# U.S. DOT/RSPA - Environmental Assessment - Proposed Rulemaking - High Consequence Areas for Gas Transmission Pipelines

- **operation:** document
- **citation:** 0900006480e8a8d5
- **title:** U.S. DOT/RSPA - Environmental Assessment - Proposed Rulemaking - High Consequence Areas for Gas Transmission Pipelines
- **source type:** rulemaking
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** current
- **official:** true
- **published on:** Not available
- **effective on:** Not available
- **summary:** DRAFT Research and Special Programs Administration U.S. Department of Transportation Environmental Assessment Proposed Rulemaking High Consequence Areas for Gas Transmission Pipelines Docket: RSPA-00-7666 DRAFT Table of Contents Preliminary Finding of No Significant Impact A. Purpose and Need for Action A. 1 A.2 A.3 A.4 Recent RSPA Pipeline Safety and Environmental Protection Programs Legislative History and National Transportation Safety Board Recommendations Interactions with Industry, Other Agencies, and Stakeholders...
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e8a8d5.json
- **markdown:** https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e8a8d5.md
- **app url:** https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e8a8d5
- **source url:** https://downloads.regulations.gov/PHMSA-RSPA-2000-7666-0157/attachment_1.pdf
**body:**

<<<PAGE 1>>>

DRAFT
Research and Special Programs Administration
U.S. Department of Transportation
Environmental Assessment
Proposed Rulemaking
High Consequence Areas for Gas Transmission Pipelines
Docket: RSPA-00-7666

<<<PAGE 2>>>

DRAFT
Table of Contents
Preliminary Finding of No Significant Impact
A.
Purpose and Need for Action
A. 1
A.2
A.3
A.4
Recent RSPA Pipeline Safety and Environmental Protection Programs
Legislative History and National Transportation Safety Board Recommendations
Interactions with Industry, Other Agencies, and Stakeholders
Future RSPA Integrity Management Initiatives
B.
Description of Proposed Action
C.
A1 tern a tives Considered
D.
Affected Environment
E.
E. 1
Environmental Consequences of Proposed Action and Alternatives
Environmental Impact of Proposed Integrity Management Rule
E.2
Environmental Impacts of the Alternatives
E.2.1
E.2.2 Take No Action
Define HCAs as Class 3 and Class 4 Areas
E.2.3 Define HCAs according to the Definition of High Population Areas from 9195.450
F. Environmental Justice Considerations
G . Information Made Available to States, Local Governments, and Individuals
H. List of Agencies and Persons Consulted
I. Conclusion
..
11
...
111
1
1
3
5
8
8
10
11
12
13
16
16
16
16
17
17
19
19

<<<PAGE 3>>>

DRAFT
Preliminary Finding of No Significant Impact
This Environmental Assessment is prepared in accordance with section 102(2)(c) of the National
Environmental Policy Act (42 U.S.C. Section 4332), the Council on Environmental Quality
regulations (40 CFR Sections 1500-1 508), and Department of Transportation Order 561 0.1 c,
Procedures for Considering Environmental Impacts. It was prepared to assist in the agency’s
planning and decision-making. This document concisely describes the Research and Special
Programs Administration’s (RSPA) proposed rulemaking to define high consequence areas for
gas transmission pipelines. This Environmental Assessment also addresses the need for the
proposed action, the alternative definitions considered, the environment affected by this action,
the consequences to the environment of the proposed action and the alternatives, and a list of the
agencies and organizations consulted. This Environmental Assessment provides sufficient
evidence to determine that the provisions of the proposed rule are expected to have no significant
impact on the environment.
...
111

<<<PAGE 4>>>

DRAFT
A. Purpose and Need for Action
The Research and Special Programs Administration (RSPA) believes that pipeline safety
regulations address the most important risks to the nation’s pipelines, and have served the
industry and the nation well. The gas pipeline industry has a good safety record compared to
other modes of transportation. However, pipeline incidents still occur and, on rare occasions,
result in serious consequences. Continued improvement in safety and environmental performance
is still RSPA’s highest objective. RSPA believes that safety programs based only on compliance
with the regulations can result in a piecemeal approach to identifying and controlling risks,
sometimes neglecting the interrelationships among failure causes and the benefits of coordinated
risk control activities. Having operators implement more systematic and integrated approaches
to assure pipeline integrity in areas where pipeline incidents have the greatest potential
consequences to people and property offers the greatest opportunity to better control risks and
improve industry’s performance.
Pipeline operators also have strong incentives to ensure the integrity of their pipelines. Ensuring
integrity has obvious positive safety and environmental benefits. In addition, operators seek to
avoid the lost product and unscheduled downtime for repairs following a major incident, which
can significantly impact the company’s financial performance and its ability to satisfy customer
commitments. Operators cannot afford to have these critical transportation assets out of service
for lengthy periods of time in today’s competitive business environment. In addition, the
damage to the company’s public image and reputation, as well as the legal implications of
serious incidents, can pose an even broader and longer term negative impact on the company’s
business operations. For these and other reasons, some pipeline operators have implemented and
are continuing to improve more systematic safety and environmental management processes,
focusing on areas where incidents have the greatest potential impact.
A. 1 Recent RSPA Pipeline Safetv and Environmental Protection Programs
To better understand and promote more comprehensive and integrated approaches to safety and
environmental protection, RSPA created the Risk Management Demonstration Program and the
System Integrity Inspection (SII) Pilot Program. These programs encourage and evaluate
operator-developed safety and environmental management processes that incorporate operator-
and pipeline-specific information and data to identify, assess, and address pipeline risks. These
programs are helping RSPA’s Office of Pipeline Safety (OPS) refine its regulatory oversight
processes. These programs help to ensure that pipeline operators have effective processes in
place to identify the most important risks to the public and the environment, and to develop and
implement cost-effective preventive and mitigative actions to manage these risks. Many of these
initiatives have validated the importance of focusing resources and establishing higher levels of
protection in areas where a pipeline failure could have significant consequences.
1

<<<PAGE 5>>>

DRAFT
Through the Risk Management Demonstration Program and the System Integrity Inspection Pilot
Program, OPS has improved its understanding of pipeline operator integrity management
systems and activities. This experience has shown that some gas pipeline operators have
formalized management systems to identify and address the most significant integrity threats to
their pipeline systems. In the Risk Management Program, participants perform systematic and
comprehensive risk assessments to identify the specific nature and location of the most
significant risks posed by operation of their pipeline system. An essential feature of these risk
assessments is the integration of information from many diverse sources to fully understand the
integrity threats at specific locations on the pipeline. Environmental consequences and the impact
on nearby populations are explicitly considered in these risk assessments. Through formal, risk-
based decision making processes, these companies use the risk assessment results to identify
projects and activities that address potential system integrity threats, thereby helping to prevent
pipeline failures. The risk management process also examines the consequences of potential
releases and explores opportunities to minimize the environmental and public safety and health
impacts should a failure occur. These investigative risk management programs, and the
preventive and mitigative risk control activities that evolve from them, supplement the minimum
regulatory requirements established in 49 CFR 192 to protect the public and the environment.
The System Integrity Inspection Program is focused on developing a more integrity-based
approach to OPS inspections. Instead of using a solely compliance-based approach, OPS is
focusing the inspection process on an operator’s integrity management processes and activities.
By working with the operator, OPS is able to understand and influence the methods and
approaches used to assess pipeline integrity, and the approaches to integrating integrity
assessment data with other pipeline specific information to identify the most significant integrity
threats to the system. Specifically, OPS has observed how operators examine internal inspection
data in conjunction with other surveillance and operating data, expected population growth, land
use, construction activity along the pipeline, and other information relevant to assuring the
integrity of the pipeline in high population areas and in environmentally sensitive areas.
Through this interaction OPS is acquiring a broader understanding and a greater confidence that
effective programs are in place to address the most significant risks. Similar to the Risk
Management Program, the SI1 Program is emphasizing how operators evaluate their system
condition and its risks, and use this information to make sound integrity management decisions.
While these two programs only involve a limited number of operators, OPS discussions with
other companies in industry forums and working groups has indicated that formal integrity
management programs are becoming more common. OPS found that many companies are
developing more sophisticated and mature integrity management systems and diagnostic tools.
OPS believes the next step is to require all operators to develop and follow at least minimum
level integrity management programs focused on areas of significant potential consequences
from pipeline incidents.
2

<<<PAGE 6>>>

DRAFT
A.2 Legislative Histow and National Transportation Safety Board Recommendations
Congress has directed DOT to consider several initiatives that could improve safety and
environmental protection, especially in locations where pipeline failures might have significant
impacts to human health and safety and the environment. Specifically Congress has directed
DOT to:
0 Prescribe standards establishing criteria for identifying gas pipeline facilities located in
high-density population areas, and hazardous liquid pipelines that cross waters where a
substantial likelihood of commercial navigation exists, are located in high-density
population area, or are located in an area unusually sensitive to environmental damage
(USA) [49 U.S.C. 0 60109(a)(2)].
0 Prescribe additional standards requiring the periodic inspection of pipelines in US As and
in high-density population areas. The regulations are to prescribe when an instrumented
internal inspection device, or similarly effective inspection method, should be used to
inspect the pipeline [49 U.S.C. 0 60102(f)(2)].
0 Survey and assess the effectiveness of emergency flow restricting devices (EFRDs) and
other procedures, systems, and equipment used to detect and locate hazardous liquid
pipeline ruptures and to prescribe regulations on the circumstances under which an
operator of a hazardous liquid pipeline facility must use an EFRD or such other
procedure, system, or equipment [49 U.S.C. 3 60102(j)].
0 Survey and assess the effectiveness of remotely controlled valves to shut off the flow of
natural gas in the event of a rupture and determine whether the use of remotely controlled
valves is technically and economically feasible and would reduce the risks associated
with a rupture, and, if the use of valves is feasible and would reduce risks, to prescribe
standards for the use of these valves, including requirements for their use in densely
populated areas [49 U.S.C. 3 601026)(3)].
In addition to these Congressional directives, the National Transportation Safety Board (NTSB)
has made several recommendations addressing improved protection for high population and
environmentally sensitive areas. These recommendations include:
0 Requiring periodic testing and inspection to identify corrosion and other time-dependent
pipeline damage.
0 Establishing criteria to determine appropriate intervals for inspections and tests, including
safe service intervals between pressure testing.
3

<<<PAGE 7>>>

DRAFT
e Determining hazards to public safety from electric resistance welded (ERW) pipe and
establishing standards for leak detection systems.
e Establishing requirements for installing automatic or remote-operated mainline valves on
high-pressure lines in urban and environmentally sensitive areas to provide for rapid
shutdown of failed pipeline segments.
RSPA has initiated several programs and activities in response to these legislative mandates and
NTSB recommendations. As summarized in Section A. 1 , the Risk Management and SI1 Pilot
Programs have provided an understanding of how these issues can be effectively addressed
within the context of a comprehensive and systematic integrity management program that
considers the total spectrum of risks from pipeline operation, including those risks in locations
where the consequences to public health and safety and the environment may be elevated. RSPA
has also undertaken a rigorous and thorough process for developing the criteria to define USAs.
This multi-year process involved numerous interactions with other Federal and State agencies,
representatives of the hazardous liquid pipeline industry, environmental organizations, and other
stakeholders. RSPA published for public comment proposed criteria to define USAs on
December 30, 1999 (64 FR 73464). Numerous public comments were received on the proposed
criteria (available in Docket # 99-5455).
The proposed USA criteria were also pilot tested to confirm that the proposed USA definition
can be used to identi% and locate unusually sensitive drinking water and ecological resources
using available data from government agencies and environmental organizations. The pilot test
identified USAs in Texas, California, and Louisiana - states with a large number of hazardous
liquid pipelines, as well as considerable drinking water and ecological resources. The results of
the pilot test, as well as the criteria in the proposed USA definition, were reviewed by a team of
nationally recognized experts on drinking water and ecological resources. In late 2000, RSPA
completed its evaluation of the feedback fi-om the technical peer review, public comments, and
the pilot test results. After extensive consultation with other Federal agencies, a final rule
defining USAs was issued on December 21,2000 (65 FR 80530).
RSPA has performed an evaluation of the potential benefits of EFRDs in limiting the volume of
product released following a hazardous liquid pipeline failure. The results were published in
"Emergency Flow Restricting Devices Study" in 1991 (available in Docket # PS-133). This
study recommended that OPS seek public input on the placement of EFRDs in urban areas, at
water crossings, at other critical areas affected by commodity release, and in areas in close
proximity to the public outside of urban areas. This study also concluded that remote control and
check valves are the only effective EFRDs.
4

<<<PAGE 8>>>

DRAFT
In January 1994, RSPA issued an advance notice of proposed rulemaking (ANPRM) (59 FR
2802) to solicit data from the public through a series of questions primarily concerning the
performance of leak detection equipment and location of EFRDs. A public workshop was held
in October 1995 to further address the issues associated with requiring EFRDs. These forums
raised important concerns about the effectiveness and cost-effectiveness of these mitigative
features. It was suggested that the need for EFRDs should evolve from an integrated evaluation
of the site-specific conditions and risks facing a particular pipeline location. This evaluation
would include assessing the effectiveness of the existing preventive and mitigative activities, as
well as considering the need for additional preventive or mitigative risk control activities.
Especially when considering mitigative actions like EFRDs, the environmental sensitivity of the
location is an important factor that must be considered to make the best overall risk reduction
decisions. Thus, RSPA deferred proposing regulations requiring EFRD installation until USAs
were defined.
RSPA believes that the experience obtained through the Risk Management Demonstration
Program, the SI1 Pilot Program, the USA definition process, and other initiatives has provided a
foundation for moving forward with a rule that addresses these Congressional mandates and
NTSB recommendations in a comprehensive and integrated manner.
A.3 Interaction with Industry. Other Agencies. and Stakeholders
On October 21, 1999, RSPA issued a Notice (64 FR 56725) announcing a public meeting to
discuss the need for additional regulations for natural gas and hazardous liquid transmission lines
in high population areas, commercially navigable waters, and areas of the environment that are
unusually sensitive to the environment damage. Areas fitting one or more of these three criteria
were referred to as “high consequence areas” or HCAs. The October 2 1, 1999 Notice included a
conceptual approach to providing improved protection in high consequence areas, and solicited
feedback on a number of specific questions relative to this approach. In the Notice, RSPA stated
that any process for protecting high consequence areas should include:
Pipeline-specific assessments in determining the need for additional preventive and
mi ti gat ive activities;
An assessment approach that considers all risk factors and risk reduction activities in an
integrated manner; and
Increased assurance that high consequence areas are being protected.
The public meeting was held on November 18 and 19, 1999, in Hemdon, Virginia. The primary
discussion topics included: the key elements of an effective integrity management program, the
5

<<<PAGE 9>>>

DRAFT
extent to which operators now have integrity management programs, and how to validate the
effectiveness of such programs. In addition, RSPA obtained feedback and input on a broad array
of integrity management issues, including:
0 How to characterize and define high consequence areas,
Key elements of operator integrity management programs,
0 Types of information that should be integrated to assure pipeline integrity; and
0 OPS review of integrity management programs, including what elements to review and
in spec t .
A synopsis of the feedback obtained at this meeting, as well as complete transcripts of the formal
presentations are available in the Docket and on the OPS home page at http://ops.dot.gov.
On December 22, 1999, RSPA issued a Notice in the Federal Register (64 FR 71 7 13)
announcing an extension of the public comment period to January 17,2000. The availability of a
new electronic discussion forum was announced to allow interested parties to express their views
on integrity management program issues and the need for improved protection in high
consequence areas. The December 22, 1999 Notice also referenced a draft conceptual model for
assuring pipeline integrity in high consequence areas, and solicited comments on the draft
approach. RSPA received comments from several organizations and individuals. These are
available in the Docket (RSPA 99-6355), and are summarized in the preamble of the NPRM
announcing the proposed rule (65 FR 21695) that resulted.
Following the public meeting, OPS hosted a number of smaller meetings and conference calls to
make sure the broadest range of comments and information were considered in drafting the
NPRM. Discussion items included the areas that should be considered high consequence areas,
reasonable milestones for completing benchmark testing, developing industry standards to
support a rule, how a rule should acknowledge differences between the gas and liquid pipeline
industries as well as among individual operators, and how best to involve affected communities.
These topics were discussed with Interstate Natural Gas Association of America (INGAA)
representatives on January 12, American Petroleum Institute (API) representatives on January 13,
National Association of Pipeline Safety Representatives (NAPSR) on January 14, February 15,
and March 3, public interest representatives on January 19 and February 29, and NTSB on
February 8. Minutes from each of these sessions are in the Docket.
OPS also initiated dialog with industry and various public interest representatives to explore
approaches to improve communication between OPS, pipeline operators, and the communities in
6

<<<PAGE 10>>>

DRAFT
which pipeline facilities are located. Initial discussions have focused on strengthening the liaison
between public officials and pipeline companies, testing the usefulness of pipeline data provided
to public officials, and developing concepts for restructuring the respective roles of federal, state,
and local officials, emphasizing the distinction between participation and communication.
Meetings were conducted on February 28 and 29,2000 to begin addressing the multi-faceted
communication issue.
After considering the feedback from the public meeting, comments to the Docket, and experience
in the Risk Management and SI1 programs, RSPA elected to implement integrity management
requirements for the pipeline industry in several steps. In the first rulemaking, OPS focused on
the hazardous liquid industry operators with 500 or more miles of pipeline. A final rule for
integrity management for these pipeline operators was published on December 1,2000 (65 FR
75378). This rule applies to pipelines that can affect high consequence areas (HCAs). HCAs for
hazardous liquid pipelines are defined in the rule as populated areas, USAs, and commercially
navigable waterways.
RSPA next proposed a similar rule covering integrity management for hazardous liquid operators
with fewer than 500 miles of pipeline (66 FR 15821; March 21,2001). RSPA received a small
number of public comments on the NPRM. After reviewing this input, as well as discussions
with other Federal agencies, RSPA decided that the same requirements for protection of high
consequence areas and the development of integrity management programs should apply to all
hazardous liquid pipeline operators. RSPA is completing resolution of comments on the
proposed rule and expects to issue a final rule in late 2001.
RSPA is now beginning rulemaking for integrity management for operators of gas transmission
pipelines. The first proposed rule covers the definition of high consequence areas (HCAs). Future
rulemaking will cover the integrity management requirements for gas transmission pipelines that
affect the defined HCAs.
OPS has been meeting with representatives of the gas pipeline industry, research institutions,
State pipeline safety agencies and public interest groups, to gather the information needed to
propose an integrity management program (IMP) rulemaking pertaining to gas operators. Since
January 2000, OPS has held nine meetings with State agencies, representatives of the Interstate
Natural Gas Association of America (INGAA), the American Gas Association (AGA), Battelle
Memorial Institute, the Gas Technology Institute (GTI), Hartford Steam Boiler Inspection and
Insurance Company, and operators covered under 49 CFR Part 192. (See DOT Docket No.
7666 for summaries of the meetings.) OPS also has met separately with Western States Land
Commissioners, National Governors Association, National League of Cities, National Council of
State Legislators, Environmental Defense Fund, Public Interest Reform Group, and Working
Group on Communities Right-To-Know.
7

<<<PAGE 11>>>

DRAFT
On February 12 -14,2001, OPS held a public meeting in Arlington, VA, on integrity
management in high consequence areas for natural gas pipelines and enhanced communications
regarding hazardous liquid and gas pipelines. At this meeting, reports on the status of industry
and govemment activities to maintain and improve the integrity of gas pipelines were featured
and meeting attendees participated in in-depth discussions on the integrity of gas pipelines. The
reports can be found in the DOT docket (#7666) and the OPS web site under InitiativesPipeline
Integrity Management P r o g r d G a s Transmission Operators Rule. At the meeting, industry and
state repregentatives and members of the public presented their perspectives on a number of
issues related to integrity management, including considerations for defining HCAs affected by
gas pipelines. Presentations from the public meeting may be viewed on the OPS web site under
InitiativesPipeline Integrity Management ProgradGas Transmission Operators Rule.
A Notice was published in the Federal Register on June 27,2001 (66 FR 343 18) requesting
further information and clarification and inviting hrther public comment on integrity
management concepts as they relate to gas pipelines. The Notice also announced the
establishment of an electronic public discussion forum for gas pipeline integrity management
issues on OPS’s internet home page. In this notice, OPS invited comment on seven elements it
considered important to include in the integrity management rule and hypotheses related to these
elements. The first of the seven elements was the definition of HCAs. OPS received numerous
comments on the issues related to the definition of HCAs, which are included in the docket along
with the transcript of the electronic discussion forum. These comments were taken into
consideration in development of the HCA definition included in this proposed rule.
In addition to the proposed rules RSPA has issued and plans to issue addressing integrity
assurance in high consequence areas, there are many other Federal, state, and local government
regulations in place to protect sensitive resources. These include regulations to protect drinking
water resources, threatened and endangered species, critical habitats for various species, and
spawning areas. Areas have been created and designated to protect and maintain aquatic life,
wildlife, and various other natural and water resources. Permits, environmental assessments, and
consultations with resource experts are required by various Federal, state, and local agencies
before a pipeline can be installed or construction to modify or repair an existing line can take
place. RSPA’s existing and planned future regulations complement and enhance these other
Federal, state, and local government regulations on sensitive drinking water or ecological
resources.
A.4 Future RSPA Integrity Management Initiatives
RSPA plans to propose rules on pipeline integrity management for interstate and intrastate
natural gas operators in the near future. The specific requirements of those rules and the
8

<<<PAGE 12>>>

DRAFT
environmental impacts associated with those requirements will be considered in the rulemaking
process.
B. Description of Proposed Action
RSPA proposes to add a new section to 49 CFR 192 defining high consequence areas (HCAs) for
gas transmission pipelines. The proposed definition of a HCA is:
W Any Class 3 area as specified in $192.5(b)(3)(i) and $192.5(b)(3)(ii) (Note: limits apply
as specified in $192.5(c))
W Any Class 4 area as specified in $192.5(b)(4) (Note: limits apply as specified in
4 1 92.5(c))
0 Any area out to 660 feet where there are hospitals, schools, day-care centers, retirement
homes, prisons or other hard to evacuate places occupied by 20 or more persons,
W Any area beyond 660 feet out to 1000 feet where there are hospitals, schools, day-care
centers, retirement homes, prisons or other hard to evacuate places occupied by 20 or
more persons, where the pipeline is greater than 30 inches in diameter and operates at a
maximum allowable operating pressure (MAOP) of 1000 psig or greater.
W Any area out to 660 feet (or out to 1000 feet where the pipeline is greater than 30 inches
in diameter and operates at MAOP of 1000 psig) where people congregate (such as
beaches, recreational facilities, campgrounds, museums, etc.) that are occupied by 20 or
more persons at least 50 days in any 12 month period. (The days need not be
consecutive.)
Class 3 locations have 46 or more buildings intended for human occupancy within an area that
extends 220 yards on either side of the centerline of any continuous one mile length of pipeline,
or are areas where the pipeline lies within 100 yards of either a building or small, well-defined
outside area (such as a playground, recreation area, outdoor theater, or other place of public
assembly) that is occupied by 20 or more persons on at least 5 days a week for 10 weeks in any
12 month period. Class 4 locations are any class location unit where buildings with four or more
stories above ground are prevalent (e.g., large office buildings).
The proposed rule imposes no requirement for action by gas pipeline operators. Future
rulemaking will define the requirements for gas pipeline operator integrity management
programs for those pipeline segments covered by HCAs as defined here. Although the specific
provisions of integrity management requirements are not yet defined, it is expected that these
provisions will include the following elements beyond the operator definition of HCAs:
9

<<<PAGE 13>>>

.
DRAFT
1. Identification and evaluation of the threats to pipeline integrity in each HCA.
2. Selection of assessment technologies best suited to effectively determine the
susceptibility of failure of each pipe segment that could affect a HCA.
3. Determination of time fiames to conduct a baseline integrity assessment and to make any
needed repair, using a graded approach under which priorities for assessment and repair
are set according to risk.
4. Identification and implementation of additional preventive and mitigative measures
appropriate to manage significant threats.
5 . Continual evaluation and reassessment at the specified interval of each pipeline segment
that could affect a HCA using a risk-based approach. The evaluation considers the
information the operator has about the entire pipeline to determine what might be relevant
to the pipeline segment.
6. Monitoring the effectiveness of the management process designed to provide additional
assurance of integrity in areas where the consequences of potential pipeline accidents are
greatest.
C. Alternatives Considered
RSPA considered alternatives in the decision process that led to the proposed HCA definition
given in Section B above. These alternatives are summarized below:
1. Take No Action. In this alternative, RSPA would rely on the existing regulatory requirements
to provide protection for high consequence areas. No additional definition of HCAs would be
performed in anticipation of new rules for integrity management by gas pipelixie operators. By
selecting this alternative, RSPA would not be responsive to the Congressional mandates to
consider internal inspection and other protective measures for high population areas (see Section
A.2).
2. Define HCAs as any Class 3 o c l a s s 4 Area. In this alternative, new requirements on
operators of gas pipelines for integrity management would be confined to those pipeline
segments adjacent to Class 3 or Class 4 areas. An HCA would be defined as:
Any Class 3 area as specified in 0 192.5@)(3)(i) and 0 192S(b)(3)(ii)
Any Class 4 area as specified in $192.5(b)(4) (Note: limits apply as specified in
10

<<<PAGE 14>>>

DRAFT
This option uses the first two parts of the proposed definition of HCAs, but excludes hard to
evacuate locations such as hospitals, schools, day-care centers, retirement homes, and prisons. It
also excludes areas where people congregate that are 660- 1000 feet away from pipelines
exceeding 30 inches in diameter and 1000 psig MAOP. This alternative definition would result in
new requirements for integrity management programs potentially being applied to fewer miles of
gas pipeline. This would occur, for example, if a pipeline segment were adjacent to hard to
evacuate facilities, but not within a Class 3 or Class 4 area.
3. Define HCAs according to the definition of high population areas from 6195.450
The HCAs for hazardous liquid pipeline integrity management in 49 CFR 195.450 include “high
population areas.” 49 CFR 195.450 defines a high population area as “...an urbanized area, as
defined and delineated by the U.S. Census Bureau, that contains 50,000 or more people and has a
population density of at least 1,000 people per square mile.” Under this alternative, HCAs for gas
pipeline integrity management would use the Census Bureau definition of “high population
areas.” This would capture pipelines within the boundaries of larger towns and cities. Such
pipelines have the possibility of being situated near areas of high population density and
residential or other development. Under this definition, therefore, HCAs would capture many
areas where gas pipeline failures could have high consequences. Some of the areas included
within the HCA definition under this alternative, however, would not necessarily be areas of high
population density or heavy development, because the boundaries of the high population areas
defined by the Census Bureau might include some areas of low population density, even though
the overall average population density within the boundaries of the areas exceeds 1,000 per
square mile. Also, some Class 3 or Class 4 areas may be excluded by this alternative, if the Class
3 or Class 4 locations do not lie within the boundaries of Census Bureau units defined as high
population areas.
Although, this alternative definition of HCAs would likely include many of the same high
population density areas as the proposed definition, RSPA believes the proposed definition has
certain features that make it superior. By using the class location scheme contained in 49 CFR
192.5 to identify HCAs, gas pipeline operators utilize information they are already required to
obtain and maintain regarding the degree of development and population density near pipelines.
Including Class 3 and Class 4 locations as HCAs ensures that areas of high population density
and high degrees of development are included, focusing on the specific conditions in the vicinity
of pipeline in the zone where pipeline accidents might have an impact, rather than within the
boundaries of an area that has an overall high population density. In addition, the proposed
definition would specifically include hard to evacuate areas and areas where people congregate,
while this alternative would not.
11

<<<PAGE 15>>>

DRAFT
D. Affected Environment
The purpose of the proposed rule is to define high consequence areas (HCAs) that may be
affected by gas pipelines throughout the United States. The intent is that future rules will define
requirements for integrity management on pipeline segments that might affect those HCAs.
Thus, the areas of the environment potentially impacted by the rule are those that fall within the
proposed HCA definition given in Section B above.
After they are initially established, high consequence areas will be updated on a periodic basis to
incorporate new information and data. For example, as communities and populations grow, the
extent of Class 3 locations (as defined in 9 192S(b)(3)(i) and 9 192S(b)(3)(ii)) may expand. If so,
the operator will need to apply any integrity management requirements to the expanded HCA.
The frequency at which these updates will be necessary has not been determined.
In addition to the HCAs, the provisions of the proposed rule will also impact areas of the
environment outside of HCAs. For example, it is expected that some operators will elect to use
internal inspection devices to fulfill integrity assessment and management requirements. Due to
economic and operational considerations, the launchers and receivers used to insert and remove
internal inspection devices are typically located at compressor stations, which can be many miles
apart. Even though a high consequence area may exist for only a short distance along the line,
because of the location of inspection device launchers and receivers, operators will likely inspect
the entire compressor station-to-compressor station segment of the line. Thus, in addition to the
information about the condition of the line in a high consequence area, the operator will obtain
integrity data about a much larger segment of pipe. Any significant threats identified in these
additional areas will also be remediated, thus providing additional protection for the regions
adjacent to high consequence areas.
E. Environmental Consequences of Proposed Action and Alternatives
This section describes the expected impact to the environment of the proposed definition of high
consequence areas (Section E. 1) and the alternatives (Section E.2).
Gas transmission pipelines transport pressurized natural gas, which is lighter than air and
flammable. If released as a result of a pipeline leak or rupture, natural gas can potentially ignite,
causing fires or explosions. Industry experience demonstrates that environmental consequences
of pipeline rupture-initiated fires are almost always limited to localized damage to the vegetation
and animal life immediately adjacent to the failure site. A review of recent ruptures for one
pipeline operator showed that the area impacted by fire is less than seven acres. It is possible
that a rupture occurring in a heavily forested area in the dry season could result in a forest fire,
12

<<<PAGE 16>>>

DRAFT
which would have a more extensive impact on wildlife and vegetation. However, the likelihood
of such an occurrence is believed to be very low. Other than localized vegetation damage in the
event of a fire or explosion, there are no significant environmental impacts from natural gas
pipeline leaks or ruptures. Unlike hazardous liquid pipelines, ruptures of gas pipelines would not
result in releases to bodies of surface water or impact groundwater.
This rule proposes a definition of high consequence areas (HCAs) to be applied to integrity
management requirements for natural gas transmission pipelines. These requirements will be
proposed in upcoming rulemaking. OPS is now considering which integrity management
approaches are most appropriate for the protection of the HCAs defined in this rule (see Section
B). Because the actions to be required of pipeline operators have not yet been specified, the
precise environmental consequences of the rule on the HCAs and other areas cannot be assessed.
OPS’s intent for new requirements for integrity management is to reduce the likelihood of
pipeline failures in the vicinity of HCAs. The reduction of pipeline failures will reduce the
impacts of pipelines on the environment in HCAs and nearby, but because of the limited extent
of environmental impacts of releases from gas pipelines, this reduction in environmental risk is
expected to be small.
E. 1 Environmental Consequences of Proposed Action
As presented in the June 27,2001 Notice on gas pipeline integrity management (66 FR 343 1 S),
the rules under consideration consist of seven elements. The first element, definition of HCAs, is
the proposed action covered here. The other six elements (See Section B) encompass the
additional actions pipeline operators will take for those pipeline segments that could potentially
impact HCAs. This section considers the potential general environmental effects of actions that
may be taken under OPS’s proposed approaches for gas integrity management requirements:
1. Identification and evaluation of the threats to pipeline integrity in each HCA.
This element encompasses comprehensive and integrated analysis of threats to HCAs
from pipelines in the vicinity. Pipeline operators would be required to assess and evaluate
risk factors. RSPA believes such analysis is a prerequisite for definition of optimal
integrity management programs and actions that protect HCAs. Consequently, it is
expected that operator performance of this analysis will lead to more effective protection
of HCAs and reduce risks to the environment within HCAs and adjacent areas from
potential pipeline integrity failures.
2. Selection of assessment technologies best suited to effectively determine the
susceptibility of failure of each pipe segment that could affect a HCA.
13

<<<PAGE 17>>>

3. 4. DRAFT
Operators will be required to perform a baseline assessment of pipeline integrity along all
segments that can affect HCAs. The baseline assessment is necessary to determine which
pipeline segments need to be repaired in order to maintain pipeline integrity. This will
better protect the environment in the HCA and adjacent area
- **truncated:** true
- **body characters:** 55716
