In response to our Operator clients’ inquiries whether additional Cathodic Protection inspections now mandated by 192.465(d) and 192.473 impact Gas Transmission & Gathering pipelines are required, PAPS contacted PHMSA for clarification.

PHMSA Response: “Yes, for NGT (Transmission) and Type A NGG (Gathering) pipelines. No, for Type B & C GG pipelines. A typical phrase we use in our Form 26 GG Type B & C inspection questions’ considerations is: Note that there are specific regulatory exceptions in Subpart I for Type B and C gathering pipelines in §192.9(d)(2) and §192.9(e)(1)(ii) as follows:

If the pipeline is metallic, control corrosion according to requirements of subpart of this part applicable to transmission lines, except the requirements in §§ 192.461(f) through (i), 192.465(d) and (f), 192.473(c), 192.478, 192.485(c), and 192.493.

For best practices, I would recommend incorporating all the subpart I requirements as Gas Gathering operators may soon be required to have an O&M Manual which would include corrosion procedures. I do not know if the exceptions will be retained, but they may.”

PAPS concludes that only Type A Gas Gathering pipelines and Gas Transmission Pipelines (regardless of Class) are subject to the expanded inspections requiring pipeline operators to identify and validate any lines that are vulnerable to stray current impacts. These lines may require additional inspections to be conducted, including a Close Interval Survey (CIS) once every 3 years.

For your convenience, copies of 192.465 and 192.473 are available by clinking the links.

PAPS can help your organization understand the impact of this rule change and is ready to support you in ensuring compliance and pipeline safety requirements are met! Call us at (281) 379-1130 or contact us via email by clicking HERE.