In This Issue

Passage of Internal Inspection Devices – Request for information

RSPA published regulations on Apr. 12, 1994 (59 FR 17281) requiring that, except where impracticable, operators of gas and hazardous liquid pipelines must design and construct certain pipelines to accommodate the passage of instrumented internal inspection devices, or smart pigs. In response to petitions for reconsideration from the American Gas Association and the Interstate Natural Gas Association of America (INGAA), RSPA proposed to modify provisions of � 192.150 that apply to offshore transmission lines and that require removal of smart pig obstructions from transmission line sections (59 FR 49896; Sept. 30, 1994). In addition, pending completion of the rulemaking, RSPA suspended enforcement of � 192.150 on offshore transmission lines and on onshore transmission line sections except replacement parts (60 FR 7133; Feb. 7, 1995).

One of the issues raised by INGAA’s petition and by comments on the proposed modification of � 192.150 concerns the applicability of � 192.150 to new offshore transmission lines 10 inches or larger. INGAA and industry commenters strongly suggested the rule should exempt all offshore transmission lines. The reasons were increased design and construction costs and lack of benefits. In addition, the Technical Pipeline Safety Standard Committee, RSPA’s advisory committee on proposed gas pipeline safety standards, supported industry’s view at a meeting in Washington D.C. on May 2, 1995.

In contrast, operators of hazardous liquid pipelines did not object to the similar pig-passage rule in � 195.120 that applies to offshore pipelines 10 inches or larger. And the Marine Board, in a 1994 study jointly sponsored by RSPA and the Minerals Management Service, “Improving the Safety of Marine Pipelines,” recommended that “[n]ew medium-to large-diameter pipelines running from platform to platform or platform to shore should be designed to accommodate smart pigs whenever reasonably practical.” (The study is available at

In light of this background and the considerable time since persons submitted written comments on the proposed changes to � 192.150, RSPA has the following questions:

  • Do operators of offshore gas transmission lines still object to applying � 192.150 to new offshore transmission lines 10 inches or larger?
  • If the answer is yes, given that new hazardous liquid pipelines 10 inches or larger are meeting � 195.120, what differences are there between gas and liquid pipeline design and construction practices that would justify exempting new offshore gas transmission lines 10 inches or larger from � 192.150?
  • Regarding the Marine Board’s recommendation, when would it not be “reasonably practical” to design new gas transmission lines 10 inches or larger running between platforms or platforms and shore to accommodate the passage of smart pigs?

To file written responses electronically, after logging on to, click on “Comment/Submissions” [Docket No. RSPA-03-16330]. You can also read all responses in the docket at The previous record of this proceeding is in Docket No. PS-126. You can read comments and other material in this docket at the Nassif Building, U.S. Department of Transportation, Room 7128, 400 Seventh Street, SW, Washington, DC 20590-0001. For access to this docket, please call Jenny Donohue at (202) 366-4046.

FOR FURTHER INFORMATION CONTACT: L. M. Furrow by phone at 202-366-4559, by fax at 202-366-4566, by mail at U.S. Department of Transportation, 400 Seventh Street, SW, Washington, DC, 20590, or by e-mail at