U.S.

Government pipeline
safety regulation
by J C Caldwell
Caldwell & Associates, USA

Contents of this Paper:

Introduction

Congressional posture

DOT/OPS regulatory activities

Major pipeline safety issues

Conclusion

Copyright 2001 Scientific Surveys Ltd. All rights reserved.

Pipeline Pigging and Integrity Monitoring Conference: Houston, 1991

Introduction
The Federal Regulatory picture becomes more complex as time passes. The Congress is requiring that more and
more areas of safety be addressed, either by way of studies and evaluation or regulations. The OPS seems to be
bogging down under the load and regulatory system. When OPS was established in 1968, a regulation normally
took about 9 months to a year from notice to final rule. The entire basic set of Natural Gas Pipeline Safety
Regulations was developed and published in less than two years. Today, there are proposed regulations on the
agenda that have been in the process since early 1987 and early 1989, and the NPRM has not even been
published. It is unfortunate, but the system seems not to be working, at least not working well.
This presentation will review the posture of the Congress regarding pipeline safety, with past and pending
activities; OPS regulatory activities; and what the future holds, including certain areas of new and existing
technology. Ill focus primarily on those areas that will impact on/or relate to the evaluation and operation of
existing pipeline systems.

Congressional posture
The Congress passed the comprehensive Pipeline Safety Reauthorization Act of 1988 that spelled out some very
definite areas of concern over the safety of gas and hazardous liquid pipelines. This included the mandating of
specific regulations and studies.
During 1990, Congress held hearings on offshore pipeline navigational hazards and passed HR 4888, a bill
requiring the OPS to establish regulations that will require an initial inspection for cover of gas and hazardous
liquid pipelines in the Gulf of Mexico from the shoreline to the 15ft depth. Based on the findings of the study, the
OPS is also directed to develop standards that will require the pipeline operators to report pipeline facilities that
are hazardous to navigation, the marking of such hazards, and establish a mandatory, systematic, and where
appropriate, periodic inspection program.
This legislation involves an estimated 1400 miles of pipeline, or about 10% of the total pipelines in the Gulf of
Mexico. The legislation will eventually have an impact on all gas and hazardous liquid pipelines in all navigable
waters of the US, particularly those in populated and environmentally-sensitive areas.
Congressional committees are now drafting legislation for 1991 which will be included in the Pipeline Safety
Reauthorization Act of 1991. It is felt that this legislation will, in addition to underwater and offshore pipelines,
include such areas as:
(a) Environmentally-sensitive and high-density populated areas - require the DOT to identify all pipelines
that are at river crossings, located in environmentally-sensitive areas, located in wetlands, or located in
high-density population areas.
(b) Smart pigs - require pipeline operators to inspect with smart pigs all lines that have been identified in
(a) above. If the pipeline will not accept a pig, then the operators will have to modify the pipeline and run
the pig under another set of rules. Also, there may be government funding to assist in the development of
a smart pig capable of detecting potential longitudinal seam failures in ERW pipe.
(c) Environmental protection - establish an additional objective of the Pipeline Safety Acts to protect the
environment. This could include increasing the membership of the Technical Pipeline Safety Standards
Committees to include representatives from the environmental community.
(d) Enforcement activities - increase the requirements and staff of OPS to provide a more comprehensive
inspection and enforcement program.
(e) Operator training - mandate requirements for programs to train all pipeline operators/dispatchers.

Copyright 2001 Scientific Surveys Ltd. All rights reserved.

U.S. Government pipeline safety regulation

(f) Leak detection - require that operators have some type of leak detection capability to detect and locate
leaks in a reasonable length of time and shut the system down with minimum loss of product.
(g) Pipeline safety policy - require that OPS to establish a policy development group within its office.
As you can see, the Congress is becoming more involved in pipeline safety matters and will be issuing more
mandates for specific regulatory requirements.

DOT/OPS regulatory activities

The DOT/OPS continues to address pipeline safety problems in their regulatory activities. Their latest regulatory
agenda, published on 29th October, 1990, contained 18 rulemaking items. Of these, there are eight that I consider
will have an impact on the activities of this group. A summary and the status of each are as follows:
OPS Regulatory Agenda: Proposed Rule stage
1. Hydrostatic testing of certain hazardous liquid pipelines (49 CFR 195)
SUMMARY: This rule would extend the requirement to operate all hazardous liquid pipelines to not
more than 80% of a prior test or operating pressure. This proposal is based on the fact that significant
results have been achieved by imposing such operating restrictions on pipelines that carry highly-volatile
liquids. This rule making is significant, because of substantial public interest.
STATUS: NPRM issued 1/00/91
2. Gas-gathering line definition (49 CFR 192.3)
SUMMARY: The existing definition of gathering line would be clearly defined to eliminate confusion
in distinguishing these pipelines from transmission lines in rural areas. Action is significant because the
definition is the subject of litigation.
STATUS: NPRM to be issued early 1991.
3. Gas pipelines operating above 72% of specified minimum yield strength (49 CFR 192)
SUMMARY: This proposal would eliminate or qualify the grandfather clause if the natural gas pipeline
safety regulations that permit operation of an existing rural or offshore gas pipeline found to be in
satisfactory condition at the highest actual operating pressure to which the segment was subjected during
the five years preceding 1st July, 1970, or, in the case of an offshore gathering line, 1st July, 1976.
STATUS: ANPRM issued 3/12/90
NPRM to be issued early 1991
4. Transportation of hydrogen sulfide by pipeline (49 CFR 192)
SUMMARY: This action examines the need to establish a maximum allowable concentration of hydrogen
sulfide that can be introduced into natural gas pipelines and how to control it.
STATUS: ANPRM issued 9/05/90
NPRM to be issued early 1991

Copyright 2001 Scientific Surveys Ltd. All rights reserved.

Pipeline Pigging and Integrity Monitoring Conference: Houston, 1991

5. Passage of internal inspection devices (49 CFR 192; 49 CFR 195)

SUMMARY: This rulemaking would establish minimum Federal safety standards requiring that new and
replacement gas transmission and hazardous liquid pipelines be designed and constructed to
accommodate the passage of internal inspection devices. This rulemaking was mandated by P.L. 100-561.
STATUS: NPRM to be issued by early 1991
6. Transportation of a hazardous liquid at 20% or less of specified minimum yield strength (49 CFR 195)
SUMMARY: This rulemaking action would assess the need to extend the Federal safety standards to
cover these lower stress level pipelines (except gathering lines), and if warranted, apply the standards to
those pipelines.
STATUS: ANPRM issued 10/31/90
7. Burial of offshore pipelines (49 CFR 192; 49 CFR 195)
SUMMARY: This rulemaking will propose that operators remove abandoned lines in water less than 15ft
deep, bury pipelines at least 3ft deep in water up to 15ft deep, and monitor the depth of buried pipelines in
water less than 15ft deep.
STATUS: NPRM to be issued 4/00/91
OPS Regulatory Agenda: Final Rule stage
8. Determining the extent of corrosion on exposed gas pipelines (49 CFR 192)
SUMMARY: This action proposed that when gas pipelines are exposed for any reason, and they have
evidence of harmful corrosion, that it be investigated to determine the extent of the corrosion.
STATUS: NPRM issued 9/25/89 Final Action by early 1991.
There are two other major issues that were required by the Reauthorization Act of 1988 to be addressed by OPS:
the internal inspections of pipelines, and emergency flow-restricting devices. The studies required have been
completed, but as of this writing have not been provided to Congress. The Internal Inspection Report was due to
Congress in April of 1990 and the Emergency Flow Restriction Device was due on 31st October, 1989.

Major pipeline safety issues

1. The areas of concern continue, as in recent years, to include the following:
The evaluation of the condition and integrity of existing pipeline systems continues to be a major concern. As
mentioned earlier, the pressure will continue on the OPS and industry to develop and use better methods and
materials to ensure the integrity of older pipeline systems.
The internal inspection (pigging) industry is establishing itself as a unified body that can speak with authority.
2. Pipeline rehabilitation
The pipeline and service industries are teaming up to do research and develop procedures and techniques to be
used in the rehabilitation of existing pipeline systems. The mileage of rehabilitation work planned or underway
has increased dramatically over the past year.

Copyright 2001 Scientific Surveys Ltd. All rights reserved.

U.S. Government pipeline safety regulation

3. Underwater pipelines and offshore operations

The passage of HR 4888 regarding the inspection of certain offshore pipelines just scratches the surface on
requirements for underwater pipelines. The Congress will continue to push these requirements for all underwater
pipelines. The inspection and survey industries will have to develop new technology and techniques to locate and
determine the cover condition of these systems. The entire area of offshore pipeline operation and maintenance is
undergoing a thorough review.
4. Handling of emergencies
This subject continues to be of high interest. We will see continued effort on requiring training of pipeline
operators, providing equipment to detect, locate and shut down systems. Also, emphasis will be stressed on
valving design and maintenance.

Conclusion
As you can see, the challenges of pipeline safety continue. During this years legislative and regulatory activities
there will be substantial opportunity for the pipeline and related industries to provide input to the process. With
the nations natural gas and hazardous liquid pipeline systems growing older each day, innovative techniques and
equipment are going to have be put into use. This will require the efforts of each of us, and hopefully reward all of
us.
Lets strive to make regulations that solve problems, not compound existing problems or create new problems.

Copyright 2001 Scientific Surveys Ltd. All rights reserved.

Pipeline Pigging and Integrity Monitoring Conference: Houston, 1991

Copyright 2001 Scientific Surveys Ltd. All rights reserved.