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That new information collection requirement has been controversial. The INGAA and individual companies had tried to convince the PHMSA to change some of the data it wants to request in both the expanded annual and incident reports companies will have to fill out, in the former case by the end of 2012. The annual report is especially important because it will be used, based on a requirement in the 2012 pipeline safety bill, by the PHMSA and Congress to determine:
• Whether to expand the integrity management program beyond high consequence areas (HCAs);
• Whether to test previously untested gas transmission pipelines located in HCAs and operating at pressure greater than 30 percent of specified minimum yield strength; and
• Whether to require in-line inspection.
The annual report must be filed by March 15, 2013. Those reports will be based on data collected by Dec. 31, 2012. Then a second report must be completed by July 3, 2013, telling the PHMSA where verification records are insufficient to confirm the established MAOP of a given segment, and where MAOP "exceeds the build-up allowed for operation of pressure-limiting or control devices . . ." The INGAA and various pipeline companies asked the PHMSA to push back the due date of the annual report to July 3, 2013, so they would only have to collect data once, not up until Dec. 31, 2012, and then again up until July 3, 2013. PHMSA declined to push back the annual report deadline.
Moreover, numerous companies plus INGAA complained about the expanded data the PHMSA will ask for. The big changes to the annual report come in sections "Q" and "R" particularly Q which solicits information on the presence of verification records establishing MAOP. Jeff Maples, director, Gas Operations, Paiute Pipeline Company, explains, "The addition of Parts Q and R is significant. The amount of effort involved to collect and quantify the data in the manner requested by the annual transmission report is substantial." He says the PHMSA report will require companies to report information beyond what is required by the 2012 Pipeline Act.
INGAA recommended replacing proposed parts Q and R with a substitute that would collect the information necessary to characterize the amount of pipe to be addressed through various Fitness for Service (FFS) methods. The PHMSA has made some changes in those two sections in the latest version it submitted to the White House Office of Management and Budget on Oct. 1. The industry had a chance to provide the OMB with comments during November. The OMB must approve the annual report before the PHMSA can order companies to complete it.