{"operation":"document","citation":"PHMSA Guidance, PHMSA Pipeline Safety: Temporary Repair and Permanent Repair Frequently Asked Questions","title":"PHMSA Pipeline Safety: Temporary Repair and Permanent Repair Frequently Asked Questions","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2022-11-02","effective_on":"2022-11-02","summary":"PHMSA Pipeline Safety: Temporary Repair and Permanent Repair Frequently Asked Questions Document PHMSA Temporary-Permanent Repair FAQs.pdf (104.73 KB) This guidance consists of a set of temporary repair and permanent repair FAQs that clarify the requirements of making repairs under 49 CFR 192 and 195. The main goal of the FAQs is to raise awareness of the issue of temporary repairs remaining on pipelines as if they a","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-guidance-phmsa-pipeline-safety-temporary-repair-and-permanent-repair-frequently-asked-questions-27b4ff1f.json","markdown":"https://regulus.evalyn.ai/document/phmsa-guidance-phmsa-pipeline-safety-temporary-repair-and-permanent-repair-frequently-asked-questions-27b4ff1f.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-guidance-phmsa-pipeline-safety-temporary-repair-and-permanent-repair-frequently-asked-questions-27b4ff1f","source_url":"https://www.phmsa.dot.gov/regulatory-compliance/phmsa-guidance/phmsa-pipeline-safety-temporary-repair-and-permanent-repair-frequently-asked-questions","body":"PHMSA Pipeline Safety: Temporary Repair and Permanent Repair Frequently Asked Questions\n\nDocument\n\n PHMSA Temporary-Permanent Repair FAQs.pdf (104.73 KB)\n\n        This guidance consists of a set of temporary repair and permanent repair FAQs that clarify the requirements of making repairs under 49 CFR 192 and 195. The main goal of the FAQs is to raise awareness of the issue of temporary repairs remaining on pipelines as if they are permanent repairs, which could lead to integrity issues. Furthermore, the FAQs help clarify the timeframes for when temporary and permanent repairs need to be made.\n\n          Issued Date: Wednesday, November 2, 2022\n\n<<<PAGE 1>>>\n\nUnited States Department of Transportation\nPipeline and Hazardous Materials Safety Administration\nOffice of Pipeline Safety\nTemporary Repair and Permanent Repair Frequently Asked Questions\nNovember 2, 2022\nThese frequently asked questions (FAQs) are guidance provided to help the\nregulated community understand how to comply with existing temporary repair\nand permanent repair regulations. FAQs are not substantive rules, are not meant to\nbind the public in any way, and do not assign duties, create legally enforceable\nrights, or impose new obligations that are not otherwise contained in the existing\nregulations and standards. However, an operator who is able to demonstrate\ncompliance with the FAQs is likely to be able to demonstrate compliance with the\nrelevant regulations. If a different course of action is taken by a pipeline operator,\nthe operator must be able to demonstrate that their conduct is in accordance with\nthe regulations.\nQ1. When must operators make permanent repairs on gas pipelines?\nA1. Permanent repairs to onshore gas gathering and transmission pipelines in\nhigh consequence areas\n49 Code of Federal Regulations (CFR) § 192.711(b) requires a pipeline operator to\nmake permanent, non-integrity management repairs on gas gathering pipelines “as\nsoon as feasible.”\nWhen making repairs to transmission pipelines in high consequence areas (HCAs)\nthat address anomalies discovered through integrity assessments, operators must\ncomply with the requirements under § 192.933. Those requirements include taking\nprompt action to address all anomalies discovered and remediate those anomalous\nconditions that could reduce a pipeline’s integrity. The operator must be able to\ndemonstrate that the repair will ensure that the condition is unlikely to pose a threat\nto the integrity of the pipeline until the next reassessment of the covered segment.\nIn addition to the other part 192 remediation requirements, § 192.935 requires\noperators of pipelines in HCAs to take additional measures to prevent a pipeline\nfailure and to mitigate consequences.\n\n<<<PAGE 2>>>\n\nSection 192.933(d) delineates that certain conditions must be treated as “immediate\nrepair conditions,” “one-year conditions,” or “monitored conditions” for\nremediation purposes. Section 192.933(d) details the special requirements for\nscheduling repairs for those conditions. For example, when an operator makes\nrepairs to an “immediate repair condition,” the operator must evaluate and\nremediate that condition pursuant to the schedule in ASME/ANSI B31.8S, section\n7 (incorporated by reference, see § 192.7) and must temporarily reduce operating\npressure or shut down the pipeline until the immediate repair condition is\nremediated. If an operator is unable to respond within the time limits for\nremediation specified in § 192.933(d), the operator must temporarily reduce the\noperating pressure of the pipeline or take other action that ensures the safety of the\ncovered segment. § 192.933(a)(1). In certain circumstances, the operator must also\nnotify PHMSA. § 192.933(a)(1).\nA2. Repairs to onshore gas transmission pipelines not in an HCA, and which do\nnot operate under an alternative maximum allowable operating pressure (MAOP)1\nThe regulations do not distinguish between the method in which a permanent and\ntemporary repair is made when repairs are made to onshore gas transmission lines\nnot in an HCA. Instead, when making repairs, operators must ensure that any\nrepair made is in a manner which is safe, and is made to prevent damage to\npersons, property, and the environment. § 192.714(b).\n2 Operators must use pipe\nand materials whose properties are documented with traceable, verifiable, and\ncomplete records. § 192.714(b).\nIf an operator is remediating certain conditions in accordance with § 192.714(d),\nthe condition must be (1) removed by cutting out and replacing a cylindrical piece\nof pipe that will permanently restore the pipeline’s MAOP based on the use of §\n192.105 and the design factors for the class location in which it is located; or (2)\nrepaired by a method, shown by technically proven engineering tests and analyses\nthat will permanently restore the pipeline’s MAOP based upon the determined\npredicted failure pressure times the design factor for the class location in which it\nis located. See § 192.714(c). Section 192.714(d) provides the timeframe within\nwhich operators must make such repairs.\n1 Pipelines operating under an alternative MAOP must comply with the repair requirements for § 192.620(d)(11).\n2 Section 192.714(b) will go into effect on May 24, 2023.\n\n<<<PAGE 3>>>\n\nFor repairs to conditions not listed under §192.714(d), operators must calculate the\npredicted failure pressure of the anomaly or defect and follow the schedule in\nASME/ANSI B31.8S. § 192.714(c).\nAdditionally, when an operator discovers a condition considered to be an\n“immediate repair condition” as defined by 192.714(d)(1) or a “two-year\ncondition” as defined under 192.714(d)(2), the operator must reduce the operating\npressure of the affected pipeline pursuant to § 192.714(e).\nQ2. When must an operator make an immediate temporary repair on a gas\npipeline?\nIf it is not feasible at the time of discovery to make a permanent repair, operators\nmust make immediate temporary repairs to protect the public. § 192.711(a).\nSection 192.711(a) Temporary Repairs requires immediate, temporary measures be\ntaken for pipelines operating at or above 40% of the specified minimum yield\nstrength (SMYS), and permanent repairs of specific conditions must be made at\ntime of discovery, when feasible. These conditions consist of leaks, imperfections,\nor damage that impair the serviceability. When it is not feasible to make a\npermanent repair at the time of discovery, section 192.711(a) requires immediate,\ntemporary measures be taken.\nA temporary repair must be replaced with a permanent repair as soon as it feasible\nto do so.\nQ3. How is a temporary repair different from a permanent repair for gas\npipelines?\nTwo important distinguishing factors between a temporary repair and a permanent\nrepair are (1) the circumstances in which the repair type may be utilized and (2) the\nlength of time such a repair type may remain in effect. ASME/ANSI B31.8S-2004,\npara. 7.2.4 (incorporated by reference, see § 192.7) states “If the analysis shows\nthat the time to failure is too short in relation to the time scheduled for the repair,\nthe operator shall apply temporary measures…until a permanent repair is\ncompleted.” A temporary repair has a limited effective life and must be replaced\nwith a permanent repair as soon as feasible, but not beyond the limited effective\nlife of the temporary repair. The timing of the replacement is based on an\n\n<<<PAGE 4>>>\n\noperator’s evaluation of all relevant factors. Relevant factors an operator should\nconsider when making an evaluation include, but are not limited to, operational,\ndesign, integrity, and environmental factors (§ 192.933(a), (c)-(d)).\nA pipeline operator cannot operate a pipeline using unsafe repair methods, whether\ntemporary or permanent. As required by part 192, all repairs must restore\nserviceability and safe operation of pipelines. For example, § 192.713(a) requires\nsteel gas transmission (and applicable gathering) pipelines to be repaired either “by\ncutting out and replacing a cylindrical piece of pipe,” or “by a method, shown by\ntechnically proven engineering tests and analyses, that will permanently restore the\npipeline’s MAOP.” Permanent and temporary repairs must restore safe operation\nof the pipeline. Temporary repairs are those that have limited effective life and\nmust be replaced by a repair that can restore permanent serviceability and safe\noperation. § 192.711. A pressure reduction may be required after a temporary\nrepair of a gas pipeline is completed to ensure serviceability and safe operation of a\npipeline. §§ 192.713(b), 192.933(a). Requirements for carrying out repairs to\nrestore permanent serviceability and safe operation in gas pipelines are set forth in\npart 192. See, e.g., §§ 192.713-192.720.\nASME B31.4-2006, table 451.6.2.9-1 (incorporated by reference, see § 195.3),\nprovides examples of permanent repair methods to address pipeline anomalies.\nWhile the table specifically addresses acceptable repair methods of liquid pipeline\nanomalies, the examples therein are informative for gas pipelines as well. In the\nevent the time to failure is too short in relation to the time scheduled for the repair,\nand it is not feasible to make a permanent repair at the time of anomaly discovery,\nmethods documented in operations and maintenance procedures and proven by\ntest, investigation, or experience that are outside of the examples listed in ASME\nB31.4-2006, table 451.6.2.9-1, may be used and considered a temporary repair.\nRegardless of whether a repair is permanent or temporary, it must restore\nserviceability and safe operation of the pipeline. A pipeline operator cannot operate\na pipeline using unsafe repair methods.\nQ4. How is a temporary repair different from a permanent repair for\nhazardous liquid pipelines?\n\n<<<PAGE 5>>>\n\nPart 195 does not explicitly distinguish between temporary repairs and permanent\nrepairs to conditions affecting the serviceability and safe operation of hazardous\nliquid pipelines. However, as with gas pipeline operators, hazardous liquid pipeline\noperators, in repairing their pipelines, must ensure that all repairs are made using\nsafe repair methods and are made to prevent damage to persons and property. §\n195.422(a). Part 195 requires all repairs to restore serviceability and safe operation\nof pipelines. For example, § 195.422(b) states, “No operator [of a hazardous liquid\npipeline] may use any pipe, valve, or fitting, for replacement in repairing pipeline\nfacilities, unless it is designed and constructed as required by this part.”\nA pressure reduction may also be required under certain circumstances for\nhazardous liquid pipelines that could affect an HCA. § 195.452(h)(1)(i)-(ii).\nRequirements for carrying out repairs to restore permanent serviceability and safe\noperation for hazardous liquid pipelines are set forth in part 195. §§ 195.401(b),\n195.452(h).\nASME B31.4-2006, table 451.6.2.9-1 (incorporated by reference, see 195.3),\nprovides examples of permanent repair methods to address liquid pipeline\nanomalies. In the event the time to failure is too short in relation to the time\nscheduled for the repair, and it is not feasible to make a permanent repair at the\ntime of anomaly discovery, methods documented in operations and maintenance\nprocedures and proven by test, investigation, or experience that are outside of the\nexamples listed in ASME B31.4-2006, table 451.6.2.9-1, may be used and\nconsidered a temporary repair.\nQ5. What steps must an operator take when implementing a temporary or\npermanent repair of a gas or hazardous liquid pipeline?\nPipeline operators must prepare and follow written procedures for making any\nrepair, whether temporary or permanent. This requirement applies to gas pipelines\nin both HCAs and non-HCAs. §§ 192.605, 192.907. It also applies to hazardous\nliquid pipelines in both HCAs and non-HCAs. §§ 195.402, 195.452.\nFor gas pipelines in non-HCAs, operators must include procedures for operating,\nmaintaining, and repairing the pipeline in accordance with each of the\nrequirements of Subparts I, L, and M. §§ 192.451-491, 192.601-623, 192.701-756.\nFor gas pipelines in HCAs, operators must develop procedures for operating\npipelines in compliance with Subpart O and ASME/ANSI B31.8S-2004.\n\n<<<PAGE 6>>>\n\n§ 192.907. When time-dependent anomalies are being evaluated, an analysis\nutilizing appropriate assumptions about growth rates must be used to assure that\nthe defect will not attain critical dimensions prior to the scheduled permanent\nrepair. ASME/ANSI B31.8S-2004, para. 7.2.4. The procedures for repair of gas\npipelines must clearly identify all repair methods used and be in accordance with\neach of the requirements of Subpart M. §§ 192.605, 192.711, 192.713-717,\n192.720.\nFor gas pipelines in HCAs, if an operator is unable to “meet the schedule for\nevaluation and remediation” prescribed by the regulations and “cannot provide\nsafety through a temporary reduction in operating pressure or other action,\n” the\noperator must notify PHMSA of the circumstances for the pressure reduction\nfollowing a temporary repair, and the process for it. § 192.933(a), (b).\nAdditionally, operators must address the factors noted in Subpart M, Subpart O,\nand ASME/ANSI B31.8S-2004, section 7, related to the timing of replacement of\nthe temporary repair, including, but not limited to, operational, design, integrity,\nand environmental elements of the pipeline. §§ 192.711, 192.714, 192.933(a)-(e).\nFor hazardous liquid pipelines, an operator’s repair procedures must consider all\nrelevant repair factors, including, but not limited to, whether the pipeline is in, or\ncould affect an HCA. §§ 195.401-402, 195.452. Hazardous liquid pipeline repair\nprocedures must also consider whether a pressure reduction is required before or\nafter a temporary repair; factors related to the timing of replacement of the\ntemporary repair, including, but not limited to operational, integrity, and\nenvironmental elements of the pipeline (§ 195.452(h)(1)); and whether the\ndeficiency is related to corrosion control (§§ 195.573(e), 195.585).\nFor a repair schedule of a hazardous liquid pipeline to be considered adequate\nwhen it is in or could affect an HCA, it must: provide for immediate repair\nconditions; complete repairs “according to a schedule prioritizing the conditions\nfor evaluation and remediation;” have specified repair timelines for certain\nintegrity conditions; and demonstrate that remediation will ensure that the\ncondition is unlikely to pose a long-term threat to the integrity of the pipeline.\n§ 195.452(h).","truncated":false,"body_characters":14537}