PHMSA Notification Regarding Operating Pressure Records

U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration (PHMSA) has issued an advisory bulletin to reminded gas pipeline facilities to preserve and verify records related to maximum allowable operating pressure (MAOP) and informed hazardous liquid operators that they should adhere to the same standards for maximum operating pressure (MOP).

The revisions reflect new requirements for reporting procedures in the recent Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011, provide key safety data to assist PHMSA in addressing National Transportation Safety Board recommendations, and make other minor changes to improve overall data quality for industry professionals as well as the general public.

The advisory informs operators that records supporting MAOP and MOP should be traceable, verifiable, complete and clearly linked to original information about a pipeline segment or facility. These records must also be verified by complimentary, but separate, documentation. The advisory informs operators that to be complete, pipeline records must display a signature, date, or other appropriate marking to show the operator considers it to be a final document.

The advisory also notifies the public of PHMSA’s intent to gather public input about eliminating a grandfather clause that allowed gas transmission operators to establish the MAOP of pipe installed before 1970 by relying upon historical records. If the grandfather clause were eliminated, these operators would be required to reestablish MAOP using hydrostatic pressure testing. The NTSB recommended the elimination of the grandfather clause.

The advisory follows a Notice issued by PHMSA on April 13, 2011, outlining the agency’s proposals to make several minor updates to accident and incident reporting forms for hazardous liquid, gas transmission, and gas gathering pipeline systems. The Notice also explains PHMSA’s consideration of a number of changes to the annual report form used by operators of natural gas transmission and gathering pipeline systems.

Comments from interested parties are being accepted through June 12, 2012.

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EH&S compliance procedures, and preparing cost-effective EH&S management programs.
For further information contact Caltha LLP at
info@calthacompany.com or Caltha LLP Website