Pip

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Farm Taps

DIMP or Not

Could It Be Any More Messed UP?

Phone – (918) 679-0801

Email – ldmiller@trcsolutions.com

Lane Miller

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You know – the OQ Rule Without the OQ

Amdt. 192-123, 82 FR 7972, January 23, 2017

Miscellaneous II Rule

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� Amdt. 192-113, 74 FR 63905, December 4, 2009

� FAQ’s• C.3.7 Are operators required to include “farm taps” in their distribution

integrity management plan?

• “… The vast majority of “farm taps” meet the definition of a distribution line given that they do not meet the criteria to be classified as a gathering line or a transmission line. …”

• “… Operators of distribution, gathering, and transmission lines with “farm taps”

must have a distribution integrity management program meeting the

requirements of Subpart P for this distribution pipeline. …”

Distribution Integrity Management Rule

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� Intent • Was intended only for those

operators that didn’t otherwise have DIMP plan

� Cost / Benefit

• In this provision, farm taps would be removed from the DIMP program in favor of a less stringent set of inspection activities and over-pressurization protection equipment. This change would yield cost savings for operators.

• However, it was previously estimated that implementing a DIMP program and conducting required mitigation would cost the affected industry approximately $78 million per year after start-up. Removing farm taps from DIMP would relieve a small portion of these costs.

Unintended Consequences

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� Individual service lines directly connected to production, gathering, or transmission pipelines

�A New Code Section -§192.740

Pressure regulating, limiting, and overpressure protection

� Inspect and Test … equipment every 3 years NTE 39 mos., to determine;

• Mechanical condition• Adequate• Set to function correctly• Properly installed

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� Cost Savings for Removal From DIMP

� Cost to Rebuild for Testing and Inspection???

(no consideration in RFA)

Costs

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� Interpretation 192.739 14 - October 22, 1992

• “… Regulator stations must be inspected and tested to comply with §192.739 using any practicable method that will demonstrate the presence or absence of the listed qualities. Set-point, lock-up, and full-stroke-operation would be part of the inspection and testing if such tests are practicable at the station concerned. …”

Rebuild to Facilitate Testing??

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� Interpretation 192.739 15 – April 28, 1993

• “… In addition, to us, practicable inspections and tests do not require the operator to disassemble the regulator, re-pipe the regulator, or cut off the supply of gas to the system. Instead, we suggest that, as a minimum, these service-type regulators be visually inspected, be checked for leaks (including the regulator vent), and be checked for correct set-point. Verifying the correct set-point on a service-type regulator can be done by measuring the pressure of the gas (downstream of the regulator) with a pressure gauge. …”

Rebuild to Facilitate Testing ??

Questions?

Lane Miller

P: 918 679-0801 | E: ldmiller@trcsolutions.com

www.trcsolutions.com