PHMSA recently released an Advisory Bulletin on Pipeline Safety: Clarification of Terms Relating to Pipeline Operational Status, Docket No. PHMSA-2016-0075 concerning the idle pipeline integrity management (IM) assessments. The Advisory Bulletin states:
“Owners and operators of pipelines that are not operating but contain hazardous liquids and gas must comply with all relevant safety requirements, including periodic maintenance, integrity management assessments, damage prevention programs, and public awareness programs,”
“PHMSA will accept deferral of certain activities for purged but active pipelines. These deferred activities might include actions impractical on most purged pipelines, such as in-line inspection.”
We like to keep our customers informed about all regulatory requirements and provide our knowledgeable interpretations. In regards to the recent bulletin, the expectation is that an idle line is indeed subject to IM regulations. Practically speaking, this means that the operator must base IM decisions on the current operation of the pipeline. For example, a properly purged pipeline may not have the same ability to affect a HCA that a line containing hazardous liquid or gas would. Similarly, the data applicable to risk assessment may classify an idled, purged line as considerably lower risk than one containing product. Although the results of these analyses may prove that the line cannot affect a HCA and effectively has no Risk Score, IM activities and assessment plans should be performed and reflect actual line conditions. However, an operator may submit an assessment deferment request to PHMSA if the operator can prove the purged pipeline’s delayed assessment will not jeopardize public safety or environmental protection.
Another existing interpretation of this expectation can be found in Gas Transmission Integrity Management FAQ-7.
Our compliance team is happy to discuss questions regarding this requirement or a specific scenario within your operations, feel free to .