US regulations have changed requirements for assessing the maximum allowable operating pressure of pipelines.
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his article is focused on a non-technical review of the new onshore gas pipeline regulations in the US, specifically how the maximum allowable operating pressure (MAOP) of applicable transmission pipelines is required to be reconfirmed. On 1 October 2019, the US Department of Transportation’s (DOT) Pipeline and Hazardous Material Safety Administration (PHMSA) issued the first of three final rules to improve the safety of onshore gas pipelines. This rule focused specifically on gas transmission pipelines by addressing US congressional mandates in the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 (2011 Pipeline Safety Act) as well as recommendations made by the National Transportation Safety Board (NTSB) as a result of its investigation of the 2010 pipeline incident in San Bruno, California.1 In anticipation of this final rule, in 2011 PHMSA published an Advanced Notice of Proposed Rule Making (ANPRM), which identified 16 major areas of regulatory reform.2 This
first of three final rules, also called “RIN 1 of the New Gas Rules”, addresses several of these major topics focused on improving the safety of pipelines that operate with incomplete or inaccurate pipeline records. This rule requires onshore gas transmission pipeline operators to reconfirm the MAOP of segments that operate with previously untested pipe, commonly referred to as “grandfathered pipelines.” These pipelines typically do not have a traceable, verifiable, and complete (TVC) pressure test or adequate material property records indicating the pipeline’s diameter, wall thickness, specified minimum yield strength (SMYS) and construction method. Several other newly implemented requirements demand that pipeline operators create and implement written procedures for achieving MAOP reconfirmation in accordance with Section §192.624 of PHMSA’s Part 49 of the Code of Federal Regulation (CFR). Pipeline operators will also be required to determine, gather and report all pipeline mileage requiring
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