Thursday, December 18, 2014

OMB Approves PHMSA Changes to Incident and Annual Report for Gas Pipeline Operators; PHMSA Plans to Initiate Rulemaking to Implement Further Changes

The Pipeline and Hazardous Materials Safety Administration (“PHMSA”) received approval from the Office of Management and Budget (“OMB”) to continue using, with changes, various “Incident and Annual Reports for Gas Pipeline Operators” under OMB Control No. 2137-0522.  PHMSA had initially proposed changes to six specific forms that were used to gather certain annual and incident information from gas pipeline operators to track gas release incidents and help guide future regulations to reduce future pipeline incidents.  OMB ultimately authorized the amendments to, and continued use of, six specific forms as detailed in the table below:

Mechanical Fitting Failure Report (PHMSA F 7100.1-2)
Modified cause categories to collect more accurate data about the cause.
Gas Distribution Incident Report
(PHMSA F. 7100.1)
Added more options for type of gas, type of pipeline system, and type of material to collect more precise data.
Incident Report—Natural and Other Gas Transmission and Gathering Pipeline System (PHMSA F 7100.2)
Added another option to type of gas to collect more precise data.  At the request of industry, added information about how the MAOP of a gas transmission pipeline was determined.
Annual Report—Natural and Other Gas Transmission and Gathering Pipeline Systems (PHMSA F. 7100.2–1)
Collecting volume transported from all operators to enable comparisons among operators.  Modified the display of summary data in Parts Q and R with no change to the data collected.
Incident Report—Liquefied Natural Gas Facilities (PHMSA F 7100.3)
Removed the geospatial coordinates from the form since the location of each LNG facility is already reported to PHMSA.
Annual Report for Calendar Year 20l Liquefied Natural Gas Facilities (PHMSA F 7100.3–1)
Removing section describing how the report differs from the previous year report.  PHMSA collects data about modifications through the national registry.  Removing sections for reportable incidents and safety-related conditions since they are reported to PHMSA on other forms.  Specified whether a data field applies to the plant or the facility.
Gas Distribution Annual Report (PHMSA F 7100.1-1)
No changes.

PHMSA submitted its proposed changes to OMB in late 2013, and OMB provided two opportunities for interested parties to participate by submitting comments for the record.  Following receipt of these comments, PHMSA recognized that further changes to the forms were required, but that the immediate proceeding was the inappropriate venue for such changes.  In summarizing one specific comment, PHMSA emphasized that: “On the MFF Report, every failure is a joint failure.”  PHMSA intends to initiate a rulemaking to change the title of regulations 191.12 and 192.1009 to more accurately reflect that failures are in joints rather than in fittings. It is anticipated that the titles will become 49 CFR Part 191.12 – “Distribution Systems: Mechanical Joint Failure Reports” and 49 CFR Part 192.1009 – “What must an operator report when a mechanical joint fails?”

These changes and the decision to institute a rulemaking are significant because they recognize the inaccurate information that, to this point, has been collected by PHMSA.  Without these changes, PHMSA’s reporting provides insufficient detail, and many failures due to incorrect installation of gasketed joints are incorrectly reported as  failures due to other causes.  While the approved changes to the form and instructions are a step in the right direction, they are insufficient by themselves to provide PHMSA with wholly accurate information.  The rulemaking is another step in the right direction.  Once the rulemaking is complete, PHMSA will at least be able to separate joint failures from fitting failures by further modifying FORM F7100-1.2 and associated instructions to reflect the better understanding that reported leaks are not in mechanical fittings, but in joints between fittings and pipe.

For more detailed information on these changes, see

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