{"operation":"document","citation":"0900006480e8d3eb","title":"U.S. DOT/PHMSA - Briefing Paper - Internal Corrosion - July 24, 2007","source_type":"rulemaking","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":null,"effective_on":null,"summary":"The briefing paper (July 24, 2007) frames a committee discussion to review the adequacy of internal corrosion regulations for hazardous liquid pipelines per Section 22 of the Pipeline Integrity, Protection, and Enforcement Safety Act of 2006. It summarizes current regulatory requirements (§195.579 and §195.452), presents recent risk history and incident statistics (2002–mid‑2007), and lists specific questions for committee consideration regarding acceptability of risk, leak detection, consensus standards, risk control strategies, PHMSA involvement, monitoring decisions following a 2006 BP internal corrosion spill, and guidance on cleaning pigs/corrosion inhibitors and design standards. The document is a discussion/decision paper and poses questions rather than asserting agency conclusions; it cites reported damages and volumes lost from internal corrosion incidents and notes an unregu‑ l","machine_formats":{"json":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e8d3eb.json","markdown":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e8d3eb.md"},"app_url":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e8d3eb","source_url":"https://downloads.regulations.gov/PHMSA-RSPA-1998-4470-0239/attachment_1.pdf","body":"<<<PAGE 1>>>\n\nBriefing Paper July 24, 2007\nTechnical Hazardous Liquid Pipeline Safety Standards Committee\nAdequacy of Internal Corrosion Regulations for Hazardous Liquid Pipelines\nCommittee action: Discussion.\nContact: Barbara Betsock\nStatutory direction: Section 22 of the Pipeline Integrity, Protection, and Enforcement\nSafety Act of 2006 directs PHMSA\n. . . in consultation with the Technical Hazardous Liquid Pipeline Safety Standards\nCommittee and other appropriate entities [to] review the internal corrosion control\nregulations set forth in subpart H of part 195 of title 49 of the Code of Federal\nRegulations to determine if such regulations are currently adequate to ensure that the\npipeline facilities subject to such regulations will not present a hazard to public safety\nor the environment.\nCurrent regulations on internal corrosion:\n• Section 195.579(a) requires an operator who transports a hazardous liquid that\nwould corrode the pipeline to take adequate steps to mitigate internal corrosion.\n• If an operator uses corrosion inhibitors, an operator must follow § 195.579(b)\nwhich sets requirements for inhibitors and coupons.\n• When an operator removes pipe from a pipeline, §195.579(c) requires an operator\nto check for internal corrosion.\n• If a pipeline’s failure could affect an HCA (commercially navigable waterway,\nhigh population area, other populated area, or unusually sensitive area), the\noperator must identify whether internal corrosion is a threat. If it is, § 195.452\nrequires an operator to have a continual process of evaluation and assessment to\nmaintain integrity.\nRisk history:\n• Between 2002 and mid-2007, hazardous liquid pipeline accidents due to internal\ncorrosion reported to PHMSA resulted in $10.9 million in property damage, and\n72.7 thousand lost barrels. Property damage includes damage to the property of\nthe operator or others, cost of clean-up and recovery, value of lost product. It is\nreportable to the extent it exceeds $50,000.\n• Slow leaks due to internal corrosion can go undetected for years and pollute\naquifers and soils.\n• Based on PHMSA data from the past 5 years, 91% of internal corrosion accidents\non hazardous liquid pipelines occurred on crude pipelines. This includes $7\nmillion of the damages and 67.9 thousand lost barrels.\n• An unregulated BP low pressure pipeline failed on March 2, 2006, and spilled an\nestimated 201,000 gallons of crude oil onto the tundra on the North Slope of\nAlaska near Prudhoe Bay. The cause was internal corrosion. Because the\npipeline is not regulated, the accident is not included in PHMSA data.\n\n<<<PAGE 2>>>\n\n• Is this extent of risk acceptable? Explain why or why not?\n• Is leak detection in use on most crude lines sufficient to detect internal corrosion\nleaks?\nControl of risk:\n• What consensus standards or best practices exist on internal corrosion?\n• Are these standards/practices adequate forms of risk control?\n• Would you use any particular strategy to assign priorities to risk control options?\nIf so, what might these be?\n• Should PHMSA get involved in controlling risks here? If so how (by regulating,\nsponsoring best practices workshops, participating in development of consensus\nstandards, etc.)\n• After the BP accident, PHMSA proposed to require low stress pipelines in high\nconsequence areas to be continually monitored for internal corrosion in a notice of\nproposed rulemaking published in September 2006. Because the low stress lines\ncovered in this first phase of low stress regulation will be covered by the continual\nevaluation requirement in integrity management, PHMSA decided to drop the\nrequirement for continual monitoring for internal corrosion risk. In the\nsupplemental notice of proposed rulemaking issued in May 2007, PHMSA noted\nthat it would consider the need for continual monitoring for internal corrosion for\nall pipelines (including those operating above 20 percent SMYS) in the second\nphase of the rulemaking on low stress lines. How should PHMSA handle this?\n• Operators commonly include use of cleaning pigs and corrosion inhibitors as part\nof internal corrosion programs. Is there good guidance on this method of control?\nIf more is needed, what is the best approach?\n• The transportation of hazardous liquids poses a greater risk of internal corrosion\nthan the transportation of natural gas. At the recommendation of the National\nTransportation Safety Board, PHMSA adopted design and construction standards\naddressing internal corrosion in gas transmission pipelines. (72 FR 20055, April\n23, 2007). Is there good guidance for hazardous liquid pipelines? If more is\nneeded, what is the best approach?","truncated":false,"body_characters":4638}