PHMSA Pipeline Safety Advisory – Flooding

The Pipeline and Hazardous Material Safety Administration (PHMSA) published a safety advisory notice in today’s Federal Register (78 FR 41991-41993) concerning the potential for damage to pipeline facilities caused by severe flooding. This Advisory Bulletin is the latest in a series of such bulletins on this topic.

The Advisory lists nine specific actions that pipeline operators should take before, during and after a flooding event:

• Evaluate the accessibility of pipeline facilities that may be in jeopardy;

• Extend regulator vents and relief stacks above the level of anticipated flooding;

• Coordinate with emergency and spill responders on pipeline location and condition;

• Deploy personnel so that they will be in position to take emergency actions;

• Determine if facilities that are normally above ground have become submerged and are in danger of being struck by vessels or debris;

• Perform frequent patrols, including appropriate overflights, to evaluate right-of-way conditions at water crossings during flooding and after waters subside; and

• Ensure that line markers are still in place or replaced in a timely manner.

Finally PHMSA reminds operators that:

“If a pipeline has suffered damage, is shut-in, or is being operated at a reduced pressure as a precautionary measure due to flooding, the operator should advise the appropriate PHMSA regional office or state pipeline safety authority before returning the line to service, increasing its operating pressure, or otherwise changing its operating status.”

PHMSA Pipeline Safety Advisory – Flooding

Today the Pipeline and Hazardous Material Safety Administration (PHMSA) published an advisory bulletin in the Federal Register (76 FR 44985-44986) for pipeline operators describing the “actions that operators should consider taking to ensure the integrity of pipelines in case of flooding”. A copy of this bulletin (ADB-11-04) is supposed to be available on the PHMSA Pipeline Safety web page (http://phmsa.dot.gov/pipeline), but as of 7:00 am EDT it was not listed on that site.

The preamble to this advisory makes it clear that PHMSA is publishing this because of the Laurel, Montana release earlier this month. The cause of that release are still not known, but the timing of the release and the flooding of the Yellowstone River ensure that most people believe that the flooding caused the release. The wording of the preamble does not explicitly adopt this assumption, but the implication is clear.

While I am certainly not a pipeline safety expert, the measures outlined in this advisory seem to be common sense measures that a reasonable person would assume that a pipeline operator would be taking in the event of flooding near their pipeline. With the extent of flooding seen across the Midwest this year I suppose that it is prudent to publish an advisory of this sort, but this really should be part of a comprehensive pipeline safety program since flooding is not that unusual an event.