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…