RCP Inc.

Search Open Menu

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

Revised PHMSA Reporting Requirements – Notice and Request for Comments

[Docket No. PHMSA–2012–0024]

PHMSA plans to make several minor revisions to the hazardous liquid pipeline systems accident report and the gas transmission and gathering pipeline systems incident report. In addition, PHMSA is considering a number of revisions to the annual report form for gas transmission and gathering pipeline systems.

Incident and Accident Report Revisions:

PHMSA is revising the gas transmission and gathering pipeline systems incident report (PHMSA F 7100.2, gas transmission incident report) and hazardous liquid pipeline systems accident report (PHMSA F 7000-1, hazardous liquid accident report) to collect additional information relative to incidents involving girth welds. The revisions to these forms will allow for the reporting of detailed information regarding the pipe involved with the weld. This information includes basic information such as pipe size, diameter, and thickness. Several other minor changes are being made to align the form with the online system used to collect the reports from pipeline operators. The gas transmission incident report is approved under OMB control number 2137-0522 and the hazardous liquid accident report is approved under OMB control number 2137-0047. PHMSA does not anticipate any change to the burden of the information collection due to the proposed revision of these forms.

Gas Transmission and Gathering Pipeline Systems Annual Report Revisions:

On September 26, 2011, the National Transportation Safety Board issued recommendations to PHMSA regarding improvements in pipeline safety. These recommendations include requiring that all gas transmission pipelines installed before 1970 be subjected to pressure testing, that manufacturing- and construction-related defects only be considered stable if a gas pipeline has been subjected to a post-construction hydrostatic test of at least 1.25 times the maximum allowable operating pressure (MAOP), and that all gas transmission pipelines be able to accommodate in-line inspection tools. On January 3, 2012, President Obama signed the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 which requires that PHMSA:

  • Issue a regulation for the testing of previously untested gas transmission pipelines located in high consequence areas (HCAs) and operating at a pressure greater than 30 percent of specified minimum yield strength;
  • Require each owner or operator to verify that their records accurately reflect the physical and operational characteristics of their pipelines and associated facilities within Class 3 and 4 locations and Class 1 and 2 HCAs; and
  • Require each owner or operator to identify and submit documentation relating to each pipeline segment for which records are insufficient to confirm the established MAOP.

PHMSA intends to revise the gas transmission and gathering pipeline systems annual report (PHMSA F 7100.2-1, gas transmission annual report) to provide a mechanism for owners and operators to identify those segments of pipelines for which it is unable to verify the MAOP. For the purpose of reporting, “verification records” are records that can be used to validate the MAOP for the subject pipelines such as as-built drawings, alignment sheets, specifications, and design, construction, inspection, testing, maintenance, manufacturer, or other related documents. These records should be traceable, verifiable, and complete. The purpose of this verification is to ensure that the records accurately reflect the physical and operational characteristics of the pipelines. In an upcoming Advisory Bulletin, PHMSA will inform operators of their responsibilities to verify that their records accurately reflect the physical and operational characteristics of their pipelines and associated facilities. In addition, the Advisory Bulletin will further clarify what PHMSA considers to be a “verifiable” record.

PHMSA also intends to revise the gas transmission annual report to collect other information related to the NTSB Recommendations and the recently signed legislation detailed above. In addition to the MAOP verification reporting, these revisions will allow for the collection of information regarding the methodology used to determine the MAOP of gas transmission pipelines, the total miles of pipelines which have not been subjected to a post-construction hydrostatic pressure test of at least 125% of the MAOP, and total miles of pipelines which are not able to accommodate the passage of instrumented internal inspection devices. PHMSA is also revising the gas transmission annual report to improve the granularity of the data, remove sections of limited value, collect data about anomalies removed from gas transmission pipeline systems, and make several minor changes to improve the quality of the data. Background for these topics is as follows:

  • Pipeline Material Reporting by State: Pipeline mileage by material type was collected state-by-state prior to 2010. This data allowed PHMSA to determine the amounts and types of pipeline materials used in each state. The proposed change would restore this granularity which was lost during the 2010 revision to the gas transmission annual report. Parts D and E of the gas transmission annual report are used to collect information regarding pipeline material type. PHMSA proposes to collect this information in the state-specific section of the report and to combine Parts D and E of the report into a single table. This change will not impact the burden of the information collection.
  • Additional Commodities: In the current gas transmission annual report, operators have the ability to report “other” as the commodity transported and then enter text describing the commodity. Based on a review of 2010 data, many operators submitted text equivalent to landfill gas to describe the “other” commodity. PHMSA proposes to add landfill gas as a commodity choice to reduce the mileage reported under the “other” category. This change will not impact the burden of the information collection.
  • Additional Material Type: PHMSA recognizes that composite pipe materials are currently being used, or considered for use, by the pipeline industry. Outside of reinforced thermosetting plastic, in certain and limited use, composite pipe can only be used if PHMSA issues a special permit. In an effort to determine the amount of composite pipe currently in use, PHMSA proposes to add “composite pipe” as a material type to Parts D and N of the gas transmission annual report. This change will not impact the burden of the information collection.
  • Removal of Sections A6 and A8: Section A6 in the gas transmission annual report allows each submitter to characterize the facilities covered by their Operator Identification (OPID) and commodity group with respect to whether they are included in an integrity management program subject to 49 CFR part 192. Section A8 allowed submitters to identify whether or not there were any changes from the previous year’s filing. PHMSA has determined that these sections provide limited value to all stakeholders and should be removed. This change will not impact the burden of the information collection.
  • Anomalies Removed from Gas Transmission Systems: The gas transmission annual report currently collects information about the number of anomalies repaired in response to integrity assessments. During data quality checks of the 2010 data, PHMSA learned that many anomalies are eliminated from gas transmission systems by pipe replacement or abandonment. This data helps to demonstrate the benefits of integrity management programs. Therefore, PHMSA proposes to revise the gas transmission annual report to collect the number of anomalous conditions eliminated by pipe replacement and abandonment in Part F of the report.

Interested persons are invited to submit comments on or before June 12, 2012 [Docket No. PHMSA-2012-0024]. Comments are invited on:

a) The need for the proposed collection of information for the proper performance of the functions of the agency, including whether the information will have practical utility;
b) The accuracy of the agency’s estimate of the burden of the proposed collection of information, including the validity of the methodology and assumptions used;
c) Ways to enhance the quality, utility, and clarity of the information to be collected; and
d) Ways to minimize the burden of the collection of information on those who are to respond, including the use of appropriate automated, electronic, mechanical, or other technological collection techniques.

For further information contact: Cameron Satterthwaite, 202-366-1319, DOT, PHMSA, 1200 New Jersey Avenue SE., PHP-30, Washington, DC 20590-0001.