In This Issue

MAOP Exceedance Reporting

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) has requested that States share the information below to those operators with gas transmission assets in the pipeline industry. Please review your internal reporting procedures and modify to capture the information outlined below.

The passage below was included in Section 23 of the federal “Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011” passed by Congress and effective January 3, 2011.

“(2) EXCEEDANCES OF MAXIMUM ALLOWABLE OPERATING PRESSURE.—If there is an exceedance of the maximum allowable operating pressure with respect to a gas transmission pipeline of an owner or operator of a pipeline facility that exceeds the build-up allowed for operation of pressure-limiting or control devices, the owner or operator shall report the exceedance to the Secretary and appropriate State authorities on or before the 5th day following the date on which the exceedance occurs.”

PHMSA is reportedly working on an electronic filing system for submission of these reports, and is also reportedly working on an Advisory Bulletin to explain its expectations. For a time, PHMSA suggested that operators hold information on an overpressure event until that system was operational. However, these actions have been delayed. PHMSA is now requesting that overpressure events be reported to using the same format as a Safety Related Condition Report (SCRC).

The format for a Safety Related Condition Report is found in the federal regulations at 49 CFR §191.25(b). With a few modifications to make that format appropriate for MAOP exceedance reporting, the report should contain the following content: The report should be titled “Gas Transmission MAOP Exceedance” and provide the following information:

  1. Name and principal address of operator.
  2. Date of report.
  3. Name, job title, and business telephone number of person submitting the report.
  4. Name, job title, and business telephone number of person who determined that the condition exists.
  5. Date condition was discovered and date condition was first determined to exist.
  6. Location of condition, with reference to the State (and town, city, or county) or offshore site, and as appropriate, nearest street address, offshore platform, survey station number, milepost, landmark, or name of pipeline.
  7. Description of the condition, including circumstances leading to its discovery, and any significant effects of the condition on safety.
  8. The corrective action taken before the report is submitted and the planned follow-up future corrective action, including the anticipated schedule for starting and concluding such action.

This list does not specifically ask for the cause of the overpressure, but that should certainly also be included in the report, if known. Also include basic pipeline information such as pipeline size, length, normal operating pressure, and MAOP. It is presumed the “build-up allowed” will be based on 49 CFR 192.201.

NOTE: These reports are required for gas transmission pipelines only.

The law states that such reports must be filed within five (5) days. You are reminded that if a report like this is made to PHMSA, an intrastate operator must concurrently file a copy with the appropriate State Agency.