[Docket No. PHMSA-2011-0023-0471]
PHMSA has made several important modifications to the incident report form and instructions for reporting Natural Gas Transmission and Gathering releases. The following changes have occurred:
- PHMSA asks what time the release met report criteria (A.4) and when the operator identified the failure. These times may be the same, but often an operator is aware of an event before any report criteria have been met.
- PHMSA now requires more details on the operational status of the pipeline at the time of the incident. For example, did the event occur during routine start-up or normal operations?
- Additional information is being collected on release consequences. The number of injuries that did not require overnight hospitalization, but did require treatment, whether at a hospital or onsite by EMTs is now required. Also, the number of private/business buildings that were affected by the event, damaged, evacuated, or had gas service interrupted, will be collected in the form.
- Additional information on when and how MAOP was first established are now required as well as the estimated gas flow through the pipe at the time of the release.
- Additional information on Stray Current Corrosion is now being collected.
- Additional questions will be required on underground facilities located within a foot of the line where the incident occurred and if it occurred in a water crossing 100 feet or greater in length.
- A new section with several questions regarding vehicular damage not related to excavation is included requiring information on the driver, vehicle, speeds, etc. for Other Outside Force Damages.
- Part J is now a separate section that includes information regarding in-line inspections. The list of ILI tools has been updated to reflect current technologies. Other data now collected include the propulsion method for the tool, the resolution of the tool (if applicable), and the type of anomalies the tool was attuned to detect. In addition, the most recent tool run year and the previous tool run year will be required. Direct Assessment questions also include updated choices for the types of assessments recently performed.
- Part K is an entirely new section and allows an operator to choose additional contributing factors. Each factor is a sub cause from the other parts of the report form. For instance, if a piece of equipment was incorrectly installed and then subsequently overpressured and caused a release, both of these factors can be indicated on the form. Any additional factors involved in the release selected in Part K will need to be explained in the Narrative section of the form.
Minor Changes include:
- Additional information is requested on the time zones and daylight savings status for the incident location
- Additional questions regarding communication and involvement of local, state, and/or federal responders, including the time the communications occurred
- Information regarding plastic pipe and the specifications of plastic pipe or plastic pipe fusions
- Additional information on girth welds involved in the event, including any changes in pipe wall thickness and other pipe specifications for both sides of the weld
- Minor changes to the answers for the item involved in the event
- The manufacture year will now be collected for all items involved
- When computing the cost of the release, the cost per square foot of gas is now required, in addition to the calculations of the cost of gas released during the event
- Requires information on gas odorization
- Exemptions to One-Call Centers if a release was due to third party excavation damage
- When calculating volumes released, gas consumed by fire should be included in the unintentional gas estimates. Intentional and controlled gas release volumes should also include any gas released by ESDs and relief devices, even if the release occurs in anticipation of repairs some time after the event occurred.
- The operator’s initial indication of the failure is now asked, rather than how the incident was identified. This change in wording follows PHMSA’s attempt to determine when an operator is first aware of a potential event and at what time they were alerted to the issue (questions A.12 and A.13). In the instructions, PHMSA notes that an operator may be aware of a possible situation before any report criteria are met or before the operator has positively identified the failure.
- Please note that Part J and K are new and include detailed instructions on the choices available and how to answer each question.