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Subject:
From:
Frederic Grevin <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Wed, 9 May 2012 09:01:00 -0400
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With respect to this development, I take note that, while the article (The AP via Sacbee.com) states



"If pipeline operators can't ensure their oil and gas lines are running at safe pressures by next year, the Pipeline and Hazardous Materials Safety Administration underscored they could face penalties or some other type of sanction."



and



"In a later phase, PHMSA also will direct energy companies on what to do if they can't find records for all their pipelines, she added."



The Pipeline and Hazardous Materials Safety Administration advisory bulletin "PHMSA Reminds Pipeline Operators to Preserve and Verify Records"  dated 2012-05-07 (http://www.phmsa.dot.gov/staticfiles//PHMSA/DownloadableFiles/Press%20Releases/phmsa0912%20-%20FINALjl.pdf<http://www.phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Press%20Releases/phmsa0912%20-%20FINALjl.pdf>) does not seem to support either of these statements. Perhaps they are derived from other sources, not credited in the article.



In addition, the language "... could face penalties or some other type of sanction" does not seem to give the requirement many sharp teeth on the enforcement side.



Finally, it is hardly reassuring to hear the PHMSA hasn't yet figured out " ... what to do if [energy companies] can't find records for all their pipelines".



I await Larry Medina's comments with bated breath.....



Fred

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