PHMSA has again released an advisory to pipeline operators on the potential for damage to pipeline facilities caused by severe flooding, as well as actions operators should consider taking to ensure the integrity of pipelines in the event of flooding, river scour, and river channel migration. The advisory is essentially identical to advisories PHMSA has issued on the same topic in July 2013 and April 2015 (see previous posts on these advisories from 2013 and 2015), reflecting a tendency of the Agency to issue such guidance cyclically.
The fourteen recommended actions in the advisory are the same as those recommended by the Agency in April 2015. As with prior similar guidance (including advisories regarding the potential for hurricane damage to pipeline facilities), the Agency invokes operators’ general duties under various regulatory provisions related to (1) pipeline surveillance and addressing unsatisfactory conditions or conditions that may adversely impact safe operation of the pipeline (49 C.F.R. Parts 192.613; 195.401); (2) maintaining a facility response plan for certain onshore pipelines (Part 194.107); and (3) taking measures to prevent and mitigate the consequences of a pipeline failure for certain pipelines (Parts 192.935, 194.107(a), and 195.452(i)).