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).