Daily Rules, Proposed Rules, and Notices of the Federal Government
Although the base commodity may not be corrosive, all hazardous liquids regulated under Part 195 could be corrosive during some phase of the production and/or manufacturing process when contaminants could be introduced. Often, the only barrier separating untreated product or corrosive materials from a pipeline transporting processed/refined products is the processing plant or refinery. These plants occasionally undergo upset conditions where all or a portion of the untreated product may bypass the treatment process and enter the downstream piping. During those upset conditions, corrosive materials might be introduced into the pipeline and could create a corrosive condition.
Pipeline operators who previously concluded that an internal corrosion control program was not needed may need to critically re-analyze operating conditions and internal corrosion risk factors and periodically monitor, or otherwise reconfirm, that the pipeline is free of corrosive materials. Operators should perform a periodic system analysis and document the results, confirming that they properly analyzed the pipeline for possible internal corrosion precursors. In addition, operators should also conduct periodic monitoring for changes that might increase this risk and identify possible sites of selective internal corrosion risks.
The workshop is intended to allow representatives of the pipeline industry, regulatory agencies, the public, and other stakeholders to discuss the implications of these results and the potential need for further research and/or regulatory changes.
The workshop will include:
(1) Overview of current PHMSA regulations and data on internal corrosion.
(2) Overview of industry internal corrosion control documents.
(3) Review of current industry practices for evaluating, monitoring, and management of internal corrosion.
Refer to the meeting Web site for a more detailed agenda:
PHMSA publishes requirements for the mitigation of internal corrosion at 49 CFR Part 195 for hazardous liquids pipelines. PHMSA and other presenters plan to discuss the process of analyzing a pipeline system to determine whether internal corrosion is a threat and how to manage the threat if it exists. PHMSA will consider the discussion at the workshop and comments submitted to the docket in determining whether changes to regulatory requirements are needed and what those changes should be.