Reader Response

Inactive Pipe Clarification
I was reading the last issue of the Damage Prevention Professional and noticed a slight inconsistency with the current PHMSA interpretation of “inactive” pipe located on page 8. Please see adjacent for a brief clarification and link to the PHMSA Advisory. In short, I think this is an important topic for your NG and HL pipeline readers and one that probably doesn’t gain enough attention, but has major ramifications from a compliance standpoint. The majority of operators may not be following this advisory and risk substantial exposure.

Also, applicable at the moment, the new HL rule was issued recently. One of the interesting things in the rule is that HL operators will have to treat all dents as immediate repairs, which is a substantial departure from previous regulation. As I’m sure you are aware, the majority of dents are located on the top of the pipe and are caused by excavation damage. PHMSA cites 2012 studies that outline how a 3% dent may cause failure, but a 6% with a secondary feature has been known to survive. Essentially, due to the size, shape and depth of geometric imperfections, operators must treat all dents as
“immediate” due to the inability to accurately predict failures.

A Regulated Gas/HL Pipeline Clarification:
The 2017 winter issue of Damage Prevention Professional references the damage prevention definition for “abandoned” versus “inactive” line pipe, which is inconsistent with the current guidance issued by PHMSA. PHMSA issued an Advisory Bulletin (ADB-2016-05) on 8/16/16 describing the recognition of only two statuses of pipelines: “In service/Active” or “Abandoned.” Abandoned pipeline is defined as “permanently removed from service,” which includes following the processes and requirements for
abandoning pipeline §192.727 for gas and §195.402(c)(10) for hazardous liquid pipelines.

PHMSA further explains that regulated gas and HL pipeline that is typically referred to as “idled,” “inactive,” or “decommissioned” and otherwise not operating, but has not gone through the formal “abandoned” process, is still considered an active pipeline. As such, operators would be required to continue all relevant safety requirements, including integrity management, damage prevention and public awareness programs.
Josie Long, Process Performance Improvement Consultants, LLC

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