The 2012 Amendments to the Pipeline Safety Act (PSA) effectively suspended all exemptions for filing Safety Related Condition Reports (SRCRs) for those conditions resulting in an exceedance of 110% MAOP. Under 49 C.F.R. Parts 191.23 and 191.25 (gas) and 195.55 (oil), SRCRs must be filed by both gas and oil pipeline operators when certain conditions arise, including unintended movement (e.g., as associated with earthquakes, landslides or floods), abnormal loading over a line, and malfunctions or operator errors than cause an exceedance of 110% MOP/MAOP. There are several exemptions to the SRCR requirement, including occurrence of an incident that is otherwise reported to the NRC, conditions that occur on lines more than 220 yards from any building intended for human occupancy (but conditions within ROW of roads or railroads remain subject to reporting), and those conditions that can be corrected by repair or replacement within five working days of discovery of the condition. Significantly, Section 23(b)(2) of the 2012 PSA amendments removed any exemptions otherwise applicable to gas transmission lines exceeding 110% MAOP. All such exceedances must now be reported as SRCRs within five days, regardless of the applicability of the exemptions found in 49 C.F.R. Part 191.23. See PHMSA Advisory Bulletin ADB-2012-11, 77 Fed. Reg. 75,699, 75,500 (Dec. 21, 2012). Click here for a copy of the Bulletin.