We thought our readers would be interested in the following “Frequently Asked Question” from the OPS integrity management website:
FAQ 7.21 Must anomalies identified during pig runs not considered “baseline” or “reassessments” under the rule be repaired in accordance with the rule’s repair criteria?
ANSWER: Yes. The integrity management rule requires a program that integrates all information regarding the integrity of the pipeline. Thus, all pig runs conducted after the effective date of the rule are considered activities covered by the rule. Anomalies discovered in segments that could affect high consequence areas after the effective date of the rule must be repaired in accordance with the criteria and schedules for repair conditions specified in 195.452(h). This includes anomalies identified by any pig run conducted after the effective date of the rule, even if the pig run is not considered a “baseline assessment” or “re-assessment”.
Editor’s note: The effective date of the rule for large liquid operators was March 31, 2001 (but President Bush instituted a 60 day delay on the effective date of all new regulations when he took office, which shifted the effective date to May 29, 2001) . The effective date for small liquid operators was February 15, 2002. Any anomaly detected after those dates would have to be investigated and repaired as described in the operator’s integrity management plan – even if the pig run / etc. was not performed as an official part of the integrity assessment program. Note also that this only applies to segments of pipe that fall under the operator’s integrity management program (“in or could affect an HCA”).