In an advisory bulletin, the federal Pipeline and Hazardous Materials Safety Administration (PHMSA) reminds owners and operators of all gas transmission pipelines of their obligation to report exceedances of maximum allowable operating pressures (MAOP) for those lines when the pressure exceeds the buildup allowed by pressure-limiting or control devices.  The exceedance must be reported to PHMSA within 5 days of its occurrence as well as to the regulatory authority of any of PHMSA’s state pipeline safety partners.

Self-implementing requirement

The MAOP-exceedance reporting requirement is a self-executing provision of the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011.  (Self-executing or self-implementing means that no implementing regulation developed by an executive agency is needed to require compliance with a statutory provision.) 

Information to be included in the exceedance report should align with information required in safety-related condition reports (SRCR) specified at 49 CFR 191.25(b), although there is one critical difference.  SRCRs are not required if the safety-related condition is corrected by repair or replacement in accordance with applicable safety standards before the deadline for filing the SRCR. This reporting exemption does not apply to reporting of MAOP exceedances.  In other words, the MAOP exceedance must be reported even if the cause is corrected in fewer than 4 days after occurrence. 

Report contents

The MAOP exceedance report should be titled GAS Transmission MAOP Exceedance and must include:

• The name and principal address of the operator, date of the report, name, job title, and business telephone number of the person submitting the report,
• The name, job title, and business telephone number of the person who determined the condition exists,
• The date the condition was discovered and the date the condition was first determined to exist,
• The location of the condition, with reference to the town/city/county and state or offshore site and, as appropriate, nearest street address, offshore platform, survey station number, milepost, landmark, and the name of the commodity transported or stored, and
• The corrective action taken before the report was submitted and the planned follow-up or future corrective action, including the anticipated schedule for starting and concluding such action.

PHMSA encourages gas transmission owners and operators to report MAOPs and buildup exceedances by e-mailing information to InformationResourcesManager@dot.gov. Reports may also be submitted by fax to 202-366-7128.

PHMSA adds that it is “poised” to issue a final rule modifying the SRCR rule to allow electronic mail (e-mail) as an acceptable reporting method.

Click here for the advisory bulletin, which was published in the December 21, 2012, FR.