U.S. DOT/RSPA - Environmental Assessment - Standards for Direct Assessment of Gas and Hazardous Liquid Pipelines

Page 1DEPARTMENT OF TRANSPORTATION RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION Docket NO. RSPA-04-16855 .- RIN 2137-AD97 Environmental Assessment Standards for Direct Assessment of Gas and Hazardous Liquid Pipelines I. Description of the Action This environmental assessment concerns regulations that the Research and Special Programs Administration (RSPA) is proposing that would require pipeline operators to meet certain standards when they use direct assessment. In the pipeline industry, “direct assessment” is a process of data gathering, inspection, examination, and evaluation that is used to determine f external corrosion, internal corrosion, or stress-corrosion cracking is adversely affecting the physical integrity of ferrous pipelines. Although the standards being proposed are already in effect under 49 CFR Part 192 for gas transmission lines in high-consequence areas, Congress has directed DOT to prescribe direct assessment standards for other gas and hazardous liquid pipelines. II. Need for the Action Many operators of gas and hazardous liquid pipelines do more to assure the integrity of their systems than RSPA’s safety regulations in 49 CFR Parts 192 and 195 require. For example, $ 5 192.465 and 195.573 require operators to use electrical tests to identify places where buried pipe may not be protected adequately from external corrosion. But, in addition to electrical tests,#

Page 22 many operators have historically used internal inspection devices or hydrostatic testing to find external corrosion. They have also used these methods to look for other pipeline defects. RSPA has long recognized the safety and environmental advantages of these additional inspection and test methods. In recent years, it became apparent that they are particularly beneficial when used as part of a comprehensive risk-based program to assure system integrity. So, in 2000, RSPA issued regulations requiring hazardous liquid and carbon dioxide pipeline operators to conduct integrity management programs using internal inspection, pressure testing, or other equally effective assessment means. Congress also saw the need for operators to do more to assure the integrity of their pipelines. In the Pipeline Safety Improvement Act of 2002, Congress directed DOT to issue regulations on managing gas pipeline integrity in high-density population areas with a program involving internal inspection, pressure testing, and direct assessment. In the same legislation, Congress also directed DOT to issue regulations prescribing standards for inspecting pipeline facilities by direct assessment. Responding to the first congressional directive, RSPA issued regulations that require operators to follow detailed prograins for managing the integrity of gas transmission lines in high- consequence areas. The regulations include standards for assessing the integrity of pipelines by direct assessment. Now RSPA is addressing the second directive by proposing to require that operators meet these same standards if they use direct assessment on regulated pipelines other#

Page 33 than gas transmission lines in high-consequence areas. 111. Alternatives RSPA considered two alternatives to respond to Congress’ second directive. First is the status quo alternative: no additional regulations are needed because RSPA has already issued regulations that prescribe standards for the use of direct assessment. This alternative was rejected, however, because the existing regulations are limited to gas transmission lines in high- consequence areas. They do not reach all pipelines that fall under the second directive. Also because the regulations affect only a small fraction of regulated pipelines, it is doubtful operators would voluntarily meet the standards when using direct assessment on other pipelines. Operators of hazardous liquid pipelines are particularly unlikely to voluntarily meet the standards, because they normally follow only those regulations that apply to hazardous liquid pipelines. The second alternative is to apply the existing direct assessment standards to regulated pipelines besides gas transmission lines in high-consequence areas. RSPA chose this alternative because the existing standards are not inherently limited to gas transmission lines in high-consequence areas. Although the existing standard for direct assessment of internal corrosion does not apply to hazardous liquid pipelines, it is not being proposed for these pipelines. A further reason for choosing the second alternative is that the existing standards have already undergone public notice and comment in the gas transmission integrity management proceeding, and they were generally well received by gas transmission operators and other coninienters. Finally, the existing standards depend heavily on consensus standards published by NACE International and#

Page 44 the American Society of Mechanical Engineers (ASME), two organizations whose standards are widely used and highly regarded in the pipeline industry. IV. The Affected Environment and Environmental Consequences of the Action The proposed regulations concern assessing the threat of corrosion on regulated onshore gas and hazardous liquid pipelines, except gas transmission lines in high-consequence areas. Thus the affected environment is the land area of the United States that could be affected by corrosion- caused leaks or ruptures in these pipelines. The proposed regulations would apply only to pipeline operators who voluntary decide to use direct assessment to evaluate the effects of corrosion on their pipelines. If they do use direct assessment, the proposed regulations would require that they meet standards currently applicable to conducting direct assessment on gas transmission lines in high-consequence areas. However, the iiitenial corrosion standard would not apply to hazardous liquid pipelines. To meet the direct assessment standards, operators would have to perform data collection, indirect inspection, direct examination, and evaluation under appropriate procedures, plans, and criteria . Conducting direct examinations of buried pipelines involves excavating predetermined locations along rights-of-way to identify and correct likely corrosion defects. This type of localized ground disturbance typically does not involve damage to vegetation or the environment beyond the immediate vicinity of the pipeline. These disturbances would have far less impact than the potential consequences of a pipeline accident that could occur if a corrosion defect went#

Page 55 uncorrected. In RSPA’s experience, the benefits of direct examinations in reducing the likelihood of corrosion-caused accidents would offset the minor adverse impacts of localized ground disturbances. A significant advantage of using direct assessment is that it can not only locate existing corrosion defects but also places where defects could develop in the future. This advantage together with increased confidence in assessments done under the proposed standards may persuade operators to use direct assessment more frequently. If so, corrosion-caused accidents should become less likely, as more conditions that could develop into leaks or ruptures are detected and corrected. Any reduction in the likelihood of pipeline accidents means greater protection of people and the environment . RSPA believes that on balance the proposed regulations may positively affect the environment because the regulations may encourage operators to more accurately determine the integrity of their pipelines. However, this impact is unlikely to be significant because use of direct assessment is voluntary under the proposed regulations. V. List of Contacts The direct assessment standards were developed during the proceeding on integrity management of gas transmission lines in high-consequence areas. RSPA interacted and consulted with several organizations in that proceeding. These organizations included the Interstate Natural Gas Association of America, the American Gas Association, the Battelle Memorial#

Page 66 Institute, the Gas Technology Institute, the Western States Land Commissioners, the National Governors Association, the National League of Cities, the National Council of State Legislators, the Environmental Defense Fund, the Public Interest Reform Group, and the Working Group on Communities Right-To-Know. Additional contacts may result from participation by interested persons in the present rulemaking proceeding. VI. Conclusion Based on the above considerations, RSPA has determined that there are no significant environmental impacts associated with this action.#