In This Issue

Pipeline Safety: Periodic Underwater Inspections

Approximately 125 companies operate underwater pipelines in the shallow waters of the Gulf of Mexico and its inlets. RSPA / OPS has published a final rule that will require each of these companies to prepare and follow a procedure to identify pipelines in waters less than 15 feet deep that are at risk of being an exposed underwater pipeline or a hazard to navigation and to conduct appropriate periodic underwater inspections. RSPA/OPS believes that at most 10% of the affected pipelines may need to be reinspected periodically. RSPA/OPS estimates that the initial cost of this proposal is $6.25 million with annual reinspection costs of approximately $200,000 per year. Under the periodic depth-of-burial inspection regulation, RSPA / OPS has:

  • imposed the same requirements for natural gas and hazardous liquid pipelines
  • limited the underwater periodic inspection requirement to waters less than 15 feet deep in the Gulf of Mexico and its inlets, and clarified that certain requirements only apply to waters less than 15 feet deep.
  • confirmed that the existing regulations at § 192.612(b)(1) and 195.413(b)(1) remain in effect.
  • confirmed that adoption of the risk analysis systems provided in the NPRM and further articulated in the TTI report is discretionary.
  • incorporated the phrase “underwater natural bottom (as determined by recognized and generally accepted practices)” in place of the term “seabed” in the affected sections, and allowed for the use of recognized and generally accepted practices to determine the underwater natural bottom
  • allowed for a performance-based alternative to reburial.
  • not including abandoned pipelines in the rule.
  • required an operator to notify RSPA/OPS if it cannot obtain required state or Federal permits in time to comply with the regulation.

This rule is effective on September 9, 2004. RCP has prepared a “marked-up” version of the old rules with the new revisions. For a copy, please contact Laura Wager at lwager@your-rcp.com