Pipeline Safety: Corrosion Control on Gas and Hazardous Liquid Pipelines

DEPARTMENT OF TRANSPORTATION

Research and Special Programs Administration

49 CFR Parts 192 and 195

[Docket No. RSPA-97-2762; Notice 2]

RIN 2137-AD24

Pipeline Safety: Corrosion Control on Gas and Hazardous Liquid

Pipelines

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

ACTION: Notice of public meeting and request for comments.

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SUMMARY: We are considering the need to modify our corrosion control

standards for gas and hazardous liquid pipelines. To start, we are

reviewing the gas standards to see if any need to be clarified, made

more effective, or upgraded to be consistent with modern safety

practices. The review will help us carry out the President's Regulatory

Reinvention Initiative and determine if rule changes are needed to

reduce the potential for corrosion-caused incidents. So far, we have

held a public meeting and met with knowledgeable persons from industry

and state regulatory agencies on the adequacy of the standards. Now, to

get feedback on the results of these efforts, interested persons are

invited to participate in a second public meeting and to submit written

comments on the matters discussed in this notice. The public meeting

will be in conjunction with the National Association of Corrosion

Engineers (NACE) 54th Annual Conference and Exhibition, CORROSION/99,

in San Antonio, Texas.

DATES: The public meeting will be on April 28, 1999, from 8:00 am to

12:00 noon at the Marriott Riverwalk Hotel in San Antonio, Texas. If

you want to make an oral presentation at the meeting, please notify

Jenny Donohue no later than April 23, 1999, by phone (202-366-4046) or

by Internet e-mail ([email protected]), and indicate the

approximate length of your presentation. In addition, no later than

June 30, 1999, you may submit written comments by mailing or delivering

an original and two copies to the Dockets Facility, U.S. Department of

Transportation, Room PL-401, 400 Seventh Street, SW, Washington, DC

20590-0001. Or you may submit written comments to the docket

electronically. To do so, log on to the following Internet Web address:

http://dms.dot.gov. Click on ``Help & Information'' for instructions on

how to file a document electronically. All

[[Page 16886]]

written comments should identify the docket and notice numbers stated

in the heading of this notice. Anyone who wants confirmation of mailed

comments must include a self-addressed stamped postcard. Late filed

comments will be considered so far as practicable.

ADDRESSES: The Marriott Riverwalk Hotel is located at 101 Bowie Street,

San Antonio, TX 78205, phone: (210) 223-1000. The Dockets Facility is

located on the plaza level of the Nassiff Building, Room PL-401, 400

Seventh Street, SW, Washington, DC. It is open from 10:00 a.m. to 5:00

p.m., Monday through Friday, except federal holidays when it is closed.

FOR FURTHER INFORMATION CONTACT: Richard Lopez by phone at 713-718-3956

or by Internet e-mail at [email protected]. You can read

comments and other material in the docket (RSPA-97-2762) at this

Internet Web address: http://dms.dot.gov. General information about our

pipeline safety program is available at this Internet Web address:

http://ops.dot.gov. Graphs showing the rate of pipeline incidents due

to corrosion will also be posted at that Web address.

SUPPLEMENTARY INFORMATION:

Background

Outside-force damage and corrosion are, respectively, the number

one and number two causes of reported incidents on gas and hazardous

liquid pipelines. Persons who participated in our Risk Assessment

Prioritization (RAP) program, which we use to allocate our resources,

rated the risk of outside-force damage as ``very high'' and the risk of

corrosion as ``high.'' In an effort to reduce outside-force damage, we

have established standards for operator programs designed to prevent

excavation damage and for state programs that oversee one-call

notification systems. Recently we began working with other concerned

organizations to inform the public on ways to reduce damage to all

underground utilities and to study and promote the use of the best

practices in damage prevention. For the corrosion risk, RAP

participants identified several risk mitigating activities, the more

significant of which, such as creating risk-based inspection programs,

establishing cathodic protection criteria for hazardous liquid

pipelines, and defining electrical survey alternatives, are among the

concerns mentioned below.

Our statistical analyses of the data that operators report under 49

CFR Parts 191 and 195 show that while corrosion remains the second

leading cause of reported pipeline incidents, the rate of reportable

incidents due to corrosion has declined in recent years. Also, as shown

by the table below for the period 1986 through 1998, the likelihood of

corrosion-caused incidents harming people or the environment continues

to be relatively low. Still, we think the record warrants our attention

and indicates there may be reasons to improve our corrosion control

standards to reduce the potential for future incidents. We are

especially interested in evaluating the best long-term corrosion

control measures to determine if cost-effective means of further

reducing corrosion can be implemented.

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Percent of

Percent of Percent of Percent of all

Pipeline all all deaths all property

incidents injuries damages

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Gas transmission and gathering.............................. 22.7 0 3.7 13

Gas distribution (non-plastic).............................. 4.9 5.6 7.0 3.9

Hazardous liquid............................................ 25.7 3.2 0.9 20

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To evaluate alternative regulatory strategies and in further

response to the President's Regulatory Reinvention Initiative

1, on September 8, 1997, we held a public meeting on how the

corrosion control standards in 49 CFR Parts 192 and 195 might be

improved (62 FR 44436; Aug. 21, 1997). The meeting was held in Oakbrook

Illinois in conjunction with NACE's Fall Committee Meetings to attract

participation by experts in corrosion control. NACE is an international

organization that provides training and certification programs,

conferences, standards, and reports on the prevention and control of

materials corrosion.

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\1\ On March 4, 1995, President Clinton issued a memorandum to

heads of departments and agencies calling for a review of all agency

regulations and elimination or revision of those that are outdated

or in need of reform.

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The Oakbrook meeting focused primarily on whether our corrosion

control standards should incorporate by reference NACE Standard RP0169-

96, ``Control of External Corrosion on Underground or Submerged

Metallic Piping Systems,'' as a substitute for all or some of the

requirements, and whether the requirements should be the same for gas

and hazardous liquid pipelines. Many participants and subsequent

commenters opposed incorporating the NACE document by reference because

it is not entirely written in regulatory, or mandatory, style. There

was also general agreement that although some changes may be needed,

our corrosion control standards for gas and hazardous liquid pipelines

should be generally the same.

After the Oakbrook meeting, we began a detailed review of the

corrosion control standards in 49 CFR Part 192, Subpart I. We began

reviewing the gas pipeline standards rather than the standards for

hazardous liquid pipelines in Part 195 because the gas standards

provide more detailed criteria. To help in this effort, we have met

from time to time with representatives from NACE, the pipeline

industry, and state governments. The meetings have helped us assess

whether the Subpart I standards are adequate for safety, need

clarification, or allow the use of new technologies.

In order to have the same standards for gas and hazardous liquid

pipelines, we are now considering whether the gas pipeline standards,

possibly with some changes, would be suitable for hazardous liquid

pipelines. The advantage of applying the gas standards to hazardous

liquid pipelines is that the gas standards are less ambiguous than the

hazardous liquid standards. However, changes besides those that may be

needed for gas pipelines may be needed to accommodate the different

operating characteristics of hazardous liquid pipelines, such as

temperature and commodity corrosiveness.

To optimize our review process, we have assigned the following

priorities to different segments of the nation's pipeline

infrastructure: We are considering hazardous liquid pipelines first,

because the current Part 195 corrosion control standards are ambiguous

in many respects and because corrosion-caused failures on these lines

pose risks to the

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environment as well as public safety. Next in importance are gas

transmission and non-rural gathering lines because of the continuing

high percentage of corrosion-caused incidents. Finally comes gas

distribution lines, because assessing the need to modify standards to

account for operational differences between gas transmission and

distribution lines and among gas distribution systems is more

difficult, requiring more information about systems and possible

alternatives to present standards. These three stages of review may

result in publication of one or more notices of proposed rulemaking

later this year after considering all the comments we receive as a

result of this notice.

Guiding Principles

At our latest meetings with industry and state representatives, in

Houston, Texas on February 16-19, 1999, at the Marriott Westside Hotel,

and in Washington, DC on March 11, 1999, at our headquarters, the

following principles were developed to guide our assessment of the need

to improve or clarify the corrosion control standards:

Evaluate existing data and use the evaluation to assess

the need to change standards.

Continue to improve public safety and environmental

protection.

Assess the need for corrosion control standards throughout

the national pipeline system based on the risk associated with

different parts of the system.

Upgrade regulations to allow for future changes in

pipeline industry technology and operating practices as appropriate.

Strive for uniform interpretation/enforcement.

To the extent practicable, involve all interested parties

in assessing the need to change standards.

Use the new cost/benefit policy framework being developed

for RSPA's pipeline safety advisory committees in determining the costs

and benefits of potential changes to standards.

Achieve balance between performance and prescriptive

language.

Develop performance measures to assess the effectiveness

of corrosion control programs.

Focus on managing corrosion to maintain pipeline

integrity.

Provide adequate regulatory flexibility to allow operators

to implement alternative measures that meet the performance

requirements of the corrosion regulations.

RSPA Concerns

Besides the guiding principles, the meetings with industry and

state representatives have helped us evaluate the following concerns we

have about the adequacy of the gas pipeline corrosion control

standards. These concerns relate generally to the clarity of the

standards, whether the standards are effective, whether they are

consistent with modern practices, and whether they are in the interest

of safety. The list does not include Sec. 192.459, for which we have

already proposed changes to deal with the problem of the extent of

corrosion on exposed pipelines (Docket PS-107; 54 FR 27041; June 27,

1989). If we were to propose changes to Part 195 based on the corrosion

control standards in Subpart I of Part 192, we would include in the

proposal any changes that may be necessary to make Part 195 consistent

with any changes made to Sec. 192.459 in Docket PS-107.

The concerns stated below relate to the Subpart I standards in 49

CFR Part 192, which apply to metallic gas gathering, transmission, and

distribution lines. As mentioned above, we are considering both the

need to change these standards in response to the concerns and whether

to apply the standards, with or without changes, to hazardous liquid

pipelines subject to 49 CFR Part 195.

Personnel Qualification (Sec. 192.453)

In view of the proposed rules on qualification of pipeline

personnel (63 FR 57269; Oct. 27, 1998), are more specific qualification

standards needed for individuals who direct or carry out corrosion

control procedures? (The proposed rules apply to personnel doing

regulated operation and maintenance tasks, including corrosion control,

on regulated pipeline facilities. However, the proposed rules do not

apply to management personnel who may oversee but not perform

corrosion-related tasks on a pipeline.)

External Corrosion: New Pipelines (Sec. 192.455)

Should a cathodic protection system be installed on

offshore pipelines in less than 1 year after the pipeline is

constructed, for example, 60 days, because of the strong corrosiveness

of salt water?

Is it in the interest of safety to exempt pipelines in

particular environments and temporary pipelines from the coating and

cathodic protection requirements?

External Corrosion: Existing Pipelines (Sec. 192.457)

Should existing compressor, regulator, and measuring

station piping continue to be excluded from the requirement to

cathodically protect effectively coated transmission line pipe?

Is the present requirement to cathodically protect certain

older existing pipelines only in areas of ``active corrosion'' adequate

for public safety? If not, what would be a cost effective alternative

standard?

Is the meaning of ``active corrosion'' clear and

technically sound? If not, how should it be changed?

External Corrosion: Coating (Sec. 192.461)

Should the implicit requirement to coat field joints and

repairs be expressly stated? Does coating need to be compatible with

the anticipated service conditions, including the effects of

temperature?

For offshore pipelines, during installation, are special

measures necessary to protect against damage to coating, including

field joint coating; and, to avoid mechanical damage, are special

coatings needed on J-tubes, I-tubes and pipelines installed by the

bottom tow method?

External Corrosion: Cathodic Protection Criteria (Sec. 192.463)

Are the cathodic protection system criteria in Appendix D

of Part 192, 300 mV shift and E-log-I, obsolete, since they are not in

NACE Standard RP0169-96? If so, should operators be allowed to continue

to use them on existing pipe, but not new pipe?

External Corrosion: Monitoring (Sec. 192.465)

Does the sampling basis prescribed for inspecting short

sections of main or transmission lines not in excess of 100 feet and

separately protected service lines provide effective corrosion control,

particularly as it applies to service lines that supply gas to public

buildings?

External Corrosion: Electrical Isolation (Sec. 192.467)

What remedial action is needed when an electrical short in

a casing results in inadequate cathodic protection of the pipeline

outside the casing?

Should newly constructed offshore pipelines be

electrically isolated from bare steel platforms unless both are

protected as a single unit?

Is electrical isolation needed where contact with

aboveground structures would adversely affect cathodic protection?

External Corrosion: Test Leads (Sec. 192.471)

Are accessible test leads needed on offshore risers that

are electrically isolated and not accessible for testing?

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For aluminum pipelines, should all test leads be insulated

aluminum conductors and installed to avoid harm to the pipe?

External Corrosion: Interference Currents (Sec. 192.473)

Where light rail systems exist, should operators

specifically be required to identify and test for stray currents and

keep records of the test results?

Internal Corrosion (Sec. 192.475)

Are special requirements needed to deal with the problem

of internal corrosion in storage field piping, as evidenced by piping

leaks in West Virginia and several Midwestern states?

Atmospheric Corrosion: General (Sec. 192.479)

Should new and existing pipelines be subject to the same

protection requirements?

Is protection needed where corrosion is a light surface

oxide or where corrosion will not likely affect the safe operation of

the pipeline before the next scheduled inspection?

Is special protection needed in the splash zone of

offshore pipelines and at soil to air interfaces of onshore pipelines?

Atmospheric Corrosion: Monitoring (Sec. 192.481)

Should the inspection interval for onshore pipelines be

extended beyond 3 years in view of the generally low incidence of

serious problems on protected pipelines?

For onshore pipelines, are more frequent inspections

needed at soil to air interfaces, under thermal insulation, at

disbonded coatings, and at pipe supports?

For offshore pipelines, are more frequent inspections

needed under poorly bonded coatings and at splash zones, support

clamps, and deck penetrations?

Records (Sec. 192.491)

Should operators keep records of findings of non-corrosive

conditions if Sec. 192.455 is changed to remove the benefit of such

findings?

Is the period for keeping corrosion control monitoring

records, ``as long as the pipeline remains in service,'' necessary for

safety or accident investigation? If not, what is an appropriate

period?

Concerns of Others

National Association of Pipeline Safety Representatives (NAPSR).

Long before the Oakbrook meeting, NAPSR reported on an extensive

review of Part 192 that included recommendations to change several of

the standards for corrosion control. We published the report and

requested public comment on its various recommended rule changes

(Docket PS-124, Notice 2; 58 FR 59431, Nov. 9, 1993). We adopted one of

NAPSR's corrosion standard recommendations (regarding Sec. 192.475) in

the final rule we published in Docket PS-124 (61 FR 28770; June 6,

1996). The others are discussed below:

With regard to Secs. 192.457 and 192.465, NAPSR

recommended changes to clarify the meaning of ``electrical survey'' and

where alternatives to electrical surveys may be used. But most

commenters either opposed or wanted to modify the recommendation,

feeling it would unreasonably limit an operator's ability to determine

areas of active corrosion by alternative methods.

With regard to Sec. 192.459, NAPSR recommended we require

operators to record the condition of protective coatings whenever they

inspect exposed portions of buried pipelines, arguing the records would

provide a useful history of the condition of the pipelines as well as

evidence that exposed pipe had been inspected as required. Opponents

argued the recommendation was unnecessary because Sec. 192.491 already

requires operators to keep records of required inspections.

With regard to Sec. 192.467(c), NAPSR recommended changes

to require that operators annually test pipeline casings for electrical

isolation, and to clarify what ``other measures'' must be taken to

minimize pipeline corrosion if isolation is not achieved. There was

strong opposition to this recommendation because studies have not

correlated shorted casings and corrosion on the carrier pipe, or

because a longer interval of inspection would be more appropriate.

With regard to Sec. 192.479(b), NAPSR recommended that

regardless of the date of installation, all aboveground pipelines or

portions of a pipeline that are exposed to the atmosphere be cleaned

and either coated or jacketed with a material suitable for the

prevention of atmospheric corrosion, unless the pipeline is in a non-

corrosive atmosphere. Commenters who objected to this recommendation

said the difficulty of proving a non-corrosive atmosphere could cause

operators to coat older pipelines that have no harmful atmospheric

corrosion.

With regard to the provision in Sec. 192.487(a) that

permits the repair rather than replacement of pipe with a small area of

general corrosion, NAPSR recommended that the provision refer to

generally accepted guidelines for determining what corroded areas may

be repaired. Although most commenters opposed the idea of requiring

operators to apply the guidelines in every case, there was no objection

to making the guidelines permissive as Sec. 192.485 does.

Finally, with regard to Sec. 192.489(b), NAPSR recommended

that we clarify that internal sealing is not an appropriate method of

strengthening graphitized pipe. There was no opposition to this

recommendation.

Gas Piping Technology Committee (GPTC)

In an April, 1995 rulemaking petition, GPTC requested the

following:

Remove from Sec. 192.467 the requirement that pipe be

electrically isolated from metallic casings. GPTC argued there are no

safety benefits from clearing shorted casings.

Amend Secs. 192.465 and 192.481 to allow operators to take

up to 39 months to carry out inspections of unprotected pipelines that

must be done at 3-year intervals. GPTC said the extra time would add

flexibility to the standards with no reduction in safety.

National Transportation Safety Board (NTSB)

As a result of a recent accident investigation, NTSB recommended

two changes to the Part 195 corrosion standards:

Revise Part 195 to require pipeline operators to determine

the condition of pipeline coating whenever pipe is exposed and, if

degradation is found, to evaluate the coating condition of the

pipeline. (P-98-35)

Revise Part 195 to include performance measures for the

adequate cathodic protection of liquid pipelines. (P-98-36)

We will be considering all these recommendations in the present

proceeding as we decide what changes, if any, to propose for the

corrosion control standards.

Alternatives

Changing the current standards to satisfy the concerns discussed

above may not be the only way to improve protection against corrosion.

Some industry representatives have expressed a desire to employ new

technologies or risk management concepts as more advanced solutions to

corrosion

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problems. So we are considering the following as alternatives to some

or all of the standards:

Corrosion Management Plans. Our experience shows that many

operators get superior results by applying their own pipeline-specific

plans for controlling corrosion. These plans often contain methods and

corrosion management techniques not required by the standards. To

encourage the development and use of these plans, we are considering

whether to allow operators to comply with corrosion management plans as

an alternative to the corrosion control standards. While we think such

plans would have to meet the objectives of the standards if not the

specifics, this regulatory approach would give operators more

flexibility to tailor their corrosion control practices to meet varying

conditions. Such plans would be subject to review by agency inspection

personnel and possible change if deemed inadequate (49 CFR 190.237).

NACE Standard RP0169-96. Another alternative to compliance

with the standards that some persons may favor is incorporation by

reference of all or part of NACE Standard RP0169-96. Although its

advisory style affects the suitability of this NACE standard for

regulatory use, it is, nonetheless, widely accepted as the most

authoritative source of up-to-date pipeline corrosion control

practices. In an analogous situation, we have recently proposed to

incorporate by reference other industry documents that are drafted in

an advisory style. In the proceeding on the safety of breakout of

tanks, we proposed to reference four documents published by the

American Petroleum Institute that are recommended practices: API

Recommended Practice 651 ``Cathodic Protection of Aboveground Petroleum

Storage Tanks,'' API Recommended Practice 652 ``Lining of Aboveground

Petroleum Storage Tanks Bottoms,'' API Recommended Practice 2003

``Protection Against Ignitions Arising out of Static, Lightning, and

Stray Currents,'' and API Recommended Practice 2350 ``Overfill

Protection for Storage Tanks In Petroleum Facilities'' (Docket RSPA-97-

2095; 63 FR 27903; May 21, 1998). Recognizing that API intended these

documents to be advisory and not imperative, we proposed that operators

follow the recommended practices unless they note in their procedural

manuals why compliance with all or certain provisions is not necessary

for the safety of a particular breakout tank or tanks. Any decisions

not to follow certain provisions would be subject to review by agency

inspection personnel and possible change if deemed inadequate (49 CFR

190.237). We could take a similar approach with respect to advisory

provisions of NACE Standard RP0169-96 that operators may decide are

unnecessary for the safety of particular pipelines.

Compliance Manual

We are also considering developing a Compliance Manual that would

contain guidelines for federal and state inspectors in evaluating

operator compliance with the corrosion standards. The manual would be

available to the public, so operators could learn what inspectors look

for in checking for compliance. We expect the manual to include

explanations and illustrations that apply the standards to hypothetical

pipelines, accounting for variations in operating conditions. For

example, we plan to include details on how to perform field pipe-to-

soil measurements, including connection of leads to the pipeline,

voltmeter, and half cell. We also want to show how to apply the

different cathodic protection criteria, and how to do a close-interval

survey. We think such a manual would advance an effective and uniform

understanding, interpretation, and application of the standards. It

could also provide a basis for training government and operator

personnel.

Public Participation

As stated in more detail above, interested persons are invited to

attend the San Antonio public meeting and present oral or written

statements about any of the principles, concerns, or alternatives

discussed in this notice. Written statements not presented at the

meeting may be submitted to the docket. If necessary, we may limit the

time for oral presentations so that everyone who requests an

opportunity to speak may do so. Those who do not request time for

presentations may have an opportunity to speak as time allows.

We are particularly interested in receiving comments on the

following:

1. Whether any existing standards deter or disallow the use of new

technologies, and, if so, how.

2. The costs and benefits of any suggested changes to standards and

alternatives to standards.

3. The amount of time operators may need to prepare for compliance

with any suggested standards or alternatives.

4. With regard to the Corrosion Management Plan and NACE Standard

alternatives--

a. The bases for evaluating the adequacy of corrosion management

plans.

b. The best way to facilitate agency review of operator decisions

under the alternatives (e.g., prior notification, reporting,

recordkeeping).

c. Whether NACE Standard RP0169-96 is adequate for pipeline

corrosion control and, if so, should we incorporate it by reference in

our corrosion control standards?

5. For hazardous liquid pipelines--

a. Whether additional standards are needed to further reduce the

possibility of damage to environmentally sensitive areas.

b. If Subpart I standards were applied to hazardous liquid

pipelines, the changes, if any, that would be needed to account for

differences between gas and liquid pipelines.

6. For gas distribution systems--

a. Root causes of corrosion leaks on coated, uncoated, protected,

and unprotected metallic lines.

b. Descriptions of operating/maintenance practices to minimize

corrosion leaks on cathodically unprotected lines.

c. Descriptions of risk-based corrosion management programs.

d. The best approach to monitoring corrosion control in urban wall-

to-wall paved areas.

7. The amount of buried piping at compressor, regulator, and

measuring stations that is not cathodically protected.

8. Explicit examples of adequate compliance with particular

standards that have had varied interpretations.

9. To provide an acceptable level of safety on existing pipelines,

must cathodic protection preserve the pipeline indefinitely or merely

slow the rate of corrosion until the pipeline has to be rehabilitated

or replaced?

Authority: 49 U.S.C. Chapter 601 and 49 CFR 1.53.

Richard B. Felder,

Associate Administrator for Pipeline Safety.

[FR Doc. 99-8628 Filed 4-6-99; 8:45 am]

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