Keeping the Operations and Maintenance (O&M) Manual updated is an important part of keeping your company ready for inspections. Federal regulations require pipeline operators to update their O&M Manual annually. Inspectors from the Pipeline and Hazardous Materials Safety Administration (PHMSA) will review the manual during routine inspections. PHMSA has already given out over 20 Notices of Amendment this year, which are warnings that plans and procedures are not satisfactory. Here are some guidelines to follow that will help you “think like an inspector” when reviewing your company’s O&M Manual.
Most pipeline operators know what it takes to run their company safely, but inspectors will be checking for regulatory compliance. Make sure that the procedures listed in your O&M Manual cite the regulatory requirements they are meeting. Most requirements are found in Title 49 of the Code of Federal Regulations (CFR) Part 192 – Minimum federal safety standards for the transmission of natural and other gas by pipeline. However, Part 192 is very long, so inspectors will be looking for citations to section (for example: 192.605) or even subsection (for example: 192.613(a)). Your manual should reference at least the following:
- Operation, maintenance and emergency procedures required in the O&M Manual at 192.605
- Procedures for pipeline surveillance at 192.613(a)
- Emergency response plans at 192.615
- Public awareness plans at 192.616
- Accident investigations procedures at 192.617
- Part 191 addresses the requirements for incident reporting, and the O&M Manual should contain procedures for reporting incidents according to the requirements of this Part
- Any industrial standards that are referenced in the manual, such as API Standard 1162, should be included in full in the manual
Check that all contact information in case of an emergency or for reporting incidents is current. Make sure the manual contains procedures for contacting the state agency overseeing pipeline activity in your area, if required, as well as PHMSA contact information. If your company uses a vendor or consultant for public awareness, make sure the manual lists the current contractor.
Finally, update the O&M Manual to meet any changes to regulations. Referring to a code book may not ensure accuracy. Code books are usually updated only once a year but regulations can be changed at any time. Already this year, PHMSA has made changes to 49CFR-191, 49CFR-192 and 49CFR-195 concernin the following topics, among others:
- Responsibility to Conduct Construction Inspections at 192.305 and 195.204
- Leak Surveys for Type B Gathering Lines at 192.9
- Qualifying Plastic Pipe Joiners at 192.285(c)
- Mill Hydrostatic Tests for Pipe To Operate at Alternative Maximum Allowable Operation Pressure at 192.112
- Transportation of Pipe at 192.65
- Threading Copper Pipe: at 192.279
- Alternative MAOP Notifications at 192.620(c)(1)
- Components Fabricated by Welding at 192.153
- Odorization of Gas Transmission Lateral Lines § 192.625
Inspectors will check to see that your company has a plan in place to track regulatory changes. Since legislative tracking takes time and requires specialized knowledge, subscribing to a legislative tracking system such as Nimonik is a great way of fulfilling this obligation without straining company resources. Nimonik’s legal content experts track legislation tailored to your company’s needs and requirements. Concise and understandable legal updates are delivered directly to your desktop, iphone or Android device. Not only does Nimonik’s system help you stay current, but using the system creates a record to show inspectors. Your company can more easily both comply with regulations and demonstrate your compliance to safety inspectors.