Tuesday, May 8, 2012

PHMSA Verification of Pipeline Records Advisory

The Pipeline and Hazardous Material Safety Administration published an advisory notice on pipeline safety record keeping requirements in yesterday’s Federal Register (77 FR 26822-26824). The notice reminds “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” (77 FR 26822).

As directed in the recently passed Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 (Act), PHMSA will require owner/operators of gas transmission pipelines to verify that their records confirm the maximum allowable operating pressure (MAOP) of their covered pipelines. PHMSA plans on having information submitted in the 2013 annual reporting cycle delineating the pipeline mileage for which verifiable records either exist or don’t exist to confirm MAOP. Reported data will be used to develop potential rulemaking to outline actions owner/operators would be required to take for pipeline sections where verifiable records don’t exist.

The Advisory explains that ‘verifiable records’ must be “traceable, verifiable and complete”. Traceable records can be clearly linked to original information about the pipeline. Verifiable records are those that can be confirmed by complimentary but separate information. Complete records are those that show evidence of completed actions by the presence of “by a signature, date or other appropriate marking”.

Finally the Advisory notes that it intends to review the records produced in response to this new requirement to prepare their response to NTSB Recommendation P-11-14 to eliminate the grandfather clause {§192.619(a)(3)} that allows gas transmission operators to establish MAOP of pipe installed before July 1, 1970, by use of records noting the highest actual operating pressure to which the segment was subjected during the five years preceding July 1, 1970.

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