Reconfirmation Plans and Options

On October 1, 2019, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published amendments to 49 CFR Parts 191 and 192 in the Federal Register issuing the Pipeline Safety: Safety of Gas Transmission Pipelines: MAOP Reconfirmation, Expansion of Assessment Requirements, and Other Related Amendments Final Rule (Final Rule).

The Final Rule requires that for on-shore steel transmission pipelines in an High Consequence Area (HCA), Class 3 or 4 location without Traceable, Verifiable and Complete (TV&C) records for §192.619(a)(2) (pressure testing, including records required by §192.517(a)) ; or where the Maximum Allowable Operating Pressure (MAOP) was established based on the Grandfather Clause and the MAOP creates a stress ≥ 30% of the Specified Minimum Yield Strength (SMYS), an operator will need to reconfirm the MAOP in accordance with the provisions of §192.624. Operators must develop and document procedures to satisfy §192.624 by July 1, 2021, and have until July 3, 2028, to Reconfirm the MAOP for 50% of their subject pipeline mileage and until July 2, 2035, to reconfirm the MAOP for 100% of subject mileage. There are six Methods prescriptively identified to Reconfirm MAOP:

1. A hydrostatic pressure test per Subpart J along with Material Verification per §192.607
2. Pressure Reduction with Material Verification in some cases
3. Engineering Critical Assessment (ECA),
4. Pipe replacement,
5. Pressure reduction for pipeline segments with Small Potential Impact Radius (PIR) (≤ 150 ft.), or
6. Alternative technology submitted to PHMSA with no objection received within 90 days.

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