PHMSA Gas Integrity Management
Time: 11/08/2008 05:31 PM

Frequently-Asked Question FAQ #35

FAQ-35: Required Completion Date for Highest-Risk Segments

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Question: Must all of the highest risk segments be assessed by December 17, 2007, or will OPS allow operators some flexibility to deal with practical issues in scheduling assessments?

Answer: The rule requires that baseline assessments must be completed on at least 50 percent of the covered segments by December 17, 2007, and that assessments be prioritized based on risk. Although OPS expects operators to concentrate on the highest risk pipe, some segments not among the highest risk pipe may be counted towards the 50 percent requirement. OPS recognizes that practical issues associated with scheduling and conducting assessments may lead to some lower risk pipe being assessed prior to high-risk pipe. For example, during an in-line inspection to address a high risk segment, an operator may also assess another lower risk segment that happens to be located in the same section of pipe that is being inspected. This additional segment may be credited against the December 17, 2007, deadline. OPS inspections will review how an operator has prioritized segments for assessment to assure that appropriate emphasis is being placed on the highest-risk pipe.

These Frequently Asked Questions (FAQs) are intended to clarify, explain, and promote better understanding of the pipeline integrity management rules. These FAQs are not substantive rules and do not create rights, assign duties, or impose new obligations not outlined in the existing integrity management regulations and standards. Requests for informal interpretations regarding the applicability of one or more of the pipeline integrity management rules to a specific situation may be submitted to PHMSA in accordance with 49 C.F.R. ยง 190.11.
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