On August 25, 2011, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published an Advance Notice of Proposed Rulemaking (ANPRM) in the Federal Register (76 Fed. Reg. 53086-53102) and is considering whether changes to pipeline security regulations (49 CFR parts 190-199) are prudent and necessary. While PHMSA is confident that integrity management requirements have raised the level of safety of gas transmission pipelines in high-consequence areas, certain recent events such as the explosion in San Bruno, California, in September 2010, and inspections of IM programs have revealed a potential need to improve and clarify some IM requirements. In the ANPRM, PHMSA seeks public comment on 14 topics within two broad categories:

Should IM requirements be revised and strengthened to bring more pipeline segments in HCAs? Topics falling with the purview of this question include...

Article Authored By McAfee & Taft Attorney: Vickie Buchanan.