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Unregulated Low-Stress Hazardous Liquid Pipelines

Unregulated Low-Stress Hazardous Liquid Pipelines. Mike Israni & John Gale Aug 5, 2009. Regulatory Requirements for Low-Stress Hazardous Liquid Pipelines.

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Unregulated Low-Stress Hazardous Liquid Pipelines

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  1. Unregulated Low-Stress Hazardous Liquid Pipelines Mike Israni & John Gale Aug 5, 2009

  2. Regulatory Requirements for Low-Stress Hazardous Liquid Pipelines • Section 4 of the Pipeline Inspection, Protection, Enforcement, and Safety Act of 2006 (PIPES Act) requires the Secretary to issue regulations subjecting low-stress hazardous liquid pipelines to the same standards and regulations as other hazardous liquid pipelines.

  3. Regulatory Requirements for Low-Stress Hazardous Liquid Pipelines (continued) • Exceptions to the PIPES Act requirements are: • (1) low-stress pipelines regulated by the US Coast Guard; • (2) A pipeline that serves refining, manufacturing, or truck, rail or vessel terminal facilities if the pipeline is less than one mile long (measured outside the facility grounds) and does not cross an offshore area or a waterway currently used for commercial navigation.

  4. The June 3, 2008, Low-Stress Pipelines Final Rule- (Phase one) Covered • Rural low-stress pipelines with a nominal diameter greater than 8⅝ inches and within ½ mile of unusually sensitive areas (USAs) • Applies full set of regulations to these pipelines • Adds annual, safety-related condition, and accident reporting for ALL rural low stress pipelines

  5. Production 10” and Operating less than 20% SMYS Storage 8⅝” coming from production – Gathering line Navigable Waterway USA Non-Rural Area Trucked In Oil Tankage Storage 6” and Operating less than 20% SMYS Refining Subject to Part 195 Requirements Low-Stress Pipelines Upstream from Refining

  6. Production 10” and Operating less than 20% SMYS Storage 8⅝” coming from production – Gathering line Navigable Waterway USA Non-Rural Area Trunked In Oil Tankage Storage 6” and Operating less than 20% SMYS Refining Subject to Part 195 Requirements After Phase 2 Low-Stress Pipelines Upstream from Refining

  7. Refining Refining Navigable Waterway Less than 1 mile USA Non-Rural Area Breakout Tankage 8 ⅝ ” operating at less than 20% 6”operating at less than 20% SMYS Airport Subject to Part 195 Requirements Low-Stress Pipelines Downstream from Refining

  8. Refining Refining Navigable Waterway Less than 1 mile USA Non-Rural Area Breakout Tankage 8 ⅝ ” operating at less than 20% 6”operating at less than 20% SMYS Airport Subject to Part 195 Requirements After Phase 2 Low-Stress Pipelines Downstream from Refining

  9. Cost-Benefit of Implementing Regulation for Unregulated Low-Stress Haz Liq. Pipelines • Risk = Probability x Consequence (Unknown- No data on unregulated LS) • Infrastructure size Total LS Miles = LS (pop+navig) + LS usa + LS rural • Reasonable cost for this Infrastructure

  10. Estimated Benefit for Low-Stress Pipelines • Currently no incident data to review • March 2009 we surveyed nine States to ascertain if they had incident data • Currently evaluating the benefits associated with Low Stress II rulemaking

  11. Supporting Data for Unregulated Low-Stress Hazardous Liquid Pipelines • Rural Low-Stress Hazardous Liquid Pipelines Survey – October 2008 • Low-Stress Pipeline Survey – Company Follow-up – March 30, 2009 • Regulatory Evaluation for Low Stress I Final Rule- June 3, 2008

  12. Supporting Data for Unregulated Low-Stress Hazardous Liquid Pipelines (continued) • Total estimated Unregulated Low-Stress Hazardous Liquid Pipelines = 1575 miles • Phase I picked up = 312 miles • Phase II will pick = 1263 miles • Of the total 1263 miles, 161 miles are estimated to be within USAs and with nominal diameter less than 8⅝ inches

  13. Estimated Costs for Low-Stress Pipelines

  14. Estimated Costs for Low-Stress Pipelines • Subpart F – Operation and Maintenance • Maps and Records – nominal cost increase • Damage Prevention Programs • Costs under development, based on State mandated One call systems • Line markers – • Initial cost: $514 per mile • Recurring cost: $134 per mile • 90% of these lines are already marked

  15. Estimated Costs for Low-Stress Pipelines • Integrity Management Programs • Impacts only those lines that are in a HCA • 161 miles of small diameter pipe within a 1/2 mile of a USA • Cost per mile is under development • Subpart H Corrosion Control • Initial cost: $15,022 per mile • Recurring cost: $400 per mile • 90% of the lines already comply with Subpart H.

  16. Low-Stress Pipelines- (Phase Two) Will Cover • Depending on supporting data either one, some, all, or none of the following will be regulated: • All Part 195 to all low-stress pipelines not currently regulated • All Part 195 to all low-stress pipelines less than 8⅝ inches diameter inside ½ mile of USAs • All Part 195 to all low-stress pipelines 8⅝ inches diameter or more outside ½ mile of USAs • All Part 195 to all low-stress pipelines less than 8⅝ inches diameter outside ½ mile of USAs • Other option

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