PHMSA Workshop on Integrity Verification Process

The Pipeline and Hazardous Material Safety Administration published a public meeting notice in Monday’s Federal Register (available on-line today, 78 FR 32010-32011) about a public workshop on the concept of “Integrity Verification Process.” This is a very preliminary and incomplete notice for the meeting in August.

Agenda

According to the Notice summary:

“At this workshop, the Pipeline and Hazardous Materials Safety Administration, the National Association of State Pipeline Safety Representatives and various other stakeholders will present information and seek comment on a proposed Integrity Verification Process that will help address several mandates set forth in Section 23, Maximum Allowable Operating Pressure, of the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 [49 USC §60139].”

More information on this workshop and its agenda will be posted on the meeting web page as it becomes available.

New MOAP Requirements

Interestingly there are three integrity verification deadlines set forth in that section of the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011:

• “The Secretary of Transportation shall require each owner or operator of a pipeline facility to conduct, not later than 6 months after the date of enactment of this section, a verification of the records of the owner or operator relating to the interstate and intrastate gas transmission pipelines of the owner or operator in class 3 and class 4 locations and class 1 and class 2 high-consequence areas.” {§60139(a)(1)}

• “Not later than 18 months after the date of enactment of this section, each owner or operator of a pipeline facility shall identify and submit to the Secretary documentation relating to each pipeline segment of the owner or operator described in subsection (a)(1) for which the records of the owner or operator are insufficient to confirm the established maximum allowable operating pressure of the segment.” {§60139(b)(1)}

• “Not later than 18 months after the date of enactment of this section, the Secretary shall issue regulations for conducting tests to confirm the material strength of previously untested natural gas transmission pipelines located in high-consequence areas and operating at a pressure greater than 30 percent of specified minimum yield strength.” {§60139(b)(1)}

Since the bill was signed into law on January 3^rd of 2012, all three of these deadlines will have passed by the time this public workshop is held. PHMSA met the first deadline last May and the second was addressed in a December 2012 PHMSA Advisory Bulletin. The rulemaking requirement has not yet seen PHMSA publish a notice of proposed rulemaking to date. I will admit that an 18-month time limit to issue a new regulation is more than a tad bit tight.

Public Participation

PHMSA is soliciting public participation at the workshop. To ensure that adequate space is provided, PHMSA is requesting advanced registration, though no method of such registration has yet been provided. You may want to contact Cameron Satterthwaite, Office of Pipeline Safety, at (cameron.satterthwaite@dot.gov). Written comments on the workshop or the workshop topics may be submitted via the Federal eRulemaking Portal (www.regulations.gov; Docket PHMSA-2013-0119); though they do seem to be having some communications issues today.