In This Issue

Periodic Updates of Regulatory References to Technical Standards and More!

[Docket No. PHMSA–2011–0337]

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) issued a Final Rule effective March 6, 2015, regarding standards incorporated by reference (IBR), as well as other miscellaneous rule amendments for both gas and liquid pipelines. The new rule incorporates about 20 updated standards and 2 new standards: API RP 5LT regarding truck transportation of pipe, and ASTM D2513-09a regarding PE plastic pipe (with the exception of re-worked plastic pipe). It also corrects typos and incorrect references, and standardizes wording and references in a number of areas. The new rule does not incorporate the latest edition of API RP 1162, dealing with public awareness programs – although it does leave the door open for incorporation once PHMSA and its state regulatory partners have had an opportunity to review the latest round of inspections under the previous RP, and have conducted a workshop to discuss best practices. But it does not stop there.

It also requires that liquid pipeline operators maintain their integrity management records for the useful life of the pipe. Perhaps the most important revision that could affect liquid pipeline operators is disallowance of Risk Based Inspection intervals for internal tank inspections under Section 6.4.3 of API Standard 653. Per the revised rule, operators who used 6.4.3 prior to March 6, 2015 to establish RBI intervals can no longer use that section, and must do an inspection by Jan 5, 2017, if:

  1. it has been longer than 20 years since the last inspection
  2. a calculation using 6.4.2 would have required re-inspection by now
  3. the inspection interval calculated under 6.4.3 was not based on actual corrosion rates and other relevant factors.

For all other tanks, operators must calculate and follow inspection intervals per 6.4.2. This effectively means a default internal inspection interval of 10 years regardless of risk, and a maximum inspection interval of 20 years if adequate data is available to support the longer interval.

For a copy of PHMSA’s Final Rule, contact Jessica Foley.