Pressure Testing Older Hazardous Liquid and Carbon Dioxide Pipelines

DEPARTMENT OF TRANSPORTATION

Research and Special Programs Administration

49 CFR Part 195

[Docket No. PS-121; Notice-2]

RIN 2137-AB46

Pressure Testing Older Hazardous Liquid and Carbon Dioxide

Pipelines

AGENCY: Research and Special Programs Administration (RSPA), DOT.

ACTION: Response to petitions for reconsideration; request for

comments.

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SUMMARY: On June 7, 1994, RSPA issued a final rule amending existing

regulations for liquid and carbon dioxide pipeline facilities. The rule

required the hydrostatic pressure testing of certain older pipelines

that were never pressure tested to current standards. The American

Petroleum Institute (Petitioner or API) and Williams Pipe Line Company

(Petitioner or Williams) filed Petitions for Reconsideration

(petitions) concerning certain provisions of the final rule. In

response to these petitions, this document clarifies certain provisions

of the final rule and seeks comments on one issue.

DATES: Interested persons are invited to submit comments on this notice

by April 13, 1998. Late filed comments will be considered to the extent

practicable.

ADDRESSES: Written comments must be submitted in duplicate and mailed

or hand-delivered to the OPS, Room 2335, U.S. Department of

Transportation, 400 Seventh Street, SW., Washington, DC 20590-0001.

Identify the docket and notice number stated in the heading of this

notice. Alternatively, comments may be submitted via e-mail to

``[email protected]''. Comments will become part of this docket

and will be available for inspection or copying in Room 2335 between

8:30 a.m. and 5:00 p.m. each business day.

FOR FURTHER INFORMATION CONTACT: Mike Israni, (202) 366-4571, or e-

mail: [email protected], regarding the subject matter of this

document, or OPS (202) 366-4046, for copies of this petition document

or other material in the docket.

SUPPLEMENTARY INFORMATION:

Background

The purpose of the pressure testing rule (59 FR 29379; June 7,

1994) is to ensure that certain older hazardous liquid and carbon

dioxide pipelines have an adequate safety margin between their maximum

operating pressure and test pressure. The rule applied to those

pipelines never pressure tested according to current standards. The

compliance dates for pressure testing the older pipelines have been

extended. (62 FR 54591; October 21, 1997). The extension is to allow

for consideration of rulemaking providing an alternative to pressure

testing in certain circumstances. This alternative to pressure testing

is based on a petition from API.

In its petitions for reconsideration of the final rule, API raised

three issues and Williams raised two issues. The most significant issue

raised by both API and Williams related to the prohibition of testing

with petroleum. The pressure testing rule prohibited the use of

petroleum as a test medium in pressure testing such pipelines. RSPA

withdrew the prohibition by amendment of the pressure testing rule on

August 11, 1994 in the Federal Register (59 FR 41259).

Remaining Issues in Petitions

Disposal of Test Water

API asserted that the final rule did not adequately address its

comments concerning problems with obtaining permits to acquire and

dispose of test water. API reiterated concerns raised in its comments

submitted during the pressure testing rulemaking comment period.

Specifically, API asked that RSPA issue administrative procedures,

perhaps in conjunction with the Environmental Protection Agency (EPA),

that would facilitate the process of obtaining permits to acquire and

dispose of test water. In its petition, API claimed that RSPA's

coordination effort ``has not reached the appropriate persons within

EPA so that it has any impact on the ability of an operator to obtain a

permit or waiver.'' Furthermore, API stated that some of its member

companies have been attempting to get EPA's attention on the subject of

permits for hydrostatic test water for several years with little

success. API claimed that member companies in EPA Region VI have

experienced ``delays of years in obtaining permits, with some permits

never issued.'' API stated that, because

[[Page 6678]]

Texas and Louisiana do not have EPA approved state programs for issuing

EPA disposal permits, operators must obtain permits from both the state

and EPA in Texas and Louisiana (both in EPA Region VI). In addition,

API claimed that its member companies have experienced similar delays

in obtaining water disposal permits in other EPA regions. As a result,

API asserted that operators will not be able to obtain such permits,

and will be unable to schedule testing to meet the compliance deadlines

established in the final rule.

Response--RSPA has written to the Assistant Administrator for Water

requesting that EPA give prompt attention to requests from operators

for National Pollutants Discharge Elimination System (NPDES) permits to

dispose of test water used to comply with the final rule. We have

provided EPA headquarters with information regarding delays in issuing

permits. RSPA believes that EPA will provide permits to dispose of test

water. If an operator cannot obtain such a permit, this would be a

basis for a waiver request. In addition, as already noted, RSPA intends

to publish an NPRM on an alternative to pressure testing in the near

future. If adopted, the alternative would at times allow an operator to

elect a means of ensuring the integrity of its pipeline other than

pressure testing. This would avoid the need to dispose of test water.

Inert Gas as Test Medium

Petitioner asserts that the final rule results in the prohibition

of any test medium other than water, although some companies use inert

gas to test short segments of line. API states that inert gas testing

accomplishes the same purpose as hydrotesting.

Response--The use of inert gas in lieu of water or liquid petroleum

as test medium was not raised in the proposed rulemaking. Therefore, we

can not address it in this response to petition for reconsideration of

the pressure test rule. However, Sec. 195.306(c) allows, under

specified conditions, the use of inert gas or carbon dioxide as a test

medium rather than water or petroleum for carbon dioxide pipelines.

Further, Sec. 195.306(d) permits the use of air or inert gas as the

test medium in low-stress pipelines.

Terminal Piping

Williams disagreed that piping systems within terminals need to be

tested. Terminal piping includes receiving and reinjection lines, both

connected by piping to breakout tanks. Williams believes that terminal

piping systems should be exempt from the testing requirements of the

regulation. Williams' position is that the final rule was issued to

test older high pressure ``pipes'' in cross-country pipelines. Williams

offered the following reasons not to test such systems.

1. Williams' low pressure piping systems operate below 275 psi,

below 20 percent of specified minimum yield strength (SMYS).

2. The ERW or seamless piping in the low-pressure systems are

generally Grade B pipe of standard wall construction in pipe sizes of

6, 8, 10, and 12 inch diameter with maximum operating pressures (MOP)

of 2130, 1881, 1711, and 1482 psi, respectively.

3. These low-pressure piping systems have series 150 American

National Standard Institute (ANSI) flanges good only for 275 psi MOP,

well under 20 percent SMYS.

4. These low-pressure piping systems are protected by full-flow low

pressure manifold relief systems set to operate at 275 psi in

accordance with 49 CFR Sec. 195.406(b).

5. A one-time pressure leak test provides an insignificant amount

of protection for the public safety and the environment.

6. Williams has no records of any seam failures occurring in ERW

pipe within its terminal boundaries.

Response--In another final rule issued after Williams filed the

petition for reconsideration (Transportation of Hazardous Liquids at 20

percent or Less of Specified Minimum Yield Strength (59 FR 35465; July

12, 1994)), RSPA extended Part 195 to cover certain previously

unregulated low-stress pipelines. (These did not include piping in

terminal areas which are addressed in the Williams petition.) However,

RSPA did not apply the pressure testing requirements of Subpart E to

these previously unregulated low-stress pipelines except for

replacements, relocations, and lines carrying highly volatile liquids

(HVL).

The piping at Williams' terminal is designed with relief valves

which ensure that the piping will never experience pressure at or

exceeding 20% SMYS. If the same rationale used in the low-stress

pipeline rule is applied, pressure testing may not be needed for safety

as long as the piping does not transport HVL. However, RSPA wants to

explore this issue further by inviting comments from the public on the

following issues:

(1) Should a segment of pipeline system (such as pipeline within

terminal, or tank farm) which is designed and operated so that stress

levels can never exceed 20% SMYS qualify for an exemption from pressure

testing?

(2) Should we require pressure testing of piping in terminals and

tank farms based on risk (considering such risk factors as location,

history of corrosion leaks, weld type, underground or above ground

terminal piping, percentage of lines under corrosion protection, etc.)?

As noted above, the requirement for pressure testing has been

stayed to allow completion of rulemaking on a risk-based approach to

pressure testing. This stay should provide sufficient time for RSPA to

evaluate comments received in response to this request and to decide on

a course of action. In any case, until these comments are evaluated and

a course of action is decided on, RSPA will not enforce the requirement

for pressure testing within terminal areas that are designed and

operated so that stress levels can never exceed 20% SMYS.

Issued in Washington D.C. on February 5, 1998.

Richard B. Felder,

Associate Administrator for Pipeline Safety.

[FR Doc. 98-3345 Filed 2-9-98; 8:45 am]

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