Editor’s
Note: Due to the importance of this advisory bulletin, we felt it was
worth repeating one more time.
On January 3, 2011, The National Transportation Safety Board (NTSB) issued
recommendations to PHMSA, CPUC, and PG&E related to the San Bruno pipeline
incident (see related article in this month’s newsletter). NTSB’s preliminary
findings indicate that the pipeline operator did not have an accurate basis for
the MAOP calculation.
PHMSA issued ADB-11-01 on January 4, 2011 entitled: Pipeline Safety: Establishing
Maximum Allowable Operating Pressure or Maximum Operating Pressure Using Record
Evidence, and Integrity Management Risk Identification, Assessment, Prevention,
and Mitigation. The ADB states that operators “must assure that the
records used are reliable” when calculating MOP / MAOP, and that “these
records shall be traceable, verifiable, and complete”. It further states
that “If such a document and records search, review, and verification cannot
be satisfactorily completed, the operator cannot rely on this method for
calculating MAOP or MOP.”
It further states: “Any operator of a hazardous liquid or gas transmission
pipeline that is not fully cognizant of the location, pipe material and seam
type, coating, cathodic protection history, repair history, previous pressure
testing, or operational pressure history, and other assessment information,
incident data, soil type and environment, operational history, or other key
risk factors of a pipeline operating at or above 30% SMYS should 1) institute
an aggressive program as soon as possible to obtain this information, 2) assess
the risks, and 3) take the proper mitigative measures based upon the operator’s
IM program risk findings. In addition, if these operators do not have verified
information on key risk factors, an immediate and interim mitigation measure
that should be strongly considered is a pressure reduction to 80 percent of the
operating pressure for the previous month, hydro testing the pipeline or
creating a remediation program to identify threat risks.”
This is a very significant advisory, and indicates a policy shift within PHMSA
that could have profound implications for some pipeline operators. For example,
operators that have relied upon “default” values for key risk factors in the
integrity management program or when calculating their MOP / MAOP (in the
absence of data about particular line segments) may now be required to
determine the actual values for each factor; and, they may be expected to take
interim pressure reductions until that data is obtained. This could require a
significant data-gathering and analysis effort – especially for older pipeline
systems.
The advisory states that “Future PHMSA inspections will place emphasis on
the areas noted in this Advisory Bulletin.” The advisory also mentions that
PHMSA and its state partners intend to sponsor a public workshop on these
issues, but the date for this workshop has not yet been determined. We will
inform you of the details once they are established.
For a copy of ADB-11-01, or for help in addressing these issues, contact Jessica Roger.
In This Issue
- PHMSA Released Control Room Management FAQs
- Control Room Management Services
- PHMSA Final Rule on Mechanical Fitting Failure Reporting
- PHMSA Notice of Extension for Comments on Collection of Safety Related Conditions
- PHMSA Free Webinar on Portal Registration February 9 – Noon (EST)
- API Pipeline Conference April 12 – 13
- Gas Industry Conferences at a Glance
- Advisory Committee Meetings
- RCP’s Web-Based Compliance Management Systems
- DIMP Integration
- Key Features
- CGA Excavation Safety Conference & Expo March 8 -10
- PHMSA Advisory Bulletin ADB -11-01: MAOP / MOP and IMP
- MAOP Analysis Services