Several questions have been answered by OPS within the past couple months and posted on their website.
FAQ-244: “Should” in standards
Question: What is the OPS position with regard to implementation of “should” statements in industry standards that are invoked by the rule?
Answer: OPS expects operators to implement “should” statements in industry standards that are invoked by the rule. Operators may choose to implement an alternative approach in meeting the recommendations of invoked standards. If this approach is taken, program requirements for the alternative approach must exist in IM Program documents and records must be generated by the alternative approach. The IM Program documents must also technically justify that the alternative approach provides an equivalent level of protection. If an operator chooses not to implement a “should” statement in an invoked standard, a sound technical basis for why it has not been implemented must be documented in the IM Program documents.
FAQ-207: 7-years as minimum reassessment requirement
Question: For pipeline operating below 30% SMYS and that is pressure tested, Table 3 of ASME/ANSI B31.8S indicates that reassessment intervals must be 5 years if test pressure was 1.7 times MAOP. Subpart J would require lower test pressures. If I conduct my assessments in accordance with Subpart J, must I reassess more frequently than once every seven years?
Answer: No. If a hydrostatic pressure test was performed per Subpart J requirements, then the operator may use a seven-year reassessment interval, unless its risk analysis indicates that reassessment is necessary at more frequent intervals.
FAQ-236: Interpolating ASME intervals
Question: If I have hydrostatically tested my pipeline to a test pressure different than those listed in table 3 of ASME/ANSI B31.8S, how can I determine an extended reassessment interval?
Answer: Operators may use straight-line interpolation to determine acceptable intervals between the 5, 10, 15, and 20 year intervals listed in Table 3. In no case must operators reassess more frequently than once every seven years unless such frequent reassessments are determined necessary by risk assessment.