PHMSA has updated two FAQ’s relating to integrity management reporting requirements. For gas transmission, FAQ #97 was updated. For liquid pipelines, FAQ #12.1 was updated.
FAQ #97 (gas transmission pipelines)
Question: What types of notifications are required by the rule?
Answer: The notifications required by the rule are:
- Substantial change to program implementation or significant change to schedule for carrying out elements. (Within 30 days of adoption). The notification should include a description of the changes and the basis on which they were made.
- Inability to meet remediation deadlines in the rule and unable to reduce pressure (When operator determines schedules cannot be met). A description of defects/repairs needed, reason for delay, why pressure can’t be reduced, basis for concluding delay won’t jeopardize health or environment, schedule for repair, other mitigative actions planned should be included.
- Use of technology other than in-line inspection, Direct Assessment, or pressure testing for conducting assessments. (180 days prior to assessment). The operator should provide a description of the "other technology", its basis for concluding that the method will result in equivalent understanding of pipe condition, and its schedule for assessment.
In addition, all notifications must include information about the pipe segments and HCAs involved.
- Pressure reduction imposed as a result of IM anomalies extends for more than 365 days. The notification must explain the reasons for the delay and justify that the continued pressure reduction will not jeopardize the integrity of the pipeline.
FAQ #12.1 (hazardous liquid pipelines)
12.1 What types of notifications are required by the rule?
The notifications required by the rule are:
Circumstance/Type
Deadline for Submittal
Information Required
Inability to meet remediation deadlines in the rule and unable to reduce pressure
When operator determines schedules cannot be met
Description of defects/repairs needed, reason for delay, why pressure can’t be reduced, basis for concluding delay won’t jeopardize health or environment, schedule for repair, other mitigative actions planned
Pressure reduction will exceed 365 days
When pressure reduction exceeds 365 days
Reasons for the delay, description of additional remedial actions
Use of technology other than in-line inspection, pressure testing, or external corrosion direct assessment for conducting assessments
90 days prior to assessment
Description of “other technology”, basis for concluding equivalent understanding of pipe condition, schedule for assessment
Variance from 5-year re-assessment interval (unavailable technology)
180 days before end of 5-year interval
Date and method of last assessment, reason why required interval cannot be met, interim evaluation of pipe integrity, schedule for assessment
Variance from 5-year re-assessment interval (engineering basis)
270 days before end of 5-year interval
Date and method of last assessment, proposed new retest interval, actions that will provide equivalent understanding of pipe condition, summary of engineering basis
In addition, all notifications must include information about the pipe segments and HCAs involved.
The on-line integrity management notification system is also being used to allow operators to submit notification of their intent to move biofuels in their pipelines. These notifications are not required by regulation. PHMSA has asked that operators voluntarily notify when they intend to use their pipelines for biofuel transportation.