Regulation Debrief: Pipeline Safety Act

September 2016

Though not fully enacted, PHMSA’s recent notices of proposed rulemaking (NPRMs) – continuations of the Pipeline Safety Regulatory Certainty and Job Creation Act of 2011, or Pipeline Safety Act – propose broad and sweeping changes that will likely require pipeline operators to adjust their integrity management (IM) plans for both natural gas and liquid pipelines. Here are the top five things to keep in mind about these NPRMs: 80 FR 61610 for liquid pipeline operators and 81 FR 20722 for gas pipeline operators.

1)  Operators will need to identify and address moderate-consequence areas on jurisdictional pipelines

Today’s regulations require that IM plans address high-consequence areas, but MCAs aren’t currently defined. The addition of new definitions and requirements around MCAs will mean that many operators will have to expand the length of pipeline covered by their existing IM plans.

2)  IM plans will need to include more quantitative risk modeling

Under these new rules, many operators will need to retool their pipeline data collection and management practices to support more complex, probabilistic risk modeling.

3)  Pipeline jurisdictions will be expanded to include gathering pipelines

Jurisdictional pipelines haven’t historically included gathering lines, so this expansion will likely require operators to adjust their annual reporting requirements or rewrite their manuals for IM or operations and maintenance (O&M).

4)  Grandfather clauses will be deprecated

With this change, operators may need to perform periodic assessments on older pipelines that were previously exempt from regulatory requirements.

5)  Maximum operating pressure (MOP) or maximum allowable operating pressure (MAOP) will need to be supported with more rigorous documentation

Requirements around reliable, traceable, verifiable and complete documentation for MOP and MAOP may require operators to research records for legacy pipelines and institute a more rigorous compliance management practice for new or verified pipelines.

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