In This Issue

Pipeline Information Collection Notice and Request for Comments

[Docket No. PHMSA-2019-0172]

On December 17, 2020, PHMSA published a notice and request for comments for gas pipelines and gas storage facilities reporting requirements, as summarized below. 

PHMSA proposes to revise PHMSA F 7100.2-1 Annual Report for Natural and Other Gas Transmission and Gathering Pipeline Systems, to

  • add a section to collect data about the number of miles of gas transmission pipelines in high consequence areas (HCA) categorized by the HCA determination method found at 49 CFR 192.903 and the type of risk model used.
  • add Part G1 to collect data on the number of relief valve lifts and compressor station emergency shutdown (ESD) events that occurred within a calendar year.
  • amend the gas transmission and gathering incident report to exclude reporting of relief valve lifts and ESD events when the systems function as expected, which is a change in PHMSA’s interpretation of “intentional” releases.

In January 2020, OMB approved changes to the Gas Transmission Annual Report form in conjunction with new regulations promulgated in a final rule titled “Safety of Gas Transmission Pipelines, MAOP Reconfirmation, Expansion of Assessment Requirements and Other Related Amendments” (84 FR 52180). During the OMB review period of the final rule, industry associations submitted joint comments on the proposed changes to the form. PHMSA’s responses to the Associations’ comments are as follows:

Industry Association CommentPHMSA Response
MCA-related reporting requirements should only apply to pipelines with a MAOP >=30% of SMYS.Disagree.  PHMSA is retaining this data collection element.
Report the total mileage of class 1 and class 2 non-HCA/non-MCA pipe segments assessed during the calendar year, but don’t break down this mileage into “baseline” and “reassessment.”Agreed.  PHMSA proposes to replace the current “baseline assessment” and “reassessed” categories with a single “miles assessed” data field.
Operators should not have to identify whether class 1 and 2 location segments that are non-HCA or non-MCA have complete MAOP records.Agreed for now.  PHMSA proposes to remove the requirement but reserves the right to pursue this data collection at a later time.
PHMSA should align the pressure test ranges in Part F with the pressure test factors specified in 49 CFR 192.619: [≥1.5], [<1.5 to ≥1.25], [<1.25 to ≥1.1], and [Less than 1.1 or no test].Agreed. The lowest allowable pressure test, in accordance with 49 CFR 192.619(a)(2), is 1.1. PHMSA proposes revising the form to combine the “1.1 to 1” and “no test” categories into a single category.
Collect mileage by individual test factor only in Part R of the form, and remove sections 3.1-3.3.Agreed. 
The revised Annual Report form should go into effect for the 2021 reporting year (due in March 2022), after operators have been required to identify those pipeline segments that are subject to the requirements of the final rule.PHMSA agrees with the timeframe and has already made the requested adjustments to the implementation schedule.

PHMSA proposes to revise PHMSA F 7100.2 Incident Report for Gas Transmission and Gathering Systems, to:

  • Revise the instructions to remove the requirement for operators to report relief valve lifts and compressor station ESD events when the systems function as expected. Instead of reporting these occurrences as incidents, operators would submit data on intentional gas releases on the Gas Transmission and Gathering Annual Report form PHMSA F 7100.2-1.
  • Return instructions that were inadvertently removed regarding when questions G6 through G8 were required to be completed. Previously, the form was clear that these questions are only required to be completed when part A14 (“onshore pipeline . . .” or “offshore pipeline . . .”) is answered.

PHMSA proposes to clarify several instructions and to modify the reporting of well counts on PHMSA F 7100.4-1 Underground Natural Gas Storage Facility Annual Report

Comments are due by February 16, 2021, and can be submitted via the Federal eRulemaking Portal, identified by docket number PHMSA-2019-0172.

For a copy of PHMSA’s Pipeline Information Collection Notice, contact Jessica Foley.