In the latest Regulation Navigation, ITS Compliance and Regulatory Specialist Warren Miller shared his key takeaways regarding the Leak Detection and Repair (LDAR) Notice of Proposed Rulemaking from the Gas Pipeline Advisory Committee (GPAC) meeting, November 27th through December 1st, 2023. Due, in part, to the large number of comments under consideration, only half of the Notice of Proposed Rulemaking (NPRM) was discussed during the meeting.
GPAC gathers government, industry, and public stakeholders to review the proposed rule’s language and develop recommendations for the final rule. PHMSA will consider these recommendations but is not bound by them.
Here are Warren’s five key takeaways from Regulation Navigation:
- This is not yet a final rule. The GPAC committee votes on and recommends language, but PHMSA is the final authority.
- There’s still time to contact the involved associations before the next GPAC meeting, which begins on March 25th. Some topics you may want to comment on include: Gas gathering, Reporting, LNG and Hydrogen, Compliance deadlines, OQ, and Miscellaneous proposals.
- Do not go out and buy new equipment until this regulation comes out as a final rule. Some of the rulemaking language may be revised.
- Prepare for change. Whatever PHMSA decides, this will certainly affect operation and maintenance, training, and possibly OQ for most operators.
- The best estimate for the date of a final rule is June 1st or later.
You can access the full transcript from the November/December GPAC meeting online or review the slides containing the proposed language at the bottom of this meeting notes page.
The next working session on the LDAR rule will be March 25, 2024.
Save the date for our next Regulation Navigation webinar on May 15th, 10 am Central Time, where we plan to discuss the rest of GPAC’s recommendations.
If your company needs assistance with compliance or regulations, contact Warren Miller about his consulting and speaking services.