U.S. DOT/PHMSA - Briefing Paper - Internal Corrosion - July 24, 2007

Page 1Briefing Paper July 24, 2007 Technical Hazardous Liquid Pipeline Safety Standards Committee Adequacy of Internal Corrosion Regulations for Hazardous Liquid Pipelines Committee action: Discussion. Contact: Barbara Betsock Statutory direction: Section 22 of the Pipeline Integrity, Protection, and Enforcement Safety Act of 2006 directs PHMSA . . . in consultation with the Technical Hazardous Liquid Pipeline Safety Standards Committee and other appropriate entities [to] review the internal corrosion control regulations set forth in subpart H of part 195 of title 49 of the Code of Federal Regulations to determine if such regulations are currently adequate to ensure that the pipeline facilities subject to such regulations will not present a hazard to public safety or the environment. Current regulations on internal corrosion: • Section 195.579(a) requires an operator who transports a hazardous liquid that would corrode the pipeline to take adequate steps to mitigate internal corrosion. • If an operator uses corrosion inhibitors, an operator must follow § 195.579(b) which sets requirements for inhibitors and coupons. • When an operator removes pipe from a pipeline, §195.579(c) requires an operator to check for internal corrosion. • If a pipeline’s failure could affect an HCA (commercially navigable waterway, high population area, other populated area, or unusually sensitive area), the operator must identify whether internal corrosion is a threat. If it is, § 195.452 requires an operator to have a continual process of evaluation and assessment to maintain integrity. Risk history: • Between 2002 and mid-2007, hazardous liquid pipeline accidents due to internal corrosion reported to PHMSA resulted in $10.9 million in property damage, and 72.7 thousand lost barrels. Property damage includes damage to the property of the operator or others, cost of clean-up and recovery, value of lost product. It is reportable to the extent it exceeds $50,000. • Slow leaks due to internal corrosion can go undetected for years and pollute aquifers and soils. • Based on PHMSA data from the past 5 years, 91% of internal corrosion accidents on hazardous liquid pipelines occurred on crude pipelines. This includes $7 million of the damages and 67.9 thousand lost barrels. • An unregulated BP low pressure pipeline failed on March 2, 2006, and spilled an estimated 201,000 gallons of crude oil onto the tundra on the North Slope of Alaska near Prudhoe Bay. The cause was internal corrosion. Because the pipeline is not regulated, the accident is not included in PHMSA data.#

Page 2• Is this extent of risk acceptable? Explain why or why not? • Is leak detection in use on most crude lines sufficient to detect internal corrosion leaks? Control of risk: • What consensus standards or best practices exist on internal corrosion? • Are these standards/practices adequate forms of risk control? • Would you use any particular strategy to assign priorities to risk control options? If so, what might these be? • Should PHMSA get involved in controlling risks here? If so how (by regulating, sponsoring best practices workshops, participating in development of consensus standards, etc.) • After the BP accident, PHMSA proposed to require low stress pipelines in high consequence areas to be continually monitored for internal corrosion in a notice of proposed rulemaking published in September 2006. Because the low stress lines covered in this first phase of low stress regulation will be covered by the continual evaluation requirement in integrity management, PHMSA decided to drop the requirement for continual monitoring for internal corrosion risk. In the supplemental notice of proposed rulemaking issued in May 2007, PHMSA noted that it would consider the need for continual monitoring for internal corrosion for all pipelines (including those operating above 20 percent SMYS) in the second phase of the rulemaking on low stress lines. How should PHMSA handle this? • Operators commonly include use of cleaning pigs and corrosion inhibitors as part of internal corrosion programs. Is there good guidance on this method of control? If more is needed, what is the best approach? • The transportation of hazardous liquids poses a greater risk of internal corrosion than the transportation of natural gas. At the recommendation of the National Transportation Safety Board, PHMSA adopted design and construction standards addressing internal corrosion in gas transmission pipelines. (72 FR 20055, April 23, 2007). Is there good guidance for hazardous liquid pipelines? If more is needed, what is the best approach?#