PHMSA Clarifies Pipeline Safety Reporting

The Pipeline and Hazardous Material Safety Administration (PHMSA) published a notice (78 FR 5866-5867) in Monday’s Federal Register (available on line yesterday) concerning certain reporting requirements for owner/operators of gas transmission pipelines and gathering lines. The notice extends the deadline for filing last year’s annual reports and notes discrepancies in many of the previously filed reports.

Filing Deadline Extension

PHMSA is extending the dead line for filing the 2012 annual report until June 15^th, 2013. This is due to the many recent changes in the reporting requirements and the fact that the new on-line reporting site has not yet been implemented. PHMSA expects to notify owner/operators by March 1^st that the new reporting system is operational.

OPID Validation

PHMSA had earlier extended the deadline for most pipeline and LNG owner/operators with Operator Identification Numbers (OPID) established prior to January 1, 2011, to validate their OPID data. They extended the deadline from June 30^th, 2012 to September 30^th, 2012. As of the end of November PHMSA notes that approximately 16% of those required to provide updated data have yet to do so.

Gas Transmission Annual Reports Discrepancies

Since 2004 PHMSA has collected data on gas transmission incidents in high consequence areas (HCA); first in the pipeline integrity management reports and, starting in 2010 in gas transmission and gathering annual reports. In addition owner/operators have been required to file incident reports and those reports have been required to indicate if the incident occurred in an HCA.

In this notice PHMSA indicates that there are serious discrepancies between the information provided in the incident reports and the annual reports. In only one year (2009) have the number of HCA incidents been the same in both sets of reports. Even then there were mismatches between the OPID of the submitting organizations. As a result, this notice reminds operators that:

“Gas transmission operators who have reported incidents in HCAs from 2004 through 2011 in either gas integrity management performance reports, gas transmission annual reports, or incident reports should submit supplemental reports as needed to correct the data.” (FR 78 5867)

LNG Annual Report Discrepancies

A similar problem exists in the annual reports that LNG operators have been required to submit to PHMSA since 2010. Incidents and safety related conditions (SRC) are required to be reported in the annual report as well as having to submit individual reports to PHMSA. Data from 2010 and 2011 show more incidents (2 vs 0) and SRCs (264 vs 5) reported in the annual reports than there have been individual reports submitted.

PHMSA notes that:

“LNG operators should review their annual reports and SRC reports and submit supplemental reports as needed to correct the data.”

Commentary

It is sad to see that there are so many discrepancies between regulatory reporting requirements and the actual data submitted to PHMSA. I suppose that it reflects the complexity of the regulatory environment. As such I applaud PHMSA’s publication of this notice rather than moving directly to taking to enforcement action. PHMSA does need the correct information to properly oversee the safety of the pipelines for which it is responsible.

On the other hand it is really sad to see that it has taken PHMSA so long to note some of these discrepancies. Just now trying to correct data inconsistencies that date back almost 10 years calls into question whether PHMSA has actually living up to its regulatory responsibilities. Hopefully this notice reflects a change in the attitude at PHMSA concerning those responsibilities.