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In This Issue

  1. PHMSA Advisory Bulletin ADB-2012-06 MAOP MOP Records Verification
  2. DOT Pipeline Compliance Workshop – May 15, 16 & 17, 2012
  3. Engineering Ethics Course
  4. Introducing MaxOp*
  5. MAOP Validation Services
  6. Revised PHMSA Reporting Requirements – Notice and Request for Comments
  7. Nebraska Major Oil Pipeline Act
  8. Changes to New Mexico Pipeline Regulations March 2012
  9. Damage Prevention Plans
  10. Louisiana Dig Law Has Changed
  11. PHMSA Recruiting for a Compliance Officer Open Period from May 3 – May 14, 2012
  12. Government/Industry Pipeline R&D Forum July 18-19 – Arlington, VA
  13. Summer / Fall Industry Conferences

PHMSA Advisory Bulletin ADB-2012-06 MAOP MOP Records Verification

[Docket No. PHMSA-2012-0068]

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) issued Advisory Bulletin ADB 2012-06 to remind operators of gas and hazardous liquid pipeline facilities to verify their records relating to operating specifications for maximum allowable operating pressure (MAOP) required by 49 CFR 192.517 and maximum operating pressure (MOP) required by 49 CFR 195.310. ADB 2012-06 informs gas operators of:

  • anticipated changes in annual reporting requirements to document the confirmation of MAOP,
  • how they will be required to report total mileage, and mileage with adequate records,
  • when they must report, and
  • what PHMSA considers an adequate record.

In addition, this Advisory Bulletin informs hazardous liquid operators of adequate records for the confirmation of MOP.

This advisory will have a major impact to both gas and liquid pipelines. As you may recall, last year, PHMSA issued Advisory Bulletin 11-01 reminding operators that if they are relying on the review of design, construction, inspection, testing and other related data to establish MAOP and MOP, they must ensure that the records used are reliable, traceable, verifiable, and complete. (See related article in the January 2011 Edition of the DOT Pipeline Compliance News.) ADB 2012-06 provides definitions for these terms (traceable, verifiable, and complete) and states that Operators should ensure all records establish confidence in the validity of the records. If a document and records search, review, and verification cannot be satisfactorily completed to meet the need for traceable, verifiable, and complete records, the operator may need to conduct other activities such as in-situ examination, measuring yield and tensile strength, pressure testing, and nondestructive testing or otherwise verify the characteristics of the pipeline to support a MAOP or MOP determination.

PHMSA will require each owner or operator of a gas transmission pipeline and associated facilities to verify that their records confirm MAOP of their pipelines within Class 3 and Class 4 locations and in Class 1 and Class 2 locations in HCAs.

PHMSA intends to require gas pipeline operators to submit data regarding mileage of pipelines with verifiable records and mileage of pipelines without records in the annual reporting cycle for 2013, via the Gas Transmission and Gathering Systems Annual Report.

ADB 2012-06 also notes PHMSA’s intent to amend 192.619(a)(3), the MAOP grandfather clause, after receiving operator data submitted for the year 2012.

For a copy of ADB-2012-06, or for help in addressing these issues, contact Jessica Roger.