CFR Dot 192

Tuesday,
January 28, 2003
Part II
Department of
Transportation
Research and Special Programs
Administration
49 CFR Part 192

Pipeline Safety: Pipeline Integrity
Management in High Consequence Areas
(Gas Transmission Pipelines); Proposed
Rule
VerDate Dec<13>2002 00:17 Jan 28, 2003 Jkt 200001 PO 00000 Frm 00001 Fmt 4717 Sfmt 4717 E:\FR\FM\28JAP2.SGM 28JAP2
4278 Federal Register / Vol. 68, No. 18 / Tuesday, January 28, 2003 / Proposed Rules
DEPARTMENT OF TRANSPORTATION ‘‘Help & Information’’ for instructions inspection of pipelines located in these
on how to file a document areas, including the circumstances
Research and Special Programs electronically. under which an inspection can be
Administration conducted using an instrumented
Privacy Act Information
internal inspection device (smart pig) or
49 CFR Part 192 Anyone is able to search the an equally effective alternative
electronic form of all comments inspection method. The proposed rule
[Docket No. RSPA–00–7666; Notice 4]
received into any of our dockets by the also incorporates the required elements
RIN 2137–AD54 name of the individual submitting the for gas integrity management programs
comment (or signing the comment, if recently mandated in the Pipeline
Pipeline Safety: Pipeline Integrity submitted on behalf of an association, Safety Improvement Act of 2002, which
Management in High Consequence business, labor union, etc.). You may was signed into law on December 17,
Areas (Gas Transmission Pipelines) review DOT’s complete Privacy Act 2002.
AGENCY: Office of Pipeline Safety (OPS), Statement in the Federal Register
Background
Research and Special Programs published on April 11, 2000 (Volume
65, Number 70; Pages 19477–78) or you RSPA/OPS is in the midst of
Administration (RSPA), DOT.
may visit http://dms.dot.gov. promulgating a series of rules intended
ACTION: Notice of proposed rulemaking. to require pipeline operators to develop
General Information integrity management programs for their
SUMMARY: This document proposes to
establish a rule to require operators to You may contact the Dockets Facility entire systems, and to conduct baseline
develop integrity management programs by phone at (202) 366–9329, for copies and periodic assessments of pipeline
for gas transmission pipelines that, in of this proposed rule or other material segments the failure of which could
the event of a failure, could impact high in the docket. All materials in this imperil the health and safety of nearby
docket may be accessed electronically at residents and cause significant damage
consequence areas (HCAs). These
http://dms.dot.gov/search. Once you to their property. These integrity
integrity management programs would
access this address, type in the last four management programs, written
focus on requiring operators to
digits of the docket number shown at differently for the liquid and natural gas
comprehensively evaluate their
the beginning of this notice (in this case pipeline systems, are designed with the
pipelines, and take measures to protect
7666), and click on search. You will goal of identifying the best method(s) for
pipeline segments located in high
then be connected to all relevant maintaining the structural soundness
consequence areas. RSPA/OPS recently
information. (i.e., integrity) of transmission pipelines
finalized the definition of high
operating across the United States.
consequence areas by a separate FOR FURTHER INFORMATION CONTACT:
RSPA/OPS began this series of integrity
rulemaking. This proposed rule Mike Israni by phone at (202) 366–4571, management rulemakings by issuing
proposes to expand the definition of by fax at (202) 366–4566, or by e-mail requirements pertaining to hazardous
HCAs by adding consideration of people at mike.israni@rspa.dot.gov, regarding liquid operators. A final rule applying to
living at distances greater than 660 feet the subject matter of this proposed rule. hazardous liquid operators with 500 or
from large diameter high pressure General information about the RSPA/ more miles of pipeline was published
pipelines. The current HCA definition OPS programs may be obtained by on December 1, 2000 (65 FR 75378). The
only requires consideration of people accessing RSPA’s Internet page at hazardous liquid rule applies to
living at distances up to 660 feet from http://RSPA.dot.gov. pipeline segments that can affect high
pipelines. SUPPLEMENTARY INFORMATION: RSPA/ consequence areas (HCAs), which under
DATES: Interested persons are invited to OPS believes it can best assure pipeline the liquid rule criteria include
submit written comments by March 31, integrity by requiring each operator to: populated areas defined by the Census
2003. Late-filed comments will be (a) Implement a comprehensive integrity Bureau as urbanized areas or places,
considered to the extent practicable. management program; (b) conduct a unusually sensitive environmental
ADDRESSES: baseline assessment and periodic areas, and commercially navigable
reassessments focused on identifying waterways. RSPA/OPS issued a similar
Filing Information and characterizing applicable threats; (c) rule for hazardous liquid operators with
You may submit written comments by mitigate significant defects discovered less than 500 miles of pipeline (66 FR
mail or delivery to the Dockets Facility, in this process; and (d) monitor the 2136; January 16, 2001).
U.S. Department of Transportation, effectiveness of their programs so Earlier this year, RSPA/OPS
Room PL–401, 400 Seventh Street, SW., appropriate modifications can be explained in the Federal Register that
Washington, DC 20590–0001. It is open recognized and implemented. This we were beginning the integrity
from 10 a.m. to 5 p.m., Monday through approach also recognizes that improving management rulemakings for gas
Friday, except Federal holidays. All integrity requires operators to gather transmission lines by first proposing a
written comments should identify the and evaluate data on the performance definition of HCAs (67 FR 1108; January
docket and notice numbers stated in the trends resulting from their programs, 9, 2002). We also described our plan to
heading of this notice. Anyone desiring and to make improvements and propose integrity management program
confirmation of mailed comments must corrections based on this evaluation. requirements for gas transmission
include a self-addressed stamped This proposed rule does not apply to gas pipelines affecting those areas. In that
postcard. gathering or to gas distribution lines. proposed rule on HCAs ( January 9,
This proposed rule will satisfy 2002), we also said we had decided first
Electronic Access Congressional mandates for RSPA/OPS to propose the definition of HCAs and
You may also submit written to prescribe standards that establish then to propose the gas integrity
comments to the docket electronically. criteria for identifying each gas pipeline management rule. We chose to propose
To submit comments electronically, facility located in a high-density the regulation in two separate steps for
access the following Internet Web population area and to prescribe a number of reasons. For example,
address: http://dms.dot.gov. Click on standards requiring the periodic operators already have good information
Federal Register / Vol. 68, No. 18 / Tuesday, January 28, 2003 / Proposed Rules 4279
(through the Class Location impacted from a pipeline rupture and requirement that the operator notify
Requirements) on where the potential explosion. However, additional RSPA of changes to its program, and a
consequences of a gas pipeline accident calculations have to be used to means to make copies of operator
may be most significant. In addition, determine the likely actual area that records available to State interstate
since we were still collecting would be impacted. This proposed gas agents.
information and verifying the validity of integrity management rule provides a
Rule Synopsis
assessment methods other than internal method to analyze how a pipeline
inspection and pressure testing, segment will impact an HCA if the The elements of an integrity
presenting the gas pipeline integrity segment fails. The definitions of a management program are to consist of:
management requirements as a single potential impact circle and potential (i) An identification of covered pipeline
rule would delay review of the HCA impact zone that we are proposing, that segments and the potential impact zone
definition. RSPA/OPS recently finalized are based on a mathematical equation, for each segment; (ii) a baseline
the definition of HCAs (67 FR 50824; will essentially determine the likely assessment plan; (iii) an identification
August 6, 2002). actual area within an HCA that would of threats to each covered pipeline
In the current definition of HCAs be impacted. Whereas the HCA segment, including risk assessments of
(August 6, 2002), we noted four definition is based on broad corridors each covered segment; (iv) a direct
significant characteristics of gas (i.e., lateral distances perpendicular to assessment plan, if direct assessment is
pipelines ruptures and explosions that pipeline) but not longitudinal distances to be used; (v) provisions for
are relevant in defining HCAs. These (i.e., axially along the pipeline), the remediating conditions found; (vi) a
same characteristics are useful here in potential impact circle and potential process for continual evaluation and
the context of developing integrity impact zones that we are proposing will assessment; (vii) preventive and
management regulations. Those provide longitudinal distances to define mitigative measures; (viii) a
characteristics are: (1) The effects of a the actual area of impact in an HCA, and performance plan as outlined in ASME/
gas pipeline rupture and subsequent narrow the area to which the proposed ANSI B31.8S, Section 9; (ix)
explosion are highly localized. The assessment and repair requirements will recordkeeping requirements; (x) a
physical properties of natural gas dictate apply. management of change process as
that it rises upward from a rupture as This proposed rule also defines a outlined in ASME/ANSI B31.8S,
the gas expands into the air; (2) The Moderate Risk Area as an area located Section 11; (xi) a quality assurance
zone of damage or heat affected zone within a Class 3 or Class 4 location, but process as outlined in ASME/ANSI
following a rupture is related to the not within the potential impact zone. B31.8S, Section 12; (xiii) a
line’s diameter and the pressure at Whether a building located in a rural communication plan based on ASME/
which the pipeline is operated; (3) The area, such as a rural church, which is ANSI B31.8S, Section 10, to include a
size of the heat affected zone from currently included in the High process for addressing safety concerns
pipeline ruptures where pipe diameter Consequence Area definition, should be raised by OPS, including safety
was less than 36 inches and operating designated as a Moderate Risk Area concerns OPS raises on behalf of a State
pressures were at or below 1000 psig, requiring less frequent assessment or authority with which OPS has an
was limited to a diameter of 660 feet; requiring enhanced preventive and interstate agent agreement and of local
and (4) The heat affected zone for mitigative measures is an issue for authorities; (xiv) a process for
pipelines of 36 inches or greater, public comment that we discuss later in providing, by electronic or other means,
operating at pressures in excess of 1000 this document. a copy of the operator’s integrity
psig, can extend 1000 feet. Based on The process of identifying pipeline management program to a State
these findings, the HCA definition segments that are located in high authority with which OPS has an
included language that would require consequence areas and moderate risk interstate agent agreement; and (xv) a
operators of large diameter pipelines areas is described below under Covered process for ensuring that each integrity
operating at high pressures to include Segments. assessment is being conducted in a
areas within a 1000 foot radius from the manner that minimizes environmental
Pipeline Safety Improvement Act of
pipeline. This proposed rule, referred to and safety risks.
2002
as the gas integrity management Covered Segments
program (IMP) rule, will expand the On November 15, 2002, Congress
current definition of HCAs (August 6, passed H.R. 3609, the Pipeline Safety Operators must identify covered
2002), by adding consideration of Improvement Act of 2002. The President segments prior to performing
people living at distances greater than signed the bill on December 17, 2002. assessments. A covered segment is any
660 feet from large diameter high Section 14 of H.R. 3609 contains transmission pipeline segment. The
pressure pipelines. This expansion is requirements for integrity management approach involves six steps that rely on
based on the need to provide the same programs for gas pipelines located in the definitions contained in section
level of added protection to population high consequence areas. The proposed 192.761. Those six steps are: (1) Identify
groups, as the current HCAs provide to rule which RSPA has been working on all high consequence areas for the
facilities that house people who are for some time is substantially in pipeline using the HCA definition as
difficult to evacuate, people with alinement with section 14 of H.R. 3609. expanded by this proposed rule; (2)
impaired mobility, people who are However, there are differences. We have calculate the Potential Impact Radius
confined, and areas where people incorporated the requirements of section (PIR) for each covered segment in the
congregate. This population group 14 into this proposed rule. These areas pipeline; (3) determine the Threshold
living at distances greater than 660 feet include the intervals for conducting Radius associated with the PIR for each
was inadvertently omitted from the baseline and reassessment testing, segment; (4) identify Potential Impact
definition when we proposed and later consideration of testing done prior to Circles for the pipeline; (5) identify the
finalized the HCA definition. the final rule, the incorporation of Potential Impact Zones (PIZ) for the
The HCA definition for gas issues raised by State and local pipeline, and based on that zone for
transmission lines was based on broad authorities, the conduct of testing in an covered segments located in Class 3 and
corridors that could potentially be environmentally appropriate manner, a Class 4 locations, identify the moderate
risk areas; and (6) determine the priority direct examinations during the period testing or internal inspection as an
of each covered pipeline segment (i.e., while direct assessment is being assessment method are required to
segments subject to the proposed rule validated. complete the baseline assessment of a
that are within a potential impact zone Some additional details regarding segment located in an HCA within 10
are considered higher impact zones; direct assessment are highlighted here years of December 17, 2002 (the date the
those segments outside a PIZ are for the purpose of acquainting readers of Pipeline Safety Improvement Act was
considered lower impact zones). this proposed rule with some of the signed into law). 50% of the covered
Additional detail on identifying covered basic principles associated with the use segments would have to be assessed
segments is provided elsewhere in this of direct assessment. First, for purposes within five years. Operators using
preamble and in the Definitions located of this rulemaking, above-ground pressure testing or internal inspection as
at section 192.761 of the proposed rule. inspection techniques (such as close an assessment method are permitted 13
interval surveys, direct current voltage years to assess pipeline segments
Assessment Methods gradient, and pipeline current mapper) located in Class 3 and 4 locations where
There are four acceptable assessment are considered indirect examinations. the area being assessed is not within the
methods defined by this rule. They are: Second, visual inspection, ultrasonic potential impact zone i.e., the areas we
(a) Internal inspection (also know as in- testing and x-ray examinations are are proposing to define as moderate risk
line inspection, ILI and pig testing); (b) considered direct examinations. Third, areas. (Additional detail on potential
pressure testing; (c) direct assessment, (a all three threats considered under direct impact zones is provided in the
process that includes data gathering, assessment (external corrosion, internal Definitions section (§ 192.761) of this
indirect examination and/or analysis, corrosion, and stress corrosion cracking) proposed rule and in the guidance that
direct examination, and post assessment are direct examination of pipe. Fourth, follows the proposed rule text.) If direct
evaluation); and (d) any other method operators who assert that their pipelines assessment is used as an assessment
that can provide an equivalent cannot be internally inspected or method, the proposal is for the operator
understanding of the condition of line pressure tested are required to include to complete the baseline assessment
pipe. In addition, the rule proposes a written justification in their plans within seven years for segments located
method known as confirmatory direct explaining why their pipeline(s) cannot in HCAs, with 50% of the segments
assessment that an operator could use as be tested using these methods. Fifth, having to be assessed within four years.
an interim reassessment method. operators who assert that internal Ten years would be allowed for a
The Pipeline Safety Improvement Act inspection or pressure testing is not pipeline segment located in a Class 3 or
of 2002 provides for assessment by ‘‘an economically feasible will likewise be 4 location where the segment being
alternative method that the Secretary required to include written justification assessed is not within the potential
determines would provide an equal or in their plans indicating why these impact zone i.e, is within a moderate
greater level of safety.’’ Because the methods are not economically feasible. risk area. Additional detail on baseline
primary function of internal inspection Another concept in the proposed rule assessments is provided elsewhere in
tools or pressure testing is to determine is the use of Confirmatory Direct this preamble and at section 192.763(g)
the condition the pipe is in, we have Assessment to evaluate a segment for of the proposed rule. The timing of
determined that equivalent or greater the presence of corrosion and third baseline assessments is covered in more
safety can be provided by ‘‘other party damage. This is a more detail at section 192.763(g)(4).
technology that an operator streamlined assessment method that The Pipeline Safety Improvement Act
demonstrates can provide an equivalent uses the steps involved in direct of 2002 provides that a baseline
understanding of the condition of the assessment to identify these significant assessment is to be completed ‘‘not later
line pipe.’’ We used this language in the threats to a pipeline’s integrity. As than 10 years after the date of enactment
liquid integrity management program discussed later in this document, RSPA/ * * *’’ The Act further provides that at
rules and are proposing to include it OPS is proposing that an operator use least 50% of covered facilities are to be
under the list of allowable assessment this method as an initial reassessment assessed ‘‘not later than 5 years after
methods for the baseline assessment and method within the required seven-year such date * * *’’ Our proposal for
reassessments. reassessment interval, if the operator baseline assessment using internal
The rule proposes to allow direct has, within the proposed limits, inspection, pressure test or equivalent
assessment as a supplemental established a longer reassessment technology is consistent with that
assessment method on any covered interval for a particular segment. The requirement. We propose a shorter time
pipeline segment and as a primary follow up reassessment by pressure test, frame for baseline assessment by direct
assessment method on a covered internal inspection or direct assessment assessment. The primary reason for
pipeline where in-line inspection and would then be conducted at the proposing a shorter time frame is that
pressure testing are not possible or established interval. direct assessment technologies are still
economically feasible or where the Additional information about direct under development and additional
pipeline operates at a low stress. None assessment and confirmatory direct information needs to be gathered on
of the permitted assessment methods assessment is provided elsewhere in their effectiveness. However, RSPA/OPS
listed above is fully capable of this preamble and at section 192.763(h) has been sponsoring research on direct
characterizing all potential threats to of the proposed rule. assessment that should help expedite its
pipeline integrity. Currently, direct validity as a method for assessment.
assessment is only an acceptable Baseline Assessment Periods
Based on the results from this research
inspection method for assessing external Under this proposal, operators are OPS may be able to lengthen the time
corrosion, internal corrosion and stress required to complete a one-time frame from five years to up to ten years.
corrosion cracking. In addition, if no baseline assessment on each covered
other assessment method is feasible, segment. After a baseline assessment is Reassessment Intervals
direct assessment may be used to completed on a segment, an operator The Pipeline Safety Improvement Act
evaluate third party damage. Operators will be required to reassess the covered requires a minimum seven-year
choosing direct assessment technologies pipeline segment at the specified reassessment period. Thus, under the
must undertake extra excavations and interval. Operators using pressure proposed rule we set a reassessment
interval of seven years for operators for corrosion to penetrate the pipe to a the requirements accordingly. Examples
using pressure test, internal inspection depth where the corrosion causes any of different requirements for pipelines
or equivalent technology, and a five year concern. operating at lower stress are in § 192.65
interval for an operator using direct • The actual reassessment interval is (Transportation of pipe), § 192.227
assessment that directly examines and based on risk factors. The reassessment (Qualification of welders), § 192.241
remediates defects by sampling. interval will depend on numerous risk (Inspection and test of welds), § 192.309
However, an operator using pressure factors, such as the baseline assessment (Repair of steel pipe), § 192.315
test, internal inspection or equivalent results, the remediation of defects found (Wrinkle bend in steel pipe), § 192.319
technology could establish a longer during the baseline and the integration (installation of pipe in a ditch, § 192.505
interval, within established limits if the of data concerning other risk factors. (Strength requirements for steel pipeline
operator by the seventh year conducts a Thus, higher risk pipe will be reassessed to operate at a hoop stress of 30% or
reassessment using confirmatory direct sooner. more of SMYS), § 192.711 (General
assessment and then conducts the • Gas supply interruptions. Gas requirements for repair procedures), and
follow up reassessment by the chosen transmission pipelines typically feed § 192.717 (Permanent field repair of
method in the year the operator has set directly into customer distribution lines leaks).
for the interval. The interval for without an intermediate storage The maximum reassessment interval
reassessment begins to run on a segment location. A pipeline’s operating pressure for operators using direct assessment as
after the operator has completed the is generally lower (i.e., pipeline is at a an assessment method is five years
previous assessment for that segment. lower stress level) when it is at the under this proposal, provided an
Under the proposed rule, an operator transition phase into a distribution line. operator directly examines and
establishes the reassessment interval for This close coupling between the remediates defects by sampling. The
covered segments based on the type of transmission and distribution systems reassessment interval under direct
assessment method the operator plans increases the likelihood of a supply assessment would be expanded to ten
on using. The type of method used interruption if a single line is shutdown years if an operator conducts a direct
establishes the maximum interval. For for assessment or repair. The 15-year examination of all indications and
operators using pressure testing, maximum is intended to minimize these remediates the anomalies. If an operator
internal inspection, or alternative supply interruptions. establishes an interval of more than
technology as an assessment method, • Industry consensus standards. seven years on a segment, the operator
the operator is to base the intervals on ASME B31.8S specifies a reassessment would have to conduct a confirmatory
the identified threats for the segment or interval of 15 years for pipelines direct assessment by the seventh year.
on the stress level of the pipeline and operating below 50% SMYS, and 20 Additional detail on reassessment
then refer to ASME/ANSI B31.8S, years for pipelines operating between intervals is provided elsewhere in this
Section 8 to establish the interval. 20% and 30% SMYS. These preamble and at section 192.763(k) of
Under either option, the proposed reassessment intervals are based on a the proposed rule.
maximum interval is ten years and 15 mathematical model Kiefner and RSPA/OPS is inviting public
years for a pipeline operating at below Associates developed. comment on whether we should allow
50% SMYS. However, because a These factors led us to conclude that an operator using direct assessment a
reassessment must be conducted by the the proposed 15-year maximum maximum ten-year reassessment
seventh year, under the proposal, if an reassessment interval for pipelines interval on a pipeline operating at less
operator establishes an interval of ten operating below 50% was reasonable for than 30% SMYS regardless of whether
years for a segment, the operator would operators yet would ensure safety. the operator excavates and remediates
have to complete a confirmatory direct Again, as discussed previously, an all anomalies on that line, or at least
assessment by the seventh year, and operator would have to complete a remediates the highest-risk anomalies.
then in the tenth year do a follow up confirmatory direct assessment by the Again, the operator would have to
reassessment using pressure test, seventh year. conduct a confirmatory direct
internal inspection tool, direct RSPA/OPS is inviting public assessment by the seventh year of the
assessment or alternative equivalent comment on whether we should allow interval.
technology. a maximum 20-year reassessment The number of excavations (Dig
OPS has predicated the proposed 15- interval (with a confirmatory direct Criteria) proposed for the direct
year maximum reassessment interval for assessment in the seventh and 14th assessment method follow those being
pipelines operating below 50% SMYS years) on pipelines operating at less developed by the National Association
on several factors. than 30% SMYS, and reassessment by of Corrosion Engineers (NACE)
• Greater safety margin the current the confirmatory direct assessment Recommended Practices on Direct
regulations provide. Current pipeline method only every seven years for Assessment, with the following
safety requirements provide a greater pipelines operating below 20% SMYS. deviations:
safety margin against corrosion for gas The proposed confirmatory direct (1) In each External Corrosion Direct
pipelines located in populated areas. assessment method could be further Assessment (ECDA) region where all
For example, the regulations require streamlined for pipelines operating indications categorized as ‘‘immediate’’
pipelines that are located in Class 3 and below 20% SMYS. OPS is considering are present, we propose that the
4 locations (high population areas) to be a maximum interval of 20 years for operator reduce operating pressure by at
of greater wall thickness than pipelines pipelines operating between 20% to least 20% until such indications have
located in Classes 1 and 2 locations. 30% SMYS (with a confirmatory direct been excavated and mitigated.
And operators must replace the existing assessment by the 7th and 14th years) (2) In each ECDA region where
pipe with thicker, stronger pipe when because numerous studies and analyses indications categorized as
population density increases (i.e., the have demonstrated that these low stress ‘‘scheduled’’are present, we propose the
class location changes). Thus, pipelines pipelines tend to leak, rather than to operator continue the excavations until
located in populated areas are less rupture. Current gas pipeline safety at least two indications are excavated
susceptible to corrosion-induced regulations recognize the reduced risk having corrosion of depth no greater
rupture, because it takes much longer that low stress levels pose, and structure than 20% of wall thickness.
(3) In each ECDA region, we propose of the assessment will be excavated and RSPA/OPS, and to provide the basis for
to require one excavation; however, the directly examined, only a fraction of the expanding requirements as needed
excavation must be made at a location ECDA indications that are protected by within the Integrity Management
the operator considers most suspect, not cathodic protection systems at the time Program (IMP) Rule. RSPA/OPS
at any random place. of the assessment will be excavated. involvement included participation in
RSPA/OPS is inviting public Additional detail is provided elsewhere the teams that developed the ASME/
comment on whether the benefits of in this preamble and at section ANSI B31.8S standard, and ongoing
these proposed requirements that are 192.763(h)(4) of the proposed rule. participation in the development of the
more extensive than the NACE NACE Recommended Practice on Direct
Recommended Practices currently being The Role of Consensus Standards
Assessment. In addition, RSPA/OPS
developed are worth the cost. The underpinning analysis for this supported participation by pipeline
rulemaking was a consensus standard safety representatives from several
External Corrosion Direct Assessment development effort. Completing this
and Internal Corrosion Direct States in the standards development and
effort required nearly two years. This review process.
Assessment effort required assembling the best This proposed rulemaking is the
Work jointly funded by the gas integrity assurance practices currently culmination of experience gained from
pipeline industry and RSPA/OPS is used by gas pipeline operators, and inspections, accident investigations and
ongoing to develop, validate and incorporating these practices into risk management and system integrity
standardize the application of the direct consensus standards. In addition the initiatives. This experience is the
assessment process to external corrosion direct assessment process, which was foundation for proposing a rulemaking
(ECDA) and internal corrosion (ICDA). conceived as a way to assess the that addresses, in a comprehensive
Future work is planned to develop, integrity of gas pipelines for which in- manner, the National Transportation
validate and standardize a direct line-inspection and pressure testing are Safety Board’s (NTSB)
assessment process for application to not possible or economically feasible, recommendations, Congressional
the stress corrosion cracking (SCCDA) needed to be developed, documented, mandates, including the mandates in
threat. Furthermore, significant and standardized. Some consensus the Pipeline Safety Improvement Act of
anecdotal evidence exists that the ECDA standards on gas pipeline integrity
2002, and pipeline safety and
process may be capable of identifying management that we are considering
environmental issues raised over the
coating damage associated with third incorporating by reference have been
party impacts on pipelines, but formal years. These issues and considerations
published. Others are still under
validation of this capability has not include:
development.
occurred. A major effort has been underway for • Several NTSB recommendations
ICDA is an assessment process that several years to develop consensus concerning pipeline safety, including
first identifies areas along the pipeline standards supporting integrity those which:
where water or other electrolytes management practices for gas pipelines. (1) Require periodic testing and
introduced by an upset condition may These standards are a necessary inspection to identify corrosion and
reside, then focuses direct examination component in assuring the quality of other time-dependent damage.
on the locations in each area where implementation of any new assessment (2) Require the establishment of
internal corrosion is most likely to exist. requirement. ASME/ANSI B31.8, criteria to determine appropriate
If no evidence of internal corrosion Supplement, issued early this year, intervals for inspections and tests,
exists in these most likely locations, structures industry knowledge and best including safe service intervals between
then the entire section can be practices into requirements for an pressure testing.
considered to be free of internal integrity management program and a set (3) Determine hazards to public safety
corrosion. An operator using direct of prescriptive requirements for from electric resistance welded (ERW)
assessment as a method to address assessing pipeline integrity. In addition pipe and take appropriate regulatory
internal corrosion in a pipeline segment this standard describes the requirements action.
must follow the requirements in ASME/ an operator must follow to implement a (4) Expedite requirements for
ANSI B31.8S, Appendix SP–B2, and in performance-based program. The installing automatic or remote-operated
this section. Additional detail on ICDA ASME/ANSI standard represents a mainline valves on high-pressure lines
is provided elsewhere in this preamble significant advance in the to provide for rapid shutdown of failed
and at section 192.763(h)(3) of the documentation of demonstrated pipeline segments.
proposed rule. integrity management practices. • Our analyses of several pipeline
ECDA is an assessment process that Although many of the tools employed ruptures in Bellingham, Washington;
combines assembly and analysis of risk in the direct assessment process have Simpsonville, South Carolina; Reston,
factor data, indirect examination using been in use for sometime, the use of Virginia; and Edison, New Jersey,
above ground detection instruments, these tools in the integrity assessment brought to light the need for operators
direct examination of suspected areas process is new. The National to address the potential
on the pipeline and post-assessment Association of Corrosion Engineers interrelationship among factors affecting
evaluation. The current approach being (NACE) undertook development of a failure causes and to implement
incorporated in the consensus standard Recommended Practices to support coordinated risk control actions to
under development for ECDA is to direct assessment and to expand the supplement the protection provided by
locate areas suspected of having standardized application of In-Line compliance with current regulations.
external corrosion by identifying defects Inspection (ILI). • Our analysis of the rupture in
in the pipe coating, then excavating RSPA/OPS is relying heavily on the Carlsbad, New Mexico, highlighting the
those defects in areas where corrosion technical content of these standards. need for methods to assess internal
activity is suspected. While all RSPA/OPS has been directly involved corrosion in pipelines that are not
indications discovered by ECDA that are in the development of these standards, piggable.
not adequately protected by the both to ensure that the standards reflect • Several Congressional mandates
cathodic protection system at the time the knowledge and perspective of identify areas where the risk of a
pipeline failure could have significant segments. The focus of the high impact At the public meeting, industry and
impact. These specify that RSPA/OPS: inspection is on understanding how State representatives presented their
(1) Prescribe standards establishing criteria operators are addressing the issues that perspectives on a number of issues
for identifying gas pipeline facilities located have been recognized as important relating to integrity management.
in high-density population areas (49 U.S.C. through past inspections and incident Gas Advisory Committee Consideration
60109(a)(2)). history. High impact inspections are
(2) Prescribe, if necessary, additional carried out periodically for each The Technical Pipeline Safety
standards requiring the periodic inspection operator and the results are documented Standards Committee (TPSSC) is the
of pipelines in high-density population areas, using heavier reliance on narrative Federal advisory committee charged
to include any circumstances when an with responsibility for advising on the
instrumented internal inspection device, or
description rather than on acceptability
check marks. We found that a system- technical feasibility, reasonableness,
similarly effective inspection method, should cost-effectiveness, and practicability of
be used to inspect the pipeline (49 U.S.C. wide approach rooted in evaluation of
60102(f)(2)). operator response to incidents and gas pipeline safety standards. The 15
(3) Survey and assess the effectiveness of recognized performance issues is a more member committee is comprised of
Remote Control Valves (RCVs) to shut off the effective and, in most cases, more individuals from industry, government,
flow of natural gas in the event of a rupture efficient means of evaluating pipeline and the general public.
of an interstate natural gas pipeline facility integrity. As part of this approach, we On February 7, 2001, RSPA/OPS
and make determination about whether the evaluate how pipeline operators briefed TPSSC members on gas integrity
use of these valves is technically and
integrate information about their management program development.
economically feasible and would reduce risks After canceling the September 13, 2001
associated with a rupture of an interstate pipelines to identify sources of risk and
to determine the best means of meeting with TPSSC members, we sent
natural gas pipeline facility. If the use of all presentation materials and progress
these valves determined to be technically and addressing risk. This experience is
reports to committee members by mail
economically feasible and would reduce risks helping us develop detailed inspection
for their comments or concerns. In May,
associated with a rupture of an interstate guidelines to evaluate compliance with
natural gas pipeline facility, then prescribe 2002, we sent a document highlighting
the requirements of this rule.
standards on the circumstances where an major issues in the gas integrity
RSPA/OPS continues to meet with management rule to the TPSSC
operator of a gas transmission pipeline
facility must use an RCV (49 U.S.C. 60102(j)).
representatives of the gas pipeline members. On July 18, 2002 the TPSSC
industry, research institutions, State met to review the Gas Transmission
Risk Management and Systems pipeline safety agencies and public Pipeline HCA Rule and the cost-benefit
Integrity Inspection Initiatives interest groups, to gather the analysis for the Gas Pipeline Integrity
This proposed rulemaking is also information needed to propose an Management Program Rule. The
based on what we learned about integrity management program (IMP) committee voted unanimously to accept
integrity management programs from rulemaking pertaining to gas operators. the cost benefit analysis as the basis for
our risk management and pipeline Since January 2000, RSPA/OPS has proceeding with the integrity
inspection activities, particularly the attended several meetings with management rule provided RSPA/OPS
Risk Management Demonstration representatives of the Interstate Natural gives consideration to several issues.
Program, the Systems Integrity Gas Association of America (INGAA), These issues and the related RSPA/OPS
Inspection (SII) Pilot Program and the the American Gas Association (AGA), positions are summarized below.
new high impact approach to Battelle Memorial Institute, the Gas The committee noted that the pipeline
inspections. These precursor activities Technology Institute (GTI), Hartford covered by the IMP Rule would include
began in 1997. Steam Boiler Inspection and Insurance class 3 and 4 locations. RSPA’s initial
In the Risk Management Company, several gas pipeline operators estimates of the total mileage in Class 3
Demonstration and Systems Integrity and several representatives of State and 4 locations turned out to be low
Inspection Pilot Programs, we studied pipeline safety agencies. (See DOT because it was based on earlier data.
and evaluated comprehensive and Docket No. 7666 for summaries of the Natural gas transmission pipeline
integrated approaches to safety and meetings.) We also have met separately operators were required to include in
environmental protection. These with Western States Land their 2001 annual reports the
approaches incorporated operator- and Commissioners, National Governors breakdown of their onshore pipeline
pipeline-specific information and data Association, National League of Cities, mileage by class location, but this
to identify, assess, and address pipeline National Council of State Legislators, information was not available at the
risks, in conjunction with compliance Environmental Defense Fund, Public time the preliminary draft analysis
with existing pipeline safety Interest Reform Group, and Working discussed with the TPSSC was
regulations. From these programs, we Group on Communities Right-To-Know. prepared.
also expanded our knowledge of the On February 12–14, 2001, RSPA/OPS RSPA/OPS has modified the cost
extent and variety of internal inspection held a public meeting in Arlington, VA, benefit analysis to use the industry-
and other diagnostic tools that on integrity management in high reported mileage in classes 3 and 4.
hazardous liquid pipeline operators use consequence areas for natural gas Because the industry regularly
in their integrity management programs. pipelines. At this meeting, reports on determines the classification of its lines,
We also learned of the wide variability the status of industry and government industry is in a better position than
in the extent and effectiveness of activities on how to improve the RSPA/OPS to estimate the amount of
programs in use by operators to support integrity of gas pipelines were featured this mileage. RSPA/OPS is aware that
management of pipeline integrity. and meeting attendees participated in there may be some discrepancy both
Additionally, based on risk in-depth discussions on the integrity of between RSPA/OPS and operators and
management principles, RSPA/OPS gas pipelines. The reports can be found among operators as to how to calculate
implemented a systems approach in the DOT docket (#7666) and the Class 3 locations. The variation in the
through a new high impact inspection RSPA/OPS Web site under Initiatives/ manner in which class 3 locations are
format that evaluates pipeline systems Pipeline Integrity Management Program/ calculated involves the concept of
as a whole, rather than in small Gas Transmission Operators Rule. clustering of buildings intended for
human occupancy in identifying pipe will require them to perform segment Electronic Discussion Forum
segments subject to the requirements identification for their lines. This would RSPA/OPS also used an electronic
associated with class 3 locations. The be an unnecessary cost if the discussion forum from June 27 through
presence of individual isolated distribution company intends to assess August 13, 2001, titled ‘‘More
buildings within a sliding mile segment all transmission lines they operate. Information Needed on Gas Integrity
will count to raise the classification of RSPA/OPS intends that operators Management Program’’ to help promote
the segment to Class 3. The question is choosing to classify their entire system
discussion of these issues. The
whether the immediate area around the as Class 3 or 4 without regard to
electronic forum listed all the areas
isolated building should be routinely population density will be allowed to
where we had asked for comment so
classified as a Class 3 cluster. RSPA/ do so without having to do segment
that commenters could easily focus on
OPS does not believe that these isolated identification according the provisions
those areas of interest to them. A
buildings are commonly included as of the rule. However, these operators
transcript of the electronic discussion
Class 3 clusters and does not intend this will not be relieved of requirements to
forum is included in the docket.
proposed rule to result in a change of evaluate the risk-based priority of
existing practice in this regard. segments in developing assessment Comments to Notice on Integrity
The committee questioned whether schedules. Management Concepts and Hypotheses
RSPA/OPS intends to use the HCA The committee expressed some (Gas Transmission Pipelines)
definition as the starting point for concern that the approach being taken
Comments to the docket were
identifying segments requiring in the rule will lead to doubling
additional integrity assurance measures, protections on pipeline segments near provided by one state, five industry
and to allow use of the potential impact population groups, since existing associations (including one association
zone to reduce the length of pipe subject regulations already require lowering of industrial gas consumers), sixteen
to the IMP Rule. Committee members pipe stress levels in Class 3 and 4 companies or groups of companies that
expressed concern both as to the locations. RSPA/OPS acknowledges this operate gas pipelines, one company that
appearance of leaving out some portions point, but notes that a significant operates hazardous liquid pipelines,
of HCAs and at the costs of including consideration in our decision to allow a and one company that builds pipeline
protections for areas which do not pose longer reassessment interval than that bridges.
the same risks to population as other for liquid pipelines is that the thicker/ Comments on all elements envisioned
HCAs. With respect to the first point, stronger pipe in areas subject to the for the gas pipeline integrity
the proposed rule includes all pipe integrity management rule lengthens the management concept, except the
segments within HCAs in the time for time-dependent deterioration element defining high consequence
requirements for integrity management. mechanisms to cause significant pipe areas, are summarized below.
However, if the segment is within a deterioration. Comments on the HCA element are
class 3 or class 4 location, but not discussed in a separate proposed rule
Notice on Integrity Management published in the Federal Register on
within the potential impact zone, that
Concepts and Hypotheses (Gas January 9, 2002 (67 FR 1108). RSPA/
is, the segment is in a moderate risk
Transmission Pipelines) OPS recently finalized the definition of
area, the proposed time for completing
the baseline assessment will be On June 27, 2001, RSPA/OPS issued HCAs (67 FR 50824; August 6, 2002).
extended to 13 years. RSPA/OPS a notice of request for comments (66 FR Scope
expects that during the next seven to ten 34318) that stated the objective in
years, many companies will choose to developing a rule on gas pipeline In the notice we indicated that we are
make many segments in Class 3 integrity management and described the considering applying the gas integrity
locations piggable in their entirety and scope and the elements of an eventual management concept to all gas
new technology will be available to gas integrity management rule. We transmission lines and support
minimize the cost associated with described seven elements that should be equipment, including lines transporting
assessing these segments. However, an included in any integrity rule to fulfill petroleum gas, hydrogen, and other gas
option RSPA/OPS is considering is to our objectives. We used similar products covered under part 192.
not require any assessment of segments elements to those employed in The American Gas Association (AGA)
located within a Moderate Risk Area, structuring the liquid integrity and American Public Gas Association
but, rather, to require enhanced management rules. Those seven (APGA) commented that the integrity
preventive and mitigative measures on elements were then elaborated upon rule should apply to gas transmission
these segments. Our premise is that if through a set of hypotheses that we pipelines operating at or above a hoop
houses are mostly clustered in one area discussed in detail in the notice. The stress level of 20% SMYS. These
of a Class 3 rectangle, a pipeline failure notice invited comment about these commenters said the rule should also
in an area beyond the cluster (i.e., in the elements and hypotheses. not include pipelines in commercially
moderate risk area) may have little, if In addition, the notice summarized navigable waterways or environmentally
any, impact on the area with the cluster the areas where RSPA/OPS was seeking sensitive areas because Congress did not
of homes. RSPA/OPS desires further information to support direct this coverage. They also said
information on this option, and development of the proposed integrity RSPA/OPS should give special
underlying assumptions, along with any management program rule for gas consideration to pipelines operating at a
cost information related to the proposed operators. The information needs were hoop stress between 20% and 30%
rule. organized under the seven elements that SMYS. Because these lines fail by leak
Committee members representing we saw as essential to any integrity rather than by rupture, different
distribution companies expressed management program rule, and under assurance methods should be
concern that they currently treat all two other categories where additional considered.
their lines as Class 3 or 4 to avoid costly information was needed to evaluate the This proposed rule covers gas
excavation and replacement of pipes effect of an integrity management transmission pipelines, including
when population densities increase. rulemaking on costs and gas supply, pipelines transporting petroleum gas,
They are concerned that this decision both seasonally and regionally. hydrogen, and other gas products
covered under Part 192 in the high (2) Complete documentation of all earlier, this proposed rule expands the
consequence areas. The definition for a risk factor data used to support the current HCA definition, by presenting
transmission line is found in section program; requirements to improve the integrity of
§ 192.3. This proposed rule does not (3) A state-of-the-art data integration pipelines located near people living at
apply to gas gathering lines or to gas process; distances greater than 660 feet from
distribution lines. (4) A process that explicitly develops large high pressure pipelines. This
lessons learned from assessment of proposed expansion is based on the
Performance-Based Option covered pipe segments and applies need to provide the same level of added
Numerous companies argued that we these lessons to pipe segments not protection to population groups, as the
should allow a performance-based covered by the Rule; HCA definition provides to facilities
option because a purely prescriptive (5) A process for evaluating all that house people who are confined,
rule would not allow companies to incidents, including their causes, within difficult to evacuate, or of impaired
effectively and cost beneficially address the operator’s sector of the pipeline mobility, and to areas where people
the unique features of their systems. industry for implications both to the congregate. The number of buildings
integrity of the operator’s pipelines and intended for human occupancy within
We are proposing a minimum set of to its integrity management program; the potential impact circle is discussed
criteria for an operator to qualify for a (6) A documented performance under the proposed rule section of this
performance-based option. Operators history that confirms the continuing preamble. The basis for identifying the
who satisfy this minimum set of criteria performance improvement realized physical area where concentrations of
will be eligible to deviate from certain under the performance-based program; people are located so additional
requirements—the time frame for and protective measures can be applied is
remediating anomalies identified during (7) The extensive set of performance discussed below.
the assessment, the conditions for using measures documented in the operator’s
direct assessment as a primary performance plan (ASME B31.8S, The Size of the Zone That Could Be
assessment method and the Section 9) are accessible to state and Impacted by a Gas Pipeline Rupture
reassessment interval (for example, the federal regulators. These measures and Explosion
reassessment interval for on a segment would be updated by the operator on a Since existing regulations provide a
assessed by the DA method could be frequency consistent with its basic level of protection, the primary
extended to ten years). However, even if performance plan. focus of the integrity management
an extended interval were allowed, the rulemaking is on reducing the
operator would still have to conduct a Define the Areas of Potentially High likelihood of a gas release in areas
confirmatory direct assessment in the Consequence where the potential consequences are
seventh year of the interval. We are In the FR notice of June 27, 2001, we greatest. The HCA definition includes
incorporating these performance-based said the first element of the integrity areas where a pipeline lies within 660
considerations because RSPA/OPS management concept involves defining feet of a building housing people who
recognizes that improving pipeline the areas where the potential would be difficult to evacuate (e.g.,
integrity can only be accomplished consequences of a gas pipeline accident hospital, school, retirement facility) or
through operators improving their may be significant or may do where 20 or more people congregate at
understanding of the condition of their considerable harm to people and their least 50 days in any 12-month period.
piping and taking appropriate action property. In a rule issued on August 6, The area is expanded to 1000 feet if the
based on this understanding. Operators 2002, we defined these high pipeline is greater than 30 inches in
who excel in these aspects of integrity consequence areas. (67 FR 50824). The diameter and operates at pressures
management should have limited definition of high consequence areas greater than 1000 psig. In addition, in
flexibility in making key integrity (HCAs) includes: (a) Current Class 3 and this proposed rule we are expanding the
management decisions. 4 Locations; (b) pipe segments in the HCA definition by proposing to include
The proposed conditions an operator area that would be impacted by a a new component of high concentration
would have to satisfy before being potential pipeline rupture where there of buildings (as discussed above)
allowed to deviate from some of the is a facility housing people who are intended for human occupancy beyond
program’s requirements include— confined, have impaired mobility or are 660 feet. The 1000-foot limit was based
1. The operator must have completed difficult to evacuate (e.g., hospital, on a mathematical model (developed by
church, school, prison, day care facility, C–FER under INGAA funding) that
a baseline assessment of all covered
retirement facility; and (c) pipe describes a heat affected zone following
segments and at least one other
segments near areas where a specified a pipeline rupture. This heat affected
assessment. Problems identified in the
number of people congregate on a zone is bounded by a ‘‘potential impact
second assessment must be remediated.
specified number of days per year (e.g., radius.’’ This model includes numerous
Also the results and insights from the
camping grounds, outdoor recreational assumptions on the size and orientation
second assessment must be incorporated
facility). The defined areas were those of the pipe rupture, the physical
into the operator’s risk model.
that would be impacted by a potential behavior of the jet issuing from a
2. An operator must also demonstrate pipeline rupture, 300, 660 or 1000 feet ruptured pipeline (the pipeline is
that it has an exceptional integrity from the pipeline depending on the assumed to fail by a double-ended
management program. To demonstrate diameter and operating pressure of the rupture), the time of ignition of the gas
this an operator must show that its pipeline. jet, the rate of decay in the flow of gas
program meets the performance-based issuing from the pipeline, the dominant
requirements of ASME/ANSI B31.8S, RSPA/OPS Decision on Using Potential heat transfer mode, and the criterion for
has a history of measurable performance Impact Radius in the HCAs determining the radius within which
improvement, and includes, at This proposed rule presents physical damage results from the heat
minimum: requirements to improve the integrity of from a burning gas jet. Given the
(1) A documented state-of-the-art risk pipelines located in areas of potentially complexity of this analysis and the
analysis process; high consequences. As discussed scope of assumptions needed, the only
way to validate the adequacy of the incorporate significant preventive Because corrosion can occur either
resulting mathematical relationship was measures), but do not eliminate the internally or externally, it essential that
to compare its predictions of potential need for operators to consider all major gas pipeline operators consider both
impact radius with actual observed burn threats to pipeline integrity. In addition, threats.
zone following historic gas pipeline we said that human error can influence We believe this threat-by-threat
ruptures. This comparison was carried any or all of these threats and therefore analysis is necessary not only because it
out using the C–FER model which must be considered as a potential will require the operator to assemble
successfully predicted the radius of the contributing factor to each threat. and use a comprehensive set of risk
burn zone surrounding ruptured gas For the gas pipeline IMP proposed factor data to identify the presence of
pipelines. rule, we decided to propose that the potential threats, but also because it will
operator make a threat-by-threat support determination of the assessment
Incorporating Mathematical approach or approaches needed to
Formulation Describing the Heat analysis of the entire pipeline. Such an
analysis will require identification and characterize the significance of these
Affected Zone Into the Rule threats.
evaluation of the significance of threats
We are proposing to require operators to pipeline integrity, which must Our concept of integrity management
to calculate the potential impact radius necessarily involve the integration of also includes the following hypotheses:
within the HCA. This potential impact numerous risk factors. Such risk factors (1) Pipeline segments having threats that
radius would be used to identify the include, but are not limited to, pipe represent higher risks should generally
areas within HCAs where the characteristics (e.g., wall thickness, be assessed sooner than those with
consequences of a rupture would be coating material and coating condition; threats that represent lower risk and (2)
greatest. An operator would first focus pipe toughness; pipe strength; pipe Pipelines that operate at a stress level
any additional integrity measures on fabrication technique; pipe elevation less than 30% SMYS fail differently
concentrations of people or hard to profile); internal and external (i.e., leak rather than rupture) from those
evacuate buildings or areas where environmental factors (e.g., soil operating at higher stress, therefore,
people congregate within the impact moisture content and acidity, gas different integrity assurance techniques
radius, then on the rest of the HCA. operating temperature and moisture may be appropriate. We have discussed
Using more realistic criteria to define content); operating and leak history this issue elsewhere in this document
areas where an operator would focus (e.g., pipe failure history, past upset and have requested comment.
additional integrity assurance measures conditions that have introduced
will allow an operator to better allocate Comments on RSPA/OPS Hypotheses
moisture into the gas); land use (e.g.,
its resources toward areas that need the INGAA provided many comments on
active farming, commercial
greatest protection. This approach will this hypothesis. The primary source of
construction, residential construction);
particularly benefit operators of small- information referenced by INGAA was
protection history (e.g., corrosion
diameter, low pressure pipelines, where the technical reports prepared by their
protection data, history of third party
the range of impact following a potential contractors during the eighteen month
hits and near misses, effectiveness of
rupture would be small. This approach interaction among INGAA, RSPA/OPS
local One Call systems); and the degree
would also benefit the public because and the states on technical issues, and
of certainty about the current condition
operators of very large diameter, very the consensus standards currently in
of the pipeline (e.g., age of the pipe,
high pressure pipelines would have an preparation. These reports are available
completeness of integrity-related
increased impact radius to consider for in the Docket. Comments from INGAA
records, available inspection data).
evaluating where additional integrity included the following:
The RSPA/OPS data on causes of gas INGAA offered the opinion that laws
assurance measures are required.
transmission pipeline accidents (i.e., should be enacted to support strong
Identify and Evaluate the Threats to threats to the pipeline) show that One-Call Programs. It also pointed out
Pipeline Integrity in Each Area of between 1990 and1999, there were total that seam cracking in pre-1970 ERW
Potentially High Consequences 777 reported accidents. The causes of piping has been observed only in piping
The second element of integrity these accidents are broken down as from certain manufacturers. Not all pre-
management discussed in the FR notice follows: 1970 pipe has that problem.
of June 27, 2001, involves identification —319 (41%) were due to outside force INGAA also expressed the opinion
of potential threats to the pipeline. In damage (30% third party, 11% earth that soil erosion is not a significant
the notice we mentioned one approach quakes/floods, and other outside direct threat to pipeline integrity,
suggested by industry in our past forces); however it may lead to increased
discussions was to divide potential —173 (22%) were due to corrosion (105 importance of third-party damage when
threats to pipeline integrity into three (14%) internal, 67 (9%) external); it results in shallow cover. In addition,
categories: Time dependent (including —119 (15%) were due to construction it noted that some materials and
internal corrosion, external corrosion, and material defects; and construction techniques are more
and stress corrosion cracking); static or —166 (21%) were due to other causes. susceptible to damage from massive soil
resident (including defects introduced The data indicates that the two movement than others, and that this
during fabrication of the pipe or greatest threats to a pipeline are from issue is treated more completely in
construction of the pipeline); and time- outside force damage (41%), and ASME B31.8 S which was under
independent (including third party corrosion (22%). Our data also shows development at the time of the
damage and outside force damage; this there are more failures from internal comment, but has subsequently been
threat category was called ‘‘random’’ in corrosion than from external corrosion. issued.
the FR notice). These three categories The internal corrosion is caused by On the subject of operator error,
are adopted here primarily to focus moisture and acidity present in the gas INGAA noted that performance
resource allocation decisions on useful transmission lines at low or near low measures are needed to evaluate the
strategies to improve integrity (e.g., points. The rupture of the gas importance of this threat to pipeline
integrity management for the ‘‘time- transmission pipeline in Carlsbad, New integrity. Lessons learned from observed
independent’’ category clearly must Mexico resulted from internal corrosion. operator errors should then be
translated into improvements in susceptibility to failure of each pipe pipeline rupture, technologies that look
operating procedures and segment that could affect an area of for evidence of past damage after the
communicated among operators. potentially high consequences: threat has occurred should be focused in
Effective management of change and • An integrity baseline needs to be areas where delayed failure is most
quality control/assurance programs will established for all pipe segments that likely.
also reduce the likelihood of operator could affect an area of potentially high • Threats related to human error will
error contributing to pipeline failure. consequences. An operator will need to be addressed largely, but not
Consensus standards were under evaluate the entire range of threats to completely, through the new Operator
development at the time of the INGAA each pipeline segment’s integrity by Qualification Rule. The integrity
response on qualification and analyzing all available information management rule will require operators
certification of individuals involved in about the pipeline segment and to evaluate the impact of operator error
analyzing in-line inspection (ILI) consequences of a failure on a high on the primary threats to pipeline
results. INGAA expressed concern about consequence area. Based on the type of integrity.
the increased demand for ILI services threat or threats facing a pipeline
potentially leading to lengthened time segment, an operator will choose an Comments
requirements by ILI vendors to produce appropriate assessment method or INGAA summarized the capability of
assessment reports, with related methods to assess (i.e., inspect or test) pipeline in Classes 3 and 4 for using
implications to the ability of the each segment to determine potential internal inspection tools as follows:
industry to meet repair and mitigation problems. 24.4% is easily piggable, 25.3% can be
requirements. • Time dependent threats will require easily made piggable, 45.9% would be
On the subject of gas storage field periodic inspection to characterize very costly to make piggable, and 4.4%
pipeline systems, INGAA stated that changes in their significance. cannot be pigged.
those in high consequence areas should • Acceptable technologies for INGAA provided a set of examples of
be treated in the same way as natural assessing integrity include in-line situations and conditions which may
gas transmission pipelines. inspection, pressure testing and direct adversely impact the accuracy of results
AGA/APGA also noted that the assessment. None of these technologies, from the indirect processes used in
process for managing pipeline integrity individually, is fully capable of external corrosion direct assessment.
should not be affected by the operating characterizing all potential threats to These include:
stress level. Lower stress pipeline pipeline integrity. (Note: RSPA/OPS is • Rocky backfill with little or no soil
operators should be required to develop co-sponsoring with industry an around the pipe.
and follow integrity management evaluation of direct assessment • Very dry, cracked soil where little
programs having the same elements as technology to determine the conditions soil contact is made with the pipe.
operators of higher stress pipelines. under which direct assessment is • High-dielectric coatings (such as
Only the tools and techniques used to effective in assessing external corrosion. polyethylene tape) that have the
assess the pipeline and the reassessment The effectiveness of direct assessment in propensity to shield the pipe from the
intervals should require customization. assessing other threats (e.g., internal flow of cathodic protection current,
NYGAS indicated that it is important corrosion, stress corrosion cracking) is where no orifices to the soil/water
to ensure that staff conducting and also under evaluation for validation. interface are present.
analyzing results from assessment of • Unless the operator demonstrates • Resolution and sensitivity of survey
pipeline integrity be qualified. In the by evaluation that they are not a threat equipment.
cases where the operator qualification to the integrity of a pipe segment, static • Correct selection of the proper
rule does not apply, operators must threats will require pressure testing at diagnostic tool matched to the
ensure proper qualification of these some time during the life of the suspected integrity threat.
people, and monitor performance pipeline. If significant cyclic stress, • Bare or unprotected pipelines.
measures designed to reveal potential such as that caused by large pressure INGAA stated that data from the
problems with personnel qualification. fluctuations, is present, then pressure ongoing external corrosion direct
NISource commented that there needs testing, or an equivalent technology, assessment process development effort
to be a clear means of identifying a will be required periodically throughout will need to be combined with data
threat as ‘‘significant.’’ the life of the pipeline. If operating from application of the process over
In aggregate these comments are conditions for a pipeline with potential time to allow statistical analysis
consistent with the RSPA/OPS seam problems from manufacture are to describing reasonable confidence bands.
decisions to require threat-by-threat be changed significantly, then the A preliminary model was presented
analysis of the pipelines and to pipeline must by pressure tested prior to by INGAA that describes the use of the
acknowledge the differences in failure the change of operation. four step direct assessment process in
mode for pipe operating at stress levels • Time-independent threats will assessing a pipeline for SCC. This
below 30% SMYS by imposing require the use of two parallel integrity description relies heavily on the
somewhat different requirements for management approaches. The vast assembly and integration of risk factor
these lines. majority (over 90%) of ruptures caused data that could indicate the possible
by time-independent threats occur at the presence of SCC. These risk factor data
Select Appropriate Assessment time that the activity takes place (e.g., are presented in the appendix of ASME
Technologies when the excavator hits the pipeline), B31.8S.
The third element of integrity and not at some later time. Therefore, AGA/APGA commented that not all
management discussed in the June 27, the use of risk management practices (or pipelines should be required to be
2001 FR notice, involves identification technologies) to prevent damage or to pressure tested for manufacturing or
of potential threats to the pipeline in immediately identify the potential for construction defects at sometime during
areas of concern. In the notice we used damage would be more effective than their lifetime. For example, a pipeline
the following hypotheses to support looking for evidence of past damage. should not require pressure testing if it
selection of the assessment technologies Secondly, since some time-independent has not experienced leaks during its
best suited to effectively determine the threats do not result in immediate lifetime. This argument assumes that
operation of the line is not subjected to measures, other than pigging, pressure should not be defined in an overly
pressure cycling of sufficient magnitude testing and direct assessment. An AGA prescriptive manner.
and frequency to produce growth of paper, dated April 26, 2001, on AGA/APGA summarized the strengths
existing cracks. AGA/APGA does ‘‘Integrity Management for Low Stress and limitations of pressure testing and
support existing requirements to Pipelines’’ (copy filed in the Docket) in-line inspection. They noted that all
pressure test all new pipelines before further expands on these alternate forms of integrity testing will have some
operation. technologies and mitigation measures. impact on gas supply reliability, and
AGA/APGA commented that that severe constraints or cut-off will be
pipelines operating at hoop stress levels AGA/APGA indicated that direct required with pressure testing.
between 20% and 30% SMYS, where assessment is: (a) Currently being The following table was developed by
the failure mode is leakage not rupture, validated and imbedded in a NACE AGA/APGA on miles of member
should be allowed to use assurance consensus standard; (b) being evaluated companies with various assessment
technologies, including mitigation for application to bare pipelines; and (c) capability.
Temp Extensive
Currently Cannot be
Miles in conversion for retrofit for pigged 2
Company membership piggable
classes 3&4 pigging pigging 1
(in percent) (in percent)
(in percent) (in percent)
AGA ...................................................................................... 13,500 12 10 43 35

APGA ................................................................................... 3,000 13 ........................ 41 46
1 Retrofit costs range from $5,000 to $250,000 per mile.
2 Costs range estimated to be from $1M to $8M per mile to replace pipe (in urban areas).
The Florida Public Service customer supply of pigging and pressure assessment as an alternative assessment
Commission recommended that both testing. technology.
magnetic flux leakage (MFL) pigging NYGAS further commented, with Comments from the public and the
and pressure testing be carried out at supporting analysis from Kiefner and pipeline industry generally supported
intervals of five to seven years, not to Associates, that under typical cyclic RSPA/OPS’s approach in developing
exceed ten years. They also indicated loading conditions, the fatigue life of a this proposed rule. The commenters
that Florida gas pipes are typically less gas pipeline operating at stresses of 72% generally agreed that the proposed rule
than twelve inches in diameter and SMYS is 100 to 400 times longer than should include: (1) A threat-by-threat
therefore should be inspected at ten year hazardous liquid pipelines, and that analysis of each pipeline segment; (2) at
intervals. lowering the operating stress level to least one pressure test during the life of
Pacific Gas & Electric Company below 30% SMYS will increase this a pipeline to characterize its
(PG&E) also indicated that increased factor to between 900 and 3600. susceptibility to material and
leak patrol frequency should be used to Therefore, pressure testing at some time construction defects, unless the operator
minimize the threat of leakage from pipe during the life of a low stress pipe can justify why a pressure test is not
segments operating at low hoop stress should not be required. NYGAS also necessary; (3) periodic assessment of
(e.g., less than 30% SMYS). noted that experience has demonstrated each pipeline segment for third party
PG&E commented that pipe segments ILI technologies do not perform damage (denting), unless the operator
operating at low stress levels should not satisfactorily at pressures below 400 psi. can justify why such assessment is not
be required to conduct a pressure test NISource commented that it does not necessary. A decision to forgo periodic
once in the pipeline life, but rather believe an integrity baseline needs to be assessment must address loading
operating history should be used to established for all pipe segments. In conditions (e.g., cyclic loading), pipe
validate material strength. They also particular, low stress pipelines have a susceptibility to delayed failure (e.g., at
noted they found direct assessment to ‘‘baseline’’ established through Edison, NJ), and pipe exposure to
be a good tool to identify residual third application of the exiting regulations potential third party damage; and (4) a
party damage. description of how to apply direct
and monitoring for evidence of leaks.
assessment, including the conditions
PG&E noted that they do consider Current practices identify the physical
under which it is not appropriate, and
erosion to be one of the Outside Forces conditions which increase the potential
conservative criteria for pipe excavation
that needs to be considered, and they for gas accumulation resulting from a
for direct examination.
conduct annual erosion surveys to leak, and the presence of these
support mitigative action where erosion conditions leads to increased Baseline Assessment and Remediation
is identified. monitoring. The fourth element of integrity
PG&E summarized the reasons why The Association of Texas Intrastate management discussed in the June 27,
some of its pipe is not piggable because Natural Gas Pipelines commented that it 2001 FR notice, related to the baseline
of the presence of one or more of the would be useful if the rule spelled out assessment and remediation time frame.
following: telescopic construction, the process by which new assessment To determine time frames to conduct a
random diameter construction, sharp technologies would be approved by baseline integrity assessment and to
radius bends, and less than full opening RSPA/OPS. complete remediation following an
valves. Several operators expressed concern assessment using an approach that
NYGAS commented that local about their ability to de-water a pipe prioritizes pipeline segments based on
distribution company (LDC) segment that is not piggable following a risk, we used the following hypotheses:
transmission lines are typically sole pressure test. Inability to de-water • The time frame for conducting the
source lines and are closely coupled to would lead to increased likelihood of baseline assessment should be based on
the distribution system. These facts will internal corrosion. This fact supports a graded or tiered approach where
greatly increase the cost and impact on the advisability of allowing direct pipeline segments are prioritized for
assessment according to the level of risk less than 139% of MAOP but above This time frame is consistent with the
they pose. Thus, highest risk segments 110% of MAOP should be repaired on baseline time frame we were
would be scheduled for assessment first, a defined schedule, and (c) those with considering based on our study of the
lowest risk last. A schedule for taking a with a safe operating pressure of relevant influencing factors. The law
remedial action on the pipeline segment greater than 139% of MAOP require further requires that at least 50% of
after the assessment would also be interval monitoring. Interval monitoring facilities in high consequence areas
based on risk factors. implies reassessment on a ten year must be assessed no later than 5 years
• The time frame for conducting the interval to assure that sub-critical from enactment. This requirement is
baseline assessment should, among anomalies will not fail during that time. also consistent with what we were
other factors, consider the impact on gas AGA/APGA commented that factors considering. Our proposal incorporates
supply to residents. This could also be considered in determining the time these requirements.
a factor in determining if a variance frame for the baseline assessment The factors we considered relevant to
from the required time frame is should include scope of the rule (i.e., establishing the time frame for an
warranted. only above 20% SMYS), availability of operator to conduct the baseline
• The sequence in which the pigging equipment, availability of assessment include:
segments are prioritized for assessment properly qualified people, and the • The desire to establish an integrity
should be determined by considering impact on the gas supply. Considering baseline for all affected pipe segments
information such as, how much pipe is these factors, they believe that a as quickly as possible.
in areas of potentially high minimum of ten (10) years should be • The ability of the gas pipeline
consequences, which of these pipe allowed to complete the baseline service industry to expand both its
segments represent the highest risk, assessment, with half of the pipeline assessment equipment, and, of equal
which threats for these segments completed within five years and importance, its qualified technical staff.
represent significant risks, how much variances available for those unable to • The ability of the pipeline industry
time will be needed to develop the meet the schedule. to gather and integrate risk factor data
infrastructure to perform the required AGA/APGA agree that repairs should
necessary to characterize the
assessments (e.g., validate the required be scheduled to reflect the seriousness
significance of threats to pipe integrity.
assessment technologies, develop of the defect. However, engineering
consensus standards for the application distinctions among the gas pipeline • The time required for the pipeline
of these technologies, expand the systems dictate that the highly industry to modify its lines to
industry capability to deploy and prescriptive approach to repair accommodate in-line inspection
effectively use these technologies to requirements in the Large Liquid equipment.
assess pipeline integrity). If the Pipeline Operator Rule is inappropriate. • The impact on critical gas supply
assessment finds potential problems, the RSPA/OPS should consider the and the associated impact on the price
schedule for making the repairs would guidance on repair and mitigation being of natural gas. INGAA recently funded
also be based on risk factors. developed by the ASME/ANSI B31.8S. a study to evaluate the supply and
The Association of Texas Intrastate consumer cost impacts associated with
Comments on Baseline Assessment and Natural Gas Pipelines commented that it various baseline assessment intervals.
Remediation would be useful if RSPA/OPS included The study did not include the actual
INGAA commented that several a special provision for assessment cost of modifying the pipeline to
practical factors will influence the time interval for new pipe segments or accommodate ILI equipment, and the
frame for completing a baseline replaced pipe segments. study assumed operators would
assessment. These include time for: (a) PG&E supported a ten year baseline perfectly coordinate their assessment
Program development (suggested, 18 assessment period. PG&E commented activities to minimize the impact on
months); (b) assembly and analysis of that practical considerations (e.g., long- customers. The study included supply
risk factor data (suggested, 18 months); lead materials, construction difficulties, impacts resulting from modifying a
(c) limitations on the availability of and economies of scale) should be pipeline to accept ILI equipment and
assessment tools from vendors; and (d) considered in developing assessment from the assessment activity itself.
potential detrimental impacts on supply schedules to ensure that economic Supply impacts associated with
to critical customers. Given these efficiencies can be realized while remediation or repair of defects
factors, INGAA estimated that the satisfying the intent of any rule that the discovered during the assessment were
shortest time for completing baseline highest risk segments be assessed first. not included. The study included
assessments would be about ten (10) Enron commented that a ten year differences in the supply impacts
years after promulgation of the rule. baseline assessment interval seems associated with different assessment
Even if ten years were allowed, INGAA appropriate, and that reassessment in technologies.
estimated in an early analysis that the class 1 and 2 locations should be on the The INGAA analysis found that
economic cost to customers over the ten same interval, but that reassessment in consumer cost impact was more
year baseline assessment period would Class 3 and 4 locations should be on a significant with short baseline
range from $3.9 to $6.1 billion. fifteen year interval. Enron also strongly assessment periods than with longer
INGAA reported that repair time urged RSPA/OPS to allow operators to times. The cost impacts in the current
frames should consider the results of a carry out repairs consistently with analysis were estimated to be $7.2B for
recently completed analysis by Kiefner existing procedures rather than a 14-year baseline period, $13.1B for a
and Associates in which the allowable imposing a prescriptive repair time 10-year baseline period, and $20.1B for
repair time is related to the calculated frame. a 5-year baseline period. Although not
(or pressure tested) safe operating Baseline assessment factors: The quantifiable in the model, the potential
pressure. Three categories were defined: recent pipeline safety law (Pipeline for critical supply interruptions,
(a) Segments with a safe operating Safety Improvement Act of 2002) resulting from the need to perform
pressure of 110% of MAOP or less requires that an operator conduct a assessments during high demand
should be repaired immediately, (b) baseline assessment not later than ten periods and the increased difficulty of
those with a safe operating pressure of years from the date the law is enacted. coordinating assessments on lines
feeding the same customers, increases as 2002) which provides for a baseline features beyond those required by
the baseline period decreases. assessment ‘‘not later than 10 years’’ regulation. The process involves
• Class location requirements. The after the law’s enactment, with 50 % establishment of a budget for additional
gas pipeline safety regulations have having to be assessed ‘‘not later than 5 safety enhancements and allocating that
class location requirements that the years’’ after enactment. As noted earlier, budget based on some structured form
liquid regulations do not. As population RSPA/OPS is proposing to require of risk assessment process, including
increases near a pipeline, the class operators choosing direct assessment feedback on potential risks from people
location requirements require technologies to undertake extra in the field.
establishment of an additional margin of excavations and direct examinations The conclusions of two INGAA-
safety. To comply with class location during the period while validation is sponsored reports on the value of RCVs
requirements, gas transmission pipeline continuing. and ASVs include:
operators maintain data on the number Our proposal on the baseline 1. Neither RCVs nor ASVs will reduce
of residences and other buildings assessment also allows for an fatalities or injuries to the public.
located near their pipelines. Based on assessment conducted five years before 2. Neither control valve system will
threshold levels of near-by dwellings the law’s enactment or date the final significantly reduce property damage.
and buildings, operators are required to rule is effective, whichever is earlier, as 3. RCVs and ASVs increase the
constrain the maximum stress level in a baseline assessment if it satisfies the likelihood of service disruption (RCVs
the pipeline to successively lower levels specified assessment criteria. If an in particular).
as the number of dwellings increases. operator chooses this option, under our 4. RCVs and ASVs can reduce the
When a class location changes to a proposal, the operator would then have amount of product lost.
higher class, an operator must reduce to begin complying with the 5. Costs for RCVs or ASVs outweigh
the stress level on the line either by requirements for reassessment of the measurable benefits.
reducing pressure, or in some cases, by segment. According to INGAA, the only
replacing the pipe. If an operator substantive benefit of RCVs and ASVs is
Identify and Implement Additional that they result in faster valve closure
replaces the pipe, an operator may use
thicker walled or higher strength pipe to Preventive and Mitigative Measures following an incident.
ensure that the capacity of the pipeline The fifth element of integrity Air Products and chemicals, an
is not reduced. management discussed in the June 27, operator of 700 miles of pipeline for
The result is that, while gas pipelines 2001, FR notice, related to identification transporting industrial gas such as
in locations of potentially high and implementation of additional hydrogen, currently uses twenty-five
consequence typically operate at stress preventive and mitigative measures. We excess flow valves along the 150 miles
levels of 40% SMYS (Class 4) or 50% used the following hypotheses in the of pipe it operates in what it considers
SMYS (Class 3), corresponding liquid notice: to be high consequence areas. These
pipelines typically operate at 72% • Assuring a pipeline’s integrity valves were added as a result of its risk
SMYS. A higher stress is typically requires more than simple periodic analysis process.
associated with thinner walled piping or inspection of the pipe. Most threats, GPTC noted that it expects ANSI to
a smaller margin to failure for a given including passive threats such as third publish a technical report describing
defect size. Therefore, time dependent party damage, require active industry practices and ideas for
threats such as external corrosion, management to prevent challenges to managing integrity this Fall and
which occur at a rate dependent on integrity. Therefore, active integrity requests that RSPA/OPS consider
factors such as soil chemistry, coating management practices are necessary. information in this document as part of
integrity and cathodic protection Some operators already go beyond the its Rulemaking effort.
effectiveness, have less wall thickness to current pipeline safety regulations by Remote Control Valves (RCVs)
penetrate before a critical defect depth implementing integrity management
is reached and the pipeline ruptures. practices such as ground displacement In response to a Congressional
The lower stress levels and thicker walls surveys, soil corrosivity analysis, gas mandate following the March 1994 gas
of gas pipelines imply that, other factors sampling and sampling and analysis of transmission pipeline failure at Edison,
being equal, corrosion would take liquid removed from pipelines at low NJ (Accountable Pipeline Safety and
longer to penetrate to a critical depth. points. Partnership Act of 1996; codified at 49
These factors support a baseline • Preventive and mitigative measures U.S.C. 60102(j)), RSPA/OPS surveyed
assessment interval of ten years for include conducting a risk analysis of the and assessed the effectiveness of
operators using in-line-assessment or pipeline segment to identify additional remotely controlled valves (RCVs) on
pressure testing, with at least 50% of the actions to enhance public safety. Such interstate natural gas pipelines. We
covered segments (the higher risk actions may include, damage prevention examined the technical and economic
segments) being assessed within five practices, better monitoring of cathodic feasibility of RCVs to rapidly shut down
years. However, for operators using protection, establishing shorter a gas transmission pipeline after a
direct assessment as the primary inspection intervals, and installing rupture.
assessment technology, we are Remote Control Valves (RCVs) or RSPA/OPS conducted a public
proposing a baseline assessment interval Automatic Shut-Off Valves (ASVs) on meeting in October 1997 to gather data
of seven years to account for the early pipeline segments. Some operators, on the technical and economic
state of development of these processes particularly hydrogen pipeline feasibility of installing RCVs. There was
and to allow time to develop data on operators, have voluntarily installed general agreement by the meeting
their validity. The highest risk half of ASVs on their pipelines closer together participants, and in written comments
the segments being assessed by direct than required as a mitigative measure. following the meeting (contained in
assessment will, however, be assessed Docket No. RSPA–97–2879), that RCVs
during the first four of these seven Comments are technically feasible, but are not
years. This proposal is consistent with INGAA described a general process economically justifiable from a cost-
The Pipeline Safety Improvement Act of used by operators to make decisions on benefit standpoint. This result is
2002 (HR 3609, signed into law Dec. 17, adding risk control or mitigation because most casualties and property
damage occur within ten minutes after So that RSPA/OPS may understand the • The periodic evaluation is based on
a pipeline rupture. Although an RCV basis on which operator decisions are an information analysis of the entire
can be closed within two or three made, we will require operators to pipeline.
minutes to isolate a pipeline section, a document their decision processes and
Comments
safe condition is not achieved until the decision criteria for RSPA/OPS review
gas between valves has either escaped or during inspections. Measures to be INGAA’s comments included a
burned off, which is almost always a considered by operators will include discussion of the results of a Battelle
longer time period than ten minutes. those practices set forth in ASME analysis on assessment intervals. The
These findings from the public B31.8S, as well as use of RCVs and analysis indicated that while the
meeting were reinforced by the results ASVs. While these two types of valves recommended reassessment interval in
of a Gas Research Institute (GRI) study have been analyzed generically for gas their report was developed based on the
of 80 gas transmission pipeline failures pipelines, RSPA/OPS believes that each assumption that operators would use
over a twelve year period which showed operator should consider the merits of thicker pipe to address the Class
that quick closure of valves could have installing these mitigative measures at Location requirements, the
prevented only one injury out of a total critical locations on their pipelines and recommended interval would not be
of 28 fatalities and 116 injuries. make installation decisions based on affected if operators chose to use higher
We closely monitored a one year field pipeline-specific and site-specific strength pipe (rather than thicker pipe)
evaluation of 90 RCVs installed by evaluations. to comply with changes in class
Texas Eastern Transmission Company, location.
mostly in New Jersey and Pennsylvania. A Process for Continual Evaluation and In addition, INGAA offered the
The RCVs’ reliability was demonstrated Assessment To Maintain a Pipeline’s opinion that the series of new integrity
by the fact that there were no unplanned Integrity management regulations will lead to a
closures of the valves during the year The sixth element of integrity situation in which the demand for
and, of the 200 plus valve cycles management discussed in the June 27, assessment equipment and people
executed remotely, the valves closed 2001 FR notice, related to the process qualified in its use and in interpretation
100 percent of the time on the first for continual evaluation and assessment of results will outpace the supply. This
attempt. of pipelines to maintain their integrity. factor should be considered in
RSPA/OPS completed a study in We used the following hypothesis in the determining the baseline and
September 1999 titled ‘‘Remotely notice: reassessment interval requirements.
Controlled Valves on Interstate Natural Operators should continually evaluate INGAA recommended that RSPA/OPS
Gas Pipelines,’’ available in Docket and reassess at the specified interval solicit information from direct
RSPA–97–2879. The study shows that each pipeline segment that could affect assessment service providers to evaluate
installing and using RCVs can an area of potentially high consequence the ability of the service providers to
effectively limit the time required to using a risk-based approach. The respond to the requirements for
isolate ruptured pipe sections when evaluation considers the information the increased assessment included in the
manual valve operation is not feasible, operator has about the entire pipeline to new IMP Rules.
thereby minimizing the consequences of determine what might be relevant to the AGA/APGA urged RSPA/OPS not to
certain gas pipeline ruptures. The study pipeline segment. require reassessment on a prescribed
supports RCVs’ effectiveness, technical • Managing a pipeline’s integrity interval. Intervals should be dictated by
feasibility, and potential for reducing requires periodic reassessment of the analysis using accepted risk principles
risk. The study indicates that the pipeline. The time frame appropriate for along with results from the baseline
quantifiable costs of RCV installations this reassessment depends on numerous assessment. If a prescriptive
would almost always exceed the factors. In the current class location requirement on reassessment interval is
benefits. change regulation, gas pipeline needed, then RSPA/OPS should allow
However, we believe that significant operators are required to replace pipe operators to deviate from that interval if
risk exists at some locations as long as segments with thicker-walled or it can justify such a deviation.
gas is being supplied to a rupture site, stronger pipe (or to decrease pressure) NYGAS commented that local
and operators currently lack the ability as the near-by population increases distribution companies (LDCs) need
to quickly close existing manual valves. above threshold levels. This greater flexibility in managing repairs
Any fire would be of greater intensity, requirement for thicker-walled or and mitigative action than is implicit in
and would have greater potential for stronger pipe in areas of higher the repair provisions of the liquid
damaging surrounding infrastructure, if population might indicate that a longer operator rule for operators with 500 or
the fire were replenished with gas over reassessment interval would be more miles of pipeline. The absence of
a protracted period of time. Therefore, appropriate where corrosion is the such flexibility will lead to gas supply
we held another public meeting in dominant threat. interruptions to customers.
November 1999 to consider the need for • If critical risk factor data are not RSPA believes that once the baseline
a rulemaking to establish time limits for available to support evaluation of risks, assessment has been completed, the
isolating ruptured sections of gas then the reassessment interval should be availability of qualified vendors and
transmission pipelines. No new data appropriately shortened to reflect that assessment equipment are no longer
were presented at the hearing to absence of knowledge. factors, since it is quite likely that the
establish critical locations where RCVs • If an operator has developed a pipeline service industry will expand to
should be installed. comprehensive picture of past and meet the new higher level of demand. In
Consistent with the hypotheses anticipated threats, including detailed addition, the major line modifications
prepared earlier, RSPA/OPS decided to information on risk factors and records required to accommodate in-line
incorporate a provision in the rule of multiple assessments carried out over inspection (ILI) equipment should be
requiring operators to evaluate the several years, the operator might be able completed. Some of the factors
potential value of a spectrum of to justify a longer reassessment interval influencing reassessment intervals are
preventive and mitigative measures, and (see the discussion above on discussed above under baseline
to act on the results of this evaluation. performance-based requirements). intervals. Other factors that influence
the periodic reassessment interval established a longer interval, conduct a The recently published standard
include: confirmatory direct assessment by the ASME B31.8S discusses operator
• The stress level at which the seventh year with a follow up performance plans in Chapter 9. This
pipeline operates; reassessment in the year the operator discussion describes four measures that
• The growth rate of corrosion sets. Our proposal takes into account the are required to be monitored by all
defects; and factors we have discussed above. operators using the standard. These
• The repair criteria used in measures are:
remediating defects discovered in Monitor the Effectiveness of Pipeline
• Number of miles of pipeline
previous assessments. Integrity Management Efforts
inspected (assessed) versus program
Figure 7–1 and Table 8–1 in ANSI/ The seventh element of integrity requirements;
ASME B31.8S sumarize the relevant management discussed in the June 27, • Number of immediate repairs
factors for determining a reassessment 2001 FR notice, related to monitoring completed as a result of the integrity
interval. The corrosion rates reflected in the effectiveness of pipeline integrity management inspection program;
these charts represent the high end of management activities. We used the
historically observed corrosion, but are • Number of scheduled repairs
following hypothesis in the notice: completed as a result of the integrity
not the highest rates that might be • Measures can be developed to track management inspection program; and
experienced under special conditions, actual integrity performance as well as
such as the presence of • Number of leaks, failures and
to determine the value of assessment incidents (classified by cause).
microbiologically influenced corrosion and repair activities. RSPA/OPS is proposing to require
(MIC). Table 8–1 relates the • Application of integrity
recommended reassessment interval in operators to track and record these four
management technologies that exceed
years to the stress level of the pipe (% overall performance measures, and
current regulations is cost effective
SMYS), the type of assessment carried make them electronically accessible (in
because many companies made the
out, and the significance of defects left real time) to RSPA/OPS for review. In
decision to implement such programs.
in the pipeline following mitigation or addition, RSPA/OPS proposes to require
repair. For a typical pipe segment in a Comments operators to develop performance plans
Class 3 Location, the stress level would INGAA suggested that RSPA/OPS consistent with ASME B31.8S, and to
be 50% SMYS. At this stress, if a should consider including the following define the extended set of measures that
pressure test were carried out at 1.39 performance measures: it will track. OPS will be able to review
times the maximum allowable operating • Number of miles of pipeline these measures during periodic field
pressure (MAOP), then the inspected under IMP. inspections. Appendix SP–A of ASME
recommended reassessment interval • Repairs: B31.8S tabulates suggested measures for
would be 10 years. This same 1. Number of immediate repairs each threat to which a pipeline might be
recommended reassessment interval completed as a result of the IMP subject.
would result if ILI were used and all inspection program; and Consideration of Impact on Gas Supply
defects were repaired that had a 2. Number of scheduled repairs
predicted failure pressure below 1.39 completed as a result of the IMP The eighth consideration of integrity
times the MAOP. The recommendations inspection program. management discussed in the June 27,
for reassessment intervals following use • Number of leaks, failures and 2001 FR notice, related to the impact of
of direct assessment are closely related incidents (classified by cause). the rule on gas supply. Performing an
to the details of the excavation criteria AGA/APGA suggested that RSPA/OPS assessment test on gas transmission
used in examining indications. The should work with stakeholders to pipelines has the effect of restricting gas
intervals shown in (Table 8–1 in ASME develop performance measures flow. Unless adequate time is allowed
B31.8S) are based on technical analysis immediately after promulgation of the and the assessment process is carefully
of time-dependent failure mechanisms integrity management rule. managed, this flow restriction can
(e.g., external corrosion). Additionally, in using these measures, significantly impact gas supply and cost
The recently-enacted pipeline safety RSPA/OPS must avoid inappropriate to customers.
law (HR 3609 signed into law Dec. 17, comparisons of performance among Different assessment technologies
2002) requires that reassessment be operators with vastly different systems. have different restrictions on gas
done at minimum intervals of seven- NYGAS stated that performance supply. In-line-inspection merely
years. Thus, in our proposed rule, we measures should be properly used to restricts flow for the relatively short
have established a seven-year interval, monitor the effectiveness of integrity time when the instrumented internal
but we also allow the operator to management efforts within individual inspection device (pig) is in the pipe.
establish the intervals depending on the companies, not to compare the However, preparing the pipe to make it
assessment method. Depending on the performance among operators. able to be internally inspected
assessment method, the maximum The Association of Texas Intrastate (piggable), requires termination of the
interval an operator is allowed to Natural Gas Pipelines commented that it gas flow in the segment being tested
establish could be longer than seven would be useful for RSPA/OPS to while modifications are made. At
years. However, if the period is longer establish performance measures that present over 75% of gas transmission
than seven years, the operator would relate to each operator’s integrity lines are not piggable or can be made
have to conduct an interim reassessment management plan, rather than requiring piggable only with extensive
by confirmatory direct assessment by one-size-fits-all reporting requirements. modifications. Pressure testing requires
the seventh year and then conduct the Enron commented that if RSPA/OPS termination of gas flow in the section
follow up reassessment in the year the were to increase the time for required being tested each time it is carried out.
operator has established. Thus, in the submission of written pipeline incident Direct assessment requires flow
seven-year period an operator must reports by an additional sixty days, then restriction (associated with lowering the
either reassess a covered segment using there would be an opportunity to pressure as a safety measure) while
the assessment method the operator has include better information on the selected locations along the pipe are
chosen, or if the operator has evaluated cause of each incident. being excavated and directly examined.
We indicated above that assessing Discussions on the INGAA Report on restrictions. Examples include recent
pipelines using any of the technologies ‘‘Consumer Effects of the Anticipated price spikes in the States of California
under consideration may result in a Integrity Rule for High Consequence and New York. These capacity
restricted gas supply because of the Areas’’ (February 2, 2002) restriction effects were the focus of the
need to take pipelines out of service or On April 3, 2002, RSPA/OPS held a study. No account was taken of the cost
by reduction in throughput. In addition, meeting with INGAA, Energy and incurred by operators making lines
some types of repairs will also require Environment Associates (EEA), the piggable, although the capacity impacts
lines to be taken out of service. If an Volpe Center, and DOE to discuss the associated with these maintenance
upstream segment of this gas INGAA report on ‘‘Consumer Effects of activities were considered.
transmission pipeline were put out of Other key assumptions in the analysis
the Anticipated Integrity Rule for High
service temporarily for test or repair, include: (1) 80% of mainline pipe and
Consequence Areas’’ (February 2, 2002).
many communities located at the end of 50% of laterals/connections will be
The meeting was designed to allow
branch lines, could be negatively inspected (these numbers are supported
RSPA/OPS, and several reviewers by consideration of the distribution of
impacted by the restricted gas supply. retained by RSPA/OPS, to explore the
This effect would be caused by the fact segments that can affect HCAs
reasonableness of the results in the throughout the pipeline systems and by
that the lines are often sole source feed, INGAA-sponsored report. The focus of
(i.e., have no other tie-in’s from an the fact that even operators using direct
discussion was on the assumptions assessment as their primary assessment
alternative source.) Because of this made in the analysis. The report was
factor, the proposed rule allows a approach will be required to reduce
produced in response to the initial need pressure in long segments of their lines
waiver of a reassessment interval greater to understand the supply and economic
than seven years, if the operator during the direct examination step of
implications of allowing or disallowing the process). (2) Effects on consumers
demonstrates that it cannot maintain direct assessment as a primary
local product supply, and OPS with limited options and flexibility in
assessment technology, and later was gas providers will be much more severe
determines that a waiver would not be expanded to evaluate the supply and
inconsistent with pipeline safety. This (e.g., Florida has one transmission line,
economic implications of various with a second to come in service this
proposal is consistent with the baseline assessment intervals ranging
provision in the Pipeline Safety summer. Load factor on the line is
from 5 to 15 years. greater than 80% and any interruptions
Improvement Act of 2002. Because a The report focuses on interstate
waiver requires public notice and would have significant downstream
transmission pipelines. INGAA effect, and therefore cost impacts). It
comment, we are proposing 180-day indicated the industry expects that most
advance notification. was noted by INGAA at the meeting that
HCA mileage will lie in Class 3 and 4 gas supply interruptions are not as
INGAA Report Locations, and that approximately 5% routinely buffered by storage capacity as
of pipeline is in class 3 and 4 locations, liquid petroleum products, which are
INGAA commissioned an extensive but that the HCA definition will include normally stored in tanks. (3) The
analysis of the economic impact of a gas some pipe segments in other locations industrial sector is more elastic than the
IMP rule. The analysis, performed by as well. INGAA said that Class 3 and 4 residential sector. Demand there was
Energy & Environment Analysis, Inc., Locations are scattered throughout the adjusted significantly when gas prices
evaluated this impact using various pipeline system so they appear in about were high over the last couple years. (4)
assumptions on the fraction of the 60% of valve stations and 80% of the The analysis assumes that the impact of
affected pipe that is currently not discharges from compressor locations. supply restrictions occurs at the time
piggable that will be assessed by INGAA further stated that a periodic the restriction occurs rather than at a
pigging, pressure testing, or direct inspection program was useful only to later time, as would occur because of
assessment. The time frame during identify the presence of dynamic failure long-term supply contracts. (5) Both
which the baseline assessment must be mechanisms or threats (i.e., corrosion). pipeline capacity and demand are
performed was also a parameter in the They questioned the value of periodic assumed to increase, as described in the
analysis, varying from five to fifteen assessment of pipelines for static threats base case of ‘‘The Pipeline and Storage
years. While (at the time of the INGAA (i.e., material and construction) or Infrastructure for a 30 Trillion Cubic
comment—August 14, 2001) sufficient random threats (e.g., third-party Feet (TCF) Market’’ better known as the
detail was not available to evaluate the damage). ‘‘30 TCF study.’’
credibility of the analysis and its The reviewers at the meeting The TCF study uses the EEA Gas
underlying assumptions, the estimated requested clarification of the study Market Data and Forecasting System.
economic impact on gas consumers for assumption regarding the fraction of This model was developed in 1995
the ten year baseline period is large, lines that are assumed to be in-line- requiring over ten person years of effort.
ranging from $3.9 billion to $6.1 billion. inspected. Scenarios 1, 2 and 3 in the The model is rigorously calibrated to
(Note, this analysis and a peer review of report assume segments described as actual historical behavior. Price
report performed by the Volpe National ‘‘currently piggable’’ and ‘‘relatively differences are calculated as a function
Transportation Systems Center (Volpe easy to make piggable’’ are treated as of load factor. The calibration is
Center) and the Department of Energy ‘‘easy to pig’’ (i.e., about 50%). The updated annually.
(DOE) have recently been completed other scenarios, 3A, 3B and 3C in the The model is a fairly coarse one in
and are discussed below). report assume that only ‘‘currently which multiple supply lines between
AGA/APGA commented that some piggable’’ segments are treated as ‘‘easy market centers are modeled as a single
forms of assessment (e.g., pressure to pig’’ (i.e., about 25%). This difference line. However, the model appropriately
testing) would require outages from 3 to in assumptions complicates comparison considers the effects of capacity
9 days. Customers would in some cases between Scenarios 1, 2 & 3 and restrictions in one line in a corridor, and
be without gas during that time, and Scenarios 3A, 3B & 3C. EEA stated that does not assume that a single line out
restoration of gas supply would require market evaluations do show that there of service terminates supply through the
extensive work, for example, re-lighting are capacity choke points and that spot corridor in which it resides. This effect
pilot lights of each affected customer. market prices respond to capacity is treated separately from the model and
provided as an input to the model. The and property damage over the past potential economic impact of
inputs to the model are developed fifteen years, but did not provide any interruptions in gas supply to industrial
assuming perfect communication among information on the impact of incidents concerns that rely on gas in the conduct
operators with lines in a single corridor, and leaks on the cost of gas to of their business.
or supplying a single market center such customers.
Conclusions From the Consumer Cost
that operators do not take multiple lines INGAA provided preliminary
Impact Evaluation
out of service that would compound the information on the estimated costs of
impact on capacity restriction at that inspection of all transmission pipelines Consumer cost and supply availability
market center. Taking multiple lines out for three different scenarios on are major factors in establishing the
of service in a single corridor might be inspection of hard-to-pig (HTP) period for operators to complete the
necessary, if the baseline assessment pipelines. These preliminary costs baseline assessment. There are
interval were sufficiently short to include estimates to convert HTP numerous assumptions made in the
require such action. segments to make them piggable. The INGAA study. In general they are
As the market becomes thinner (i.e., inspections were assumed to be carried designed to underestimate the predicted
supply is restricted relative to demand out over a ten year period. cost impact. For example, the study
at a market center) consumers bid does try to optimize time of testing, and
against each other causing spot market Consumer assume infinite availability of pig
prices to rise. Costs developed in the Scenario description cost for 10 vendors and equipment. However, there
model may be overstated over a 10-year years period are also assumptions in the study that
(millions) would lead to prediction of higher cost
period, because all consumers do not
pay spot prices. As pipelines are re- 1⁄2 HTP portion pigged, 1⁄2 HTP impact than might realistically be
contracted, however, those costs will be portion DA ............................. $3,892 expected. For example, the study does
reflected in the new contracts. 1⁄2 HTP portion pigged, 1⁄2 HTP not assume learning on the part of the
In response to questions about why portion Hydro ........................ 6,095 operators, and the analysis reflects
pipe assessments carried out prior to the 1⁄3 HTP portion pigged, 1⁄3 HTP
marginal costs rather than contracted
rule currently being considered have not portion DA, 1⁄3 HTP portion costs.
strongly affected gas prices, INGAA DA ......................................... 4,048 The EEA analysis found that
indicated that people who currently consumer cost impact was more
administer active pigging programs The numbers in this table were significant with short baseline
represent only about 25% of the total updated through the completed INGAA/ assessment periods than with longer
pipeline mileage and implemented their EEA analysis discussed above. times. The cost impacts were estimated
programs over about a 20 year period. On the question of small business to be $7.2 billion for a 14-year baseline
INGAA said that in response to the impacts, INGAA noted that no more period, $13.1 billion for a 10-year
anticipated rule, operators would have than 50,000 miles of approximately baseline period, and $20.1 billion for a
to assess a significant fraction of their 274,000 miles of natural gas 5-year baseline period. Although not
systems (the segments covered by a rule) transmission pipelines (and probably quantifiable in the model, the potential
over ten years. The associated supply much less) could be owned by small for critical supply interruptions,
impacts and consumer costs will businesses. Also, many of the resulting from the need to perform
therefore be much larger. contractors likely to be involved in assessments during high demand
The reviewers at the meeting inspections are small businesses. periods and the increased difficulty of
suggested it would be very useful if Finally, the potential exists that coordinating assessments on lines
INGAA would summarize all major increased gas costs will impact small feeding the same customers, increases as
assumptions and discuss the direction business customers. the baseline period decreases.
and approximate magnitude (e.g., small AGA/APGA strongly suggested that
medium, large) of the effect of each RSPA/OPS develop the integrity rule for RSPA’s Conclusions About the INGAA
gas transmission pipelines around a Study
assumption on the resultant cost impact.
INGAA agreed to consider how best to performance-based approach. From its review of the INGAA study
respond to comments raised during the The Florida Public Service RSPA concluded that—
meeting and in the review documents Commission noted that performance Study Performers. The organization
that had been prepared in advance by type regulations can only work if that performed the study for INGAA is
Volpe and DOE reviewers. For detailed operators are willing to share recognized as an expert in the type of
discussion on this subject see minutes information on both performance and analysis performed. This conclusion is
of this meeting in the docket. potential problems with the regulators. supported by the fact that EEA has been
They believe that the risk management called to testify on significant supply
Other Issues Including Those Related to demonstration program has shown the issues before Congress, and that the gas
Cost/Benefit operators are unwilling to openly share pipeline industry is using the results of
The ninth consideration of integrity needed information. the study on which the present impact
management discussed in the June 27, The New York Gas Group strongly analysis is based as a major factor in
2001 FR notice, related to other issues supports the development of a expansion decisions.
including those related to the cost/ performance-based rule that will allow Study Conservatism. The peer review
benefit analysis. companies the flexibility needed to identified several assumptions used in
manage the risks associated with their the analysis in which it would lead to
Comments pipelines, as effectively as possible. over-prediction of the gas supply and
INGAA commented that RSPA/OPS They asserted that this position is cost impacts, as well as some areas
should perform its cost-benefit analysis supported by the NY State Public where the model would be expected to
starting with current industry practices Service Commission staff. result in under-estimation of these
(as described in recent INGAA reports) The Process Gas Consumers Group impacts. In balance, the model together
as the baseline. They also provided (PGC) commented that RSPA/OPS with its major assumptions seems to
some data on the number of incidents should give strong consideration to any produce a reasonable, possibly an
underestimate, of the anticipated supply operator-supplied information to map church, school, prisons, day care
and cost impacts. the high consequence areas that it facility); or where there is evidence that
Baseline Assessment Time Frame. defines in a gas integrity management 20 or more people congregate at least 50
The decision on a baseline assessment rule, similar to how it is mapping these days in a year (e.g. beach, camping
interval must reflect the need to areas for the liquid operators. A separate ground, religious facility). The full text
expedite pipeline assessment without rulemaking on mapping will address of the HCA definition can be reviewed
dramatically impacting gas availability this issue. in the Federal Register document
and price. The INGAA/EEA analysis referenced above.
supports the conclusion that a ten-year Treatment of Storage Fields An identified site can be identified by
baseline assessment requirement is Storage fields have provided a source one of several means listed in the rule:
consistent with managing supply and of pipeline integrity problems for it is visibly marked, it is licensed or
cost impacts resulting from the new decades. RSPA/OPS asked for registered, it is on a list or map
assessment requirements. The predicted information to help identify the cause of maintained by or available from a
impact on consumer energy cost and prevent piping-related failures Federal, State or local agency or a
associated with this baseline time frame associated with storage fields that could publicly or commercially available
is $13.1 billion. While this is a very affect high consequence areas. INGAA database or it is know by public
large cost, it represents a small stated that those in high consequence officials. RSPA/OPS is inviting
percentage impact on total gas costs areas should be treated in the same way comment on whether we should use the
over the time period of the analysis. as natural gas transmission pipelines. term public safety officials ( e.g. Police,
RSPA has concluded that a ten-year The proposed rule requirements will Fire department) and/or emergency
baseline assessment period, with 50% of include pipelines within the storage response officials instead of public
covered segments being assessed within fields because under § 192.3(c) such officials. Currently, pipeline operators
five years, will allow the impact on gas pipelines are defined as transmission are required to conduct liaison activities
supply and cost to be adequately lines. with public safety officials or emergency
managed by the operators. The Proposed Rule safety officials. We would like comment
on whether the term ‘‘public safety
Mapping RSPA/OPS is proposing a officials or emergency response official’’
We stated in the proposed rule on modification to section 192.761 and will cover the persons having the
high consequence areas (67 FR 1108; addition of a new section 192.763 to relevant information about these
January 9, 2002), that RSPA/OPS is subpart M: High Consequences Area identified sites.
creating the National Pipeline Mapping Definitions and Integrity Management On September 5, 2002, the American
System (NPMS), a database that Programs. The § 192.761 titled Gas Association (AGA), the American
contains the locations and selected ‘‘Definitions’’ defined ‘‘high Public Gas Association (APGA), the
attributes of natural gas transmission consequence areas’’ in a recently issued Interstate Natural Gas Association of
lines and hazardous liquid trunk lines final rule (67 FR 50824; August 6, 2002); America (INGAA), and the New York
and liquified natural gas facilities and proposed a new section 192.763 Gas Group (NYGAS) filed a petition for
operating in the United States. ‘‘Pipeline Integrity Management in High the reconsideration of the final rule on
RSPA/OPS will require operators to Consequence Areas’’ is described in this the definition of HCAs for gas
provide their pipeline data by a separate rule. transmission pipelines (67 FR 50835;
rulemaking on mapping. Submission of August 8, 2002). This petition is in the
this information has been voluntary in High Consequence Area Definitions—
§ 192.761 docket. The petition raised the
the past. At present, RSPA/OPS has following issues.
received data on pipe locations for 90% The definition of high consequence (1) The splitting of the gas integrity
of liquid pipelines but only 52% of gas areas recently published in the Federal rule into two rulemakings—the
pipelines. Currently, RSPA/OPS has no Register (67 FR 50824; August 6, 2002) definition and the integrity
data on areas of higher population includes: (a) Current Class 3 locations; requirements—causes confusion,
density (Class 3 and 4 locations) (b) current Class 4 locations; (c) an area particularly, since the Potential Impact
associated with gas pipelines. Present that extends 300 feet from the centerline Zone concept was not included in the
gas pipeline regulations are structured of the pipeline to the identified site for definition.
to provide increasing levels of a pipeline not more than 12 inches in (2) The HCA definition should clarify
protections, consistent with diameter and having a maximum that it applies to those gas transmission
predetermined thresholds. Accordingly, operating pressure lower than 1200 psig; pipelines that have the potential to
gas pipeline operators are required to (d) an area of 1000 feet from the impact high population density areas
monitor data on the number of centerline of the pipeline to the and does not apply to distribution
dwellings within 660 feet of their identified site for a pipeline greater than pipelines.
pipelines to either lower operating 30 inches in diameter operating at a (3) The identified site component
pressure or to replace the pipe with one pressure greater than 1000 psig; (e) an (buildings and outside areas) is overly
having greater wall thickness or strength area that extends 660 feet from the broad. The definition should instead use
as the number of dwellings increases centerline of the pipeline to the the language in 192.5.
above predefined threshold. RSPA/OPS identified site for all other pipelines. RSPA/OPS believes issuance of this
therefore believes that operators have The areas of 300, 660 and 1000 feet are proposed rule will alleviate most of the
excellent data on population and places corridors that have been determined concerns raised in the petition. As
where people congregate near their based on generalized estimates of previously discussed, the HCA rule only
pipelines. potential rupture consequences. An defines general areas of high
Maps incorporating these data would identified site is defined as a building consequence. It includes corridors
be useful not only to pipeline operators, or outside area that can be identified by (lateral distances of 300, 660, and 1000
but also to federal and state inspectors one of several means and that houses feet), but not axial distances along the
and for local officials and community people who are difficult to evacuate or pipeline. The axial distances can only
needs. RSPA/OPS intends to use have impaired mobility (e.g., hospital, be determined by analysis of potential
impact zones which are covered in this of integrity improvement requirements the threshold radius on either side of
proposed rule. We have put the for those pipe segments. The approach the centerline of the pipe. For greater
proposed potential impact zones involves the six steps that rely on the clarity see the diagram in Appendix E.
definition under the same section definitions below: (1) Identify all HCAs Threshold Radius—Threshold Radius
192.761, where HCAs are defined. for the pipeline using the HCA is a bounding radius intended to
The petitioners argued it would be definitions as expanded by this provide an additional margin of safety
difficult to identify a building or outside proposed rule; (2) calculate the Potential beyond the distance calculated to be the
area that is frequented by 20 or more Impact Radius (PIR) for each segment in potential impact radius. If the calculated
persons on at least 50 days in any 12- the pipeline; (3) determine the potential impacted radius is less than
month period, and would include Threshold Radius associated with the 300 feet, the operator must use a
isolated and infrequently occupied PIR for each segment; (4) identify threshold of 300 feet. If the calculated
buildings. RSPA/OPS does not know Potential Impact Circles for the pipeline; potential impacted radius exceeds 300
how many rural buildings would be (5) identify Potential Impact Zones (PIZ) feet but is less than 660 feet, the
covered by the HCA definition or how for the pipeline and in Class 3 and Class threshold is 660 feet. If the calculated
many miles of pipeline segments would 4 locations, identify the moderate risk potential impacted radius exceeds 660
have to be added to the assessment areas; and (6) determine the priority of feet, but is less than 1000 feet, the
plans to include these buildings which each segment covered by this proposed threshold is 1000 feet. And, if the
are populated for a short time relative to rule—covered segments located within a calculated potential impact radius
the other populated areas. We are trying potential impact zone are considered exceeds 1000 feet, the threshold is 15%
to focus on high risk areas for higher priority, whereas those located greater than the actual calculated
assessment. Instead of including rural outside a PIZ are considered lower impacted radius.
buildings, such as rural churches as priority.
High Consequence Areas, we could The following proposed definitions Pipeline Integrity Management in High
designate them as Moderate Risk Areas help to understand these six steps: Consequence Areas—Proposed Section
requiring less frequent assessment or Potential Impact Circle (PIC)—PIC is 192.763
requiring enhanced preventive and a circle of radius equal to the threshold The proposed new § 192.763 titled
mitigative measures only. We would radius used to establish higher priority ‘‘Pipeline integrity management in high
like public comment on this issue. We areas within HCAs. A potential impact consequence areas’’ imposes integrity
are proposing to define a Moderate Risk circle contains any of the following (for management program requirements on
Area as an area located within a Class greater clarity see the diagram in all gas transmission pipelines covered
3 or Class 4 location, but not within the Appendix E): under Part 192 that impact high
potential impact zone. • 20 or more buildings intended for consequence areas.
This proposed rule presents human occupancy within a circle of The proposed rule requires an
requirements to improve the integrity of radius 1000 feet, or larger if the operator of a transmission line to
pipelines located in areas of potentially threshold radius is greater than 1000 develop and follow an integrity
high consequences that go beyond those feet; management program that provides for
HCAs. The proposed IMP rule proposes • A facility that houses people who continually assessing the integrity of all
to expand the definition of HCA by are difficult to evacuate as defined in pipeline segments in the high
adding consideration of people living at § 192.761; or consequence areas using internal
distances greater than 660 feet from • A place where people congregate as inspection, pressure testing, direct
large diameter high pressure pipelines. defined in § 192.761. assessment or other equally effective
Populated areas at distances less than Potential Impact Radius (PIR)—PIR assessment means. The proposed rule
660 feet are already accounted for under means the radius of a circle within further requires that the program
Class 3 and 4 locations, however, which the potential failure of a pipeline provide for evaluating the entire range
populated areas beyond 660 feet were could have significant impact on people of threats to the integrity of each
left out of the HCA final rule of August or property. PIR is determined by the pipeline segment through
6, 2002 (67 FR 50824). In this proposed formula r = 0.69 * (square root of comprehensive information analysis.
rule, we are adding a new proposed (p*d2)), where ‘‘r’’ is the radius of a Further, for each covered pipeline
HCA component of populated areas in circular area surrounding the point of segment, the operator must provide
paragraph 192.761 (g). We are proposing failure (ft), ‘‘p’’ is the maximum additional protection to a pipeline
to require that an operator consider 20 allowable operating pressure (MAOP) in segment’s integrity though remedial
or more buildings intended for human the pipeline segment (psi), and ‘‘d’’ is actions and enhanced preventive and
occupancy within an potential impact the diameter of the pipeline (inches). mitigative measures.
circle of radius 1000 feet or larger. We (Note: 0.69 is the factor for natural gas.
calculated that 20 buildings within a This number will vary for other gases (a) Which Operators Must Comply?
circular area of a 1000-foot radius depending upon their heat of Proposed § 192.763(a)
represent a resident density equivalent combustion. An operator transporting The rule proposes that any operator of
to 46 buildings within a rectangular area gas other than natural gas must use a gas transmission pipeline must
one mile long and 1320 feet wide Section 3.2 of ASME/ANSI B31.8S to comply with the integrity management
(current Class 3 location definition). calculate the impact radius formula). program requirements.
Therefore, by using 20 or more Potential Impact Zone (PIZ)—PIZ is a
buildings within circular area of radius rectangular area along the pipeline (b) Which Pipeline Segments are
1000 feet we are, including areas having derived from the potential impact circle. Covered? Proposed § 192.763(b)
the same density of population as Class The potential impact zone extends Any gas transmission pipeline located
3 locations. axially along the length of the pipeline in a high consequence area, including
To understand the provisions of this from the center of the first potential transmission pipelines transporting
proposed rule, it is necessary to impact circle to the center of the last petroleum gas, hydrogen, and other gas
understand both the pipe segments contiguous potential impact circle, and products covered under Part 192. Gas
covered by the proposal and the ranking extends perpendicular to the pipe out to transmission is defined in § 192.3, and
includes pipelines within storage fields to change to reflect operating integrity management performance
as transmission lines. Thus, this experience, conclusions drawn from requirements—the time frame for
proposed rule covers pipelines within results of the integrity assessments, and reassessment, as long as a confirmatory
storage fields. Pipeline, by definition, other maintenance and surveillance direct assessment were done every
means all parts of those physical data, and evaluation of consequences of seven years, using direct assessment as
facilities through which gas moves in a failure on the high consequence area. a primary method without having to
transportation, including pipe, valves In addition, the program must evolve to satisfy the pre-conditions and the time
and other appurtenances attached to reflect the best practices used in the frames for remediating anomalies found
pipe, compressor units, metering pipeline industry to assure pipeline during the assessment.
stations, regulator stations, delivery integrity. An operator will have to • Exceptional Performance. To show
stations, holders, and fabricated document any change it makes to its exceptional performance the rule
assemblies. The proposed rule does not program before implementing the proposes that an operator have
apply to gas gathering or to gas change. In addition, if a change is completed a baseline assessment of all
distribution lines. significant enough that it affects the covered pipeline segments, and at least
program’s implementation or one other assessment; remediate all
(c) What Must an Operator Do?
significantly modifies the program, the anomalies identified in the second
Proposed § 192.763(c)
operator must notify OPS within 30 assessment according to specified
The rule proposes that no later than days of adopting the change into its requirements; and incorporate the
one year after the effective date of the program. An initial decision on the type results and lessons learned from the
final rule, each operator is required to of assessment method an operator is second assessment into the operator’s
establish a written integrity going to use is not considered a risk model. An operator would also
management program that addresses the significant change. have to demonstrate that it has an
threats on each pipeline segment that • A plan for baseline assessment of exceptional integrity management
could impact a high consequence area. the pipeline. The plan must identify program that meets the performance-
The operator would then implement segments to be assessed, applicable based requirements of ASME/ANSI
and follow the program it has threats for each segment, method(s) B31.8S, has a history of measurable
developed. Initially, the program would selected to assess each pipeline segment performance improvement, and
consist of a framework. Within one year (including internal inspection tool or includes, at minimum:
after the final rule becomes effective, we tools, pressure test, direct assessment, or (A) A state-of-the-art process for risk
would expect an operator’s integrity other technology that the operator analysis;
management program to consist of: demonstrates can provide an equivalent (B) all risk factor data used to support
• Identification of all pipeline understanding of the condition of the the program;
segments that are in a high consequence line pipe), the basis on which each (C) a state-of-the-art data integration
area as defined in § 192.761 (and assessment method was selected, and a process;
expanded by this proposed rule). It schedule for completing the baseline (D) a process that applies lessons
would also include categorization of integrity assessment. An operator would learned from assessment of covered pipe
whether these segments fall into a also have to show that it is conducting segments to pipe segments not covered
potential impact zone. All segments the assessment in a manner that by this section;
identified will be required to have minimizes environmental and safety (E) a process for evaluating all
enhanced integrity protection. The risks. See also the preamble discussion incidents, including their causes, within
identification of potential impact zones under section 192.763(e). the operator’s sector of the pipeline
is required to determine the length of • A direct assessment plan for industry for implications both to the
baseline assessment intervals for these operators intending to use one of the operator’s pipeline system and to the
segments. Because identification of the direct assessment processes, describing operator’s integrity management
pipeline segments is the trigger for all how these processes will be used, program;
other integrity management including identification of External (F) a performance matrix that
requirements, the identification must be Corrosion Direct Assessment Regions. confirms the continuing performance
done within one year from the final To carry out the requirements of the improvement realized under the
rule’s effective date. When evaluating proposed rule, an operator would, performance-based program;
the consequences of a failure within the where specified, follow the prescriptive (G) a set of performance measures
potential impact zone the operator refer requirements of ASME/ANSI B31.8S, beyond those that are required that are
to Section 3.3 of ASME/ANSI B31.8S for and its appendices, unless the proposed part of the operator’s performance plan
a minimum set of consequence factors rule provides otherwise, or the operator and are made accessible in real time to
to consider. demonstrates that an alternative practice OPS and state pipeline safety
• A program framework that is supported by a reliable engineering enforcement officials; and
addresses each of the required program evaluation and provides an equivalent (H) an analysis that supports the
elements, including continual integrity level of safety for the public and their desired integrity reassessment interval
assessment and evaluation. The property. and the remediation methods to be used
framework is required to document how Performance-Based Option. ASME/ for all pipe segments.
decisions will initially be made to ANSI B31.8S provides the essential
implement each element. To be features of both a performance-based (d) What Are the Elements of an
effective, an integrity management and a prescriptive integrity management Integrity Management Program?
program must constantly change. RSPA/ program. The proposed rule allows an Proposed § 192.763(d)
OPS expects that the initial program operator to use a performance-based The proposed rule requires an
will consist of a framework that approach if the operator satisfies certain operator to include certain minimum
specifies the criteria for making exceptional performance requirements. elements in its integrity management
decisions to implement each of the If the operator satisfies these program that are either specified in the
required elements. The program evolves requirements, the proposal would allow proposed rule or in the ASME/ANSI
from the framework and must continue an operator to deviate from certain B31.8S standard. Initially, an operator
must develop a framework describing of the entire pipeline, evaluates its raised by OPS, including safety
these elements. The framework relevance to each segment within an concerns OPS raises on behalf of a State
describes how each element of the HCA, and estimates the likelihood and or local authority with which OPS has
program will be carried out initially and consequences of a failure. Requirements an interstate agent agreement.
documents expected near-term and guidance on the gathering, review • A process for providing, by
improvements to be implemented to and integration of risk factor data is electronic or other means, a copy of the
these processes. Over time, this provided in ASME B31.8S, Section 4. operator’s integrity management
framework evolves into a program Acceptable approaches to analyzing the program to a State authority with which
description as the operator learns from risks associated with each segment are OPS has an interstate agent agreement.
its experience and that of other presented in ASME B31.8S, Section 5. • A process for ensuring that each
operators, and incorporates that The purpose of this analysis is to utilize integrity assessment is being conducted
knowledge into an ever-improving the best available information, including in a manner that minimizes
process description. The proposed operating experience on the entire environmental and safety risks.
required program elements include: pipeline, to determine the susceptibility One of the most important elements of
• A process for identifying all to failure of each segment to each an integrity management program is
potential threats to pipeline integrity in potential threat, then to estimate the operator qualification. This proposed
each high consequence area. Section 2.2 relative magnitude of the threat so rule requires an operator to verify that
of ANSI/ASME B31.8S standard assessment actions can be prioritized. supervisors possess and maintain a
describes how all significant threats to • A continual process of assessment thorough knowledge of the integrity
the pipeline can be grouped into 9 and evaluation to maintain a pipeline’s management program and its elements
categories. It further regroups these 9 integrity: Reassessment intervals for for which they are responsible.
categories of threats into three types: different assessment techniques, pipe Individuals who qualify as supervisors
time dependent threats (e.g., external stress levels and characteristics of for any aspect of integrity management
corrosion, internal corrosion, stress residual defects (e.g., predicted failure programs must have appropriate
corrosion cracking); stable or static pressure, hydro-test pressure, or DA
training or experience in that area. This
threats (e.g., manufacturing related repair scope) are discussed in ASME
proposed rule requires the operator to
defects (defective pipe seam, defective B31.8S, Section 8, and summarized in
document requirements for these
pipe), welding/fabrication related Table 8–1.
supervisory individuals and others, who
(defective girth or fabrication weld, • Identification of preventive and
are responsible for gathering and
wrinkle bend , etc.), equipment failure mitigative measures to protect the high
interpreting the results of integrity
(gasket, control/relief valve, pump seal, consequence area: ASME B31.8S
assessments.
etc.); and time independent threats (e.g., presents an extensive listing of
third party damage). preventive measures in Section 7. (e) What Must Be in the Baseline
• A baseline assessment plan RSPA/OPS expects each operator to Assessment Plan? Proposed § 192.763(e)
(discussed in § 192.763(e). evaluate the value of instituting these
• Criteria for remedial actions to The proposed rule requires that an
practices in the light of information on
address integrity issues raised by the operator must include in its written
threats posed to each segment and to
assessment methods and information baseline assessment plan each of the
implement applicable and cost-
analysis, (criteria for repair are following elements:
beneficial measures.
discussed in B31.8S, Section 7). These • A performance plan, including • Potential threats to the integrity of
criteria recognize that the nature and methods to measure the effectiveness of each pipeline segment. Candidate
timing of action related to a defect the program: Performance measurement threats are discussed in this section
depend on the severity of the defect. is treated in the discussion of under § 192.763(f).
Some require immediate action, some performance planning in Section 9 of • The method or methods selected to
require mitigation over a prescribed ASME B31.8S, and candidate measures assess the integrity of the line pipe in
period, and some must be monitored to for each threat are presented in the high consequence area. The integrity
ensure they do not represent a future Appendix SP–A. assessment method(s) used must be
threat to the integrity of the pipeline. • A process for review of integrity based on threats to which the segment
ASME B31.8S, Section 7, also assessment results and information is susceptible. More than one method
recognizes that the repair threshold an analysis by a person qualified to and/or tool may be required to address
operator chooses for taking action on a evaluate the results and information. An all the threats in the pipeline segment.
recognized defect is related to the time operator must use qualified persons An operator must assess the integrity of
acceptable before a follow-up with the necessary technical expertise to the line pipe by: internal inspection tool
reassessment is performed. If only very evaluate and analyze the results and or tools capable of detecting corrosion,
small defects are not mitigated in the data from the integrity assessments, the and any other threats to which the pipe
pipe, then a longer time is acceptable periodic evaluation, the information segment is susceptible; pressure test
before reassessment is needed. Repair analyses, etc. Qualifications for these conducted in accordance with subpart J;
criteria in Section 7 of ASME B31.8S people must be documented and records direct assessment in accordance with
reflect the current reality that made available to verify qualifications. the proposed requirements; or other
developing assessment techniques, such • A management of change process, technology that the operator
as direct assessment, are not yet as as outlined in ASME/ANSI B31.8S, demonstrates can provide an equivalent
mature as in-line-inspection and Section 11. understanding of the condition of the
pressure testing. Therefore, operators • A quality assurance process, as line pipe. An operator choosing to use
choosing direct assessment must either outlined in ASME/ANSI B31.8S, the other technology option must notify
excavate all indications, or they must Section 12. RSPA/OPS 180 days before conducting
reassess their pipe at shorter time • A communication plan that the assessment. RSPA/OPS expects an
intervals. includes the elements of ASME/ANSI operator to make the best use of current
• A risk analysis that considers all B31.8S, Section 10, and that includes a and innovative technology in assessing
available information about the integrity process for addressing safety concerns the integrity of the line pipe.
• A schedule for completing the is not feasible, and where only one type evaluate each threat; (2) integrate
integrity assessment. of currently proven direct assessment numerous risk factors; (3) evaluate the
• An explanation of the assessment tool could be used or where pipeline is susceptibility of each affected segment
methods the operator selected and an not easily accessible for direct to each threat; and (4) prioritize affected
evaluation of risk factors the operator assessment. Some examples of such segments in accordance with the ASME/
considered in establishing the applications are, cased piping (i.e., ANSI B31.8S. The minimum sets of data
assessment schedule for the pipeline under either a river or road crossing), needed to evaluate each of the nine
segments. pipe in frozen ground or where bare threat categories are presented in
• For an operator using direct pipe needs to be examined. Two Appendix SP–A of that standard.
assessment, a plan that takes into examples of emerging technologies Data integration requirements in the
consideration the definition of ECDA currently being reviewed and evaluated proposed rule should be satisfied by
and ICDA Regions and the by RSPA/OPS are: (1) Long-range addressing the requirements in ASME/
complementary tools to be used for each ultrasonic testing or guided wave ANSI B31.8S, Section 4. Data
ECDA regions. ultrasonic testing for in-service integration must go beyond risk
• A process describing how the monitoring of corrosion and other metal modeling to include consideration of
operator is ensuring that the baseline loss defects; and (2) ‘‘No-Pig’’ specific locations where combination of
assessment is being conducted in a technology, a tool that can determine these risk factors may lead to increased
manner that minimizes environmental internal and external corrosion of the risk significance. Examples of data
and safety risks (e.g., where would pipeline from above ground. integration are presented in Section 4 of
launchers and receivers be placed; how the referenced standard.
the operator plans to dispose of (f) How Does an Operator Identify Human error analysis required by the
hydrostatic test water; how low point Potential Threats to Pipeline Integrity? proposed rule should follow the
drains would be tested; what extra Proposed § 192.763(f) proposed training requirements.
attention would be given during The proposed rule requires each If piping with certain material coating
excavations.). This proposed operator to identify and evaluate all and environmental characteristics is in
requirement applies to any assessment potential threats to pipeline integrity in an HCA and the assessment shows it to
method the operator uses and to the each area of potential high consequence. be severely corroded, then other similar
reassessments, not just the baseline Threats that an operator must consider piping outside the high consequence
assessment. include, but are not limited to: area must also be evaluated, and
Direction on the analysis of threats, • Time dependent threats such as mitigated as appropriate. This provision
including the data requirements, and on internal corrosion, external corrosion, is critical in ensuring that the
the selection of assessment techniques and stress corrosion cracking; knowledge accumulated in
is provided in ASME B31.8S, Appendix • Static or resident threats such as implementing the integrity management
SP–A. fabrication or construction defects; requirements on pipe segments within
Internal inspection is one of the most • Time independent threats such as HCAs is effectively utilized to improve
useful tools in an integrity management third party damage and outside force integrity throughout the system.
program. Depending on the threats damage; and The following additional
present, RSPA/OPS expects an operator, • The effect of human error. requirements and guidance applies to
with pipelines that are piggable or that The nine threat categories that the assessment process:
can easily be made piggable, to consider comprise the first three general types of • Pipelines exposed to threats that
using geometry tools (for detecting threat are discussed in ASME B31.8S, represent higher risks should generally
changes in circumference) and metal Appendix SP–A. In this Appendix be assessed sooner than those with
loss tools (for determining wall human error is treated as a contributing threats that represent lower risk. Thus,
anomalies, or wall loss due to factor to many of the major threats for the baseline assessment, 50% of
corrosion). Both high resolution and low rather than as a separate threat. For covered segments (the higher risk
resolution metal loss tools can be example, it may be the dominant cause segments) will have to be assessed
beneficial in integrity assessment. For of rupture for third party damage within five years if pressure test,
details of each internal inspection tool, incidents in which the equipment internal inspection or alternative
including their selection, capabilities, operator attempted to locate the equivalent technology is used, and
effectiveness, and use, operators should pipeline before beginning excavation, within four years if direct assessment is
refer to Section 6 of the ANSI/ASME but was given erroneous information used. The determination of which
B31.8S. This standard discusses about the location of the pipeline. In segments are at higher risk should be
corrosion/metal loss tools for internal that Appendix, soil erosion is not made using methods discussed in
and external corrosion threat, crack treated as a separate threat, but viewed ASME B31.8S, Section 5. Here several
detection tools corrosion cracking as a contributor to making the pipe more alternative risk assessment approaches
threat, metal loss or geometry tool for vulnerable to third party damage or are described for use in ranking
third party and mechanical damage outside force damage. Appendix SP–A segments for integrity assessment.
threat. presents detailed prescriptive • Pipelines that operate at a stress
This proposed rule will allow ‘‘other requirements for managing the integrity level less than 30% SMYS fail
technology’’ as one of the four methods of each of the nine threat categories. differently (i.e., leak rather than rupture)
to assess the condition of pipeline These requirements include the from those operating at higher stress.
segments that could impact high minimum data set needed to evaluate Therefore, different integrity assurance
consequence areas. RSPA/OPS expects the presence of a threat, integrity techniques may be appropriate. These
that as these tools are developed they assessment options, responses and low stress pipes have been shown both
may become useful assessment tools or mitigation approaches, assessment by fracture mechanics analysis and by
as complements to direct assessment intervals and candidate performance evaluation of failure experience data to
tools. We expect these tools could be measures. fail by leaking, not by rupture.
used where internal inspection tools The proposed rule also requires each Therefore, the techniques most effective
cannot be used, where pressure testing operator to: (1) Collect data needed to in assuring the integrity of these
pipelines could reasonably involve a • Other technology that the operator susceptibility to third party damage. In
combination of integrity assessment demonstrates can provide an equivalent addition, operators unable or who
techniques and enhanced leak understanding of the condition of the believe it unnecessary to use a geometry
detection. line pipe. An operator choosing this tool must excavate and directly examine
• The proposed rule applies to option must notify RSPA/OPS 180 days indications from ILI runs or from direct
transmission pipelines, as that term is before conducting the assessment. assessment that are suspected of
defined in § 192.5. There may be some The proposed rule requires operators resulting from third party damage. The
transmission pipelines operating at less to evaluate and assess for third party comprehensive preventive measures
than 20% SMYS that are covered by the damage. For gas transmission pipe employed must be documented in the
proposed rule. Pipelines operating at segments in Class 3 and 4 locations, the operators integrity management
that low stress level are unlikely to major cause of failure is third party program, and measures of their
rupture and therefore, pose little risk. damage. This probably results from a effectiveness established and monitored.
We have requested comment on higher level of excavation activity in To address manufacturing and
establishing longer reassessment higher populated areas, combined with construction defects (including seam
intervals for these low stress lines. the fact that thicker and stronger pipe in defects), the rule proposes that an
• As a part of its regular surveillance classes 3 and 4 are less susceptible to operator must a pressure test at least
program operators would have to corrosion failure. The vast majority of once in the life of the segment unless
determine whether new construction third party damage failures the operator can document in its
activity or newly identified recreational (approximately 90%) occur at the time assessment plan why pressure testing is
activity may add pipe segments to those the third party contact occurs. However, not required. At anytime the historic
that can affect an HCA. When such a small fraction of these failures are operating pressure or other stress
conditions are identified, but no less delayed after the initial contact (e.g., the conditions is anticipated to change, then
than annually, the operator must rupture at Edison, New Jersey). the operator must assess the pipeline
reevaluate which pipeline segments can Therefore, some consideration needs to using appropriate assessment
affect HCAs. be given to delayed failures. The technology prior to making the change
primary cause of delayed failure from in operating condition. The methods an
(g) How Is the Baseline Assessment To third party damage is believed to be operator selects to assess low frequency
Be Conducted? Proposed § 192.763(g) cyclic fatigue from pressure cycling. Gas electric resistance welded (ERW) pipe or
The proposed rule requires that an pipelines are not typically subject to lap welded pipe susceptible to seam
operator must select the assessment this type of pressure fluctuation. failures must be capable of assessing
Given the considerations above, it is seam integrity and of detecting
technologies best suited to effectively
clear that lowering the risk associated corrosion anomalies.
determine the susceptibility to failure of
with third party damage requires that The present understanding of the
each pipe segment that could impact an
the third party damage threat must be conditions leading to failure from
area of potentially high consequences.
addressed through comprehensive materials and construction defects has
Assessment tool selection should be
preventive measures. In addition, each improved significantly as a result of
based first on the threats to which a operator must evaluate whether cyclic analyzing failure experience. For
segment is susceptible, and second on fatigue of sufficient magnitude or other example, while some pre-1970 ERW
which assessment techniques can loading condition (including ground piping has experienced failures
reasonably be applied. More than one movement, suspension bridge resulting from seams defects, only
method and/or tool may be required to condition) necessitate a periodic certain manufacturers’’ pipe has
address all the threats to which a assessment for dents and gouges. These demonstrated susceptibility to this type
pipeline segment is susceptible. The evaluations must assume the presence of failure. In addition, a once-in-a-life
order in which assessment is carried out of deep dents, and determine whether pressure test has proven to significantly
must take into account priorities known and anticipated loading lower the likelihood of failure in these
determined by a risk assessment. In conditions would lead to failure of such susceptible pipe segments. Further,
addition, the proposed rule stipulates hypothesized dents. The results of these piping that has not been hydro-tested
that an operator must assess the evaluations together with the criteria has shown susceptibility only when
integrity of the line pipe by applying used to evaluate the significance of this operating parameters are changed
one or more of the techniques below threat must be documented in the significantly. Therefore, careful analysis
depending on the threats to which the operators integrity management plan. of industry operating experience and
segment is susceptible: Operators must assess segments which comparison of the root causes of historic
• Internal inspection tool or tools for are vulnerable to delayed failure failures with the operators pipe will
detecting corrosion and deformation following third party damage using ILI allow operators to determine the risk of
anomalies as appropriate. For guidance tools such as deformation or geometry failure from these mechanisms. Incident
on selecting appropriate internal tools. Direct assessment may be used as root cause analysis also indicates that
inspection tools an operator must refer primary assessment method for third any anticipated increase in operational
to ASME/ANSI B31.8S standard. party damage, if no other approach is pressure will require the operator to
• Pressure test conducted in feasible. Direct assessment has been perform a hydro-test prior to changing
accordance with subpart J of part 192. successfully used to screen piping for operational characteristics. This
• Direct assessment method for the presence of significant residual third requirement applies even if an operator
external corrosion threats, internal party damage, thereby supporting plans to increase operating pressure
corrosion threats, stress corrosion evaluation of the need for additional from the historic level, but not to exceed
cracking, and third party damage (if assessment and focusing on the the MAOP.
other assessment methods are not segments where the use of internal Time period. Each operator must
feasible). This method must be carried inspection tools is most necessary. prepare a baseline assessment plan that
out in accordance with the ASME/ANSI Under such conditions, it may be used documents the order in which each
B31.8S standard and the specified in combination with data collection and pipeline segment will be assessed
proposed requirements. integration to evaluate segment according to level of risk the segment
poses. Operators must complete the segments have to be assessed during the needed to apply the Standards. As
baseline assessment within the specified first four years of the seven-year period. additional experience is gained in the
time frame regardless of the stress level Prior assessment. The proposed rule use of direct assessment processes,
at which the pipeline is operating. The allows an operator to use an integrity RSPA/OPS can consider relaxing these
plan for conducting the baseline assessment conducted five years requirements.
assessment must, among other previously from December 17, 2002 (the
date of enactment of the Pipeline Safety (h) When Can Direct Assessment Be
considerations, minimize the impact on Used and Under What Conditions?
gas supply to residents. Improvement Act of 2002) as the
Proposed § 192.763(h)
• An operator using pressure test or baseline assessment if the previous
internal inspection tool assessment integrity assessment method meets the Direct assessment is an integrity
method on a segment located in an HCA proposed requirements. However, if an assessment method that utilizes a
and in the potential impact zone must operator uses this prior assessment as its process to evaluate certain threats (i.e.,
complete the baseline assessment baseline assessment, the operator must external corrosion, internal corrosion
within ten years from December 17, reassess the line pipe according to the and stress corrosion cracking) to
2002 (the date of enactment of the proposed reassessment requirements. pipeline integrity. The process includes
Pipeline Safety Improvement Act of Newly-identified areas. When assembly and integration of risk factor
2002). An operator must assess at least information is available from the data, indirect examination or analysis to
50% of the line pipe, beginning with the information analysis that the population identify areas of suspected corrosion,
highest risk pipe, by 5 years from density around a pipeline segment has direct examination of the pipeline in
December 17, 2002. changed so as to fall within the these areas, and post assessment
definition in § 192.761 of a high evaluation. The process typically makes
• An operator using pressure test or
consequence area, the operator must use of data on the pipeline, its
internal inspection tool assessment
incorporate the area into its baseline environment and its operating history to
method within an HCA but outside of
assessment plan as a high consequence determine the significance of potential
the potential impact zone (also known
area within one year from the date the threats to integrity and to identify
as a moderate risk area) must complete
area is identified. An operator must indirect assessment techniques (either
the baseline assessment within 13 years
complete the baseline assessment of any analytical or above-ground examination)
from December 17, 2002 (the date of
line pipe that could affect the newly- that an operator can use to determine
enactment of the Pipeline Safety
identified high consequence area within where a threat possibly damaged the
Improvement Act of 2002).
10 years (or 7 years if direct assessment pipeline. Once suspect locations are
• An operator using direct assessment is being used) from the date the area is identified and ranked, then direct
has seven years to complete the baseline identified. physical examination determines the
assessment and has to assess at least Background on Direct Assessment. extent of damage and the need for
50% of the line pipe beginning with the Significant development work was mitigative action. Each threat to which
highest risk pipe within four years. carried out during the past two years to direct assessment is applicable uses a
• An operator using direct assessment expand the use of indirect assessment somewhat different process to evaluate
as an assessment method on a pipeline tools (e.g., Close Interval Surveys, Direct the presence of the threat.
segment located within a moderate risk Current Voltage Gradient, Pipeline While the direct assessment process
area (area in a Class 3 or Class 4 Current Mapper, electromagnetic tools) itself is new, operators have used the
location, but not within the potential into an integrated integrity assessment analytical techniques, above-ground
impact zone), must complete the process capable of identifying pipeline measurement tools, and direct
baseline assessment of the line pipe defects based on a combination of data examination technologies that the
within 10 years. analysis and integration, above ground process employs, for many years.
The proposed rule specifies the assessment, and direct examination. Examples of above-ground techniques
conditions under which direct These efforts are resulting in the with long prior use include close
assessment can be used as a primary production of an industry consensus interval surveys (CIS), direct current
assessment tool. The primary reason standard on External Corrosion Direct voltage gradient (DCVG), and pipeline
that the shorter time frame for Assessment, and towards the current mapper (PCM). Examples of
completing the assessment using the production of standards on direct direct examination techniques with long
direct assessment process is that the assessment as applied to internal prior use include direct physical
processes are still developmental, and corrosion and stress corrosion cracking. examination, ultrasonic testing, and x-
additional information must be gathered RSPA/OPS, along with ray examination.
on the method’s effectiveness so that representatives from several States, Why consider allowing the use of
any needed adjustments can be made. participated in the standard direct assessment? Although in-line
These adjustments will then be reflected development process. This participation inspection (pigging) technologies and
in the second assessment process. The led to the identification of several areas pressure testing have been used for
seven-year period is based on RSPA/ where we believe that additional years, there are several reasons for
OPS’s assessment of the minimum time requirements are needed. These allowing direct assessment as an
needed to collect and analyze risk factor additional requirements would help assessment method.
data, to develop internal practices and ensure the application of the standards INGAA reports that, at present, 24.4%
expertise in application of the is carried out by competent of its members’ transmission pipelines
processes, and to allow the service practitioners, and that innovations are already piggable. According to
industry to develop and qualify people developed by more experienced INGAA, another 25.3% can easily be
needed to responsibly apply the practitioners will be available for use by made piggable, 45.9% (∼82,620 miles)
processes. The time frame selected is less experienced operators. Additional would be very costly to pig and 4.4%
compatible with that required for requirements could also strengthen (∼7,920 miles) cannot be pigged. AGA
completion of baseline assessments in those areas where we believe too much indicates that 35% of its members’
the hazardous liquid pipeline rule. In discretion is allowed the operator in pipelines (∼4,725 miles) are not
addition, the riskiest half of the covered establishing basic decision criteria piggable. They could only be made
piggable with extensive modifications, may be capable of identifying coating There is a need for alternative
at a cost of between $1M and $8M per damage associated with third party assessment technologies capable of
mile. APGA indicates that the impacts on the pipeline, but formal finding and characterizing pipe defects.
comparable percentage of mileage for its validation of this capability has not yet RSPA/OPS decided to allow selective
members is 46% (∼1,380 miles). Based been performed. use of direct assessment for application
on these industry-provided numbers, The current strategy, being in characterizing certain integrity-
the cost of making the ‘‘very costly’’ incorporated in the developing threatening defects in pipe that cannot
lines piggable, excluding the increased consensus standard for external (for economic or operational
cost of gas supply due to capacity corrosion direct assessment for use with configuration) be pigged or hydro-
restrictions, can be estimated to be the ECDA process, is to locate areas tested. The conditions for use of direct
between $88B and $710B. While these suspected of having external corrosion assessment are based on draft NACE
numbers are exceedingly large and rely by identifying defects in the pipe consensus standards with additional
on the AGA costs, developed for making coating, then excavating those defects in requirements that reflect the
difficult to pig lines piggable in urban areas where corrosion activity is developmental nature of the processes.
areas, they do indicate that much work suspected. While all indications Under What Conditions Can Direct
on existing lines would be needed to discovered by ECDA that are not Assessment Be Used?
make all gas transmission lines piggable adequately protected by the cathodic
using today’s ILI technology. INGAA protection system at the time of the The proposed rule proposes to allow
also argues that pressure testing much of an operator to use direct assessment as
assessment will be excavated and
the currently non-piggable pipeline a supplement to the other allowable
directly examined, only a fraction of the
could be costly or impractical because assessment methods, and to use direct
ECDA indications that are protected by
of service interruptions needed to assessment as a primary assessment
cathodic protection systems at the time
complete the hydro-test, and because method for external corrosion, internal
of the assessment will be excavated.
the process introduces electrolytes into corrosion, or stress corrosion cracking
This excavation strategy is incorporated
the system that will be difficult to only when the operator can demonstrate
in the draft NACE consensus standard
completely remove, thereby increasing that a specified condition exists. These
on ECDA. The draft standard describes
the likelihood for future internal conditions are when the other
the process by which operators make
corrosion. assessment methods cannot be applied
decisions on the need for continued
In addition to the feasibility of ILI and to the pipeline segment for economic or
excavation of features in an ECDA
the costs associated with making lines technological reasons; the other
region, based on the severity of defects
piggable, the cost to consumers and the assessment methods would result in a
revealed in previous excavations. If
potential of critical supply interruptions substantial impact on gas customers;
excavation of the indications that are
are other factors in the RSPA/OPS excavation and direct examination will
expected to be most severe reveal no
decision to allow direct assessment. The be done on the entire covered pipeline
significant pipe damage, then further
INGAA study, as mentioned previously, segment; or the covered pipeline
excavations in that region are not
evaluated the cost to consumers segment operates at a maximum
necessary. If excavation continues to
associated with capacity restrictions allowable operating pressure below 30%
reveal significant pipe damage, then a
resulting from gas pipe integrity SMYS. To use direct assessment as a
larger fraction of protected indications
assessment. This study evaluated primary method for external corrosion,
capacity restrictions and related would be excavated.
internal corrosion or stress corrosion
consumer cost impacts for integrity An approach is under development by cracking, the operator has to follow
assessment scenarios involving different the Gas Technology Institute (GTI) for ASME/ANSI B31.8S and additional
mixes of ILI, hydro-test and direct ultimate incorporation in a NACE requirements set forth in the proposed
assessment technologies. For a baseline consensus standard to locate internal rule.
assessment time frame of ten years, the corrosion (ICDA). The process, using In addition, to use direct assessment
study determined that the difference in direct assessment, is focused as the primary assessment method for
cost to the consumer (excluding the cost exclusively on pipe transporting third party damage, an operator has to
of making lines piggable) between nominally clean dry gas, in which show that no other assessment method
conducting direct assessment on moisture (electrolyte) has been is feasible, and that the operator will
twenty-five percent and zero percent of introduced by abnormal operation. combine the method with data
piping would be over two billion Further, it assumes that internal collection and integration to evaluate
dollars. Some supply interruptions corrosion will only occur if moisture is the segment’s susceptibility to third
could also result if direct assessment present at the location in question. The party damage.
were not allowed as an alternative Southwest Research Institute, under GTI An operator choosing the external
assessment technology. funding, developed a mathematical corrosion direct assessment (ECDA)
What threats are direct assessment model to predict locations where method as its primary assessment
capable of characterizing? Work jointly moisture would accumulate along the technology must prepare a detailed plan
funded by the gas pipeline industry and line, if it were introduced during an in which the following information is
RSPA/OPS is ongoing to develop, upset condition. These models, together documented:
validate and standardize the application with a common sense approach to • Data requirements for using ECDA;
of the direct assessment process to the identifying other pockets where these must include as a minimum the
assessment of external corrosion (ECDA) moisture might accumulate, are to be data requirements specified in
and internal corrosion (ICDA). Future used to identify areas where excavations Appendix SP–A1 for external corrosion
work is planned to develop, validate and direct examination is required. in ASME B31.8S.
and standardize a direct assessment While not yet validated, this approach • Criteria for evaluating ECDA
process for application to the stress is drawn from industry experience and feasibility.
corrosion cracking (SCCDA) threat. is based on reasonable assumptions • Criteria for defining ECDA Regions.
Furthermore, significant anecdotal about the most likely location of Further discussion is presented later in
evidence exists that the ECDA process internal corrosion. this section.
• The basis on which two applied along the pipeline. These should typically be no greater than the
complementary tools are selected for methods must be selected based on their local depth of coverage of the pipeline.
assessing each ECDA Region. Further ability to detect external corrosion • Indirect inspections using the two
information is in Appendix E. activity and deficiencies in the pipe complementary tools in an ECDA
• Criteria for identifying and coating under the conditions expected Region should be carried out as close
documenting indications that must later to be encountered. The tools selected together in time as practical.
be characterized for severity and must be complementary, such that the • Above ground measurements
considered for direct examination. strengths of one tool overlap the should be geo-referenced and
These criteria must consider, as a limitations of the other. Appendix E documented so inspection results can be
minimum, the known sensitivities of presents information to support compared and excavation locations
assessment tools, the procedures for the selection of the two complementary accurately identified.
use of each tool, and the approach to be tools. A few examples of indirect After indirect examination
used for decreasing the physical spacing examination tools are Close Interval measurements are completed for an
at which indirect assessment tool Surveys (CIS), Direct (or Alternate) ECDA Region, the operator must align
readings are to be taken when presence Current Voltage Gradient (DCVG or the measures taken with the
of a defect is suspected. ACVG), and electromagnetic techniques complementary tools and evaluate the
• Criteria for characterizing (e.g., Pipeline Current Mapper (PCM) consistency of the observations using
indications identified in the ECDA and C-Scan). the following guidance:
process. These criteria must define how Direct assessment with only one • If the results from the two
an indication will be characterized as inspection tool will be permitted to complementary tools are not consistent
severe, moderate or minor. assess for external corrosion only if the and cannot be explained by differences
• Criteria for defining the urgency of operator develops and documents a plan in the capabilities of the tools, then
excavation and direct examination of specifying and justifying the special tool either direct examination or additional
each indication. These criteria must or tools being used. The conditions indirect inspections must be used to
define the urgency of excavating the where this deviation is permitted are as evaluate the reasons for the differences.
indication as immediate, scheduled or follows: • If additional indirect inspections or
monitored. • Pipe in frozen ground; direct examinations are not carried out
• Criteria for scheduling excavation • Pipe under paved roadways; and or if they do not resolve the
of each urgency level of indication. • Pipe in cased crossings (either road inconsistencies, then the feasibility of
These criteria are discussed at greater or river). ECDA must be reevaluated.
length below. ECDA Region: As part of the Pre- • Indications must be identified and
• Criteria for data gathering Assessment step, the operator must located following indirect inspection,
associated with each excavation. define ECDA regions. An ‘‘ECDA and the severity of each indication must
• Criteria for the qualification of Region’’ is a portion of a pipeline, not be classified as severe, moderate or
people who carry out and interpret the necessarily contiguous, that has similar minor using the criteria in the ECDA
results from the direct assessment physical characteristics, operating and Plan.
process. corrosion history, expected future • These classifications should be
• Criteria and measures for long-term corrosion conditions, and in which the conservatively developed the first time
process effectiveness evaluation. same indirect assessment tools are used. the process is applied. Results from the
Due to their similarity, these regions Pre-Assessment step (Step 1) must next
Completion of the Following Four Steps will be used in each of the remaining be compared with prior history for each
Step 1: Pre-Assessment—As part of three steps in the ECDA process. In ECDA Region.
the Pre-Assessment step, the pipeline these subsequent steps, ECDA regions • If assessment results are not
operator must analyze and integrate the are used to support aggregation and consistent with operating history, then
risk factor data to determine whether evaluation of indirect and direct the operator must reassess the feasibility
conditions exist that would preclude the examination data. Additionally, ECDA of ECDA.
effective use of ECDA. The following regions may be redefined, or the ECDA Step 3: Direct Examination
conditions may rule out ECDA process may be determined to be (Excavation and Data Gathering)—The
application or make it difficult to apply. inapplicable for an entire region. operator must next use the results from
Should any of these conditions exist, Step 2: Indirect Examination—The the indirect examination step to develop
the operator must document in the operator must carry out the indirect and carry out a direct examination plan.
ECDA Plan why ECDA is considered to examination step using the tools The activities to be included in this step
be valid and the special provisions it selected for each ECDA Region. In are listed below:
will implement to ensure ECDA defining the boundaries for use of each • The order and timing of excavations
effectiveness. pair of ECDA tools, the operator must in the direct examination step must be
• The presence of coatings that cause ensure completeness of coverage by determined from results of the indirect
electrical shielding; providing for some overlap between examination step. Both order and timing
• Backfill around the pipe with adjacent regions. The following are derived from a classification of the
significant rock content or the presence additional provisions must be indications. Criteria developed in the
of rock ledges; incorporated when the ECDA process is ECDA Plan must be used to determine
• Situations impeding timely above- applied to a segment of pipe: whether each indication is classified as
ground data gathering; • Repeat indirect inspections on a requiring immediate action, scheduled
• Locations with adjacent buried sample basis to ensure consistent data action or monitoring.
metallic structures; and are obtained. • All indications that are categorized
• Inaccessible areas. • Select intervals for capturing tool as ‘‘immediate action’’ require direct
As part of the Pre-Assessment step, readings that are closely spaced enough examination (excavation). Should any of
the operator must select at least two to ensure consistent data are obtained. these indications be associated with
different indirect examination methods Data sampling intervals (locations of test defects that require immediate
for each location where ECDA is to be points) for indirect examination tools mitigation, the operator must reduce
operating pressure by at least 20% in • The reassessment interval must be internal corrosion in a pipeline segment
the associated ECDA Region and not determined based on the largest defect must follow the requirements in ASME/
exceed this pressure until 100% of such remaining in the pipe segment and on ANSI B31.8S, Appendix SP–B2, and in
indications are excavated, evaluated and the corrosion rate appropriate for the this section.
mitigated as necessary. pipe, soil and protection conditions. For internal corrosion direct
• All excavations of ‘‘immediate The largest remaining defect must be assessment, in addition to requirements
action’’ indications must be carried out taken to be the size of the largest defect in ASME/ANSI B31.8S, Appendix SP–
promptly after indirect examination step discovered in the ECDA segment. The B2, an operator must carry out the
is complete. An operator must take corrosion growth rate must be process described below. This process
prompt action to address all anomalous conservatively estimated based on data consists of four steps: pre-assessment,
conditions found. taken during the direct examination. identification of ICDA regions and
• A minimum of one direct The reassessment interval must be excavation locations, direct
examination (excavation) is required for estimated as half the time required for examination, and post assessment and
each ECDA Region. This examination the largest defect to grow to a critical continuing evaluation. The process is
must be made at the most severe size. designed to evaluate potential for
indication, based on risk evaluation of • An operator that directly examines internal corrosion caused by water,
the indications. If no indications are and appropriately remediates defects CO2, O2, chlorides, hydrogen sulfide
shown in the ECDA Region, then the consistent with the sampling provisions and other contaminants present in the
excavation must be made at a location presented in this rule must reassess gas, as well as MIC.
that the operator considers to be the each segment at an interval not to Step 1: Pre-assessment—The first step
most suspect. exceed every five years. in the ICDA process is pre-assessment.
• At least two indications found in • An operator that examines all In this step the operator gathers
each ECDA Region categorized as anomalies by excavation and remediates information needed to support
‘‘scheduled action,’’ require direct these anomalies may be allowed to identification of areas where internal
examination. Excavation of ‘‘scheduled extend the reassessment interval from 5 corrosion is most likely to exist. This
action’’ indications must continue, in years, as specified in the main body of step requires the operator to:
priority order, until at least two the rule, paragraph (g)(4)of the proposed • Gather all data elements listed in
indications are excavated having rule, to as much as 10 years. Appendix SP–A2 of ASME/ANSI
corrosion of depth no greater than 20% • The operator must define and B31.8S.
of the wall thickness. monitor measures to determine the • Assemble information needed to
• The operator must collect all data effectiveness of the ECDA process. determine where internal corrosion is
specified in its ECDA Plan for each Measures should be developed to track: most likely to occur including: (a)
excavation completed. These data are to (a) The effectiveness of the overall Location of all gas input and withdrawal
be used in determining the nature and process (e.g., the change in the points on the line; (b) location of all low
timing of remediation as well as in the calculated reassessment interval); (b) the points on the line such as sags, drips,
fourth step of the ECDA process, the extent and severity of corrosion found; inclines, valves, manifolds, dead-legs,
Post Assessment step. (c) the number of indications in each and traps; (c) the elevation profile of the
• Except for conditions specified in classification located on successive pipeline in sufficient detail that angles
the body of the rule Section (h)(4), the applications of ECDA; and (d) the time of inclination can be calculated for all
operator must carry out remediation on from discovery of an indication pipe segments; (d) the diameter of the
a time frame and in a manner specified categorized as immediate action or pipeline, and the range of expected gas
by ASME B31.8S. Remedial action must scheduled action to its excavation. velocities in the pipeline.
be consistent with a determination of Additional Documentation • Assemble and evaluate operating
remaining strength using ASME B31G, Requirements: In addition to the ECDA experience data that would provide an
RSTRENG, or equivalent. Plan, the operator must document all indication of historic upsets in gas
• If any exposed segment has data on Pre-Assessment, Indirect conditions, locations where these upsets
significant coating degradation or Examination, verification of indirect have occurred, and any indications of
corrosion, then the operator must examination by excavation, Direct damage resulting from these upset
increase the size of that excavation until Examination and Post-Assessment, and conditions.
coating and pipe are determined to be performance measures. The operator Step 2: Identification of ICDA Regions
adequate. must also have procedures documenting and Excavation Locations—The
• The operator must identify the root communications requirements among principal innovation of the gas pipeline
cause of all significant corrosion activity various organizations conducting each industry in its development of the ICDA
revealed by excavation. step of the direct assessment process. Process is the capability to evaluate the
• When ECDA identifies any defect in critical slope of a pipeline beyond
an ECDA Region that requires Internal Corrosion Direct Assessment which moisture in the gas is unlikely to
immediate mitigation, or when the root Internal corrosion direct assessment be carried over. The primary
cause of any defect is a condition that (ICDA) is a process that identifies areas assumptions in this analysis include: (a)
ECDA is ineffective at assessing (e.g., along the pipeline where water or other For internal corrosion to occur an
MIC or shielded corrosion), then an electrolyte introduced by an upset electrolyte such as water must be
alternate assessment technology must be condition may reside, then focuses present in the pipeline; (b) the gas being
used for that ECDA Region. direct examination on the locations in transported is nominally clean and dry
Step 4: Post-Assessment—The each area where internal corrosion is but may potentially be subject to upset
operator must carry out a Post most likely to exist. If no evidence of conditions; (c) any entrained moisture
Assessment step to determine the internal corrosion exists in these most carried in the gas stream will either
reassessment interval and to evaluate likely locations, then the entire section evaporate or accumulate in a film along
the overall effectiveness of the ECDA can be considered to be free of internal the wall of the pipe and be carried
process. In carrying out this step, the corrosion. An operator using direct downstream by the shear force of the gas
following requirements apply: assessment as a method to address movement; (d) there is a critical pipe
angle above which gas that is swept be required to characterize the pipe for For example, in the proposed rule, if
along the wall will not progress internal corrosion. At any location an operator is using pressure testing or
downstream because the gravitational where indications of metal loss exist, internal inspection, it could establish a
force will exceed the shear force of the mitigation must be undertaken. ten-year reassessment interval for a
gas on the liquid film. Step 4: Post Assessment and covered segment. By the seventh year,
The purpose of this step is to define Continuing Evaluation—After the operator would have to conduct a
ICDA Regions, and to use these regions completing excavation and needed confirmatory direct assessment on that
to identify areas where excavation and mitigation of the two suspect locations segment to identify corrosion or third
direct physical examination of the in each ICDA Region, the operator must party damage. The operator would then
pipeline is needed to look for internal document and implement a program of have to conduct the follow up
corrosion. ICDA Regions are regions continuing monitoring for segments reassessment in the tenth year. If the
along the pipeline where internal where internal corrosion has been operator has established a seven-year or
corrosion may occur and further identified. This program may include shorter interval for the segment, the
evaluation is needed. An ICDA Region use of coupons located in suspected operator would not have to conduct the
is bounded by a location where a new areas, but must include periodic confirmatory direct assessment.
gas stream enters the pipe and the reassessment at the prescribed interval. The rule proposes that the
nearest location downstream of that In addition, fluids drawn off of the confirmatory direct assessment method
point where a the pipe slope exceeds pipeline at low points must be retained be used to identify internal and external
the critical angle, given local gas and chemically analyzed for the corrosion and third party damage. For
velocity. The operator identifies these presence of corrosion products. external corrosion, an operator’s plan to
ICDA Regions by applying the results of Evidence of corrosion products must be use this method would have to include
the mathematical flow model as interpreted as requiring further steps for pre-assessment, indirect
represented in Graph E.III.1 in excavations of locations down stream examination, direct examination, and
Appendix E of this document. Flow where moisture might accumulate, or remediation.
modeling must include explicit use of an alternative assessment • The pre-assessment would be the
consideration of changes in pipe technology such as in-line-inspection. same as that proposed for direct
diameter as well as locations where gas assessment;
Stress Corrosion Cracking (SCC)
enters a line (providing potential to • The indirect examination would be
introduce moisture) and locations down As described in ASME/ANSI B31.8S,
the same as that proposed for direct
stream of gas draw-offs (where gas Appendix SP–B3, direct assessment
assessment except the examination can
velocity is reduced). techniques represent the single most
be conducted using only one indirect
Once the ICDA Regions are identified, significant historic approach to evaluate
examination tool most suitable for the
the most likely locations for internal for the presence of stress corrosion
application.
corrosion in each region can be cracking (SCC). Only recently ILI tools
identified. A minimum of two locations have become available to reliably • The direct examination would
must be identified for excavation in identify SCC in pipelines, and the use follow that for the direct assessment,
each ICDA Region. One location is the of these tools must be guided by a pre- except that all immediate action
low point (e.g., sags, drips, valves, assessment review that identifies where indications must be excavated n each
manifolds, dead-legs, traps) nearest to to look for the possibility of SCC. ECDA region, and at least one high risk
the beginning of the ICDA Region. The For SCC direct assessment, in indication that meets the criteria of
second location is at the upstream end addition to text in ASME B31.8S scheduled action must be excavated in
of the pipe incline nearest the end of the standard, an operator must consider the each ECDA region. No excavation is
ICDA Region. The first point represents following condition: required for indications categorized as
the most likely locations for • Systematic SCC data collection, monitored indications.
accumulation of electrolyte in the ICDA evaluation and accumulation process • The remediation requirements
Region, and the second point represents must be instituted for all segments that follow those proposed for direct
the location furthest from the beginning satisfy the criteria in the ASME B31.8S assessment.
of the ICDA Region where internal standard. This process must include For internal corrosion, an operator’s
corrosion may occur.. gathering and evaluating data related to plan to use this method would have to
Step 3: Direct Examination—At a SCC at all excavation sites where the include steps for pre-assessment,
minimum the operator must excavate criteria indicate the potential for SCC. identification of ICDA Regions,
the two locations described above, in • If any evidence of SCC is identification of excavation locations,
each ICDA Region where the potential discovered, then the operator must direct examination and remediation.
for moisture accumulation exists, and select and implement a suitable • The pre-assessment would follow
must perform direct examination for assessment approach. that proposed for direct assessment.
internal corrosion by inspecting both Confirmatory Direct Assessment is a • The identification of ICDA Regions
locations. Acceptable direct more focused application of the would follow that proposed for direct
examination technologies are described principles and techniques of direct assessment.
in ASME/ANSI B31.8S, Appendix SP– assessment. It utilizes process steps • The identification of excavation
B2, and include ultrasonic examination similar to direct assessment to evaluate locations and excavation would follow
and x-ray. for the presence of suspected corrosion that proposed for direct assessment,
If no internal corrosion exists at either and third party damage, but it is not as except that the operator must identify
of these locations, then the remainder of involved as direct assessment. The rule for excavation at least one high risk
the ICDA Region is likely to be proposes that an operator use location in each ICDA Region.
corrosion free. However, if corrosion confirmatory direct assessment to • The direct examination (excavation)
exists at either of these locations, then reassess a pipeline segment within the and remediation would follow that for
either much more extensive excavation required seven-year interval if the direct assessment, except one high risk
is required or an alternative assessment operator has established a longer location in each ICDA Region is to be
technology (e.g., in-line-inspection) will reassessment interval for that segment. chosen for excavation.
For identifying third party damage, be less than or equal to 1.1, require 7, an operator must treat the following
the operator’s confirmatory direct immediate response. ‘‘Scheduled conditions as immediate repair
assessment plan would include response,’’ means that the indications conditions:
identification of pipeline segments must be reviewed within six months of • A calculation of the remaining
where construction or other discovery and response plans developed strength of the pipe shows a predicted
groundbreaking activity was reported consistent with the severity of the failure pressure less than 1.1 times the
near the pipeline right-of-way since the defect. Figure 7–1 of ASME/ANSI established maximum operating
previous assessment. B31.8S presents criteria for remediation pressure at the location of the anomaly.
time as a function of the stress level of Suitable remaining strength calculation
(i) What Actions Must Be Taken To
the pipe and the severity of the defect methods include, but are not limited to,
Address Integrity Issues? Proposed
(i.e., the ratio of the predicted failure ASME/ANSI B31G (‘‘Manual for
§ 192.763(i)
pressure to the MAOP). ‘‘Monitored Determining the Remaining Strength of
The proposed rule requires that an defects,’’ are those for which the Corroded Pipelines’’ (1991) or AGA
operator must take prompt action to response time for mitigation is greater Pipeline Research Committee Project
address all anomalous conditions that than the reassessment interval, and, PR–3–805 (‘‘A Modified Criterion for
the operator discovers through the therefore, the indications will be Evaluating the Remaining Strength of
integrity assessment or information reexamined as part of the reassessment Corroded Pipe’’ (December 1989)).
analysis. In addressing all conditions, process. These documents are available at the
an operator must evaluate all anomalous The proposed rule also defines addresses listed in Appendix A to Part
conditions and remediate those that ‘‘discovery of condition.’’ Discovery of a 192.
could reduce a pipeline’s integrity. An condition occurs when an operator has • A dent that has any indication of
operator must be able to demonstrate adequate information about the metal loss, cracking or a stress riser.
that the remediation of the condition condition to determine that the • An anomaly that in the judgment of
will ensure that the condition is condition presents a potential threat to the person designated by the operator to
unlikely to pose a threat to the long- the integrity of the pipeline. An operator evaluate the assessment results requires
term integrity of the pipeline. If an must promptly, but no later than 180 immediate action. Such an evaluation is
operator is unable to respond within the days after an integrity assessment, required by all operators using direct
time limits for certain conditions obtain sufficient information about a assessment.
specified below, operating pressure of condition to make that determination If 180-day evaluation. Except for
the pipeline must be temporary the operator cannot make the necessary conditions listed in ‘‘immediate repair’’
reduced. An operator must determine determination within the 180 day conditions of this section, an operator
the temporary reduction in operating period, them it must notify RSPA/OPS must complete evaluation and schedule
pressure for dents and gouges using of the reasons for the delay and the remediation of the following within 180
section 851.42 of ASME/ANSI B31.8; expected time for completing the days of discovery of the condition:
and for corrosion using ASME/ANSI assessment. • Calculation of the remaining
B31G, RSTRENG, or equivalent, or by Except for special requirements for strength of the pipe shows a predicted
reducing the operating pressure to a scheduling remediation of certain failure pressure between 1.1 times the
level not exceeding 80% of the level at conditions specified in paragraph (h)(4) established maximum operating
the time the integrity assessment results of the proposed rule, an operator is pressure at the location of the anomaly,
were received. A reduction in operating required by the proposed rule to follow and the ratio of the predicted failure
pressure cannot exceed 365 days a threat by threat schedule specified in pressure to the MAOP shown in Figure
without an operator taking further the ASME/ANSI B31.8S Standard. An 7–1 of ASME B31.8S to be appropriate
remedial action on anomalies that could operator must complete remediation of for the stress level of the pipe and the
reduce a pipeline’s integrity. An a condition according to a schedule that reassessment interval. For example, if
operator must comply with Section 7 of prioritizes the conditions for evaluation the pipe is operating at 50% SMYS and
ASME/ANSI B31.8S when defining the and remediation. If an operator cannot the reassessment interval is ten (10)
time frame for making a repair. Section meet the schedule for any condition, the years, then the predicted failure
7 of this standard defines conditions for operator must justify the reasons why it pressure ratio for scheduling
which the required response is cannot meet the schedule and that the examination and remediation during
‘‘immediate’’ or can be ‘‘scheduled,’’ changed schedule will not jeopardize that ten year period would be 1.39.
and other conditions for which the public safety. An operator must notify 180 day remediation. The following
indications can be ‘‘monitored.’’ RSPA/OPS if it cannot meet the conditions must be remediated within
‘‘Immediate response,’’ means that upon schedule and cannot provide safety 180 days of discovery of the condition:
discovery of the condition the operator through a temporary reduction in • A dent with a depth greater than
will immediately either shut the line operating pressure. An operator must 6% of the pipeline diameter (greater
down or reduce pressure to 80% of its send the notice to the address specified than 0.50 inches in depth for a pipeline
previous level or less, if necessary to in paragraph (n) of the proposed rule. diameter less than Nominal Pipe Size
achieve a safe condition, and maintain The proposed rule also tabulates (NPS) 12).
that lower pressure until the defect is special conditions for scheduled • A dent with a depth greater than
mitigated. Under no circumstances shall remediation as follows: 2% of the pipeline’s diameter (0.250
this temporary pressure reduction be Immediate repair conditions. An inches in depth for a pipeline diameter
extended beyond 365 days after the operator’s evaluation and remediation less than NPS 12) that affects pipe
condition is discovered. Immediate schedule must provide for immediate curvature at a girth weld or a
response conditions are defined for repair conditions. To maintain safety, an longitudinal seam weld.
threats including corrosion, stress operator must temporarily reduce • A potential crack indication that
corrosion cracking and third party operating pressure or shut down the when excavated is determined to be a
damage. In addition, conditions for pipeline until the operator completes crack.
which the ratio of the predicted failure the repair of these conditions. • Corrosion of or along a longitudinal
pressure to the MAOP is determined to Consistent with ASME B31.8S, Chapter seam weld.
• A gouge or groove greater than reducing the volume of gas release. The reassessment interval for the covered
12.5% of nominal wall. operator must document the criteria segment that is greater than seven years,
Scheduled Remediation. The ASME/ used in evaluating the need for ASVs the operator must within the seven-year
ANSI B31.8S Standard includes and RCVs, and document the decisions period, conduct a reassessment by
provisions for scheduled repairs over a resulting from application of these confirmatory direct assessment on the
period exceeding 180 days. For all criteria. covered segment, and then conduct the
indications that are not excavated and follow-up reassessment at the
remediated within 180 days, the (k) What Is a Continual Process of
Evaluation and Assessment To Maintain established interval. The length of the
following requirements apply: interval will depend on the method of
• For segments assessed using ILI a Pipeline’s Integrity? Proposed
§ 192.763(k) assessment.
techniques, the failure pressure must be If an operator uses pressure testing or
determined and remediation carried out The integrity assessment requirements internal inspection as an assessment
on a time frame consistent with Figure proposed in this rule do not stop with method, the operator must establish the
7–1 in ASME/ANSI B31.8S. the baseline integrity assessment. An reassessment interval for covered
• For segments assessed using direct operator must, on a continual basis, pipeline segments by either basing the
assessment, at least one direct assess the integrity of the line pipe and intervals on the identified threats for the
examination, beyond those required in evaluate the integrity of each pipeline segment (as identified in the proposed
Paragraph (g)(4) of the proposed rule, of segment that could affect a high rule and in ASME/ANSI B31.8S, Table
a scheduled indication must be carried consequence area. The proposed rule 8–2, section 8) and on the analysis of
out in each ECDA Region between requires an operator to conduct a the results from the last integrity
assessments. The results of this direct periodic evaluation of each pipeline assessment and from the required data
examination must be compared with segment, as frequently as needed, to integration or by using the intervals for
those from earlier direct examination assure the pipeline’s integrity. An different stress levels of pipeline
results for consistency. Should the operator would determine frequency specified in ASME/ANSI B31.8S, Table
defect be larger than any of those based on threats specific to the pipeline
8–1, section 8. However, under either
identified in previous excavations in segment, plus threats specified in
option, the maximum reassessment
that region, then further excavation proposed § 192.763(e) and in Section 2
interval must not exceed ten (10) years
must be carried out until the of the ANSI/ASME B31.8S Standard.
The evaluation is based in part, on the for a pipeline operating at or above 50%
requirements in Paragraph (g)(4) of the
information analysis the operator SMYS, and 15 years for a pipeline
proposed rule are satisfied.
conducts of the entire pipeline to operating below 50% SMYS. These
(j) What Additional Preventive and maximum assessment intervals will be
determine what history and operations
Mitigative Measures Must an Operator acceptable, only if the operator
elsewhere could be relevant to the
Take To Protect the High Consequence demonstrates it has enhanced
segment. The evaluation must also
Area? Proposed § 192.763(j) preventive and mitigative programs in
consider the past and present integrity
The proposed rule includes the assessment results, and decisions about place and the operator conducts a
following general requirement: An repair, and preventive and mitigative confirmatory direct assessment within
operator must take measures to prevent actions. The evaluation must be carried the seven-year interval.
and mitigate the consequences of a out by a person qualified to evaluate the An operator that establishes the
pipeline failure that could affect a high results and other related data. maximum period allowed for
consequence area in accordance with As with the baseline assessment, the reassessment must conduct a
the standard ASME/ANSI B31.8S. Table continual integrity assessment method confirmatory direct assessment within
7–1 in the ASME standard describes must be by internal inspection, pressure the seven-year interval and demonstrate
some preventive and mitigative test, direct assessment, or other that it has implemented enhanced
measures appropriate for each threat. In technology that provides an equivalent preventive and mitigative measures for
addition, operators must conduct risk understanding of the condition of the the segment.
analysis of their pipeline segments to line pipe. As with the baseline If an operator uses direct assessment,
identify additional actions to enhance assessment, if an operator chooses other it must determine the reassessment
public safety. Such actions include, but technology as a reassessment method, interval according to a calculation. The
are not limited to, installing Automatic the operator must give 90-days advance reassessment interval cannot exceed five
Shut-off valves or Remote Control notice (by mail or facsimile) to RSPA/ years, if an operator directly examines
Valves, computerized monitoring and OPS. As with the baseline assessment, and remediates defects by sampling, or
leak detection systems, extensive an operator must have a process for ten years, if an operator conducts a
inspection and maintenance programs, ensuring that the assessment is being direct examination of all anomalies and
and heavier wall thickness. done in a manner to minimize remediates these anomalies. A ten-year
Automatic Shut-off valve (ASV) or environmental and safety risks. interval would necessitate an interim
Remote Control Valves (RCV). If an Each covered pipeline segment must reassessment by confirmatory direct
operator determines that an ASV or RCV be reassessed at seven-year intervals, or assessment in the seventh year.
is needed on a pipeline segment to five years if direct assessment is used The proposed rule requires each
protect high consequence areas in the and the operator directly examines and operator to evaluate the cause of threats
event of gas release, an operator must remediates defects by sampling. The for which mitigative action was
install the ASV or RCV. In making that period for reassessment begins with the undertaken, and determine whether
determination an operator must at least completion of the prior assessment on there is reason to reassess the pipe at
consider magnitude of leak detection that segment. The proposed rule allows shorter intervals based on the nature of
and pipe shutdown capabilities, the an operator to base the reassessment significant threats. For example, if the
type of gas, pressure, the rate of interval on the risk the pipe poses to the dominant cause of pipe deterioration in
potential release, the potential for high consequence area to determine the a particular segment was MIC, then the
ignition, location of nearest response priority for assessing the pipeline operator is required to reassess its
personnel, and benefits expected by segments. If the operator establishes a similar pipe segments on a shorter
interval, consistent with the growth rate a continuing measure of integrity for evaluating and remediating
of MIC corrosion. management program effectiveness over anomalous conditions; (d) adopts
OPS can only allow a waiver of a time. This standard lists four overall certain changes into its program; and (f)
maximum reassessment interval greater program measurements that must be seeks a waiver from a reassessment
than seven years in two instances—for determined and documented. Those interval greater than seven years.
lack of internal inspection tools or to measurements are: (1) Number of miles
maintain local product supply- and if of pipeline inspected versus program Appendix E to Part 192
OPS determines that such a waiver requirements; (2) number of immediate We are adding a new Appendix E to
would not be inconsistent with pipeline repairs completed as a result of integrity Part 192. This Appendix gives guidance
safety. Because public notice and management inspection program; (3) on determining a potential impact zone
comment is required for a waiver, we number of scheduled repairs completed within a high consequence area and
are proposing an operator provide 180 as result of the integrity management shows diagram of a potential impact
days advance notification. inspection program; (4) number of leaks, zone under figure E.I.1. This Appendix
The proposed rule requires the failures and incidents. describes the steps an operator needs to
operator to assess the integrity of the The proposed rule requires that an perform in order to determine segments
line pipe by one or more of the operator periodically make available for covered under potential impact zones.
following techniques: inspection the four primary This Appendix also provides
• Internal inspection tool or tools; for performance measures enumerated recommendations on how to select
details on selecting appropriate internal above from Section 9.4 in ASME/ANSI external corrosion direct assessment
inspection tools an operator must refer B31.8S. (ECDA) Tools and how to identify ECDA
to ASME/ANSI B31.8S section 6.2. Regions. In addition, this Appendix
• Pressure test conducted in (m) What Records Must be Kept?
Proposed § 192.763(m) provides a spreadsheet under Graph
accordance with Subpart J of Part 192. E.III.1 for calculating critical angle for
• Direct assessment method for The proposed rule requires that an liquid hold-up for internal corrosion
external corrosion threats, internal operator maintain certain records for direct assessment (ICDA).
corrosion threats, and other threats must inspection, including its written An operator is required to follow the
be carried out in accordance with the integrity management program, and, if recommendations on ECDA Tool
ASME/ANSI B31.8S standard Section applicable, its plan for using direct selection and ECDA Regions, unless the
6.3 and paragraph (h) of the proposed assessment. This requirement is not operator notes in its plan the reasons
rule. different from the procedural manual an why compliance with all or certain
• Other technology that the operator operator is required to maintain for provisions is not necessary to maintain
demonstrates can provide an equivalent operations, maintenance and integrity of their specific pipeline
understanding of the condition of the emergencies. An operator would also be system. The Appendix contains
line pipe. An operator choosing this required to maintain for review during recommendations on:
option must notify RSPA/OPS 180 days inspection, any documents that support • Selection of indirect inspection
before conducting the assessment, by the decisions and analyses made, and tools for direct assessment: how
sending a notice to the address or to the actions taken to implement and evaluate selection of indirect inspection tools
facsimile number specified in paragraph each element of the integrity may vary along a segment; minimum
(n) of the proposed rule. management program. This would number of tools needed for all ECDA
include records documenting any locations and items that should be
(l) What Methods To Measure Program modifications, justifications, variances,
Effectiveness Must Be Used? Proposed considered when selecting indirect
deviations and determinations made. inspection tools; and conditions under
§ 192.763(l) All records required under direct
The proposed rule requires an which some indirect inspection tools
assessment must also be maintained and may not be practical or reliable.
operator to include in its integrity available for RSPA/OPS review during • Identification of ECDA Regions:
management program methods to inspections. Again, this requirement is how to (a) Collect appropriate risk factor
measure the program’s effectiveness in no different from the myriad of data; (b) define criteria to identify ECDA
assessing and evaluating the integrity of documents an operator now maintains regions; and (c) identify locations
each pipeline segment and in protecting to comply with the other provisions of having similar physical characteristics,
the high consequence areas. The the pipeline safety regulations. soil conditions, corrosion protection
proposed rule requires that an operator
(n) Where Does an Operator Send a maintenance. In addition, guidance on
use four overall performance measures
Notification? Proposed § 192.763(n) establishing ECDA Regions is presented
specified in Section 9.4 of ASME/ANSI
This section of the proposed rule by illustrating an example of the ECDA
B31.8S and specific measures for each
clarifies that any required notification regions for a hypothetical pipeline.
identified threat specified in ASME/
must be sent to the Information • Internal Corrosion Direct
ANSI B31.8S, Appendix SP–A.
The performance measures help an Resources Manager, Office of Pipeline Assessment: how to calculate critical
operator determine whether all integrity Safety, Research and Special Programs angle for liquid hold-up using a graph
management program objectives were Administration, U.S. Department of from GRI report GRI–02/0057. The
accomplished and whether pipeline Transportation, Room 7128, 400 approach helps determine if internal
integrity and safety are effectively Seventh Street SW., Washington, DC corrosion is likely to or unlikely to exist
improved through the integrity 20590, or to the facsimile number (202) in a chosen length of pipe.
management program. Proper selection 366–7128. Notification is required when Regulatory Analyses and Notices
and evaluation of performance measures an operator: (a) Uses alternative
are an essential activity in determining technology for an integrity assessment; Executive Order 12866 and DOT
integrity management program (b) cannot meet its schedules for Regulatory Policies and Procedures
effectiveness. According to ASME/ANSI identification of segments and The Department of Transportation
B31.8S Standard, evaluations must be identification of ECDA regions if (DOT) considers this action to be a
performed at least annually to provide applicable; (c) cannot meet schedules significant regulatory action under
section 3(f) of Executive Order 12866 require reassessment of these areas at The proposed rule requires a baseline
(58 FR 51735; October 4, 1993). least every seven years. assessment of covered pipeline
Therefore, it was forwarded to the Office This proposed rulemaking addresses segments through internal inspection,
of Management and Budget. This the target problem described above, and pressure test, direct assessment or use of
proposed rule is significant under is a comprehensive approach to certain other technology capable of equivalent
DOT’s regulatory policies and NTSB recommendations and performance. Unless an operator uses
procedures (44 FR 11034: February 26, Congressional mandates, as well as direct assessment, the baseline
1979) because of its significant public pipeline safety and environmental assessment must be completed within
and government interest. A regulatory issues raised over the years. ten years after December 17, 2002 (the
evaluation of this proposed rule on This proposed rule focuses on a date the Pipeline Safety Improvement
Integrity Management for gas systematic approach to integrity Act of 2002 was signed into law), with
transmission pipelines has been management to reduce the potential for at least 50% of covered segments being
prepared and placed in the docket. natural and other gas transmission assessed within five years. With direct
pipeline failures that could affect assessment the baseline assessment
Cost-Benefit Analysis populated areas. This proposed must be completed in seven years, with
A copy of the draft regulatory rulemaking requires pipeline operators 50% of the covered segments completed
evaluation has been placed in the to develop and follow an integrity within four and 1/2 years. Until we see
docket for this proposed rule. The management program that continually the results from operators’ assessments
following section summarizes the draft assesses, through internal inspection, we cannot determine whether direct
regulatory evaluation’s findings. pressure testing, direct assessment or assessment by itself is adequate to
Natural and other gas pipeline equivalent alternative technology, the assess pipeline integrity or whether
ruptures can adversely affect human integrity of those pipeline segments that pigging might also be needed. The
health and property. However, the could affect areas we have defined as period for a baseline assessment may
magnitude of this impact differs from high consequence areas i.e., areas with extend to 13 years, or ten years for
area to area. There are some areas in specified population densities, direct assessment, for segments in
buildings containing populations of moderate risk areas, that is, areas within
which the impact of an accident will be
limited mobility, and areas where a class 3 or 4 location that are not in the
more significant than it would be in
people gather that occur along the route impact zone from a potential rupture.
others due to concentrations of people
of the pipeline. The program must also After this baseline assessment, the
who could be affected. Because of the
evaluate the segments through rule further proposes that an operator
potential for dire consequences of
comprehensive information analysis, periodically reassess and evaluate the
pipeline failures in certain areas, these
remediate integrity problems and pipeline segment to ensure its integrity
areas merit a higher level of protection.
provide additional protection through within a ten-year interval for pipelines
RSPA/OPS is proposing this regulation
preventive and mitigative measures. operating at greater than 50 percent of
to afford the necessary additional This proposed rule (the third in a specified minimum yield strength
protection to these high consequence series of integrity management program (SMYS) and a fifteen-year interval for
areas. regulations) covers operators of pipelines operating below 50 percent
Numerous investigations by RSPA/ transmission pipelines for natural and SMYS. However, to meet the
OPS and the National Transportation other gases. RSPA/OPS chose to start requirements of the Pipeline Safety
Safety Board (NTSB) have highlighted the series with hazardous liquid Improvement Act of 2002, if an operator
the importance of protecting the public pipeline operators because the pipelines establishes an interval greater than
and environmentally sensitive areas they operate have the greatest potential seven years, the operator will need to
from pipeline failures. NTSB has made to adversely affect the environment. conduct an interim reassessment by the
several recommendations to ensure the This proposed rule completes the seventh year using a more-focused
integrity of pipelines near populated application of integrity management to direct assessment (Confirmatory Direct
and environmentally sensitive areas. all interstate (and many intrastate) Assessment) method. If an operator
These recommendations included pipelines. elects to perform a reassessment, using
requiring periodic testing and We have estimated the cost for one of the other methods, every seven
inspection to identify corrosion and operators to identify pipeline segments years, the operator need not use the
other damage, establishing criteria to that can affect high consequence areas at confirmatory direct assessment. The
determine appropriate intervals for approximately $23.34 million, the cost proposed reassessment interval for
inspections and tests, determining to develop the necessary programs at pipelines assessed with direct
hazards to public safety from electric approximately $90.9 million (with an assessment is five years unless all
resistance welded pipe and requiring additional one-time cost of $367,400 to anomalies are excavated, in which case
installation of automatic or remotely- provide RSPA/OPS and state inspectors it is ten years.
operated mainline valves on high- with real-time access to performance Confirmatory direct assessment is a
pressure lines to provide for rapid measures) and an annual cost for more-focused application of the
shutdown of failed pipelines. program upkeep and reporting of $13.36 principles and techniques of direct
Congress also directed RSPA/OPS to million. An operator’s program begins assessment, that is concentrated on
undertake additional safety measures in with a baseline assessment plan and a identifying critical segments of
areas that are densely populated. These framework that addresses each required suspected corrosion and third party
statutory requirements included having program element. The framework damage. RSPA/OPS has structured the
RSPA/OPS prescribe standards for indicates how decisions will be made to proposed requirements for confirmatory
identifying pipelines in high density implement each element. As decisions direct assessment in a manner intended
population area and issue standards are made and operators evaluate the to allow maximum flexibility for
requiring periodic inspections using effectiveness of the program in operators. Indirect examinations may be
internal inspection devices on pipelines protecting high consequence areas, the performed using only one, rather than
in densely-populated and program will be updated and improved, two, tools. Corrosion regions may be
environmentally sensitive areas, and to as needed. larger than for regular direct
assessments. The number of excavations or mitigative actions that the notice accommodate in-line inspection. This
required per region is less. These proposes an operator take is to install approach was taken, because of industry
changes will allow operators to plan and automatic shutoff valves or remotely comments that significant amounts of
conduct confirmatory direct controlled valves. RSPA/OPS could not pipeline would likely be modified and
assessments in a manner that is most estimate the total cost of installing such the costs for that work. Some pipe
cost-effective, i.e., identifies areas of valves because there are too many already can accommodate in-line
concern at lowest cost. factors that would have to be analyzed inspection tools. Some can be modified
There is no data available at present in order to produce a valid estimate of to accommodate the in-line inspection
regarding the cost to implement how many operators will install them. tools with relatively simple
confirmatory direct assessment. The However, based on the results of a modifications. Others require much
flexibility included in these proposed generic feasibility study on remotely more extensive retrofits. Until we see
requirements means that costs may vary controlled valves that RSPA/OPS results of operators assessments we can
depending on assumptions the operator completed in 1999, we concluded that not judge whether direct assessment is
makes in planning and conducting these conversion of existing sectional block sufficient or pigging is needed. One of
assessments. For purposes of this valves to remote operation was not the analyzed scenarios assumed that
evaluation, the RSPA/OPS assumes that economically feasible. Operator- and only the piping that can easily be
the cost will be less than, but more than location-specific factors could change modified would be changed. The other
half, that of direct assessment, or $3,000 this conclusion for individual valves but scenario was based on the assumption
per mile. Actual costs for many RSPA/OPS could not analyze these that a portion of the pipe requiring more
operators may be lower, and the total specific factors for individual block extensive changes would also be
cost estimates in this analysis are thus valves and therefore, did not estimate modified. As a result of this work,
expected to be conservatively high. the total cost for installing remote RSPA/OPS has estimated the annual
It is estimated that the cost of periodic valves. RSPA/OPS presumes that cost of additional baseline assessment
reassessment will generally not occur operators will analyze valve-specific that will be required by this proposed
until the sixth year (when reassessment factors and will not replace valves rule as between approximately $59
costs will begin for a pipeline baseline unless that action is cost-beneficial. million and $298 million annually. The
assessed using direct assessment) unless RSPA/OPS estimates that the cost to cost for additional re-assessment is
the baseline assessment indicates operators to perform the required risk estimated at approximately $32 million
significant defects that would require analyses will be approximately $24.1 per year.
earlier reassessment. million.
RSPA/OPS believes that the higher Affected operators will be required to Although there are a variety of
the operating pressure of a pipeline, the assess more line pipe in segments that benefits associated with this proposed
greater the potential risk the pipeline could affect high consequence areas as rule, the principal benefits are difficult,
poses to the general public. That is a result of this proposed rule than they if not impossible, to quantify. The
because a failure of a pipeline operating would have been expected to assess if proposed integrity management program
at a higher pressure will result in a the proposed rule had not been issued. requirements will ensure that all gas
larger impact area and potentially more Integrity assessment consists of a transmission operators perform at least
significant consequences. It is under baseline assessment, and subsequent to an established baseline safety level
this assumption that RSPA/OPS is reassessment. The period in which and will raise the overall level of safety
proposing the shortest assessments baseline assessments must be completed performance nationwide. The proposed
intervals for pipelines that operate at or depends upon the assessment method rule will lead to greater uniformity in
above pressures of 50 percent of SMYS. chosen and the grade of the high how risk is evaluated and addressed and
By basing the assessment interval consequence areas. The baseline period will provide a better and clearer basis
according to pipeline pressure, for most pipe is ten years for pipeline for government, industry and the public
operators will have to focus their safety to be assessed with in-line inspection or to discuss safety concerns and how they
resources on lines that pose the greatest hydrostatic testing and five years for can be resolved. Public awareness of the
danger. RSPA/OPS believes that varying pipeline to be assessed using direct integrity program will lead citizens to be
the assessment interval according to the assessment. These periods are extended more informed about pipeline safety
risk provides the greatest reward per to 13 and 7 years, respectively, for and provide information to operators
dollar of safety operators will expend. pipeline that can affect lower grade high about activities on the pipeline right-of-
Integrating information related to the consequence areas, containing relatively way that will help to improve safety.
pipeline’s integrity is a key element of lower population densities. The integrated integrity management
the integrity management program. Reassessments must be conducted at no programs that operators will be required
Costs will be incurred in realigning less than ten year intervals for pipeline to implement in response to this
existing data systems to permit operating above 50 percent SMYS and proposed rule will result in a higher
integration and in analysis of the 15 years for pipeline operating at less level of safety, which should in turn
integrated data by knowledgeable than 50 percent SMYS. The proposed result in improved public confidence in
pipeline safety professionals. The total reassessment interval for pipe assessed the safety of natural gas transmission
costs for the information integration with direct assessment is five years pipelines. Operators have begun
requirements in this proposed rule are unless all anomalies are excavated, in integrity programs on their own because
$31.5 million in the first year and which case the interval may be they have recognized the importance of
$15.75 million annually thereafter. extended to ten years. Confirmatory knowing the condition of their pipelines
The proposed rule requires operators direct assessments would be required to and having the public assured that the
to evaluate the risk of pipeline segments be performed at least every seven years, lines are safe. After a major pipeline
that can affect high consequence areas if an operator established a reassessment accident, and the accompanying
to determine if additional preventive or interval longer than seven years. national spotlight from the media the
mitigative measures that would enhance RSPA/OPS analyzed two scenarios, public becomes alarmed with the
public safety should be implemented. varying the amount of pipeline that potential threat that pipelines pose.
One of the many additional preventive operators are expected to modify to Pipelines that are presently unpiggable
have most likely not been inspected. than would be indicated by historical degree than RSPA/OPS had estimated,
The public becomes very concerned precedents. The reason for this is the industry would choose to modify
when it becomes aware that ‘‘aging’’ continued increase in the population existing pipeline to make it possible to
pipelines underground in their living near, and utilizing land near, inspect using in-line inspection tools.
community have never been internally pipelines. Accidents that occur in rural The TPSSC also commented that costs
inspected. The only method to reassure settings typically have resulted in fewer had been greatly underestimated,
the public of the safety of pipelines is deaths, serious injuries, and property primarily because the additional
that there are requirements that these damage than accidents that occur in mileage they will need to internally
pipelines be internally inspected and developed areas. As the amount of inspect in order to inspect segments that
evaluated on a periodic basis. This development near pipelines increases, can affect high and lower risk areas will
improved confidence is consistent with relatively more accidents would be be much larger than the amount
the objectives of the Administration’s expected to occur in developed areas estimated in the draft regulatory
National Energy Plan. The importance and the consequences of those accidents analysis. The much larger total amount
of integrity management is also reflected would be expected to increase. of mileage that will require inspection
in its inclusion in the requirements of As a result of these factors, RSPA/OPS could lead to supply disruptions while
the Pipeline Safety Improvement Act of concludes that the quantifiable benefits testing and repair is underway.
2002. of the proposed rule are on the order of Nevertheless, the committee
RSPA/OPS, as well as the pipeline $40 million per year. This is less than, unanimously concluded that the
industry has gained valuable knowledge but on the same order of magnitude as, expected benefit in terms of improved
from accidents and near misses in the the continuing costs. Initial costs, for public confidence in pipeline safety is
90’s. RSPA/OPS has found that program development and modification substantial and justifies the expected
operators have gathered valuable of pipelines to facilitate testing, are costs and that with edits, the RSPA/OPS
information but that they have not used significantly higher. The quantifiable draft regulatory analysis provided a
that information effectively or used it to benefits alone cannot justify those costs. basis for proposing this rule. RSPA/OPS
maximum effect. Analysis of recent They need not, however. Recently, gas has revised the draft regulatory analysis
major accidents indicates that better use transmission pipeline operators have in response to the TPSSC comments.
of existing information through data indicated that, of the choices of testing
With the increased understanding of
integration and evaluation has the available, they frequently are going to
the condition of the pipeline that will
potential to prevent major accidents. choose internal inspection as the best
Data integration requirements should long term investment and while the result from the added assessments and
lead operators to make better and more costs are higher for the modifications repairs required in the proposed rule,
informed decisions about what needed to operate this method, the there is the potential for pressures to be
preventive and mitigative actions to take operators clearly think the investment is maintained that would otherwise have
and how to set priorities. RSPA/OPS worthwhile. to be reduced to allow adequate safety
believes that it is possible for operators The principal benefit to be derived margins. Additional demand for supply
to gather and integrate the necessary from the proposed rule is one that may potentially be better met by not
data and implement the needed changes cannot easily be quantified. That is having to impose restrictions to the flow
with little additional investment. improved public confidence in pipeline of natural gas through existing
The benefits that can be quantified are safety. That confidence has been shaken transmission pipelines in areas where
expected reductions in deaths, serious by accidents in recent years. It is population is increasing and pipe
injuries, and property damage costs necessary that actions be taken to replacement or pressure reductions
resulting from accidents on gas restore that confidence. Improved would be required. Current
transmission pipelines. RSPA/OPS has public confidence in pipeline safety requirements provide that natural gas
developed a level-of-magnitude estimate will, in turn, produce additional benefit. transmission pipelines in areas that
of these benefits. That estimate is based It will result in improved ability to site would be defined as high consequence
on the accident data reported to RSPA/ and construct the additional pipelines areas operate at pressures that limit
OPS over a sixteen year period (1986 to that will be needed to serve growing stresses in the pipe walls to levels
2001). RSPA/OPS estimates that the demand for natural gas in the United significantly below those allowed in
benefit of completely eliminating the States, as indicated in the National more rural areas. The reduced stresses
fatalities, serious injuries, and property Energy Plan. This growth results not are intended to provide additional
damage caused by those accidents only from increasing population, but margin against accidents that might
would be equivalent to approximately from increased use of natural gas, as an result from unknown damage or
$53.25 million per year. RSPA/OPS environmentally desirable fuel, for degradation mechanisms. The proposed
does not expect that this rule will generating electricity and other requirements would result in operators
eliminate all accidents on natural gas industrial uses. Inability to meet these inspecting for, identifying, and
transmission pipelines that would result increased demands will challenge our remediating such damage. RSPA/OPS
in deaths, serious injuries, or property nation’s ability to realized desired has experience, through the Risk
damage. RSPA/OPS does expect that the environmental goals. Management Demonstration Program,
proposed rule will significantly reduce RSPA/OPS discussed the draft that indicates that the improved
the frequency and consequences of such regulatory analysis with the Technical confidence in pipeline integrity afforded
accidents. The magnitude of the Pipeline Safety Standards Committee by the type of integrated integrity
expected reduction cannot now be (TPSSC) at a public meeting on July 18, management program required by this
estimated with certainty. RSPA/OPS 2002. The TPSSC, composed equally of rule can lead RSPA/OPS to allow
concludes, however, that the reduction representatives of industry, government, operation at higher pressures in these
will be significant. and groups representative of public areas. Down the road with the program,
RSPA/OPS notes that the involvement in pipeline safety issues, applying that experience may make it
consequences of future accidents, in the provided numerous comments on the possible for RSPA/OPS to approve
absence of any new actions to improve draft analysis. Industry members of the operation of pipelines in some areas at
pipeline safety, would likely be higher TPSSC indicated that, to a much greater higher pressures, allowing additional
natural gas to be supplied by the risks in the most effective manner. This strengthening the pipeline system and
existing infrastructure. (The particular integrity-based approach provides a reducing the public’s exposure to risk.
circumstances of each area would have good opportunity to improve industry RSPA/OPS does not believe that
to be taken into account in deciding performance and assure that these high requiring this comprehensive process,
whether operation at increased pressure consequence areas get the protection including the re-assessment of pipelines
is acceptable). they need. in high consequence areas at the
The quantitative estimates of benefits A particularly significant benefit is proposed intervals, will be an undue
also considers only direct effects, i.e., the quality of information that will be burden on natural and other gas
damages caused by the explosion and gathered as a result of this proposal to transmission pipeline operators covered
fire resulting from a natural gas aid operators’ decisions about providing by this proposal. RSPA/OPS believes
transmission pipeline rupture. There are additional protections. Two essential the added security this assessment will
other consequences of such accidents elements of the integrity management provide and the generally expedited rate
that can be avoided or prevented. program are that an operator continually of strengthening the pipeline system in
Unplanned business interruption can assesses and evaluates the pipeline’s populated areas is benefit enough to
have a severe economic impact on the integrity, and performs an analysis that promulgate these requirements.
area in which an accident occurs. integrates all available information
Regulatory Flexibility Act
Temporary cessations in operation, about the pipeline’s integrity. The
longer term pressure restrictions, and process of planning, assessment and Under the Regulatory Flexibility Act
repair efforts often require interruption evaluation will provide operators with (5 U.S.C. 601 et seq. RSPA/OPS must
of natural gas supply to some customers. better data on which to judge a consider whether this rulemaking
In some areas, this can include entire pipeline’s condition and the location of would have a significant impact on a
communities that may be served by sole potential problems that must be substantial number of small entities.
source laterals receiving gas from addressed. RSPA/OPS estimates that there are 668
transmission lines in the vicinity of the Integrating this data with the safety gas transmission operators that could
accident. Interruption of natural gas concerns associated with high potentially be impacted by this
service has both economic and safety consequence areas will help prompt proposed rulemaking. This data comes
consequences. Service must be restored operators and the Federal and state from RSPA/OPS user fee data base. A
in a controlled manner to avoid governments to focus time and pipeline company would be impacted if
subsequent explosions from natural gas resources on potential risks and its pipeline could effect a high
escaping into businesses and residences consequences that require greater consequence area (HCA). HCA’s are
from open pilot valves. Gas distribution scrutiny and the need for more intensive located primarily urban areas but
company employees must enter each preventive and mitigation measures. If include rural areas where more than 20
customer’s premises, isolate pilot baseline and periodic assessment data is people congregate.
valves, purge piping of air that may not evaluated in the proper context, it The Small Business Administration
have become entrained, and relight pilot is of little or no value. It is imperative (SBA) defines small entities in the gas
lights. This is a labor intensive effort that the information an operator gathers transmission industry as those with
that can take several days for a is assessed in a systematic way as part revenues of less than $6 million
moderately-sized community. An of the operator’s ongoing examination of annually. RSPA/OPS does not collect
integrity management program will all threats to the pipeline integrity. The information on operator revenues. The
allow an operator to identify and repair proposed rule is intended to accomplish Census Bureau however does collect
defects that could lead to accidents that. data on natural gas transmission
before they occur. Since these tests and The proposed rule has also stimulated pipeline companies. Natural gas
repairs can be planned, their the pipeline industry to develop transmission companies are listed under
performance can be done at the supplemental consensus standards to North American Industry Classification
optimum time to minimize detrimental support risk-based approaches to System (NAICS) 486210 Pipeline
effects on businesses, homes and supply integrity management. These standards Transmission of Natural Gas. The 1977
generally. will lead to better quality control on a Census lists 1,450 establishments.
Consistent with RSPA/OPS practice, national basis, particularly important in Establishments in the case of gas
much of the proposed rule is written in the area of using new assessment transmission companies means unique
performance-based language. This technologies where correct application pipelines. Seven hundred and fifty two
approach stimulates the development is critical to achieving the desired safety of these establishments have revenues
and use of new technologies for outcome. Without such standards, there under $5 million annually. These
assessing pipeline integrity which may have been instances of incorrect establishments are aggregated into firms.
allow more accurate detection of application of assessment technology NAICS 486210 has 155 firms. Seventy-
problems that can now be found or leading to incidents. These and future one of these firms have revenues of less
detection of problems that have incidents of this type can be avoided. than $5 million annually and could be
heretofore been difficult to find. The proposed rule provides for a considered small entities under the
The performance approach also verification process, which gives the SBA.
results in supporting operators’ regulator a better opportunity to It is evident from the discussion
development of more formal, structured influence the methods of assessment above that several of the 668
risk evaluation programs and RSPA/ and the interpretation of results. RSPA/ transmission operators reporting to
OPS’s evaluation of the programs. Most OPS will provide a beneficial challenge RSPA/OPS are in fact establishments
important, the performance approach to the adequacy of an operator’s and not firms. RSPA/OPS does not have
encourages a balanced program, decision process. Requiring operators to information on how many unique firms
addressing the range of prevention and use the integrity management process, there are among the establishments that
mitigation needs and avoiding reliance and having regulators validate the report.
on any single tool or overemphasis on adequacy and implementation of this RSPA/OPS does not have detailed
any single cause of failure. This will process, should expedite the operators’ information on the number of small
lead to addressing the most significant rates of remedial action, thereby entities in the gas transmission industry.
Some of the companies in the Census designed to require operators of gas annually. Finally RSPA/OPS estimates
Bureau’s figures are gas distribution transmission pipelines to develop a it will take operators with 40 or more
companies that have transmission lines program to provide direct integrity miles of pipeline 1020 hours to annually
that serves their gas distribution testing and evaluation of gas integrate the necessary data. It will take
business. Many of these transmission transmission pipelines in high operators with less than 40 miles of
lines that serve gas distribution consequence areas. pipeline approximately 255 hours to
companies may be in HCA’s. Other The following is a summary of the annually integrate the necessary data.
limited mileage transmission lines serve highlights of the paperwork reduction Comments concerning this
the fuel needs of one industrial plant. act analysis. The complete analysis can information collection should include
Many of these industrial transmission be found in the public docket. the docket number of this proposal.
lines may be in rural areas and outside There are 668 gas transmission They should be sent to Docket Facility,
the scope of this proposed rule. operators that could potentially be U.S. Department of Transportation,
RSPA/OPS has never received subject to this proposed rule. It is Plaza 401, 400 Seventh Street, SW,
comments from small gas transmission estimated that 296 of these gas Washington, DC 20590–0001.
operators concerning the burdens of its transmission operators have 40 or more Comments are specifically requested
regulations. While RSPA/OPS believes miles of pipeline. The remaining 372 concerning:
that the costs of this proposal will be operators have less than 40 miles of Whether the collection is necessary
proportionate to the amount of mileage pipeline. It is estimated that the for the proper performance of the
the pipeline company operates RSPA/ operators with more than 40 miles of functions of the Department, including
OPS, seeks public input on any pipeline will have considerably more whether the information would have a
potential undue impact that this time and expense to develop integrity practical use;
proposal would have on any small management programs. However, before The accuracy of the Department’s
entities. operators can develop integrity estimate of the burden of collection of
INGAA estimates that its members management programs they must information including the validity of
account for 80% of the gas pipeline determine how much of their pipeline is assumptions used;
transmission mileage in the United located in high consequence areas The quality, usefulness and clarity of
States. INGAA has only 24 members (HCA’s). It is estimated that it will take the information to be collected; and
however, 3 of these members are not the operators with 40 or more miles of minimizing the burden of collection of
U.S. gas transmission operators. pipeline 1,000 hours to estimated the information on those who are to
Therefore, approximately 21 companies amount of pipeline impacted. Operators respond, including through the use of
account for 80% of the U.S. gas with less than 40 miles of pipeline will appropriate automated electronic,
transmission pipeline mileage. The take only 250 hours. mechanical, or other technological
remainder of the pipeline companies in It is estimated that operators with 40 collection techniques or other forms of
this industry share only 20% of the total or more miles of pipeline will need information technology e.g., permitting
pipeline mileage. 3,968 hours to develop an integrity electronic submission of responses.
Because the remaining companies management plan framework. For According to the Paperwork
have relatively small mileage compared operators with less than 40 miles of Reduction Act of 1995, no persons are
to the top 20, many may fall entirely pipeline it is estimated this task will required to respond to a collection of
outside of HCA’s, and will therefore not take 2,400 hours. However, it is information unless a valid OMB control
be impacted by this proposed rule. estimated that 25% of the companies number is displayed. The valid OMB
However, if they are impacted by this with more 40 miles or more of pipeline control number for this information
proposal, their costs of compliance will already have integrity management collection will be published in the
be significantly lower than those with program frameworks. Federal Register after it is approved by
thousands of miles of pipeline as the Additionally, all the operators will be the OMB. For details see, the complete
costs of inspection and planning should required to integrate the new data they Paperwork Reduction analysis available
be considerably lower. Nevertheless, collect into their current management for copying and review in the public
RSPA/OPS stands ready to provide systems. The time to integrate the data docket.
special help to any small operators to the first year will be 2,040 hours for the
assist them in complying with this companies with 40 or more miles of Executive Order 13084
proposed rule. Based on the above pipeline and 510 hours for companies This proposed rule has been analyzed
discussion I certify that this proposed with less than 40 miles of pipeline. It is in accordance with the principles and
rule will not have a significant impact estimated that 25% of all operators with criteria contained in Executive Order
on a substantial number of small 40 or more miles of pipeline already 13084 (‘‘Consultation and Coordination
entities. have a system for integrate their data. with Indian Tribal Governments’’).
It will take operators initially, Because this proposed rule does not
Paperwork Reduction Act approximately 16 hours of a computer significantly or uniquely affect the
This proposed rule contains programmer’s time to provide OPS and communities of the Indian tribal
information collection requirements. As state pipeline safety offices ‘‘real time’’ governments and does not impose
required by the Paperwork Reduction access to their performance measures substantial direct compliance costs, the
Act of 1995 (44 U.S.C. 3507(d)), the via the operator’s web site or a dial-up funding and consultation requirements
Department of Transportation has modem. of Executive Order 13084 do not apply.
submitted a copy of the Paperwork The integrity management plans need
Reduction Act analysis to the Office of to be modified on a yearly basis. RSPA/ Executive Order 13132
Management and Budget for its review. OPS estimates that it will take all This proposed rule has been analyzed
The name of the information collection operators regardless of size 313 hours in accordance with the principles and
is ‘‘Pipeline Integrity Management in per year to update their plans annually. criteria contained in Executive Order
High Consequence Areas Gas RSPA/OPS further estimates it will take 13132 (‘‘Federalism’’). This proposed
Transmission Pipeline Operators.’’ The an additional 160 hours per operator to rule does not propose any regulation
purpose of this information collection is perform the necessary record keeping that:
(1) Has substantial direct effects on significant adverse effects on energy assessed. The reason for this is because
the States, the relationship between the supply, distribution, or use. internal inspection devices are inserted
national government and the States, or The proposed rule will not have any and removed from the pipeline segment
the distribution of power and significant impact on the wellhead near compressor stations which are up
responsibilities among the various production capacity or prices. The to 50 miles apart. The HCAs may be
levels of government; proposed rule affects natural gas only a few miles of this entire 50 mile
(2) Imposes substantial direct transmission lines in high consequence section. The industry maintains that
compliance costs on States and local areas (HCAs) and has no effect on the 50% of all lines or approximately
governments; or wellhead production capacity or prices. 150,000 miles of all gas pipelines will
(3) Preempts state law. The proposed rule does not impact be internally inspected. If this is correct
Therefore, the consultation and gathering lines and offshore then, temporary impact on local gas
funding requirements of Executive transmission lines, and has limited supplies may be realized. While RSPA/
Order 13132 (64 FR 43255; August 10, effect on the onshore transmission lines OPS did not estimate the size of such
1999) do not apply. Nevertheless, in that are not located in the HCAs. temporary impacts it could lead to small
November 18–19, 1999, and in February Therefore, the proposed rule will have changes in natural gas prices for certain
12–14, 2001 public meetings, RSPA/ no significant impact on natural gas areas on the spot market. Not
OPS invited National Association of production or wellhead prices. RSPA/ withstanding possible temporary price
Pipeline Safety Representatives OPS estimates that the proposed rule fluctuations in the spot market, RSPA/
(NAPSR), which includes State pipeline will directly affect 42,268 miles of OPS believes the proposed regulation
safety regulators, to participate in a transmission lines in a network of will not significantly impact the overall
general discussion on pipeline integrity. 300,000 miles of transmission lines, as energy supply, distribution, and use.
Since then, RSPA/OPS has held well as 900,000 miles of distribution
lines. Therefore, a relatively small Unfunded Mandates
conference calls with NAPSR, to receive
their input before proposing an HCA proportion of pipelines will be affected This proposed rule does impose
definition and integrity management by the proposed rule. unfunded mandates under the
The proposed rule may affect the
rule. Unfunded Mandates Reform Act of
movement of natural gas in certain areas
1995, because it may result in the
Executive Order 13211 during integrity inspection. Inspection
expenditure by the private sector of 100
This rulemaking is not a ‘‘significant requirements may temporarily affect
million or more in any one year. The
transportation capacity in some
energy action’’ within the meaning of cost-benefit analysis estimating yearly
pipelines. Built-in redundancies, such
Executive Order 13211 (‘‘Actions cost for operators to meet the proposed
as, loop lines, multiple lines, storage
Concerning Regulations That rule requirements has been placed in
facilities, are part of natural gas
Significantly Affect Energy Supply, the docket. State regulators have
transportation infrastructures. The
Distribution, or Use’’). It is a significant participated in our meetings with the
intricate interconnections between
regulatory action under Executive Order industry and research institutions on
pipelines, the availability of storage at
12866 because of its significant public various integrity management issue
the market centers, and a well-
and government interest. As concluded discussions and have provided
developed capacity release market all
from our Energy Impact Statement recommendations during our meetings
contribute towards meeting natural gas
below it is not likely to have a demand with efficient movement of and conference calls. We believe it is
significant adverse effect on the supply, supply. Most inspections can be the least burdensome alternative that
distribution, or use of energy. Further, conducted without any significant achieves the objective of the rule,
this rulemaking has not been designated disruption of throughput especially because it gives options to industry on
by the Administrator of the Office of during off-peak seasons. how to implement the rule.
Information and Regulatory Affairs as a The proposed rule may not have any
significant energy action. National Environmental Policy Act
significant price effects on end-use
Summary of the Energy Impact consumers. In general, inter-fuel We have evaluated the proposed rule
Statement competition and gas-storage availability for purposes of the National
play significant roles in short-term price Environmental Policy Act (42 U.S.C.
(For a detailed Energy Impact determination in U.S. because of 4321 et seq.) and have preliminarily
Statement, please refer to Docket RSPA– extensive fuel switching capability in concluded that this action would not
00–7666) industry and power generation and the significantly affect the quality of the
RSPA/OPS is currently proposing existence of a sizable storage capacity. human environment. The
regulations to assess, evaluate, Weather is the other significant player Environmental Assessment determined
remediate, and validate the integrity of determining the spot market prices. that the combined impacts of the
natural gas transmission pipelines Transportation cost only accounts for a baseline assessment (pressure testing,
through comprehensive analysis and small proportion of the cost paid by the internal inspection, or direct
inspection of pipeline systems. The end-users. The pipeline capacity assessment), the periodic reassessments,
proposed rule applies to all gas reduction due to the proposed integrity and the additional preventive and
transmission lines, including lines rule may to a large extent be pre- mitigative measures that may be
transporting petroleum gas, hydrogen, planned and the market would have implemented for gas pipeline segments
and other gas products covered under time to adjust for the reduction, that could affect high consequence areas
49 CFR Part 192. minimizing shortages and avoiding will result in positive environmental
In compliance with the Executive short-term price increases. impacts. The number of incidents and
Order 13211 (66 FR 28355), RSPA/OPS However, because the percentage of the environmental damage from failures
has evaluated the effects of proposed assessments that the industry maintains near high consequence areas is likely to
rule on energy supply, distribution, or will be done by internal inspection, be reduced. However, from a national
use. RSPA/OPS has determined that this much more than 42,268 miles of perspective, the impact is not expected
proposed regulatory action will not have pipeline cited earlier may in fact be to be significant.
Although the effects of the proposed protection to high consequence areas, pipeline’s integrity. The process
rule will likely lead to fewer incidents, and that the small additional risk includes the gathering and integration of
gas pipeline leaks that lead to adverse reduction benefits of additional risk risk factor data, indirect examination or
environmental impacts are rare under controls are not justified. analysis to identify areas of suspected
current conditions. Although the The primary benefit of the proposed corrosion, direct examination of the
damage from failures could be reduced, rule will be to establish requirements for pipeline in these areas, and post
the environmental damage resulting conducting integrity assessments and assessment evaluation.
from gas pipeline failures is usually periodic evaluations of integrity of High consequence area means any of
minor under current conditions. The segments that could impact high the following areas:
effects are typically negligible, but can consequence areas. This will codify the (a) An area defined as a Class 3
consist of localized, temporary damage integrity management programs and location under § 192.5, except for an
to the environment in the immediate assessments operators are currently area within the class 3 location defined
vicinity of the failure location on the implementing. It will also require other as a moderate risk area.
pipeline. operators, who have little, or no, (b) An area defined as a Class 4
Some operators covered by the integrity assessment and evaluation location under § 192.5, except for an
proposed rule already have integrity programs to raise their level of area with the class 4 area defined as a
assessment programs. These operators performance. Thus, the proposed rule is moderate risk area.
typically consider the pipeline’s expected to ensure a more consistent, (c) * * *
proximity to populated areas when and overall higher level of protection for (d) * * *
making decisions about where and high consequence areas across the (e) * * *
when to inspect and test pipelines. As industry. (f) * * *
a result, some pipeline segments that The Environmental Assessment of (g) An area of a circle of threshold
could impact high consequence areas this proposed rule is available for radius 1000 feet or larger that has a
have already been recently assessed, review in the docket. cluster of 20 or more buildings intended
and others would be assessed in the for human occupancy. The threshold
next several years without the List of Subjects in 49 CFR Part 192 radius is measured from the centerline
provisions of the proposed rule. The High consequence areas, potential of the pipeline to the nearest building in
primary effect of the proposed rule— impact areas, pipeline safety, and the cluster.
accelerating integrity assessment in record-keeping requirements. Moderate risk area means an area
some high consequence areas—shifts In consideration of the foregoing, located within a Class 3 or Class 4
increased integrity assurance forward RSPA/OPS proposes to amend part 192 location, but not within the potential
for a few years for some segments that of title 49 of the Code of Federal impact zone.
could affect high consequence areas. Regulations as follows: Potential impact circle is a circle of
Because pipeline failure rates are low, radius equal to the threshold radius and
shifting the time at which these PART 192—[AMENDED] is used to establish the higher priority
segments are assessed forward by a few area within a Class 3 or 4 area of a high
years has only a small effect on the 1. The authority citation for part 192 consequence area. A potential impact
likelihood of pipeline failure in these continues to read as follows: circle contains any of the following
locations. Authority: 49 U.S.C. 5103, 60102, 60104, within its radius (refer to the diagram in
The proposed rule does require 60108, 60109, 60110, 60113, and 60118; and Appendix E):
operators to conduct an integrated 49 CFR 1.53. (1) Twenty or more buildings
assessment of the potential threats to 2. In subpart M, under the intended for human occupancy within a
pipeline integrity, and to consider undesignated centerheading ‘‘High 1000-foot or larger circle of radius;
additional preventive and mitigative Consequence Areas,’’ in § 192.761, in (2) A facility that is occupied by
risk control measures to provide the definition beginning ‘‘A high persons who are hard to evacuate as
enhanced protection. If there is a consequence area,’’ the word ‘‘A’’ is defined in § 192.761 no matter the size
vulnerability to a particular failure removed, paragraphs (a) and (b) are of the circle of radius; or
cause, these assessments should result revised, paragraph (g) is added, and new (3) A place where people congregate
in additional risk controls to address definitions of Confirmatory direct as defined in § 192.761, no matter the
these threats. However, without assessment, Direct assessment, size of the circle of radius.
knowing the specific high consequence Moderate risk area, Potential impact Potential impact radius (PIR) means
area locations, the specific risks present circle, Potential impact radius, Potential the radius of a circle within which the
at these locations, and the existing impact zone, and Threshold radius are potential failure of a pipeline could
operator risk controls (including those added alphabetically to read as follows: have significant impact on people or
that surpass the current minimum property. PIR is determined by the
regulatory requirements), it is difficult § 192.761 Definitions. formula r = 0.69 * (square root of
to determine the impact of this The following definitions apply to (p*d2)), where ‘‘r’’ is the radius of a
requirement. this section and § 192.763: circular area surrounding the point of
Some gas pipeline operators already Confirmatory direct assessment is a failure (ft), ‘‘p’’ is the maximum
perform integrity evaluations or risk streamlined integrity assessment allowable operating pressure (MAOP) in
assessments that consider the method that utilizes process steps the pipeline segment (psi) and ‘‘d’’ is
environmental and population impacts. similar to direct assessment to evaluate the diameter of the pipeline (inches).
These evaluations have already led to for the presence of corrosion and third Note: 0.69 is the factor for natural gas.
additional risk controls beyond existing party damage. This number will vary for other gases
requirements to improve protection for Direct assessment is an integrity depending upon their heat of
these locations. For many segments, it is assessment method that utilizes a combustion. An operator transporting
probable that operators will determine process to evaluate certain threats (i.e., gas other than natural gas must use
that the existing preventive and external corrosion, internal corrosion Section 3.2 of ASME/ANSI B31.8S to
mitigative activities provide adequate and stress corrosion cracking) to a calculate the impact radius formula.
(See Appendix A to this part 192 for threshold radius for each covered features of both a performance-based
incorporation by reference and pipeline segment, and any process and and a prescriptive integrity management
availability information.) factors used in determining the program. An operator that uses a
Potential impact zone is a rectangular potential impact zone. performance-based approach that
area along the pipeline derived from the (ii) Develop a framework addressing satisfies the requirements in paragraph
potential impact circle. The potential each element required to be in an (c)(5)(i) may deviate from certain
impact zone extends axially along the integrity management program, that requirements in this section, as
length of the pipeline from the center of includes a plan for baseline assessment provided in paragraph (c)(5)(ii).
the first potential impact circle to the of the line pipe (see paragraphs (e) and (i) Exceptional performance. To
center of the last contiguous potential (g) of this section), and a plan for deviate from any of the requirements set
impact circle, and extends continual integrity assessment and forth in paragraph (c)(5)(ii), an operator
perpendicular to the pipe out to the evaluation (see paragraphs (d) and (k) of must have completed a baseline
threshold radius on either side of the this section). The framework must assessment of all pipeline segments
centerline of the pipe. (Refer to the document how decisions will initially covered by this section, in accordance
diagram in Appendix E). be made to implement each program with paragraph (g) of this section, and
Threshold radius is an additional area element, and planned near-term at least one other assessment. An
of safety beyond the distance calculated improvements to program elements and operator must remediate all anomalies
as the potential impact radius. If the decision processes. identified in the second assessment
calculated potential impact radius is (iii) Develop a plan that describes according to the requirements in
less than 300 feet, the operator must use how the operator will use direct paragraph (i), and incorporate the
a threshold radius of 300 feet. If the assessment as part of its integrity results and lessons learned from the
calculated potential impact radius assessment (see paragraph (h) of this second assessment into the operator’s
exceeds 300 feet but is less than 660 section), to include identification of risk model. An operator must also
feet, the threshold radius is 660 feet. If External Corrosion Direct Assessment demonstrate that it has an exceptional
the calculated potential impact radius Regions and Internal Corrosion Direct integrity management program that
exceeds 660 feet, but is less than 1000 Assessment Regions. This requirement meets the performance-based
feet, the threshold radius is 1000 feet. only applies to an operator that plans to requirements of ASME/ANSI B31.8S,
And, if the calculated potential impact use direct assessment. has a history of measurable performance
(iv) Develop a process for continual improvement, and includes, at
radius exceeds 1000 feet, the threshold
improvement of the framework into an minimum—
radius is 15% greater than the actual
ongoing integrity management program. (A) A state-of-the-art process for risk
calculated impact radius. (2) Time period. An operator must
3. A new § 192.763 is added under a analysis;
complete the requirements of paragraph (B) All risk factor data used to support
new undesignated centerheading of (c)(1) no later than [12 months from the
‘‘Pipeline Integrity Management’’, in the program;
effective date of the final rule]. (C) A state-of-the-art data integration
subpart M to read as follows: (3) Implementation. An operator must process;
Pipeline Integrity Management implement and follow the program it (D) A process that applies lessons
develops. In carrying out this section, an learned from assessment of covered pipe
§ 192.763 Pipeline integrity management in operator must follow the requirements
high consequence areas.
segments to pipe segments not covered
of this section and of ASME/ANSI by this section;
(a) Which operators must comply? B31.8S, and its appendices, where (E) A process for evaluating all
This section applies to each operator specified. (See Appendix A to this part incidents, including their causes, within
who owns or operates a transmission 192 for incorporation by reference and the operator’s sector of the pipeline
line that transports gas, including, availability information.) An operator industry for implications both to the
petroleum gas, hydrogen, or other gas may follow an equivalent standard or operator’s pipeline system and to the
product covered under this part. practice only when the operator operator’s integrity management
(b) Which pipeline segments are demonstrates the alternative standard or program;
covered? practice provides an equivalent level of (F) A performance matrix that
Transmission pipeline segments as safety to the public and property. In the confirms the continuing performance
defined in § 192.3 that are in a high event of a conflict between this section improvement realized under the
consequence area, as defined in and ASME/ANSI B31.8S, the performance-based program;
§ 192.761. requirements in this section control. (G) A set of performance measures
(c) What must an operator do? (4) Program changes. An operator beyond those required in paragraph (l)
(1) General requirements. No later must document, prior to implementing of this section that are part of the
than [one year from the effective date of any change to its program, any change operator’s performance plan (see
the final rule], an operator must develop to the program and reasons for the paragraph (d)(1)(viii)) and are made
and follow a written integrity change. In addition, an operator must accessible in real time to OPS and state
management program that addresses the notify OPS in accordance with pipeline safety enforcement officials;
risks on each pipeline segment covered paragraph (n) of this section of any (H) An analysis that supports the
by this section. An operator must— change to the program that substantially desired integrity reassessment interval
(i) Identify all high consequence areas affect the program’s implementation or and the remediation methods to be used
as defined in § 192.761, and identify the significantly modifies the program or for all pipe segments.
potential impact zone within each high schedule for carrying out the program (ii) Deviation. Once an operator has
consequence area. Based on the elements. An operator must provide the demonstrated that it has satisfied the
identification of the potential impact notification within 30 days after requirements of paragraph (c)(5)(i), the
zone within Class 3 and Class 4 adopting this type of change into its operator may deviate from the
locations, identify all moderate risk program. prescriptive requirements of ASME/
areas. The identification must include (5) Performance-based option. ASME/ ANSI B31.8S and of this section only in
the calculation used in determining the ANSI B31.8S provides the essential the following instances.
(A) The time frame for reassessment (ix) Record keeping requirements explanation of why the assessment
as provided in paragraph (k), except that meeting the requirements of paragraph method was selected to address the
reassessment by some method (e.g., (m) of this section. identified threats to each covered
confirmatory direct assessment) must be (x) A management of change process segment. The integrity assessment
carried out at intervals no longer than as outlined in ASME/ANSI B31.8S, method an operator uses must be based
seven years; Section 11. on the threats identified to the segment
(B) Direct assessment as a primary (xi) A quality assurance process as (see paragraph (f) of this section). More
assessment method without having to outlined in ASME/ANSI B31.8S, than one method may be required to
meet the conditions specified in Section 12. address all the threats to the pipeline
paragraph (h)(1); and (xii) A communication plan that segment;
(C) The time frame for remediation as includes the elements of ASME/ANSI (3) A schedule for completing the
provided in paragraph (i). B31.8S, Section 10, and that includes a integrity assessment of all covered line
process for addressing safety concerns segments, including, risk factors
(d) What are the elements of an
raised by OPS, including safety considered in establishing the
integrity management program?
concerns OPS raises on behalf of a State assessment schedule;
(1) General. An operator’s initial or local authority with which OPS has (4) If applicable, a direct assessment
integrity management program an interstate agent agreement. plan that meets the requirements of
framework and subsequent integrity (xiii) A process for providing, by paragraph (h) of this section.
management program must, at electronic or other means, a copy of the (5) A process describing how the
minimum, contain the following operator’s integrity management operator is ensuring that the baseline
elements. (When indicated, refer to program to a State authority with which assessment is being conducted in a
ASME/ANSI B31.8S for more detailed OPS has an interstate agent agreement. manner that minimizes environmental
information on the listed element.) (xiv) A process for ensuring that each and safety risks.
(i) An identification of covered integrity assessment is being conducted (f) How does an operator identify
pipeline segments and the potential in a manner that minimizes potential threats to pipeline integrity?
impact zone for each segment. An environmental and safety risks. (1) Threat identification. An operator
identification includes a calculation of (2) Training. (i) Supervisory must identify and evaluate all potential
the potential impact radius and personnel. An operator’s integrity threats to each covered pipeline
threshold radius for each segment. management program must provide that segment. Potential threats that an
(ii) A baseline assessment plan each supervisor possesses and operator must consider include, but are
meeting the requirements of paragraphs maintains a thorough knowledge of the not limited to, the threats listed in
(e) and (g) of this section. operator’s integrity management ASME/ANSI B31.8S , section 2 and the
(iii) An identification of threats to program and the elements for which the following:
each covered pipeline segment, which supervisor is responsible. The program (i) Time dependent threats such as
includes a risk assessment to evaluate must provide that any person who internal corrosion, external corrosion,
the failure likelihood of each covered qualifies as a supervisor for the integrity and stress corrosion cracking;
segment. An operator will use the threat management program has appropriate (ii) Static or resident threats, such as
identification and risk assessment to training or experience in the area for fabrication or construction defects;
prioritize segments for assessment which the person is responsible. (iii) Time independent threats such as
(paragraphs (g) and (k)) and evaluate the (ii) Persons who evaluate. An third party damage and outside force
merits of additional preventive and operator’s integrity management damage; and
mitigative measures (paragraph (j)). The program must provide criteria for the (iv) Human error.
identification and risk assessment qualification of persons who review and (2) Data gathering and integration. To
process must comply with the analyze results from integrity identify and evaluate the potential
requirements in paragraph (f) of this assessments and evaluations. These threats to a covered pipeline segment,
section. criteria include criteria for persons who an operator must gather and integrate
carry out and interpret the results from data and information on the entire
(iv) A direct assessment plan, if
the direct assessment process. pipeline that could be relevant to the
applicable, meeting the requirements of
(3) Newly-identified areas. The covered segment. In performing this
paragraph (h) of this section.
program must provide for identification data gathering and integration, an
(v) Provisions meeting the operator must follow the requirements
and assessment of newly-identified high
requirements of paragraph (i) of this in ASME/ANSI B31.8S, section 4. At a
consequence areas. When an operator
section for remediating conditions minimum, an operator must gather and
has information that the area around a
found during an integrity assessment. evaluate the set of data specified in
pipeline segment satisfies any of the
(vi) A process for continual evaluation definitions for high consequence areas Appendix SP–A to ASME/ANSI B31.8S,
and assessment meeting the in § 192.761, the operator must and consider both on the covered
requirements of paragraphs (h)(6) and incorporate the area into its integrity segment and similar segments, past
(k) of this section. If applicable, the management program within one year incident history, corrosion control
process must include a plan for from the date the area is identified. records, continuing surveillance
confirmatory direct assessment meeting (e) What must be in the baseline records, patrolling records, maintenance
the requirements of paragraph (h)(6). assessment plan? An operator must history, and all other conditions specific
(vii) Preventive and mitigative include each of the following elements to each pipeline.
measures meeting the requirements of in its written baseline assessment plan: (3) Risk assessment. An operator is to
paragraph (j) of this section. (1) Identification of the potential conduct a risk assessment on each
(viii) A performance plan as outlined threats to each of the covered pipeline covered segment that follows ASME/
in ASME/ANSI B31.8S, Section 9 that segments. (See paragraph (f) of this ANSI B31.8S, section 5, and uses the
includes performance measures meeting section); threats identified for each segment. An
the requirements of paragraph (l) of this (2) The methods selected to assess the operator will use the risk assessment to
section. integrity of the line pipe, including an prioritize the segments for the baseline
and continual re-assessments inspection tools, such as deformation or in conducting the baseline assessment
(paragraphs (e), (g) and (k) of this geometry tools. An operator may use of the covered segments.
section), and in determining what direct assessment as the primary (i) Internal inspection or pressure test.
additional preventive and mitigative assessment method for third party An operator that uses an internal
measures are needed (paragraph (j) of damage only if no other approach is inspection tool or pressure test as an
this section). feasible, and it is combined with data integrity assessment method must
(g) How is the baseline assessment to collection and integration to evaluate comply with the following time periods
be conducted? segment susceptibility to third party for conducting the assessment.
(1) Assessment methods. An operator damage. An operator that does not use (A) Unless the exception in paragraph
must assess the integrity of the line pipe a geometry tool for the internal (g)(4)(i)(B) of this section applies, an
in each covered segment by applying inspection or uses direct assessment operator using a pressure test or internal
one or more of the following methods must excavate and directly examine all inspection tool as an assessment method
depending on the threats to which the indications that could be the result of must complete the baseline assessment
segment is susceptible. An operator third party damage. by December 17, 2012. An operator
must select the method or methods best (ii) Cyclic fatigue. An operator must must assess at least 50% of the line pipe
suited to address the threats identified evaluate whether cyclic fatigue or other being assessed by either of these
to the segment (See paragraph (f) of this loading condition (including ground methods beginning with the highest risk
section). movement, suspension bridge pipe, by December 17, 2007. An
(i) Internal inspection tool or tools condition) necessitates a periodic operator must prioritize segments for
capable of detecting corrosion, and any assessment for dents and gouges. An assessment in accordance with
other threats to which the pipe segment evaluation must assume the presence of paragraphs (f)(3) and (g)(2) of this
is susceptible. An operator must follow deep dents, and determine whether section, giving highest priority to those
ASME/ANSI B31.8S in selecting the loading conditions would lead to failure segments located in the potential impact
appropriate internal inspection tools. of such hypothesized dents. An operator zone (refer to Appendix E for guidance).
(ii) Pressure test conducted in (B) An operator using a pressure test
must use the results from an evaluation
accordance with subpart J of this part; or internal inspection tool as an
together with the criteria used to
(iii) Direct assessment to address assessment method on a pipeline
evaluate the significance of this threat.
threats of external corrosion, internal segment located in a moderate risk area
(iii) Manufacturing and construction (an area within a Class 3 or Class 4
corrosion, and stress corrosion cracking.
defects. To address manufacturing and location, but not within the potential
An operator must conduct the direct
construction defects (including seam impact zone), must complete the
assessment in accordance with ASME/
defects), an operator must perform a baseline assessment by December 17,
ANSI B31.8S and paragraph (h) of this
pressure test at least once in the life of 2015.
section;
the segment unless the operator (ii) Direct assessment. An operator
(iv) Other technology that an operator
demonstrates why pressure testing is that uses direct assessment as an
demonstrates can provide an equivalent
not necessary to address this threat. If integrity assessment method must
understanding of the condition of the
an operator does not perform a pressure comply with the following time periods
line pipe. An operator choosing this
test, and at anytime the historic for conducting the assessment.
option must notify the Office of Pipeline
operating pressure or other stress (A) Unless the exception in paragraph
Safety (OPS) 180 days before conducting
condition changes, including any (g)(4)(ii)(B) applies, an operator using
the assessment, in accordance with
condition that affects cyclic fatigue, the direct assessment as an assessment
paragraph (n) of this section.
(2) Prioritizing segments. An operator operator must, prior to changing the method must complete the baseline
must prioritize the covered pipeline stress condition, assess the pipeline assessment by December 17, 2009. An
segments for the baseline assessment using an assessment method allowed by operator must assess at least 50% of the
according to a risk analysis that this section. line pipe being assessed by this method,
considers the potential threats to each (iv) ERW pipe. The methods an beginning with the highest risk pipe, by
segment. The risk analysis must comply operator selects to assess low frequency December 17, 2006. Direct assessment
with the requirements in paragraph (f) electric resistance welded pipe or lap must be carried out in accordance with
of this section. welded pipe susceptible to seam failures paragraph (h) of this section. An
(3) Assessment for particular threats. must be capable of assessing seam operator must prioritize segments for
In choosing an assessment method for integrity and of detecting seam assessment in accordance with
the baseline assessment, an operator corrosion anomalies. paragraphs (f)(3) and (g)(2) of this
must take the following actions to (v) Corrosion. If an operator finds section, giving highest priority to those
address particular threats that it has corrosion on a covered pipeline segment segments located in the potential impact
identified. (See paragraph (f) of this that could adversely affect the integrity zone (refer to Appendix E for guidance).
section). of the line (conditions specified in (B) An operator using direct
(i) Third party damage. An operator paragraph (i)), the operator must assessment as an assessment method on
must address the third party damage conduct an integrity assessment and a pipeline segment located within a
threat through the following: remediate all pipeline segments with moderate risk area (area in a Class 3 or
(A) Preventive measures. An operator similar material coating and Class 4 location, but not within the
must implement comprehensive environmental characteristics. An potential impact zone), must complete
additional preventive measures (see operator must establish a schedule for the baseline assessment of the line pipe
paragraph (j)) to address the threat, and evaluating and remediating the similar being assessed by this method by
monitor the effectiveness of the segments that is consistent with the December 17, 2012.
preventive measures. operator’s established operating and (5) Prior assessment. An operator may
(B) Assessment tools. An operator maintenance procedures under Part 192 use an integrity assessment conducted
must assess covered segments that are for testing and repair. after December 17, 2007 as a baseline
vulnerable to delayed failure following (4) Time period. An operator must assessment, if the integrity assessment
third party damage using internal comply with the following requirements method meets the requirements of this
section. However, if an operator uses corrosion, internal corrosion, and stress accordance with paragraph (h)(3)(v) of
this prior assessment as its baseline corrosion cracking. An operator may use this section.
assessment, the operator must reassess direct assessment as the primary (J) Criteria for data gathering
the line pipe according to the assessment method for third party associated with each excavation.
requirements of paragraph (k) of this damage only if no other assessment (K) Criteria for the qualification of
section. method is feasible, and the operator persons who carry out and interpret the
(6) Newly identified areas. When the uses it in combination with data results from the direct assessment
operator has information that the area collection and integration to evaluate process (See paragraph (d)(2)(ii) of this
around a pipeline segment satisfies any the segment’s susceptibility to third section).
of the definitions in § 192.761, the party damage. (L) Criteria and measures for
operator must incorporate the area into (3) External corrosion direct evaluating the long-term effectiveness of
its baseline assessment plan as a high assessment (ECDA). An operator that the ECDA process (See paragraph
consequence area within one year from uses direct assessment as the primary (h)(3)(vii) of this section).
the date the area is identified. An method to assess external corrosion (ii) Pre-assessment. An operator using
operator must complete the baseline must follow the requirements in this ECDA must conduct a pre-assessment,
assessment of any line pipe in the newly section and in ASME/ANSI B31.8S, in which the operator analyzes and
identified high consequence area within Section 6 and Appendix SP–B. integrates the data and information
10 years (7 years if direct assessment is (i) ECDA plan. An operator using required in paragraph (f) of this section
being used) from the date the area is External Corrosion Direct Assessment to carry out the following—
identified. (ECDA) must prepare a plan that (A) Feasibility. An operator will use
(h) When can direct assessment be includes— the data to determine whether any of the
used and under what conditions? (A) A process that provides, according following conditions exists that is likely
(1) General. (i) An operator may use to the requirements of this paragraph, to preclude the effective use of ECDA.
direct assessment as a supplement to the for Pre-Assessment, Indirect If any of the listed conditions is present,
other assessment methods allowed Examination, Direct Examination, and the operator must demonstrate why the
under this section. However, an Post-Assessment. use of ECDA would be a more effective
operator may use direct assessment as a (B) Data requirements for using ECDA. method to assess external corrosion than
primary assessment method for external These must, at a minimum, include the the other assessment methods allowed
corrosion, internal corrosion, or stress data requirements for external corrosion under this section and specify the
corrosion cracking only when the specified in Appendix SP–A1 to ASME/ provisions the operator will implement
operator can demonstrate one of the ANSI B31.8S. to ensure ECDA effectiveness.
following conditions applies— (C) Criteria for evaluating ECDA
(1) The presence of a coating that
(A) The operator demonstrates that feasibility, in accordance with
causes electrical shielding;
other assessment methods allowed paragraph (h)(3)(ii)(A) of this section.
(D) Criteria for defining ECDA (2) Backfill around the pipe with
under this section can not be applied to
Regions, in accordance with paragraph significant rock content or the presence
the pipeline segment for economic or
(h)(3)(ii)(B) of this section. of rock ledges;
technological reasons;
(B) The operator demonstrates that (E) The basis on which an operator (3) Situations impeding timely above-
other assessment methods allowed selects two complementary assessment ground data gathering;
under this section would result in a tools to assess each ECDA Region. (4) Locations with adjacent buried
substantial impact on gas customers, as Guidance on selecting tools is found in metallic structures;
for example, when only one pipeline Appendix E of this part. (5) Inaccessible areas.
delivers gas to homes or local (F) Criteria for identifying and (B) ECDA Region. An operator must
businesses, and service would be documenting those indications that use the data gathered to define all ECDA
completely shut down during the must be considered for direct regions within the covered pipeline
assessment; examination. Minimum criteria include segment. ECDA regions are those
(C) The operator will excavate and the known sensitivities of assessment portions within a pipeline segment, not
conduct a direct examination of the tools, the procedures for using each tool, necessarily contiguous, that have
entire covered pipeline segment in and the approach to be used for similar physical characteristics,
accordance with the requirements of decreasing the physical spacing of operating and corrosion history,
this paragraph; or indirect assessment tool readings when expected future corrosion conditions,
(D) The covered pipeline segment the presence of a defect is suspected. and which are suitable for the same
operates at a maximum allowable (G) Criteria for characterizing indirect assessment methods. An
operating pressure below 30% SMYS. indications identified in the ECDA operator may redefine ECDA regions at
(ii) An operator using direct process. These criteria must define how any time the information the operator
assessment as a supplemental an operator will characterize an develops in conducting justifies a
assessment method must have a plan indication as severe, moderate or minor redefinition. If a condition, such as
that follows the requirements for (See paragraph (h)(3)(iv) of this section). those specified in paragraph (h)(3)(vi)(C)
confirmatory direct assessment in (H) Criteria for defining the urgency of of this section, exists for which ECDA
paragraph (h)(6) of this section. An excavation and direct examination of is ineffective at assessing, an operator
operator using direct assessment as a each indication. These criteria must must select an alternate assessment
primary assessment method must have specify how an operator will define the technology allowed under this section.
a plan that complies with the urgency of excavating the indication as (iii) Indirect examination. An
requirements for use of direct immediate, scheduled or monitored. operator’s ECDA plan must provide for
assessment in ASME/ANSI B31.8S, Monitored indications are defects that indirect examination of the ECDA
section 6.4 and in this section. are not serious and may or may not regions. In carrying out the indirect
(2) Specific threats. An operator may require direct examination. examination, an operator must follow
only use direct assessment as a primary (I) Criteria for scheduling excavation ASME/ANSI B31.8S, Appendix SP–B2
assessment method for external of each urgency level of indication, in and the requirements of this section.
(A) Unless the exception in paragraph (A) If the results from the two must excavate each scheduled action
(h)(3)(iii)(B) of this section applies, an complementary tools are not consistent indication in order of priority, until the
operator must select at least two and cannot be explained by differences operator excavates at least two
different, but complementary, indirect in the tools’ capabilities, the operator indications that have a corrosion of
examination methods, for each location must either conduct a direct depth no greater than 20% of the wall
where ECDA is to be applied along the examination or additional indirect thickness.
pipeline segment. An operator must examinations to evaluate the reasons for (D) Make a direct examination of at
select the methods that can best detect the differences. least one of the highest risk indications
external corrosion activity and holidays (B) If additional indirect inspections in an ECDA region that contains only
in the pipe coating under the conditions or direct examinations are not carried monitored indications.
the operator expects to find on the out or if they do not resolve the (E) Make a minimum of one direct
pipeline. (Appendix E gives guidance inconsistencies, the operator must re- examination in each ECDA Region. This
on selecting two complementary evaluate the feasibility of ECDA. examination must be made at the
methods). Indirect examination methods (C) An operator must identify and indication of highest risk. If no
include, but are not limited to, Close locate indications following the indirect indications are shown in the ECDA
Interval Surveys (CIS), Direct (or inspection, and classify the severity of Region, then the excavation must be
Alternate) Current Voltage Gradient each indication as severe, moderate or made at a location that the operator
(DCVG or ACVG), and electromagnetic minor using the criteria in the ECDA considers to be the most suspect.
techniques, such as Pipeline Current Plan. (See paragraph (h)(3)(i) of this (vi) Remediation. Except for
Mapper (PCM), and C-Scan). An section). These classifications must be conditions specified in paragraph (i)(4)
operator must perform the indirect conservatively developed the first time of this section, an operator must
examination using the complementary the process is applied. remediate indications found during the
methods selected for each ECDA Region. (D) An operator must compare the direct assessment according to the
An operator must define the boundaries results from the pre-assessment step requirements in ASME/ANSI B31.8S,
with the prior history for each ECDA section 7. Remediation must be
for use of each pair of ECDA tools, and
Region. If assessment results are not consistent with a determination of
ensure complete coverage through
consistent with operating history, the remaining strength using ASME B31G or
overlap between adjacent ECDA regions.
(B) If one of the following conditions operator must reassess the feasibility of RSTRENG. (See Appendix A to this part
applies, an operator must use one ECDA. 192 for incorporation by reference and
(v) Direct examination. An operator’s availability information). If an operator
indirect examination tool and one
ECDA plan must include a process for finds an indication is associated with a
alternative (e.g. ultrasonic) tool to assess
using the results from the indirect defect that requires immediate
for external corrosion, unless the
examination to develop and carry out a remediation, the operator must reduce
operator demonstrates that one method
direct examination plan. A direct operating pressure by at least 20% in
will be adequate to assure the integrity
examination includes an excavation to the associated ECDA Region and not
of the segment being assessed for
confirm the ability of the indirect increase this pressure until the operator
external corrosion.
(1) Pipe in frozen ground; examination to locate external has excavated, evaluated and
(2) Pipe under paved roadways; corrosion. To carry out the direct remediated, as necessary, 100% of such
(3) Pipe in cased crossings (either examination an operator must— indications within the region. In
road or river). (A) Determine the order and timing of remediating a condition, an operator
(C) An operator must also provide for excavations from results of the indirect must also comply with the following—
the following in its indirect examination integrated with the risk (A) If any exposed segment has
examination. factor data. An operator must base both significant coating degradation or
(1) Repeating indirect examination order and timing on a classification of corrosion, the operator must increase
methods on a sample basis to ensure the indications as immediate action, the size of that excavation until coating
consistent data are obtained; scheduled action or monitored action. and pipe are determined to be adequate.
(2) Selecting intervals for capturing (See paragraph (h)(3)(i) of this section). (B) The operator must identify the
tool readings that are closely spaced (B) Make a direct examination root cause of all significant corrosion
enough to ensure consistent data are (excavation) of all indications that meet activity revealed by excavation.
obtained. Data sampling intervals the criteria for immediate action. An (C) When an operator identifies any
(locations of test points) for indirect operator must excavate all immediate defect in an ECDA Region that requires
examination methods should typically action indications promptly, but no later immediate mitigation, or determines
be no greater than the local depth of than six months after completing the that the root cause of any defect is a
coverage of the pipeline;. indirect examination. If an operator condition that ECDA is ineffective at
(3) Carrying out indirect examination finds any evidence of severe corrosion assessing (e.g., MIC or shielded
in an ECDA Region using the two in an ECDA region, the operator must corrosion), the operator must for the
complementary tools as close together evaluate the entire covered segment and current assessment cycle reassess the
in time as practical; all other covered and non-covered entire ECDA Region, using an
(4) Geo-referencing above ground segments in the operator’s pipeline alternative assessment method allowed
measurements to compare examination system with similar characteristics, for by this section.
results and accurately identify corrosion, and take appropriate action (vii) Post-Assessment. An operator
excavation locations. for that segment, which could include must determine the reassessment
(iv) Post-indirect examination. After an integrity assessment, remediation, or interval for the pipeline segment and
an operator completes its indirect additional preventive or mitigative evaluate the overall effectiveness of the
examination measurements for an ECDA measures. ECDA process.
Region, the operator must align the (C) Make a direct examination of at (A) Reassessment. An operator must
measures with the complementary tools least two of the highest risk indications determine the reassessment interval
and evaluate the consistency of the in each ECDA Region that meet the according to the requirements in
observations. criteria of scheduled action. An operator paragraph (k)(3) of this section.
(B) Performance measures. An locations where water may accumulate, examination for internal corrosion at
operator must define and monitor to identify ICDA regions, and to support each location, using ultrasonic thickness
measures to determine the effectiveness the flow model. This information measurements. If corrosion exists at
of the ECDA process. At minimum, includes, but is not limited to— either location, the operator must—
these measures must track— (1) All data elements listed in (1) Remediate the conditions it finds
(1) The effectiveness of the overall Appendix SP–A2 of ASME/ANSI in accordance with paragraph (i) of this
process (e.g., the change in the B31.8S. section;
calculated reassessment interval); (2) Information needed to support a (2) As part of the operator’s current
(2) The extent and severity of flow model that an operator uses to integrity assessment either perform
corrosion found; determine areas along the pipeline additional excavations in the ICDA
(3) The number of indications in each where internal corrosion is most likely region or use an alternative assessment
classification located on successive to occur. This information, includes, but method allowed by this section to assess
applications of ECDA; and is not limited to, location of all gas the pipe for internal corrosion; and
(4) The time from discovery of an input and withdrawal points on the (3) Evaluate all pipeline segments
indication categorized as immediate line; location of all low points on the (both covered and non-covered) in the
action or scheduled action to its line such as sags, drips, inclines, valves, operator’s pipeline system with similar
excavation. manifolds, dead-legs, and traps; the characteristics to those in which the
(4) Internal corrosion direct elevation profile of the pipeline in corrosion was found, and remediate the
assessment (ICDA). ICDA is a process sufficient detail that angles of conditions it finds in accordance with
that identifies areas along the pipeline inclination can be calculated for all pipe paragraph (i) of this section.
where water or other electrolyte segments; and the diameter of the
(E) Post Assessment and Continuing
introduced by an upset condition may pipeline, and the range of expected gas
Evaluation. An operator must
reside, then focuses direct examination velocities in the pipeline.
(3) Operating experience data that continually monitor each covered
on the locations in each area where
would provide an indication of historic segment where internal corrosion has
internal corrosion is most likely to exist.
upsets in gas conditions, locations been identified using techniques such as
An operator using direct assessment as
where these upsets have occurred, and coupons or electronic probes. An
an assessment method to address
any indications of damage resulting operator must also periodically draw off
internal corrosion in a pipeline segment
from these upset conditions. fluids at low points and chemically
must follow the requirements in ASME/
(B) Identification of ICDA regions. An analyze the fluids for the presence of
ANSI B31.8S, Appendix SP–B2, and in
operator must define all ICDA Regions corrosion products. The frequency of
this section.
within each covered pipeline segment. the monitoring and fluid analysis must
(i) ICDA plan. An operator that uses
An ICDA region extends from the be based on results from past and
direct assessment to assess internal
location where water may first enter the present integrity assessment results and
corrosion must prepare a plan that, at
pipeline and encompasses the entire risk factors specific to that pipeline. If
minimum, provides for the following—
(A) A process for data gathering to area along the pipeline where internal an operator finds any evidence of
evaluate the potential for internal corrosion may occur and further corrosion products the operator must,
corrosion, and to support pre- evaluation is needed. To identify ICDA either—
assessment in accordance with regions, an operator must apply the (1) conduct excavations at locations
paragraph (h)(4) (ii) (A) of this section; results of a mathematical flow model downstream where moisture might
(B) Identification of ICDA Regions, in that defines the critical pipe incline accumulate; or
accordance with paragraph (h)(4)(ii)(B) above which water film cannot be (2) assess the segment using another
of this section; transported by the gas. This flow model integrity assessment method allowed by
(C) Identification of excavation must consider changes in pipe diameter, this section, and remediate the
locations and direct examination of the locations where gas enters a line conditions it finds in accordance with
locations in accordance with paragraphs (potential to introduce moisture) and paragraph (i) of this section. The
(h)(4)(ii)(C) and (h)(4)(ii)(D) of this locations downstream of gas draw-offs interval for re-assessing the segment
section; (gas velocity is reduced). Graph E.III.A with another assessment method must
(D) Post assessment and continuing in Appendix E of this Part provides the not exceed the time frames specified in
evaluation in accordance with flow model. paragraph (k)(3)(ii) of this section.
paragraph (h)(4)(ii)(E). (C) Identification of excavation (5) Stress Corrosion Cracking (SCC).
(ii) Corrosion identification. An locations. After identifying the ICDA An operator using direct assessment as
operator must have a process to evaluate regions, an operator must then identify an integrity assessment method to
the potential for internal corrosion for excavation the most likely locations address stress corrosion cracking must
caused by water, CO2, O2, chlorides, for internal corrosion in each region. An develop and follow a plan that provides
hydrogen sulfide and other operator must identify a minimum of for—
contaminants present in the gas, and for two locations for excavation in each (i) Development and implementation
MIC. This process must, in accordance ICDA Region. One location must be the of a systematic SCC data collection and
with the requirements of this paragraph, low point (e.g., sags, drips, valves, evaluation process for all segments to
provide for pre-assessment, manifolds, dead-legs, traps) nearest to identify if the conditions for SCC are
identification of ICDA regions and the beginning of the ICDA Region. The present and to prioritize the segments
excavation locations, direct examination second location must be at the upstream for assessment. An operator may refer to
and post assessment. end of the pipe incline nearest the end ASME/ANSI B31.8S, Appendix SP–A3
(A) Pre-assessment. An operator must of the ICDA Region. for identifying the threat of SCC. This
gather information needed to identify (D) Direct examination. An operator process must include gathering and
areas along the covered pipeline must, at a minimum, excavate in each evaluating data related to SCC at all
segment where internal corrosion is ICDA Region the two locations excavation sites where the criteria
most likely to exist. An operator will identified for excavation in paragraph indicate the potential for SCC. This data
use this information to identify the (h)(4)(ii)(C), and must perform a direct includes at minimum, the data specified
in ASME/ANSI B31.8S, Appendix SP– (B) The identification of ICDA the integrity of the pipeline. An operator
A3. Regions must follow the requirements in must promptly, but no later than 180
(ii) Selection and implementation of paragraph (h)(4)(ii)(B) of this section. days after conducting an integrity
an integrity assessment method and (C) The identification of excavation assessment, obtain sufficient
remediation of the threat, if conditions locations and excavation must follow information about a condition to make
for SCC are identified. An operator must the requirements in paragraph that determination, unless the operator
use the bell hole examination and (h)(4)(ii)(C) of this section, except that demonstrates that the 180-day period is
evaluation technique to assess SCC, as the operator must identify for impracticable. If the operator cannot
specified in ASME/ANSI B31.8S, excavation at least one high risk make the necessary determination
Appendix SP–A3. location in each ICDA Region. within the 180-day period, an operator
(6) Confirmatory direct assessment. (D) The direct examination must notify OPS of the reasons for the
An operator using the confirmatory (excavation) and remediation must delay and the expected time for
direct assessment method as allowed in follow the requirements in paragraph obtaining the information.
paragraph (k)(3) of this section must (h)(4)(ii)(D) of this section, except that (3) Schedule for evaluation and
have a plan that meets the following the operator is to choose one high risk remediation. An operator must complete
requirements: location in each ICDA Region for remediation of a condition according to
(i) Threats. For any covered segment excavation. a schedule that prioritizes the
on which confirmatory direct (iv) Third party damage. An conditions for evaluation and
operator’s plan for confirmatory direct remediation. Unless a special
assessment is used, the focus must be on
assessment for identifying third party requirement for remediating certain
identifying damage resulting from
damage must include identification of
external corrosion, internal corrosion conditions applies, as provided in
pipeline segments where construction
and third party damage. paragraph (h)(3)(vii) or paragraph (i)(4)
or other groundbreaking activity was
(ii) External corrosion plan. An of this section, an operator must follow
reported near the pipeline right-of-way
operator’s plan for confirmatory direct the schedule in ASME/ANSI B31.8S. If
since the previous assessment. The
assessment for identifying external an operator cannot meet the schedule
confirmatory direct assessment for third
corrosion must includes processes for for any condition, the operator must
part damage must follow the
pre-assessment, indirect examination, justify the reasons why it cannot meet
requirements in paragraph (g)(3)(i) of
direct examination and remediation. the schedule and that the changed
this section.
(A) The pre-assessment must follow (i) What actions must be taken to schedule will not jeopardize public
the requirements in paragraph (h)(3)(ii) address integrity issues? safety. An operator must notify OPS in
of this section, and include (1) General requirements. An operator accordance with paragraph (n) of this
identification of External Corrosion must take prompt action to address all section if it cannot meet the schedule
Direct Assessment (ECDA) regions. anomalous conditions that the operator and cannot provide safety through a
(B) The indirect examination must discovers through the integrity temporary reduction in operating
follow the requirements in paragraph assessment. In addressing all pressure.
(h)(3)(iii) of this section, except that the conditions, an operator must evaluate (4) Special requirements for
examination may be conducted using all anomalous conditions and remediate scheduling remediation.
only one indirect examination tool those that could reduce a pipeline’s (i) Immediate repair conditions. An
suitable for the application. integrity. An operator must be able to operator’s evaluation and remediation
(C) The direct examination must demonstrate that the remediation of the schedule must follow ASME/ANSI
follow the requirements in paragraph condition will ensure that the condition B31.8S, Section 7 in providing for
(h)(3)(v) of this section with the is unlikely to pose a threat to the long- immediate repair conditions. To
following exceptions— term integrity of the pipeline. If an maintain safety, an operator must
(1) Excavation of all immediate action operator is unable to respond within the temporarily reduce operating pressure
indications is required in each ECDA time limits for certain conditions or shut down the pipeline until the
region; specified below, the operator must operator completes the repair of these
(2) Excavation of at least one high risk temporarily reduce the operating conditions. An operator must treat the
indication that meets the criteria of pressure of the pipeline. An operator following conditions as immediate
scheduled action is required in each must determine the temporary reduction repair conditions:
ECDA region; and in operating pressure using section (A) A calculation of the remaining
(3) No excavation is required for 851.42 of ASME/ANSI B31.8 for dents strength of the pipe shows a predicted
indications categorized as monitored and gouges, ASME/ANSI B31G or failure pressure less than 1.1 times the
indications. RSTRENG for corrosion, or reducing the established maximum operating
(D) The remediation must follow the operating pressure to a level not pressure at the location of the anomaly.
requirements in paragraph (h)(3)(vi) of exceeding 80% of the level at the time Suitable remaining strength calculation
this section. the condition was discovered. (See methods include, ASME/ANSI B31G
(iii) Internal Corrosion plan. An Appendix A to this part 192 for ‘‘Manual for Determining the Remaining
operator’s plan for confirmatory direct incorporation by reference and Strength of Corroded Pipelines’’ (1991);
assessment for identifying internal availability information). A reduction in AGA Pipeline Research Committee
corrosion must include processes for operating pressure cannot exceed 365 Project PR–3–805 (‘‘A Modified
pre-assessment, identification of days without an operator taking further Criterion for Evaluating the Remaining
Internal Corrosion Direct Assessment remedial action to ensure the safety of Strength of Corroded Pipe’’ (December
(ICDA) Regions, identification of the pipeline. 1989)); or an alternative equivalent
excavation locations, direct examination (2) Discovery of condition. Discovery method of remaining strength
and remediation. of a condition occurs when an operator calculation. These documents are
(A) The pre-assessment must follow has adequate information about the incorporated by reference and available
the requirements in paragraph condition to determine that the at the addresses listed in Appendix A to
(h)(4)(ii)(A) of this section. condition presents a potential threat to Part 192.
(B) A dent that has any indication of leak detection systems, replacing pipe be based on a data integration of the
metal loss, cracking or a stress riser. segments with pipe of heavier wall entire pipeline as specified in paragraph
(C) An anomaly that in the judgment thickness, providing additional training (f) of this section to identify the threats
of the person designated by the operator to personnel on response procedures, specific to a pipeline segment. The
to evaluate the assessment results conducting drills with local emergency evaluation must consider the past and
requires immediate action. responders and implementing present integrity assessment results,
(ii) 180-day remediation. Except for additional extensive inspection and data integration information (paragraph
conditions listed in paragraph (i)(4)(i) of maintenance programs. (f) of this section), and decisions about
this section, an operator must remediate (2) Third Party Damage and Outside remediation and preventive and
any of the following within 180 days of Force Damage. An operator must take mitigative actions (paragraphs (i) and (j)
discovery of the condition: additional measures to prevent and of this section).
(A) A dent with a depth greater than minimize the consequence of a release (3) Re-Assessment intervals. An
6% of the pipeline diameter (greater from third party damage or outside force operator must establish a re-assessment
than 0.50 inches in depth for a pipeline damage. These measures must be in interval for each covered pipeline
diameter less than Nominal Pipe Size addition to any already required under segment. An operator must comply with
(NPS) 12). this Part. An operator may follow the following requirements in
(B) A dent with a depth greater than ASME/ANSI B31.8S, Table 7–1 of establishing the interval for the
2% of the pipeline’s diameter (0.250 Section 7 in identifying these measures. operator’s covered pipeline segments.
inches in depth for a pipeline diameter To minimize the consequences from (i) General. Unless a period of less
less than NPS 12) that affects pipe third party damage, including than seven years is specified, each
curvature at a girth weld or a vandalism, measures include, but are covered pipeline segment must be re-
longitudinal seam weld. not limited to, increasing the frequency assessed at a seven-year interval. If the
(iii) Remediation longer than 180 of aerial and foot patrols, participating operator establishes a reassessment
days. An operator may take more than in one-call systems, conducting interval for the covered segment that is
180 days following discovery of the extensive public education campaigns, greater than seven years, the operator
condition to remediate any of the increasing marker frequency, increasing must within the seven-year period,
following conditions unless the cover depth, and adding leakage control conduct a confirmatory direct
anomaly grows to critical stage. If the measures. To minimize the assessment on the covered segment, and
anomaly grows to critical stage, the consequences from outside force then conduct the follow-up
operator must follow the immediate damage (e.g. earth movement, floods, reassessment. The reassessment done by
repair requirements in paragraph (i)(4)(i) unstable suspension bridge) these confirmatory direct assessment must be
of this section. measures include, but are not limited to, done in accordance with paragraph
(A) In a segment assessed by internal increasing the frequency of aerial and (h)(6) of this section.
inspection, a calculation of the foot patrols, adding external protection, (ii) Pressure test or internal
remaining strength of the pipe shows a reducing external stress, and relocating inspection, or other equivalent
predicted failure pressure greater than the line. technology.
1.1 times the established maximum (3) Automatic Shut-off valve (ASV) or (A) An operator that uses pressure
operating pressure at the location of the Remote Control Valves (RCV). If an testing or internal inspection as an
anomaly. An operator must remediate operator determines that an ASV or RCV assessment method must establish the
the condition in accordance with is needed on a pipeline segment to reassessment interval for covered
ASME/ANSI B31.8S, Section 7, Figure protect a high consequence area in the pipeline segments by—
7–1. event of a gas release, an operator must (1) Basing the intervals on the
(B) In a segment assessed by any install the ASV or RCV. In making that identified threats for the segment as
integrity assessment method, an determination, an operator must, at listed in paragraph (f) of this section and
anomalous condition other than those least, consider the following factors— in ASME/ANSI B31.8S, Table 8–2,
listed in paragraphs (i)(4)(i) or (ii) of this swiftness of leak detection and pipe section 8, and on the analysis of the
section. shutdown capabilities, the type of gas results from the last integrity assessment
(j) What additional preventive and being transported, operating pressure, and from the data integration required
mitigative measures must an operator the rate of potential release, pipeline by paragraph (f) of this section; or
take to protect the high consequence profile, the potential for ignition, and (2) Using the intervals for different
area? location of nearest response personnel. stress levels of pipeline specified in
(1) General Requirements. An (k) What is a continual process of ASME/ANSI B31.8S, Table 8–1, section
operator must take measures to prevent evaluation and assessment to maintain 8.
a pipeline failure and to mitigate the a pipeline’s integrity? (B) However, under either option, the
consequences of a pipeline failure in a (1) General. After completing the maximum reassessment interval must
high consequence area. An operator’s baseline integrity assessment of a not exceed ten (10) years for a pipeline
measures will be based on the threats it covered segment, an operator must operating at or above 50% SMYS, and
has identified to each pipeline segment continue to assess the line pipe of that 15 years for a pipeline operating below
(see paragraph (f)). These measures segment at the intervals specified in 50% SMYS. An operator choosing the
include an operator conducting, in paragraph (k)(3) and periodically maximum period allowed for
accordance with one of the risk evaluate the integrity of each covered reassessment must demonstrate that it
assessment approaches in ASME/ANSI pipeline segment as provided in has implemented enhanced preventive
B31.8S, Section 5, a risk analysis of the paragraph (k)(2). The reassessment and mitigative measures for the
covered pipeline segments to identify period for a segment begins upon segment.
additional actions to enhance public completion of the prior assessment. (iii) Direct assessment.
safety. Such actions include, but are not (2) Evaluation. An operator must (A) An operator that uses direct
limited to, installing Automatic Shut-off conduct a periodic evaluation as assessment must determine the
valves or Remote Control Valves, frequently as needed to assure pipeline reassessment interval according to the
installing computerized monitoring and integrity. The periodic evaluation must following calculation.
(1) Determine the largest defect most selecting the appropriate internal include those developed and used in
likely to remain in the segment and the inspection tools; support of any identification,
corrosion rate appropriate for the pipe, (ii) Pressure test conducted in calculation, amendment, modification,
soil and protection conditions. accordance with subpart J of this Part; justification, deviation and
(2) Take the largest remaining defect (iii) Direct assessment to address determination made, and any action
as the size of the largest defect threats of external corrosion threats, taken to implement and evaluate any of
discovered in the ECDA or ICDA internal corrosion, and stress corrosion the program elements.
segment. cracking that is conducted in (4) Documents that demonstrate
(3) Estimate the reassessment interval accordance with ASME/ANSI B31.8S personnel have the required training,
as half the time required for the largest section 6.3, and paragraph (h) of this including a description of the training
defect to grow to a critical size. section; program, in accordance with paragraph
(B) However, the reassessment (iv) Other technology that an operator (d)(2) of this section.
interval cannot exceed five (5) years, if demonstrates can provide an equivalent (5) Documents to carry out the
an operator directly examines and understanding of the condition of the requirements in paragraph (h) of this
remediates defects by sampling, or ten line pipe. An operator choosing this section for a direct assessment plan.
(10) years, if an operator conducts a option must notify the Office of Pipeline (6) Documents demonstrating the
direct examination of all anomalies and Safety (OPS) 180 days before conducting integrity management program has been
remediates these anomalies. the assessment, in accordance with provided to the interstate agent, and that
(4) Waiver from interval greater than paragraph (n) of this section. any safety concerns raised by OPS on
7 years in limited situations. In the (v) Confirmatory direct assessment behalf of an interstate agent have been
following limited instances, OPS may when used on a covered segment that is addressed.
allow a waiver from a reassessment scheduled for reassessment at a period (n) How does an operator notify OPS?
interval greater than seven years but longer than seven years. An operator An operator must provide notification
within the maximum allowable interval using this reassessment method must required by this section by—
if OPS finds a waiver would not be comply with paragraph (h)(6) of this (1) Sending the notification to the
inconsistent with pipeline safety. section.
(i) Lack of internal inspection tools. Information Resources Manager, Office
(l) What methods must be used to of Pipeline Safety, Research and Special
An operator may be able to justify a measure program effectiveness? (1)
longer assessment period for a covered Programs Administration, U.S.
General. An operator must include in its Department of Transportation, Room
segment if internal inspection tools are integrity management program methods
not available to assess the line pipe. An 7128, 400 Seventh Street SW.,
to measure whether the program is Washington DC 20590;
operator must demonstrate that the effective in assessing and evaluating the
internal inspection tools cannot be (2) Sending the notification by
integrity of each pipeline segment and facsimile to (202) 366–7128; or
obtained within the required assessment in protecting the high consequence
period and must also demonstrate the (3) Entering the information directly
areas. These measures must include the on the Integrity Management Database
actions it is taking to evaluate the four overall performance measures
integrity of the pipeline segment in the (IMDB) Web site at http://
specified in ASME/ANSI B31.8S, primis.rspa.dot.gov/imdb/.
interim. An operator must, in Section 9.4, and the specific measures
accordance with paragraph (n) of this 3. Appendix A to Part 192, section
for each identified threat specified in II.D would be amended by adding
section, notify OPS 180 days before the ASME/ANSI B31.8S, Appendix SP–A.
end of the required reassessment paragraph (9) to read as follows:
An operator must make the four overall
interval that the operator may require a performance measures accessible in real Appendix A to Part 192—Incorporated
longer assessment interval, and provide time to OPS and state pipeline safety by Reference
an estimate of when the assessment can enforcement officials. * * * * *
be completed. (2) Direct assessment. In addition to II. * * *
(ii) Maintain local product supply. An the general requirements for D. * * *
operator may be able to justify a longer performance measures, an operator (9) ASME/ANSI B31.8S 2001
assessment period for a covered segment using direct assessment to assess the Supplement to B31.8 on Managing
if the operator demonstrates that the external corrosion threat must define System Integrity of Gas Pipelines,
reassessment will shut off the local and monitor measures to determine the January 31, 2002.
product supply, and that alternative effectiveness of the ECDA process. 4. A new Appendix E to Part 192
supply is not available. An operator These measures must meet the would be added to part 192 to read as
must, in accordance with paragraph (n) requirements of paragraph (h)(3)(vii) of follows:
of this section, notify OPS 180 days this section.
before the end of the required (m) What records must be kept? An Appendix E to Part 192
reassessment interval that the operator operator must maintain for review I. Guidance on Determining a Potential
may require a longer assessment during an inspection— Impact Zone Within a High
interval, and provide an estimate of (1) A written baseline assessment plan Consequence Area
when the assessment can be completed. in accordance with paragraphs (e) and
(5) Assessment methods. In (g) of this section; Within each high consequence area,
conducting the integrity reassessment, (2) A written integrity management an operator is to calculate the potential
an operator must assess the integrity of program in accordance with the impact zone. (Refer to figure E.I.1 for the
the line pipe by any of the following requirements of this section. diagram of a potential impact zone)
methods. (3) Documents to support the High consequence areas and potential
(i) Internal inspection tool or tools decisions, analyses and processes impact zone are defined in § 192.761.
capable of detecting corrosion, and any developed and used to implement and The potential impact zone will help an
other threats to which the pipe segment evaluate each element of the baseline operator determine the area where
is susceptible. An operator must follow assessment plan and integrity segments must be given priority for
ASME/ANSI B31.8S, section 6.2, in management program. Documents assessment.
The Potential Impact Zone definition A. Selection of Indirect Inspection Tools • The pipeline operator should define
(§ 192.761) expands the area protected criteria for identifying ECDA regions.
The rule (§ 192.763(h)(3)(iii)), requires
and provides the basis for prioritizing • An ECDA region should include
an operator to select a minimum of two
the pipeline segments for assessment locations that have similar physical
and remediation. The priority an indirect inspection tools for all ECDA
characteristics, corrosion histories,
operator is to give each covered segment locations along the pipeline segment.
expected future corrosion conditions,
depends on the population density • The pipeline operator must select and use the same indirect inspection
within the potential impact radius. An indirect inspection tools based on their tools.
operator will need to perform the ability to reliably detect corrosion • The pipeline operator should
following— activity under the specific pipeline consider physical characteristics, soil
(1) Identify all high consequence conditions to be encountered. conditions, and corrosion protection
areas; • The ‘‘indirect inspection tool mechanisms that the pipeline operator
(2) Calculate the Potential Impact selection’’ column in Table E.II.1 considers significant in affecting
Radius (PIR) for each pipeline segment; includes items that should be external corrosion when defining
(3) Determine the Threshold Radius considered when selecting indirect criteria for identifying ECDA regions.
associated with the PIR for each inspection tools. Table E.1 may be used as guidance in
segment; • Table E.II.2 provides guidance on establishing ECDA regions.
(4) Identify the Potential Impact Circle selecting indirect inspection tools and • A single ECDA region does not need
for each segment; specifically addresses conditions under
(5) Identify the Potential Impact Zone to be contiguous. That is, an ECDA
which some indirect inspection tools region may be broken along the
for each segment; may not be practical or reliable.
(6) Determine the priority of each pipeline, for example, if similar
segment giving higher priority to any • The pipeline operator does not have conditions are encountered on either
segment within a potential impact zone. to use the same indirect inspection tools side of a river crossing.
at all locations along the pipeline • An operator should include the
II. Guidance on ECDA Tool Selection segment. Figure E.II.1 demonstrates how entire pipeline segment in an ECDA
and Definition of External Corrosion the selection of indirect inspection tools region.
Direct Assessment (ECDA) Regions may vary along a segment. • Figure E.II.2 gives an example
This section gives guidance to help an B. Identification of ECDA Regions definition of ECDA regions for a given
operator implement the requirements pipeline.
for a direct assessment plan in § 192.763 The rule (§ 192.763(h)(3)(ii)) requires • A pipeline operator should define
(h). An operator that chooses to use an operator to analyze data it has five distinct areas based on soil
direct assessment to assess the threat of collected to identify ECDA regions. characteristics and previous history.
external corrosion on the operator’s • The definition of ECDA regions will • Based on the choice of indirect
covered pipeline segments may refer to evolve through the Indirect Inspection inspection tools, the soil characteristics,
this guidance for selecting inspection Step and the Direct Examination Step. and the previous history, the pipeline
tools to carry out the indirect inspection An operator is expected to establish a operator should define seven ECDA
requirements and for defining external preliminary definition and fine tune it regions.
corrosion regions. later in the ECDA process. BILLING CODE 4910–60–P
EP28JA03.000</GPH>
EP28JA03.001</GPH>
EP28JA03.002</GPH>
EP28JA03.003</GPH>
EP28JA03.004</GPH>
EP28JA03.005</GPH>
EP28JA03.006</GPH>
BILLING CODE 4910–60–C

EP28JA03.007</GPH>
Notes Shielding by Disbonded Coating: None of where pipe burials exceed normal depths.
these survey tools is capable in the detection Field conditions and terrain may affect depth
1 = Applicable: Small coating holidays
of this type coating condition that exhibits no ranges and detection sensitivity.
(isolated & typically < 1sq. in.) and physical orifice to the soil. If there is a
conditions that do not cause fluctuations in Limitations & Detection Capabilities: All
pathway to the soil through a small holiday
CP potentials under normal operating survey methods are limited in sensitivity to
or orifice, then tools such as DCVG or
conditions. electromagnetic methods may detect these the type and make up of the soil, presence
2 = Applicable: Large coating holidays defect areas. This definition pertains to only of rock and rock ledges, type coating such as
(isolated or continuous) or conditions that one type of shielding from disbonded high dielectric tapes, construction practices,
cause fluctuations in CP potentials under coatings. We also find current shielding from interference currents, other structures, etc. At
normal operating conditions. other metallic structures and from geological least two or more survey methods may be
conditions. required in order to get desired results and
NA: Not Applicable to this tool without
Pipe Depths: All of the survey tools are confidence levels required.
additional considerations. sensitive in the detection of coating holidays
Issued in Washington, DC on January 22,

2003.
Stacey L. Gerard,
Associate Administrator for Pipeline Safety.
[FR Doc. 03–603 Filed 1–27–03; 8:45 am]
EP28JA03.008</GPH>
BILLING CODE 4910–60–C

CFR Dot 192

Caricato da

Informazioni sul documento

Titolo originale

Copyright

Formati disponibili

Condividi questo documento

Condividi o incorpora il documento

Opzioni di condivisione

Hai trovato utile questo documento?

Questo contenuto è inappropriato?

Copyright:

Formati disponibili

CFR Dot 192

Caricato da

Copyright:

Formati disponibili

Tuesday,

January 28, 2003

49 CFR Part 192

AGA ...................................................................................... 13,500 12 10 43 35

BILLING CODE 4910–60–C

Issued in Washington, DC on January 22,

BILLING CODE 4910–60–C

Potrebbero piacerti anche