In This Issue

API Petitions DOT/OPS: Integrity Management Rule Changes

The American Petroleum Institute (API) and the Association of Oil Pipeline (AOPL) have submitted two petitions to DOT/OPS to amend Title 49 CFR Part 195.452. While most API member companies are primarily engaged in the transportation of hazardous liquids, some of the members do operate small amounts of gas pipelines that are subject to the Part 192 Subpart O Pipeline Integrity Management Rule.   Acceptance of the petition would allow operators to incorporate their gas pipelines into their hazardous liquid pipeline integrity management program under Part 195.452.

A second request was made requesting clarification and modification to Title 49 Part 195.452 to allow engineering judgment and flexibility under the “Special requirements for scheduling repairs”.   The proposed change would be similar to that of the published natural gas integrity rule and ASME B31.8S. Acceptance of the entire petition would allow hazardous liquid operators to redefine the following:

  • Expanding immediate repairs to include any dent with an indication of cracking rather than just top side dents with cracking.
  • Remove 3% dents from the 60-day condition category.
  • Create a 365-day condition category.
  • Creating a monitoring conditions category, which in addition to including the 180-day conditions, consists of the “other conditions” category under the rule as published?

If you would like to receive a copy of the petitions, please contact Laura Wager.