# U.S. DOT/RSPA - Environmental Assessment

- **operation:** document
- **citation:** 0900006480e8ae8d
- **title:** U.S. DOT/RSPA - Environmental Assessment
- **source type:** rulemaking
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** current
- **official:** true
- **published on:** Not available
- **effective on:** Not available
- **summary:** Research and Special Programs Administration U.S. Department of Transportation Environmental Assessment Final Rule Pipeline Integrity Management in High Consequence Are 13s for Hazardous Liquid Pipeline Operators Operating Less than 500 Miles of Pipeline Docket: RSPA 00-7408 Preliminary Finding of No Significant Impact This Environmental Assessment is prepared in accordance with section 102(2)(c) of the Natio: ial 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 5610. IC,...
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<<<PAGE 1>>>

Research and Special Programs Administration
U.S. Department of Transportation
Environmental Assessment
Final Rule
Pipeline Integrity Management in High Consequence Are 13s
for
Hazardous Liquid Pipeline Operators
Operating Less than 500 Miles of Pipeline
Docket: RSPA 00-7408

<<<PAGE 2>>>

Preliminary Finding of No Significant Impact
This Environmental Assessment is prepared in accordance with section 102(2)(c) of the Natio: ial
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 5610. IC,
Procedures for Considering Environmental Impacts. It was prepared to assist in the Research ;md
Special Programs Administration’s (RSPA) planning and decision-making. This document is an
update of the original Environmental Assessment prepared in support of the proposed rule (66
FR 15821).
This document concisely describes the RSPA’s final rule on integrity management in high
consequence areas for certain operators of hazardous liquid pipelines. It also addresses the n a d
for the proposed action, the alternative actions 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 suffici .:nt
evidence to determine that the provisions of the final rule are expected to have no significant
impact on the environment.
i

<<<PAGE 3>>>

Table of Contents
A.
A. 1
A.2
A.3
A.4
B.
Purpose and Need for Action
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
1
1
2
5
8
Description of Proposed Action 10
C.
D.
Alternatives Considered 14
Affected Environment 15
E.
Environmental Consequences of Proposed Action and Alternatives 19
E. 1
E.l.l
E. 1.2
E.1.3
E. 1.4
E. 1.5
E. 1.6
Environmental Impact of the Integrity Management Rule Overview of Internal Inspection and Pressure Testing
Environmental Impacts of Internal Inspection and Pressure Testing
Environmental Impacts of Baseline Integrity Assessment Requirements in Final Rule
Environmental Impacts of Periodic Assessment Requirement in Final Rule
Environmental Impacts of Other Preventive and Mitigative Actions
Summary of Environmental Impacts for Final Rule
19
20
22
23
27
29
31
E.2
Environmental Impacts of the Altematives
E.2.1
E.2.2
Take No Action
Mandatory Integrity Assessment in all High Consequence Areas Every Ten Years
F.
Environmental Justice Considerations
33
33
34
35
G.
Information Made Available to States, Local Governments, and Individuals
H.
List of Agencies and Persons Consulted
I.
Conclusion
J.
References
Appendix 1 Environmental Impacts of Oil Spills
36
38
39
40
41
I I

<<<PAGE 4>>>

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 hazardous liquid pipeline industry has a good safety record
compared to other modes of transportation. However, pipeline incidents still occur and, on
occasion, with serious consequences. Continued improvement in safety and environmental
performance is still RSPA’s highest objective. RSPA believes that safety programs based onllr
on compliance with the regulations can result in a piece-meal approach to identifying and
controlling risks, sometimes neglecting the relationships among different risk factors and the
potential benefits of coordinated risk control activities. Having operators implement more
systematic and integrated approaches to assure pipeline integrity and address the most important
pipeline risks offers the greatest opportunity to improve the industry’s performance.
Pipeline operators also have strong incentives to ensure the integrity of their pipelines. In
addition to the positive safety and environmental benefits, the lost product and unscheduled
downtime for repairs following a major incident can significantly impact the company’s financial
performance, and its ability to satisfy customer commitments. Operators can not 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 arid
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 reasoi is,
many pipeline operators have implemented and are continuing to improve more systematic sa fety
and environmental management processes.
A. 1 Recent RSPA Pipeline Safety and Environmental Protection Promams
To better understand and promote more comprehensive and integrated approaches to safety a id
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 operatc r-
and pipeline-specific information and data to identify, assess, and address pipeline risks. Thtmse
programs, along with the Oil Spill Response Plan Review and Exercise Program, are helping
RSPA’s Office of Pipeline Safety (OPS) refine its regulatory oversight processes. These
processes 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. These initiatives have
validated the importance of focusing resources and establishing higher levels of protection ir
areas where a pipeline failure could have significant consequences.
Through the Risk Management Demonstration Program and the System Integrity Inspection I?ilot
Program, OPS has improved its understanding of pipeline operator integrity management sy:,tems
and activities. This experience has shown that a number of liquid operators have formalized
1

<<<PAGE 5>>>

management systems to identify and address the most significant integrity threats to their pipelline
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 posec by
operation of their pipeline system. An essential feature of these risk assessments is the
integration of information fi-om many diverse sources to fully understand the integrity threats it
specific locations on the pipeline. Environmental consequences and the impact on nearby
population are explicitly considered in these risk assessments. Through formal, risk-based
decision making processes, these companies use the risk assessment results to identify projecl s
and activities that address potential system integrity threats, thereby helping to prevent oil spi Is.
The risk management process also examines the consequences of potential releases and exploires
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 195 to protect the public and the environment.
The SII Program is focused on developing a more integrity-based approach to OPS inspectior s.
In addition to verifying an operator's compliance with the pipeline safety regulations, OPS is
focusing the inspection process on an operator's integrity management processes and activiticms.
By working with the operator, OPS is able to understand and influence the methods and
approaches used to integrate integrity assessment data with other pipeline specific informatio ,I to
identify the most significant integrity threats to the system. Specifically, OPS has observed how
operators examine in-line inspection data in conjunction with other surveillance and operatin
data, expected population growth, land use, construction activity along the pipeline, and othe .
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 mc st
significant risks. Similar to the Risk Management Program, the SI1 Program is emphasizing liow
operators evaluate their system condition and its risks, and use this information to make sour d
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 have indicated that formal integrity
management programs have become more common, particularly within the liquid pipeline
industry. OPS found that many liquid companies are developing more sophisticated and mal ure
integrity management systems, analytical methods, data integration processes, and diagnostic:
tools. OPS believes the next step is to require all operators to develop and follow at least
minimum level integrity management programs.
A.2 Legislative History and National Transportation Safety Board Recommendations
Congress has also directed DOT to consider several initiatives that could improve safety and
environmental protection, especially in locations where pipeline failures might have signific mt
2

<<<PAGE 6>>>

impacts to human health and safety and the environment. Specifically Congress has directed
DOT to:
Prescribe standards establishing criteria for identifying gas pipeline facilities located ii I
high-density population areas, and hazardous liquid pipelines that cross waters where I
substantial likelihood of commercial navigation exists, are located in high-density
population area, or are located in an area unusually sensitive to environmental damage
(USAs) [49 U.S.C. 4 60109(a)(2)].
Prescribe additional standards requiring the periodic inspection of pipelines in US As rind
in high-density population areas. The regulations are to prescribe when an inst”enti2d
internal inspection device, or similarly effective inspection method, should be used to
inspect the pipeline [49 U.S.C. 4 60102(f)(2)].
0 Survey and assess the effectiveness of emergency flow restricting devices (EFRDs) ar,d
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. 4 60102(i)].
,
In addition to these Congressional directives, the National Transportation Safety Board (NTS B)
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-dependiznt
pipeline damage.
Establishing criteria to determine appropriate intervals for inspections and tests, inch ding
safe service intervals between pressure testing.
0 Determining hazards to public safety from electric resistance welded (ERW) pipe and
establishing standards for leak detection systems.
Establishing requirements for installing automatic or remote-operated mainline valve s 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 SII Pili kt
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 locatic ns
where the consequences to public health and safety and the environment may be elevated.
3

<<<PAGE 7>>>

RSPA has also undertaken a rigorous and thorough process for developing the criteria to definje
USAs. This multi-year process involved numerous interactions with other Federal and State
agencies, representatives of the hazardous liquid pipeline industry, environmental organizatioi,is,
and other stakeholders. RSPA published for public comment proposed criteria to define USA!;
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 identify and locate unusually sensitive drinking water and ecological resources
using available data from government agencies and environmental organizations. The pilot te st
identified USAs in Texas, California, and Louisiana - states with a large number of hazardou,;
liquid pipelines, as well as considerable drinking water and ecological resources. The results Iof
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 from 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 evaluated 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 recommendecl
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 tl e
only effective EFRDs.
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 hcmld
in October 1995 to further address the issues associated with requiring EFRDs. These forums
raised important concems 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 reductio 1
decisions. Thus, RSPA deferred proposing regulations requiring EFRD installation until US.Qs
were defined.
RSPA believes that the experience obtained through the Risk Management Demonstration
Program, the SLI Pilot Program, the USA definition process, and other initiatives has providcd a
foundation for moving forward with a rule that addresses these Congressional mandates and
NTSB recommendations in a comprehensive and integrated manner.
4

<<<PAGE 8>>>

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 lines in high
population areas, commercially navigable waters, and areas of the environment that are unusu:illy
sensitive to the environment damage (Le., high consequence areas). This Notice included a
conceptual approach to providing improved protection in high consequence areas, and solicite d
feedback on a number of specific questions relative to this approach. In the Notice, RSPA sta,ted
that any process for protecting high consequence areas should include:
8 Pipeline-specific assessments in determining the need for additional preventive and
mitigative activities;
a An assessment approach that considers all risk factors and risk reduction activities in ;In
integrated manner; and
a Increased assurance that high consequence areas are being protected.
The public meeting was held on November 18 and 19, 1999, in Hemdon, Virginia. The prirriary
discussion topics included: the key elements of an effective integrity management program, tl le
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 airay
of integrity management issues, including:
a How to characterize and define high consequence areas,
a Key elements of operator integrity management programs,
a Types of information that should be integrated to assure pipeline integrity; and
a OPS review of integrity management programs, including what elements to review arid
inspect.
A synopsis of the feedback obtained at this meeting, as well as complete transcripts of the fo ;mal
presentations are available in Docket # 99-6355, 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 7 17 13) annoui icing
an extension of the public comment period to January 17,2000. The availability of an electIonic
discussion forum was announced to allow interested parties to express their views on integri y
management program issues and the need for improved protection in high consequence area:,'.
This Notice also referenced a draft conceptual model for assuring pipeline integrity in high
consequence areas, and solicited comments on the draft approach. RSPA received commenl s
from several organizations and individuals. These are available in the Docket # 99-6355, and are
5

<<<PAGE 9>>>

summarized in the preamble of the Notice of Proposed Rulemaking (NPRM) announcing the
proposed requirements for integrity management programs. (65 FR 21695, April 24,2000: See
additional discussion below).
Following the public meeting, RSPA hosted a number of smaller meetings and conference cal s
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 areal;,
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 communitii :s.
These topics were discussed with Interstate Natural Gas Association of America (INGAA)
representatives on January 12, American Petroleum Institute (MI) representatives on January 13,
National Association of Pipeline Safety Representatives (NAPSR) on January 14, February 1 ,
and March 3, public interest representatives on January 19 and February 29, and the NTSB on
February 8. Minutes from each of these sessions are in the Docket.
After considering the feedback from the public meeting, comments to the Docket, and experimce
in the Risk Management and SII programs, RSPA elected to implement integrity managemen1
requirements for the pipeline industry through a series of rules focused on different objectives.
On April 24,2000, RSPA published a Notice of Proposed Rulemaking (NPRM) “Pipeline
Integrity Management in High Consequence Areas” (65 CFR 21695). This proposed rule
focused on the hazardous liquid industry operators who own or operate 500 or more miles of
pipeline. Approximately 87% of the hazardous liquid transportation lines are operated by
operators with 500 or more pipeline miles.
A number of individuals and organizations provided comment on the proposed rule describec in
the NPRM. These comments are available in Docket # 99-6355, and summarized in the
preamble to the final rule. In addition to public input, RSPA also continued its consultations
with other Federal agencies, including the Environmental Protection Agency, the Departmenl of
Justice, and the Department of the Interior. Guidance was also obtained from the Technical
Hazardous Liquid Pipeline Safety Standards Committee, RSPA’s statutory advisory committ ,:e
for hazardous liquid pipeline safety. On December 1 , 2000, RSPA published a final rule on
htegrity Management in High Consequence Areas covering Hazardous Liquid Operators wit 1
500 or More Miles of Pipeline (65 FR 75378). The key provisions of the final rule are
summarized below:
0 Operators must identify pipeline segments on their systems where a release could impact
a high consequence area. High consequence areas are defined as populated areas, US As,
and commercially navigable waterways.
0 Operators must conduct baseline integrity assessments on pipeline segments that cou .d
affect high consequence areas. Acceptable methods for assessment include internal
inspection, pressure testing, or another technology that the operator demonstrates can
provide an equivalent level of understanding of the pipe’s condition. Baseline
6

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assessments for these pipeline segments must be completed by March 3 I , 2008, with 5 0%
of the distance assessed by September 30,2004. The highest risk segments must be
assessed first.
Operators must perform periodic integrity assessments on segments that could affect high
consequence areas at intervals not to exceed 5 years.
Operators must develop and follow a written integrity management program that consiists
of the following elements:
t
a process for determining which pipeline segments could affect high consequei ice
t
b
t
t
t
areas,
a Plan for conducting the baseline assessments noted above,
a process for continual integrity assessment and evaluation,
an analytical process that integrates all available information about pipeline
integrity and the consequences of a failure,
repair criteria to address issues identified by the integrity assessment method aiid
data analysis (the rule provides minimum repair criteria for certain, higher risk,
features identified through internal inspection, as well as time frames in which
certain features must be repaired),
a process to identify and evaluate preventive and mitigative measures to protecmt
high consequence areas,
methods to measure the integrity management program's effectiveness, and
a process for review of integrity assessment results and data analysis by a
qualified individual.
On March 2 1,2001, RSPA issued a NPRM (66 FR 15821) to extend the same requirements 1 o
protect high consequence areas and establish integrity management programs to all hazardou ,;
liquid pipeline operators regulated under 49 CFR 195 (i.e., include those operating less than ,io0
miles of pipeline). An Environmental Assessment was prepared in support of this NPRM. I his
final Environmental Assessment is an update of the previous work.
RSPA received a small number of public comments on the NPRM. After reviewing this inpi it, as
well as discussions with other Federal agencies, RSPA has decided that the same requirements
for protection of high consequence areas and the development of integnty management prog ams
should apply to all hazardous liquid pipeline operators. Section B of this Environmental
Assessment describes these requirements.
In addition to these requirements for integrity management 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 be.:n
created and designated to protect and maintain aquatic life, wildlife, and various other naturd
and water resources. Permits, environmental assessments, and consultations with resource
7

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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 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 Intea-itv Management Initiatives
RSPA plans to propose additional rules on pipeline integrity management for interstate and
intrastate natural gas operators in the near future. RSPA has met with representatives of CNGI,A
on January 12, March 29, April 19, June 15, July 20, September 6, September 19, October 12.
and December 18,2000 to discuss a variety of issues related to improved integrity manageme it
for gas pipelines, including:
a the definition of high consequence areas for gas pipelines;
a integrity assessment technologies for gas pipelines, including “direct assessment”;
e inspection fiequency;
e data integration and analysis;
e integrity management for low hoop stress piping;
a the level of integrity assurance provided by the current regulations (including high
population areas);
a current company practices that go beyond the protection explicitly required in the
regulations; and
a fbture standards to support integrity management.
On February 12 and 14, 2001 RSPA conducted a public meeting in Arlington, VA to discuss
these subjects and other topics relevant to an integrity management rule for gas pipeline
operators. Subsequent to the public meeting RSPA synthesized the input received, and issued a
Notice to request public comment and input on integrity management concepts related to gas
pipelines (June 27,2001; 66 FR 34318). This input is currently being evaluated. RSPA expticts
to issue one or more proposed rules for gas pipelines beginning in late 2001.
RSPA has also initiated dialog with industry and various public interest representatives to
explore approaches to improve communication between OPS, pipeline operators, and the
communities in which pipeline facilities are located. Initial discussions have focused on
strengthening the liaison between public officials and pipeline companies, testing the usefuli less
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
8

<<<PAGE 12>>>

participation and communication. Meetings were conducted on February 28 and 29, Septemb ,:r
17, and October 10, 2000 to begin addressing the multi-faceted communication issue. During a
public meeting on February 13,2001 , OPS sought additional input on enhancing communicat on
with the public and local officials near pipeline facilities. RSPA is currently considering how to
best improve communications between pipeline operators, the government, and local officials
The specific requirements of any future proposed rules related to integrity management for
natural gas pipelines and communications, and the environmental impacts associated with thc se
requirements will be considered in their respective rulemaking processes.
9

<<<PAGE 13>>>

B. Description of Proposed Action
On December 1, 2000, RSPA published a final rule establishing new requirements for integrit,y
management in high consequence areas for operators that own or operate 500 or more miles o I
pipe (65 FR 75378). RSPA is now establishing similar requirements for the remaining hazarclous
liquid operators. ’ Under these requirements, high consequence areas covered by this rule are
populated areas, commercially navigable waterways, and areas unusually sensitive to
environmental damage. (Section D provides more detailed definition and description of high
consequence areas.) The final rule establishes new requirements to enhance and validate the
integrity of hazardous liquid pipelines in high consequence areas. Furthermore, the rule prov des
additional assurance that appropriate preventive and mitigative measures are in place to prote :t
these high consequence areas.
The final rule requires operators to develop and implement an Integrity Management Program for
all portions of their pipelines that could affect high consequence areas. This Integrity
Management Program includes at a minimum:
a the identification of all pipeline segments that could impact high consequence areas,
a a Baseline Assessment Plan to assure integrity of these segments, and
a a framework that identifies how each element of the Integrity Management Program will
be implemented.
The operator’s Integrity Management Program must include the following elements:
a a process for determining which pipeline segments could affect a high consequence ai-ea;
a a Baseline Assessment Plan (as described below);
a a process for conducting periodic integrity assessments and evaluation on those segments
that could affect a high consequence area;
a an analytical process that integrates all available information about pipeline integrity and
the consequences of a failure (also noted above);
a repair criteria to address issues identified by the integrity assessment method and dat i
analysis;
’ Throughout the remainder of this Environmental Assessment, wherever “operator” is
used in the text, it means hazardous liquid operators operating less than 500 miles of pipelin e
used in transportation.
10

<<<PAGE 14>>>

0 a process to identify and evaluate additional preventive and mitigative measures to
protect high consequence areas;
0 methods to measure the Integrity Management Program’s effectiveness; and
a process for review of integrity assessment results and data analysis by an individual
qualified to perform evaluate integrity assessment results.
Each of these elements must be addressed in the framework.
Operators must follow recognized industry practices in their Integrity Management Program.
The pipeline segments that could affect a high consequence area must be identified within nir e
months of the rule’s effective date. The Baseline Assessment Plan and Framework must be
documented within one year of the rule’s effective date.
The Baseline Assessment Plan delineates the integrity assessment method(s) selected for eacli
high consequence area, the schedule by which these initial integrity assessments will be
performed, and the technical basis for integrity assessment method(s) selection and risk facto ’s
used in scheduling the assessments. The rule requires operators to perform a baseline integril y
assessment within seven years after the effective date of the rule for all pipelines that could a ‘fect
a high consequence area, with 50% of this pipeline mileage being assessed within three and c ne-
half years. In scheduling the baseline assessments, operators are to perform assessments of tlie
highest risk segments first. Operators who have performed and documented integrity
assessments in the five years previous to the effective date of the final rule may use these
assessments to validate a pipeline segment’s integrity if the assessment approach and
documentation are consistent with the provisions of the rule. The acceptable methods for
conducting the baseline integrity assessment are pressure testing, instrumented internal
inspection2, or other technology that the operator demonstrates can provide an equivalent
understanding of the pipe’s condition.
In evaluating the results of integrity assessments, operators must integrate information from ()her
relevant sources with the inspection or testing results to hlly identify and characterize the
potential threats to pipeline integrity. These other information sources might include cathodi c
protection system data, close interval surveys, results of previous internal inspections, operat mg
and leak history, patrolling reports, exposed pipe reports, etc. From this evaluation, the operator
should identify the location, nature, and relative severity of anomalies and defects that could
threaten pipeline integrity. Operators will be expected to address the important threats by
evaluating and repairing, if necessary, defects or anomalies in the pipe. Operators must use ; L
risk-based approach in prioritizing repair activities, in which any severe defects or damage that
have the potential to result in a near term leak or failure are addressed immediately. The ruli :
The integrity assessment methods used for low frequency, electric resistance weldel 1
(ERW) pipe and lap welded pipe susceptible to longitudinal seam failures must be capable o f
assessing seam integrity and detecting corrosion and deformation anomalies.
11

<<<PAGE 15>>>

provides minimum mitigation and repair schedules and criteria that must be applied for certaii i,
higher risk features identified through internal inspection.
In addition to the initial, baseline integrity assessment, the rule requires that operators
periodically reconfirm pipeline integrity in high consequence areas through regular integrity
assessments. An operator must perform subsequent assessments of line segments that could
affect high consequence areas no later than five years after the previous assessment.3 Within 1 his
five year limit, operators must establish assessment frequencies commensurate with the risk e ich
pipeline segment presents to a high consequence area. In other words, those segments present ng
a greater risk to high consequence areas would be assessed more frequently than segments
presenting lower risk. The risk factors to be considered when selecting integrity assessment
methods and establishing a schedule for a particular segment include:
m
results of previous pressure testing and internal inspection data and results,
a
pipe design, materials, and manufacturing information,
pipe coating type and condition,
a
leak history, and repair history,
a
cathodic protection system performance,
m
product transported,
operating stress level,
a
a
local environmental factors that could affect integrity (e.g., soil corrosivity, ground
movement potential, and climatic factors),
current or projected activities in the pipeline vicinity, and
physical support of the segment such as by a cable suspension bridge.
Guidance for identifylng and applying risk factors is provided in Appendix C of the final rulc
The rule allows operators to extend the period between integrity assessments to more
than five years if a reliable engineering evaluation and other external monitoring activities show
the pipe to be in good condition, or if an integrity assessment technology the operator plans t I
use is not readily available. If the justification for extending the re-assessment period is on an
engineering basis, an operator must notify OPS nine months before the end of the five-year
interval. If the justification is because of unavailable technology, an operator must notify OE'S
180 days before the end of the five year interval.
12

<<<PAGE 16>>>

Besides the integrity assessment provisions of the rule, operators also have to conduct an
integrated evaluation of line segments that could affect high consequence areas to understand the
greatest risks to these locations. This evaluation must include the results of the integrity
assessments along with other information necessary to obtain a complete understanding of thc
risk contributors to a particular pipe segment. As part of this evaluation, the operator must
critically evaluate the effectiveness of existing preventive and mitigative risk control measure s,
and consider if additional preventive and mitigative actions can improve protection for these
areas. The operator must explicitly consider whether the installation of EFRDs or enhancing 1 eak
detection system capability is warranted. The need for additional preventive and mitigative
measures in high consequence areas must be periodically re-assessed in light of new informal ion
such as changes in the pipeline condition, operating parameters, or the nearby population demity
or environment.
The final regulatory language articulating these requirements is provided in 195.450, 195.452,
and the Federal Register Notice establishing the final requirements for operators who operate less
than 500 miles of hazardous liquid pipeline.
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C. Alternatives Considered
RSPA considered several alternatives in the decision process that led to the final rule. These
altematives are summarized below.
1. Take No Action. In this alternative, RSPA would rely on the existing regulatory requiremc :nts
to provide protection for high consequence areas. Without the provisions of the rule, operatoi’s
would not be required to conduct the baseline integrity assessments, perform an integrated
approach to integrity evaluation, conduct periodic reassessments, and consider other preventi Ive
and mitigative actions for pipeline segments that could affect high consequence areas. 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 and area,;
unusually sensitive to environmental damage (see Section A.2).
2. Require Mandatorv Intemitv Assessments in All High Consequence Areas Everv Ten Yea E.
In determining the practical and appropriate requirements for operators who operate less thar 500
miles of hazardous liquid pipeline, RSPA considered establishing different requirements for
conducting the baseline and subsequent integrity assessments than those established for oper, itors
operating 500 or more miles of pipeline. Initially RSPA considered allowing up to ten years for
this group of operators to conduct the baseline assessments on segments that could affect higli
consequence areas, and allowing an interval for periodic reassessments of up to ten years. BI )th
of these periods are longer than seven years allowed for baseline assessments, and the maxini um
five year interval for subsequent assessments that were recently established for operators
operating 500 or more miles of pipeline (65 FR 75378). RSPA was initially concerned that
operators who operate less than 500 miles of pipeline would not have the financial and tech ical
resources available to comply with the requirements described in Section B. RSPA was also
concerned that during the initial few years, the demand for internal inspection tools might be
more than the inspection device vendors could satisfy (with the simultaneously high demand
being placed by operators operating 500 or more miles of pipeline). If internal inspection de vices
were not available, operators would be forced to conduct hydrostatic testing to achieve
compliance - which in some instances might not be the most desirable approach.
During the period leading up to the proposed rule, RSPA reviewed its internal data, talked N ith
several operators, and gathered information from its Regional inspectors who routinely inspcict
these operators in standard compliance inspections. This investigation showed that many
operators who operate less than 500 miles of pipe already perfom periodic internal inspection or
pressure testing on sizeable portions of their pipeline system (see Section E. 1.3). Thus, RSF A’s
initial assumption about the technical and financial resource capabilities of this group of
operators was not valid. Furthermore, new information obtained from vendors of intemal
inspection devices indicated that while the demand for these tools will be high, the industry
should be capable of satisfying pipeline operators’ needs f
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