In This Issue

API/AOPL submit recommendations for High Volume, Low Stress liquid pipelines

The API and AOPL have submitted comments to PHMSA regarding currently unregulated pipelines that operate less than 20% SMYS and are located in Unusually Sensitive Areas. If this proposal is accepted and incorporated into final rulemaking, operators of “Regulated Low Stress Pipelines” will have to develop a written program for minimizing risk of a release from the pipeline, or include the pipeline in the operator’s Integrity Management Program (§195.452). The following are a few highlights of the proposed changes.

A Regulated Low Pressure Pipeline is defined as a pipeline with a diameter greater than 8 5/8”, operates at 20% or less specified minimum yield strength (SMYS), is located off owner/operator property, and is located within a Ľ mile of an USA(s).

Operators shall identify all Regulated Low Pressure Pipelines within their operations within one year after the effective date of this rule. Operators must complete implementation of the program required by this Subpart within 5 years after the effective date of this rule.

An operator must include in the program:

Identification of the affected pipelines:
An operator must identify all Regulated Low Pressure Pipelines.

Reporting Accidents and Safety Related Conditions:
An accident report is required for all failures of Regulated Low Pressure Pipelines of this Subpart. Reporting shall be consistent with the requirements of Subpart B of this Part.

Corrosion Control:
The program must include corrosion control requirements consistent with the requirements of Subpart H of this Part. The program must analyze available information regrading the threat of corrosion and take measures to mitigate corrosion where necessary. Such measures may include, but are not limited to, a maintenance pigging program and/or a chemical treatment program.

Inspect the pipeline using in-line inspection tools, direct assessment, pressure testing, or commensurate technology to assess the pipeline segment. The assessment will occur as often as necessary, but not more than every 5 years, unless the operator can justify via a valid engineering analysis to extend the interval beyond 5 years.

Leak Detection:
The operator must have a means to detect leaks on the covered pipelines. The program must evaluate the capability of the leak detection means and modify them, as necessary, to protect the USA. The evaluation must consider the following factors: length and size of pipeline, type of product carried, swiftness of leak detection, location of nearest response personnel and equipment, and leak history.

Line Markers:
All regulated low pressure pipelines will be clearly marked in accordance with section 195.410.

Damage Prevention:
Operators must put in place basic damage prevention practices, such as registering these facilities with one-call organizations and excavation monitoring.

Training for Abnormal Operating Conditions:
Operator personnel must be trained to recognize and respond to abnormal operating conditions.