Operations & Maintenance Enforcement Guidance Part 192 Subparts L and M

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Enforcement Guidance

O&M Part 192

Revision Date


Code Section


Section Title

Continuing Surveillance

Existing Code


(a) Each operator shall have a procedure for continuing surveillance of its facilities to determine and take appropriate action concerning changes in class location, failures, leakage history, corrosion, substantial changes in cathodic protection requirements, and other unusual operating and maintenance conditions.

(b) If a segment of pipeline is determined to be in unsatisfactory condition but no immediate hazard exists, the operator shall initiate a program to recondition or phase out the segment involved; or, if the segment cannot be reconditioned or phased out, reduce the maximum allowable operating pressure in accordance with §192.619 (a) and (b).

Origin of Code

Original Code Document, 35 FR 13248, 08-19-70

Last Amendment



Interpretation: PI-89-027 Date: 12-11-1989

Regulations specify the depth to which a pipeline must be buried at the time of construction. However, when an operator learns that a pipeline is, or has become, unsafe because of potential damage of flooding or a farming activity, it must correct the problem. Remedial action may include lowering the pipeline, adding more cover over the line, or otherwise protecting it against outside force damage.

Interpretation: PI-89-023 Date: 10-18-1989

Regulations allow pipeline operators to use whatever means are suitable to achieve compliance, including aerial videotaping. We believe aerial videotaping could be an acceptable part of the process of complying with the standards, if appropriately applied by the operator.

Interpretation: PI-77-026 Date: 11-14-1977

Regarding the question whether Federal regulations contain specific requirements governing the safety of a situation where a building is proposed for construction over the area of an existing gas line.

If the Class location changes the operator would have to confirm or revise the MAOP in accordance with the new Class location. Even if the Class location would not change, Section 192.613 would require that the operator take appropriate action to correct any unsafe operating conditions that might be created by construction of the building.

Interpretation: PI-77-013 Date: 05-01-1977

Regarding whether Federal regulations would require upgrading or encasing an existing pipeline when a highway right of way is expanded,

Section 192.613 requirements may apply to this situation if an unsafe condition is created b y expanding the right of way.

Interpretation: PI-77-011 Date: 04-15-1977

These regulations do not require that an existing pipeline be encased when a road is constructed over the pipeline. However, in the case of gas pipelines, Sections 192.613 and 192.703(b), and in the case of liquid pipelines, Section 195.402, require that the operator of a pipeline must take appropriate remedial action to correct an unsatisfactory condition. Applying this rule to the situation of bad construction over an existing pipeline, an operator would be obligated to correct any unsafe condition which occurs during construction of the road. The corrective action, if necessary, might include encasement or any other appropriate safety measure such as deeper burial of the line.

Interpretation: PI-77-003 Date: 01-26-1977

As initiated by loss of pipeline cover, safety standards are enforceable only against persons who own or operate pipelines and do not apply to third parties or outside contractors who may interfere with a pipeline, such as by construction of a roadway. Refusal or inability of persons other than the operator to correct unsafe situations which they have created on an operator's pipeline does not relieve the operator of its responsibility for compliance.

Interpretation: PI-75-052 Date: 10-30-1975

Construction of a building over an existing pipeline may result in an unsafe condition requiring remedial action under Section 192.613.

Interpretation: PI-75-023 Date: 05-29-1975

Construction of a road over an existing pipeline may result in an unsafe condition requiring remedial action under Section 192.613.

Advisory Bulletin/Alert Notice Summaries

Advisory Bulletin, ADB-11-04, Potential for damage to pipeline facilities caused by severe flooding.

Severe flooding can adversely affect the safe operation of a pipeline. Operators need to direct their resources in a manner that will enable them to determine the potential effects of flooding on their pipeline systems. Operators are urged to take the following actions to prevent and mitigate damage to pipeline facilities and ensure public and environmental safety in areas affected by flooding:

1. Evaluate the accessibility of pipeline facilities that may be in jeopardy, such as valve settings, which are needed to isolate water crossings or other sections of a pipeline.

2. Extend regulator vents and relief stacks above the level of anticipated flooding, as appropriate.

3. Coordinate with emergency and spill responders on pipeline location and condition. Provide maps and other relevant information to such responders.

4. Coordinate with other pipeline operators in the flood area and establish emergency response centers to act as a liaison for pipeline problems and solutions.

5. Deploy personnel so that they will be in position to take emergency actions, such as shut down, isolation, or containment.

6. Determine if facilities that are normally above ground (e.g., valves, regulators, relief sets, etc.) have become submerged and are in danger of being struck by vessels or debris; if possible, such facilities should be marked with an appropriate buoy with Coast Guard approval.

7. Perform frequent patrols, including appropriate overflights, to evaluate right-of-way conditions at water crossings during flooding and after waters subside. Determine if flooding has exposed or undermined pipelines as a result of new river channels cut by the flooding or by erosion or scouring.

8. Perform surveys to determine the depth of cover over pipelines and the condition of any exposed pipelines, such as those crossing scour holes. Where appropriate, surveys of underwater pipe should include the use of visual inspection by divers or instrumented detection. Information gathered by these surveys should be shared with affected landowners. Agricultural agencies may help to inform farmers of the potential hazard from reduced cover over pipelines.

9. Ensure that line markers are still in place or replaced in a timely manner. Notify contractors, highway departments, and others involved in post-flood restoration activities of the presence of pipelines and the risks posed by reduced cover.

If a pipeline has suffered damage, is shut-in, or is being operated at a reduced pressure as a precautionary measure as a result of flooding, the operator should advise the appropriate PHMSA Regional Office or State pipeline safety authority before returning the line to service, increasing its operating pressure, or otherwise changing its operating status. PHMSA or the State will review all available information and advise the operator, on a case-by-case basis, whether and to what extent a line can safely be returned to full service.

Advisory Bulletin, ADB-08-06, Dynamic riser inspection, maintenance, and monitoring records on offshore floating facilities.

To remind owners and operators of the importance of retaining inspection, maintenance, and monitoring records for dynamic risers located on offshore floating facilities.

Advisory Bulletin ADB-07-02, Updated Notification of the Susceptibility to Premature Brittle-Like Cracking of Older Plastic Pipe.
All owners and operators of natural gas distribution systems who have installed and operate plastic piping are reminded of the phenomenon of brittle-like cracking. Brittle-like cracking refers to crack initiation in the pipe wall not immediately resulting in a full break followed by stable crack growth at stress levels much lower than the stress required for yielding. This results in very tight, slit-like, openings and gas leaks. Although significant cracking may occur at points of stress concentration and near improperly designed or installed fittings, small brittle-like cracks may be difficult to detect until a significant amount of gas leaks out of the pipe, and potentially migrates into an enclosed space such as a basement. Premature brittle-like cracking requires relatively high localized stress intensification that may result from geometrical discontinuities, excessive bending, improper installation of fittings, dents and/or gouges. Because this failure mode exhibits no evidence of gross yielding at the failure location, the term brittle-like cracking is used. This phenomenon is different from brittle fracture, in which the pipe failure causes fragmentation of the pipe.
All owners and operators of natural gas distribution systems are further advised to review the three earlier advisory bulletins on this issue. In addition to being available in the Federal Register, these advisory bulletins are available in the docket, and on PHMSA’s Web site at http://phmsa.dot.gov/ under Pipeline Safety Regulations.
Advisory Bulletin ADB-04-02, Unauthorized Excavations and the Installation of Third-Party Data Acquisition Devices on Underground Pipeline Facilities

RSPA/OPS is issuing this advisory bulletin to owners and operators of gas and hazardous liquid pipeline systems on the potential for unauthorized excavations and the unauthorized installation of acoustic monitoring devices or other data acquisition devices on pipeline facilities. These devices are used by entities that hope to obtain market data on hazardous liquid and gas movement within the pipelines. Recent events have disclosed that devices were physically installed on pipelines without the owner’s permission. Operators must control construction on pipeline right-of-ways and ensure that they are carefully monitored to keep pipelines safe. This is in line with our efforts to prevent third-party damage as reflected by our support of the Common Ground Alliance, which is a nonprofit organization dedicated to shared responsibility in damage prevention and promotion of the damage prevention Best Practices. This advisory bulletin emphasizes the need to ensure that only authorized and supervised excavations are undertaken along the nation's pipeline systems.

Advisory Bulletin, ADB-99-02, Potential failures due to brittle-like cracking of older plastic pipe in Natural Gas Distribution Systems.

A review of Office of Pipeline Safety (OPS) reportable natural gas pipeline incidents and the findings of NTSB Special Investigation Report (NTSB/SIR-98/01) indicate that certain plastic pipe used in natural gas distribution service may be susceptible to brittle-like cracking. The standards used to rate the long-term strength of plastic pipe may have overrated the strength and resistance to brittle-like cracking of much of the plastic pipe manufactured and used for gas service from the 1960s through the early 1980s.

It is recommended that all owners and operators of natural gas distribution systems identify all pre-1982 plastic pipe installations, analyze leak histories, and evaluate any conditions that may impose high stresses on the pipe. Appropriate remedial action, including replacement, should be taken to mitigate any risks to public safety.

Advisory Bulletin, ADB-99-01, Potential failure due to brittle-like cracking certain polyethylene plastic pipe manufactured by Century Utility Products Inc.

All owners and operators of natural gas distribution systems who have installed and continue to use polyethylene pipe extruded by Century Utility Products Inc, (now defunct) from the resin DHDA 2077 Tan resin manufactured by Union Carbide Corporation during the period 1970 to 1973 (Century pipe) are advised that this pipe may be susceptible to premature failure due to brittle-like cracking. Premature failures by brittle-like cracking of Century pipe is known to occur due to poor resin characteristics, excessive local stress intensification caused by improper joints, improper installation, and environments detrimental to pipe long-term strength. All distribution systems containing Century pipe should be monitored to identify pipe subject to brittle-like cracking. Remedial action, including replacement, should be taken to protect system integrity and public safety.

In addition, in light of the potential susceptibility of Century pipe to brittle-like cracking, RSPA recommends that each natural gas distribution system operator with Century pipe revise their plastic pipe repair procedure(s) to exclude pipe pinching for isolating sections of Century pipe. Additionally, RSPA recommends replacement of any Century pipe segment that has a significant leak history or which for any reason is of suspect integrity.

Advisory Bulletin, ADB-97-03, Potential soil subsidence on pipeline facilities.

Pipeline and Hazardous Materials Safety Administration (PHMSA) is advising operators of pipeline facilities of the need for caution associated with heavy rainfall, flooding and soil movement. In particular, pipeline operators should conduct training, and patrol their rights-of-way to identify areas of potential soil subsidence that could adversely affect the safe operation of their pipelines. Additionally, emergency plans should be reviewed to assure they adequately address conditions possible in areas of soil subsidence.

Advisory Bulletin, ADB-94-05, Pipelines affected by flooding.

As the result of seven natural gas and hazardous liquid pipeline flood-related failures in or near the San Jacinto River in Texas on October 19-21, 1994, operators should consider the actions recommended in this Advisory Bulletin for application to pipelines located in any area of the United States subject to widespread flooding.

Operators need to direct their re-sources in a manner that will enable them to determine the potential effects of the flooding on their systems, and take actions as appropriate.

Advisory Bulletin, ADB-94-04, Coordinating Emergency Planning with offshore producers.

This bulletin calls the attention of offshore operators to an NTSB safety recommendation regarding the need for emergency planning and coordination between themselves and offshore producers.

Alert Notice, ALN-92-02, Address concerns arising from Allentown, PA explosion.

  1. If a segment of pipeline, including cast iron, is determined to be in unsatisfactory condition but no immediate hazard exists, the operator shall initiate a program to recondition or phase out the segment involved; (2) cast iron pipe on which general graphitization is found to a degree where fracture might result, must be replaced; and (3) cast iron pipe that is excavated must be protected against damage.

Alert Notice, ALN-91-02, NTSB Recommendation S P-91-12, 07/90 Allentown PA: replacement of cast iron piping.

Operators should have a program to replace cast iron pipe.

Alert Notice, ALN-90-01, Advise offshore water operators of recurring safety problem involving marine vessel operations and crew safety.

The purpose of this Alert Notice is to advise all operators of natural gas and hazardous liquid pipelines located in offshore waters of recurring safety problems involving marine vessel operations and to alert you that exposed pipelines pose a threat to the safety of the crews of fishing vessels in shallow coastal waters and to other marine operations in shipping lanes and deeper offshore waters

Weather related Alert Notices and Advisory Bulletins:

Advisory Bulletin ADB-11-02, Dangers of Abnormal Snow and Ice Build-Up on Gas Distribution Systems

Advisory Bulletin ADB-05-08, Potential for Damage to Pipeline Facilities Caused by the Passage of Hurricane Katrina.

Advisory Bulletin ADB-05-07, Potential for Damage to Natural Gas Distribution Pipeline Facilities Caused by the Passage of Hurricane Katrina.

Advisory Bulletin ADB-04-04, Potential for Damage to Pipeline Facilities Caused by the Passage of Hurricane Ivan.

Advisory Bulletin ADB-98-03, Potential for damage to pipeline facilities caused by the passage of Hurricane Georges.

Advisory Bulletin ADB-97-01, Potential Damage to Pipelines by Impact of Snowfall, and Actions Taken by Homeowners and Others to Protect Gas Systems from Abnormal Snow Build-up.

Advisory Bulletin, ADB-92-01, Potential damage to pipeline facilities by Hurricane Andrew.

Other Reference Material

& Source

GPTC Guide Material is available

Guidance Information

  1. The operator must have and follow a procedure for continuing surveillance of its pipeline system. This regulation is quite broad in its requirements that it pertains to the entire pipeline system, not just High Consequence Areas. The intent of the regulation is to require the operator to continually assess its pipeline system to detect conditions or issues that can impact pipeline integrity. The operator is expected to detect integrity threatening issues and address them to prevent failures, releases, or others events that may endanger public safety. The regulation specifically identifies changes of class location, failures, leakage history, corrosion, substantial changes in cathodic protection requirements, but also includes the broad category of unusual operating and maintenance conditions. The regulation specifies continuing surveillance, implying that the regulation requires the analysis of integrated pipeline data over time to detect changes, not just reaction to a one-time event. The surveillance should be appropriate for the threats on the pipeline segment and any changes or detection of specific issues should be analyzed to determine if preventative and mitigative actions are required.

  2. Some of the factors to consider in determining the adequacy of the operator’s continuing surveillance include but are not limited to the following:

    1. Proximity of the public to the pipelines

    2. Corrosion history

    3. Coating condition

    4. Repair history

    5. Leak history

    6. Failures or releases

    7. Proximity of other pipelines

    8. Cathodic protection requirements

    9. The characteristics and vintage of the pipe

    10. The operating pressure

    11. Right-of-way conditions

    12. Depth of cover

    13. Encroachment

    14. Proximity to roads and highways

    15. River and stream crossings

    16. Overhead crossings

    17. Flooding

    18. Subsidence

    19. ILI’s performed (or lack of)

    20. Blasting

    21. Nearby construction and development, including road crossings

    22. Abnormal operations.

  1. Final Order Guidance:

  1. Northern Natural Gas Company [3-2003-1009] (February 16, 2006): 49 C.F.R. §192.613(a) requires operators “to establish procedures for continuing surveillance of its facilities to determine and take appropriate action concerning changes in class location.” If operators follow their own procedures, but are still unable to take appropriate action, regulatory compliance pursuant to §192.605(a) has not been achieved, as the operator must adequately conduct continuing surveillance of its facilities in accordance with the operating procedures established under §192.613(a). CP

Examples of a Probable


  1. The lack of a procedure is a violation of §192.605.

  2. The lack of records is a violation of §192.603.

  3. The operator does not have a continuing surveillance procedure appropriate for identifying the conditions or hazards to the pipeline system.

  4. The operator has not performed continuing surveillance according to their procedures.

  5. The operator fails to take appropriate preventative and mitigative measures based on findings from the continuing surveillance.

Examples of Evidence

  1. A copy of the operator’s continuing surveillance procedures and associated prescribed documentation.

  2. Photographs of field locations showing examples of the conditions or integrity issues that were not identified or addressed by the operator’s continuing surveillance program.

  3. A description of operator pipeline facility locations and stationing, mile post, or coordinates of integrity issues that should have been identified and addressed by the continuing surveillance program.

  4. Inquiries or complaints by the public, other pipeline operators, other agencies, or local authorities on integrity issues involving the operator’s pipeline facilities.

  5. Documented statements from an operator representative concerning the operators actions taken (or not taken) related to integrity threatening condition that should have been identified by the operator’s continuing surveillance program.

  6. The operator’s pipeline maintenance records, cathodic protection records, rectifier records, ILI data, CIS data, incident reports, valve inspection records, patrolling records, leak detection survey records, etc., and other associated procedures may be needed to support the allegation of a violation of this regulation.

Other Special Notations

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