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Appendix B: Federal Pipeline Safety Regulatory Framework
Pages 115-121

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From page 115...
... The regulations are intended to establish minimum safety standards applicable to all hazardous liquid pipeline facilities, thereby setting a safety floor that all operators must meet across the spectrum of pipeline systems. The regulations cover pipelines that transport crude as well as refined products.
From page 116...
... OPS reasoned that because pipeline operators have the most compre­ hensive and detailed knowledge of their systems, they are in the best position to devise their safety assurance programs, as long as they are given the motivation, tools, and regulatory flexibility to make effective choices.3 In 2000, OPS issued a landmark rulemaking titled Pipeline Integ­ rity Management in High Consequence Areas.4 Rather than prescrib­ ing specific operations and maintenance procedures, new rules laid out the key steps to be followed in developing and implementing a rationalized integrity management program based on principles of risk management. The regulations defined the core elements of the required program, such as the development of a written plan explain­ ing how risks are to be identified; the logic used in choosing the tools, methods, and schedules employed for detecting and assessing risks; 2  §195.406.
From page 117...
... Box B-1 outlines the basic set of rules governing the transportation of hazardous liquids by pipeline, as contained in the Code of Federal Regulations, Title 49, Part 195. Examples of prescriptive rules, in addition to the aforemen­ tioned standard for maximum operating pressure, are those concerning pipeline design and construction features, such as the requirement for shutoff valves located at each side of a water crossing.6 Nevertheless, in instances where alternatives to prescribed measures have safety merit, the operator can seek a waiver, or special permit, from OPS by demon­ strating that the alternative measures will yield the same or higher levels of safety than the prescribed ones.7 An example of a special permit application is the original plan of TransCanada Corporation to construct the Keystone XL pipeline.
From page 118...
... Subpart C -- Design §195.100 to §195.134 Includes pipe and component design require­ ments governing design temperature, internal design pressure, external pressure and loads, valves and fittings, closures and connections, and station pipe and breakout tanks. Subpart D -- Construction §195.200 to §195.266 Includes construction-related requirements gov­ erning material inspection, transportation of pipe, location of pipe, installation and coverage of pipe, welding procedures and welder qualifications, weld testing and inspection, valve location, pumping sta­ tions, and crossings of railroads and highways.
From page 119...
... The conditions covered include, among other things, quality control checks during the manufacture and coating of the pipe, tighter valve spacing, remote control valves, monitoring and control of operating temperatures, more frequent pig cleaning, and specific limits on the levels of water and sediment contained in the products transported. Although Trans­ Canada Corporation eventually withdrew the special permit applica­ tion, it agreed to comply with the 57 conditions as part of its separate
From page 120...
... Inspecting for compliance under these circumstances requires an approach more akin to a quality assurance audit to ensure that opera­ tors are following a well-defined set of actions. In addition, the advent of performance-based regulations has meant that OPS safety researchers now have responsibility for providing technical guidance to aid opera­ tors in developing rigorous risk management programs, including devel­ opment of the requisite analytic tools.
From page 121...
... Inspectors also review records documenting the evaluations that have been performed to identify and prioritize risk factors, devise integrity management strategies, and prior­ itize the preventive and mitigative measures. If OPS has reason to believe that a specific risk factor is escaping the scrutiny of a pipeline operator, it can review company records to determine whether and how the risk is being treated.


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