Frequently Asked Questions (FAQs) On Gas Transmission .

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Frequently Asked Questions (FAQs) on Gas Transmission Final RuleTitle: Frequently Asked Questions (FAQ) for the Final Rule titled “PipelineSafety: Safety of Gas Transmission Pipelines: MAOP Reconfirmation,Expansion of Assessment Requirements, and Other Related Amendments,”published on October 1, 2019Date: September 15, 2020Summary:PHMSA is issuing these Frequently Asked Questions (FAQs) to assist gas pipeline owners andoperators in complying with the pipeline safety regulations in 49 CFR Parts 191 and 192. Theseregulations were amended on October 1, 2019, by the Final Rule entitled “Pipeline Safety: Safetyof Gas Transmission Pipelines: MAOP Reconfirmation, Expansion of Assessment Requirements,and Other Related Amendments” (84 FR 52180). This guidance document was not deemed“significant” or “otherwise of importance to the Department’s interests,” as defined by 49 CFR5.37. However, PHMSA voluntarily posted the FAQs to the Federal Register on January 29,2020, for public comment, under Docket Number PHMSA-2019-0225. A public meeting wasthen held on February 27, 2020. In finalizing this guidance document, PHMSA consideredcomments made at the public meeting along with the 18 comments submitted to the docket as ofMarch 30, 2020. This guidance document is not intended to replace or revise any previouslyissued guidance.This guidance does not have the force and effect of law and is not meant to bind the public in anyway, although pipeline operators must still comply with the underlying safety standards. TheseFAQs are only intended to clarify existing requirements under the pipeline safety laws, PHMSAregulations, and agency policies.General FAQsFAQ-1. What are key implementation dates associated with this Final Rule?July 1, 2020 Operators must prepare and follow procedures (per §§ 192.13(c) and 192.605) addressingapplicable regulations without timeframes explicitly defined in the Final Rule (§§ 191.23,191.25, 192.3, 192.5, 192.7, 192.9, 192.18, 192.67, 192.127, 192.150, 192.205, 192.493,192.506, 192.517, 192.607 (if material verification is being used per § 192.712), 192.619,192.632, 192.710, 192.712, 192.805, 192.909, 192.917, 192.921, 192.933, 192.935,192.937, 192.939, 192.949 (removed and replaced with 192.18), and Appendix F to Part192.Operators must begin to identify, schedule (according to a risk-based prioritization), andperform assessments required by § 192.710 (see FAQ-12 regarding MCA identification).Page 1 of 16

Frequently Asked Questions (FAQs) on Gas Transmission Final RuleJuly 1, 2021 Operators must begin retaining records for each individual welder qualification at thetime of construction for a minimum of 5 years following construction, per § 192.227.For transmission pipe installed after July 1, 2021, operators must begin retaining recordsfor each person’s plastic pipe joining qualifications at the time of construction for aminimum of 5 years following construction, per § 192.285.If subject to § 192.624, operators must develop and document procedures for completingall actions required by this section (see FAQ-12 regarding MCA identification). Theseprocedures must include:o A process for reconfirming MAOP for any pipelines that meet a condition of§ 192.624(a)o A process for performing a spike test or material verification per §§ 192.506 and192.607, if applicableo A process for performing an engineering critical assessment (ECA) for MAOPreconfirmation per § 192.632, if implementedOperators must modify their launchers and receivers that will be used after this date tomeet the conditions of §192.750.March 15, 2022 Operators must submit a revised Annual Report (PHMSA F 7100.2-1) that reflect thisrulemaking.July 3, 2028 Operators must complete all actions required by § 192.624 on at least 50% of the pipelinemileage subject to MAOP reconfirmation.July 3, 2034 Operators must complete all originally identified assessments required by § 192.710.July 2, 2035 Operators must complete all actions required by § 192.624 on 100% of the pipelinemileage subject to MAOP reconfirmation.FAQ-2. Do any of the new rules apply to regulated gas gathering lines?Yes. While the new rule focuses on the safety of onshore gas transmission lines, newrequirements apply to regulated gas gathering lines. Section § 192.9 identifies the safetyrequirements applicable to regulated gas gathering lines. Sections §§ 192.9(b), 192.9(c), and192.9(d) identify code sections that do not apply to gas gathering lines. Operators of regulatedgas gathering lines should review the following code sections, revised in this rulemaking, to seePage 2 of 16

Frequently Asked Questions (FAQs) on Gas Transmission Final Rulehow they apply to their systems: §§ 191.23, 191.25, 192.3, 192.5, 192.7, 192.18, 192.67,192.127, 192.205, 192.227, 192.517, 192.619(a), 192.619(f), 192.750, and 192.805.FAQ-3. Who qualifies as a “subject matter expert” for purposes of reviewing andvalidating failure pressure analyses under § 192.712?PHMSA described the qualifications of a “subject matter expert” in the Preamble of the FinalRule at 84 FR 52206: PHMSA expects a qualified subject matter expert to be an individual withformal or on-the-job technical training in the technical or operational area being analyzed,evaluated, or assessed. The operator must be able to document that the individual isappropriately knowledgeable and experienced in the subject being assessed.The intent of § 192.712 is to require operators to conduct rigorous failure pressure analyses thatare properly documented, for review and evaluation by qualified experts. Subject matter expertsdon’t necessarily need to perform the analyses, but they must review and confirm the analyses.FAQ-4. What date or what activities should an operator use to compute the beginning ofthe five-year period from which it needs to retain individual joining or weldingqualification records pursuant to § 192.227(c)?Records required by 192.227(c) must be retained for a minimum of five years after the end ofconstruction. PHMSA considers the end of construction to be prior to an operator placing a gas,as defined by §§ 192.1(a) and 192.3, into the pipeline, making it an in-service pipeline, andoperating that pipeline. Per § 192.227(c), “construction” activities include the installation ofpipe—be it for new construction, replacement, relocation, or repair. These construction activitieswould also include the installation or replacement of components with pipe attached.FAQ-5. Removed.Reporting FAQsFAQ-6. When is the effective date of the revised incident report form? (The revised formrequires collecting data on the MAOP reconfirmation method and moderate consequencearea location for the pipe segment involved in an incident.)Operators can report new data requirements on the revised incident form (Form PHMSA F7100.2) starting July 1, 2021. However, operators can view this revised form currently on thedocket (PHMSA-2019-0225). Section 191.15 requires each operator of a transmission or agathering pipeline system to submit DOT Form PHMSA F 7100.2 as soon as practicable, but notmore than 30 days after detecting an incident required to be reported under § 191.5 of Part 191.The form has been modified to collect information and data the pipeline operator must obtain aspart of the Final Rule, including a record(s) of the maximum allowable operating pressure(MAOP) reconfirmation method used for the pipeline segment that experienced the incident, andwhether the incident occurred in a moderate consequence area (MCA). Operators must identifyMCAs to determine if the new requirements under §§ 192.624(a) and 192.710(a) apply to them.Page 3 of 16

Frequently Asked Questions (FAQs) on Gas Transmission Final RuleFAQ-7. When will Form PHMSA F 7100.2-1 (annual report) be revised to reflect theadditional information that PHMSA expects to collect for miles of pipe in MCAs andMAOP reconfirmation?The revised annual report form (Form PHMSA F 7100.2-1) for gas transmission pipelines hasbeen modified to collect MCA and MAOP reconfirmation information. Operators will be able tostart using the annual report form on July 1, 2021. Operators, however, can view this revisedform currently on the docket (PHMSA-2019-0225). PHMSA will require operators to use therevised annual report form beginning Calendar Year 2021, due no later than March 15, 2022.The Final Rule does not require modifications of the annual report for gas distribution; therefore,that report remains unchanged.Other Technology Notification FAQsFAQ-8. Does the notification process set forth in § 192.18 apply to all of Part 192?No. The notification guidance in § 192.18(a) and (b) applies to all sections of Part 192. Thesections specifically identified in § 192.18(c) require that the operator provide notification toPHMSA at least 90 days prior to using other technologies or methodologies. These sectionsinclude as follows: §§ 192.506(b), 192.607(e)(4), 192.607(e)(5), 192.624(c)(2)(iii),192.624(c)(6), 192.632(b)(3), 192.710(c)(7), 192.712(d)(3)(iv), 192.712(e)(2)(i)(E),192.921(a)(7), or 192.937(c)(7). Operators are also required to notify PHMSA of changes totheir Operator Qualification and Integrity Management plans per § 192.805(i) and § 192.909 (b),respectively.FAQ-9. Removed.FAQ-10. Must operators wait for written approval from PHMSA prior to implementingother technology for purposes of complying with the sections identified in § 192.18(c)?No, operators may proceed with using other technologies if they submitted a notification per §192.18 and PHMSA did not respond within 90 days. After 90 days following notificationsubmission, an operator does not have to wait for a written approval or a “no objection letter”from PHMSA to proceed with using “other technology.” An operator seeking a written “noobjection letter” from PHMSA prior to implementing the alternative technology per § 192.18(c)should include a specific request for the written response in its § 192.18 notification.Page 4 of 16

Frequently Asked Questions (FAQs) on Gas Transmission Final RuleModerate Consequence Area (MCA) FAQsFAQ-11. In identifying MCAs affecting their pipelines, where can operators obtaininformation as to the location of a designated interstate, other freeway or expressway, andother principal arterial roadway with 4 or more lanes?To identify applicable roadways, PHMSA expects operators to use all information availableincluding but not limited to the following: www.thenationalmap.gov, www.fhwa.dot.gov, andother federal and state highway mapping data; aerial imagery; pipeline patrols and surveys(ground and aerial); and, pipeline route maps. When identifying an MCA, PHMSA expectsoperators to capture the area between the outermost edge of the paved surfaces, including allmedians. Entrance and exit ramps to access-controlled roadways should be included in the MCAanalysis. There is no comprehensive GIS-based source of roadways as defined in the FederalHighway Administration’s (FHWA) Highway Functional Classification Concepts, Criteria andProcedures, Section 3.1 tatewide/related/highway functional classifications/fcauab.pdf). However, Section 4 of the FHWA document includes recommendations andguidance on how to obtain GIS-based roadway inventory data at a state level. PHMSA does notintend to develop a single source of data for operators to use to determine if an MCA exists ontheir pipeline system.FAQ-12. When must operators complete the initial determination of MCAs on theirpipeline system?The new rule, which went into effect July 1, 2020, requires operators to develop procedures per §192.605(b)(1) to determine the location of MCAs on their pipeline system and to incorporatethese procedures into their manual for maintenance and normal operations. Operators must thenimplement those procedures to complete the initial identification of MCAs by July 1, 2021 andrecord those MCAs in the revised incident and annual reports after this date. (See FAQ-6 andFAQ-7.)PHMSA anticipates that some operators will incorporate an MCA identification process intoexisting HCA and class identification procedures, while other operators might prepare a separateprocedure for identifying MCAs. MCAs are used to determine a pipeline segment’s applicabilityunder §§ 192.624 and 192.710.Operators must begin performing assessments according to a risk-based prioritization schedulestarting July 1, 2020, the effective date of the rule, and complete all assessments no later thanJuly 3, 2034, per § 192.710(b). Operators must also begin performing MAOP reconfirmationson July 1, 2021, to complete all actions required by the schedules in § 192.624(b)(1) and (2).An assessment performed prior to July 1, 2020, the effective date of the rule, that meets theconditions outlined in § 192.710(b)(3) may be used as an assessment. Operators who use a priorassessment for a pipeline segment located in an MCA must conduct ongoing reassessments ofthat segment within 10 years as per § 192.710(b)(2)—not 14 years as would be the case for aninitial assessment under § 192.710(b)(1).Page 5 of 16

Frequently Asked Questions (FAQs) on Gas Transmission Final RuleFAQ-13. Do operators need to identify, document, and track “unpiggable” MCAsoperating less than 30% Specified Minimum Yield Strength (SMYS)?Yes. Operators must identify, document and track all MCAs—regardless of piggability andoperating stress—for annual and incident report data collection.FAQ-14. How frequently must a re-evaluation of MCAs be performed and when must newMCAs be incorporated into an operator’s plans and procedures?PHMSA expects that operators will re-evaluate their MCAs once per calendar year, not toexceed a period of 15 months, consistent with current HCA and class location change studies(per §§ 192.905 and 192.609). PHMSA also expects that operators will add any newly identifiedMCAs to their § 192.710 assessment schedule within one year of the discovery date. Thisexpectation is consistent with current Gas IMP FAQ-19, FAQ-20, and FAQ-179, posted on thePHMSA’s Technical Resources site at anagement-faqs.Spike Hydrostatic Testing FAQsFAQ-15. Under § 192.506 Transmission lines: Spike hydrostatic pressure test, is a spike testrequired for all pipelines that are hydrotested (or re-hydrotested) and are operating at30% or more of SMYS? For what threats is a spike hydrostatic pressure test appropriate?No. A spike test is not required for all pipelines that are hydrotested or re-hydrotested and areoperating at 30% or more of SMYS. The hydrostatic spike pressure testing requirements in§ 192.506 applies only when conducted as required by §§ 192.710 and 192.921.A spike test is appropriate and should be considered for time-dependent threats, such as thefollowing: stress corrosion cracking; selective seam weld corrosion; manufacturing and relateddefects, including defective pipe and pipe seams; and, other forms of defect or damage involvingcracks or crack-like defects, such as those listed in §§ 192.710(c)(3), 192.917(e)(6) and192.937(c)(3).If an operator decides to spike test a transmission pipeline operated at a hoop stress greater than30% SMYS, the test must be conducted according to the spike-test procedures listed in §192.506.Material Verification FAQsFAQ-16. Is the use of § 192.607 Verification of Pipeline Material Properties and Attributesallowed outside of HCAs, MCAs, and Class 3 and Class 4 locations?Yes. While pipeline operators must verify material properties per § 192.607 where explicitlyreferenced in Part 192, PHMSA also allows the voluntary use of § 192.607 (per § 192.619(a)(4))Page 6 of 16

Frequently Asked Questions (FAQs) on Gas Transmission Final Rulefor material property verification outside of HCAs, MCAs, and Class 3 and Class 4 locations inorder to determine key Subpart C – Pipe Design attributes. Operators of pipeline segments thatdo not meet the applicability of § 192.624 may, and in fact are encouraged to, conduct and usethe results of a properly conducted testing program such as those outlined in §192.607 to ensurethe safe operation of the pipeline regardless of location. That said, operators must consider thenewly determined material property results regardless of pipeline location when they analyzepredicted failure pressures for anomalies, develop appropriate repair procedures, conductengineering critical assessments, or fulfill other requirements under Part 192.FAQ-17. PHMSA allows the data collection process to be accomplished“opportunistically” per § 192.607(c). Is there a deadline by which operators are expectedto complete this process?No. The opportunistic gathering of data on unknown material properties does not need to meetthe MAOP reconfirmation schedule outlined in § 192.624(b), except when the selected MAOPreconfirmation method requires material properties testing to reconfirm the MAOP. Thetimeframe for opportunistic data collection may vary, based on the length of the pipeline, amountof pipe with missing material properties, number of opportunities, and testing results. (See§ 192.607 for a complete description.) Also, § 192.712 requires the operator to know the pipematerial properties when conducting the analysis of predicted failure pressure for anomalies ordefect evaluations.FAQ-18. When determining separate pipe “populations” for conducting a verifiablematerial properties and attributes sampling program that satisfies § 192.607(e)(1), must anoperator compare the dates of manufacture and construction together, or must themanufacture and construction dates be compared separately? For example, would twosegments of pipe that were manufactured in the same year but were installed together, 3years after manufacture, be in the same population? As a second example, would twosegments of pipe that were manufactured in the same year but installed 3 years apart be inthe same population?When determining the vintage of two potentially similar pipeline segments (e.g., same diameter,wall thickness, grade, and seam type), operators must consider the following: If the differencebetween either the manufacturing date of the two segments or the construction date of the twosegments is greater than 2 years, the two segments cannot be considered similar and must beplaced in separate populations per the mandate in § 192.607(e)(1). In the first example, the twopipe segments would be in the same population. In the second example, the operator would notbe able to place the two pipe segments in the same population unless additional recordsdemonstrate traceability to another population of pipe.Page 7 of 16

Frequently Asked Questions (FAQs) on Gas Transmission Final RuleFAQ-19. It appears to be a requirement to separate pipe segments into differentpopulations based on the material properties and attributes listed in § 192.607(e)(1), buthow do you handle the situation where you are missing documentation for an attribute likepipe manufacturing dates?Operators should only split populations based on known attributes and they should have separatepopulations of pipe segments where attributes are unknown. Operators that can document pipematerial properties but are missing the manufacturing or construction date attributes would notneed to conduct an expanded sampling program to determine material properties. When materialattributes are unknown, operators must use manufacturing and construction dates noted in§ 192.607(e)(1) and FAQ-18 to delineate the boundaries of the material properties samplingprogram.FAQ-20. How should operators define populations where necessary documentation ismissing? Can an operator group all pipe sections with unknown attributes into onepopulation?Per § 192.607, operators must implement a sampling program for each unique pipe populationgroup with unknown pipe attributes. Operators can initially group pipe segments with no knownmaterial properties information into

Frequently Asked Questions (FAQs) on Gas Transmission Final Rule Page 1 of 16. Title: Frequently Asked Questions (FAQ) for the Final Rule titled “Pipeline Safety: Safety of Gas Transmission Pipelines: MAOP Reconfirmation, Expansion of Assessment Requirements, and Other Related Amendments,” published on October 1, 2019 . Date: September 15, 2020

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