On May 15th, 2024, Warren Miller, the ITS Regulatory Compliance Specialist, and Chris Taylor, the VP of Learning and Compliance, hosted the Regulation Navigation webinar to discuss the second GPAC meeting on the NPRM for LDAR from this past March.  

GPAC stands for the Gas Pipeline Advisory Committee Meeting. This meeting concluded discussion of the Leak Detection and Repair (or LDAR Rule) NPRM and the committee recommended language on certain areas of proposed regulation for PHMSA to include when developing its final rule. 

The webinar focused on the anticipated changes coming to the pipeline industry, including requirements for gathering lines and leak detection requirements in general.  

Expect expanded leak detection regulations and new challenges for all types of pipelines, especially those that require additional mapping and reporting.  

Here are Warren’s five key takeaways from Regulation Navigation:  

  1. Comments were closed for LDAR as of April 29. We hope you were able to get comments into PHMSA before the deadline. You can still comment on the Class Location NPRM until August 27, 2024 if you want your comments on the official docket.
  2. If you are an operator, let your company leadership know there is pending regulation coming, and it will affect your operations. You may want to provide the voting slides from GPAC so they are aware of the possible changes.   
  3. Do not go out and buy new equipment until this regulation comes out as a final rule. Some of the rulemaking language may change.   
  4. Prepare for change. This will affect operation and maintenance, training, and possibly OQ for most operators.    
  5. “When will this be final?” The best estimate after this last GPAC looks like December of 2024. There are several approvals that must occur before PHMSA can publish the Final Rule.  Two dates that must be accounted for: the publication of the FR and the effective date of the rule that will be spelled out in the initial part of the FR.

 

You can access the document list and voting slides from the March 2024 GPAC Meeting.

Watch the latest Regulation Navigation here.

Save the date for our next Regulation Navigation webinar on September 11, at 10 am Central Time.

If your company needs assistance with compliance or regulations, contact Warren Miller about his consulting and speaking services.