dot pipeline compliance news | December 2018
PHMSA Pipeline Safety: Guidance on the Extension of the 7-year Integrity Management Reassessment Interval by 6 Months
[Docket No. PHMSA-2018-0073]
On November 15, 2018, PHMSA published a document titled “Pipeline Safety: Guidance on the Extension of the
7-year Integrity Management Reassessment Interval by 6 Months.” PHMSA is requesting comments on the FAQs
developed for the aforementioned subject.
Under the amended section 5 of the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011,
an operator may request an extension of 6 months beyond the required 7-year reassessment interval of
high-consequence areas (HCA). The guidance consists of one revised and two new FAQs on the eligibility
for this type of extension. The main points of the FAQs are summarized below.
In order to request an extension of no more than 6 months, an operator must notify PHMSA 180 days prior to the
end of the 7-year assessment date (49 CFR 192.949).
- The operator must include documentation (49 CFR 192.943) which:
- Explains why the deadline could not be met and how it will not compromise safety
- Identifies any additional actions to ensure public safety during the extension period.
Section 192.939(a)(1) specifies two options for establishing reassessment intervals: (i) considering identified
threats, assessment results, data integration, and risk analysis, or (ii) using Table 3 of ASME/ANSI B31.8S.
Operators choosing option (i) may establish intervals longer than those in Table 3 but must not exceed the maximum
intervals listed in the table in 192.939.
- For operators conducting assessments by pressure testing:
Higher pressure tests are required to justify reassessment intervals which extend beyond the
7 years (192.937(c)(2), 192.937(a), and 192.939(a) and (b)).
If using test pressures meeting Subpart J requirements, the operator may establish a 7-year
reassessment interval regardless of the result from Table 3, unless their analysis under 192.939(a)(i)
indicates a need for a shorter interval.
If using test pressures and reassessment intervals from Table 3, the operator may establish a
reassessment interval up to the maximums listed in the table in 192.939, unless their analysis under
192.939 indicates a need for a short interval. In order to establish intervals longer than 7 years,
the operator must conduct a confirmatory direct assessment within the 7-year period. This assessment
may be substituted with a low-stress reassessment per 192.941 for pipe segments operating under 30%
specified maximum yield strength (SMYS).
Comments can be submitted on the
on or before December 17, 2018. Reference Docket No.
PHMSA-2018-0073 when submitting comments. For a copy of the Notice from the Federal Register,
contact Jessica Foley