On May 7, 2012 PHMSA issued an Advisory Bulletin (AB) to remind operators of gas and hazardous liquid pipeline facilities to verify their records relating to operating specifications for maximum allowable operating pressure (MAOP) required by 49 CFR 192.517 Records and maximum operating pressure (MOP) required by 49 CFR 195.310 Records. This AB provided guidance and definitions for the terms traceable, verifiable and complete. PHMSA provided guidance and examples to clarify what constitutes as sufficient supplemental support to validate a pipeline's MAOP. The AB also notifies operators of PHMSA’s intent to amend 192.619(a)(3), the MAOP grandfather clause, after receiving operator data submitted for the year 2012.
AGA has been in discussions with PHMSA since the advisory was issued and had received verbal confirmation that a single record that contained the needed information to confirm a pipeline’s MAOP would be acceptable. In June, AGA submitted an official request for interpretation to PHMSA and subsequently received the confirmation below.
PHMSA Confirmation that a Single Record is Acceptable for Establishing MAOP (July 31, 2012)