The Minerals Management Service (MMS) has issued a Notice to Lessees and Operators and Pipeline Right-of-way Holders (NTL) No. 2009-G28 concerning alternate compliance and departure requests in pipeline applications.

The purpose of the NTL is to provide guidance in submitting certain alternate procedures and equipment (alternate compliance) and departure requests from the regulations contained in 30 CFR 250 Subpart J. The following requests are routinely made to the MMS Gulf of Mexico OCS Region (GOMR) in pipeline applications, particularly those involving subsea tie-backs:

  • Alternate compliance from the requirements of 30 CFR 250.1002(a) to use the provisions of API RP 1111 to calculate internal design pressure;
  • Departure from the requirements of 30 CFR 250.1002(d) to allow the maximum allowable operating pressure (MAOP) of the pipeline to be less than the maximum source pressure (MSP) for Barrier Concept applications;
  • Alternate compliance from the requirements of 30 CFR 250.1003(b)(1) to pre-test pipelines; and
  • Alternate compliance or departure from the requirements of 30 CFR 250.1004(b)(9) to use subsea pipeline pumps.

The NTL is effective October 13, 2009. For a copy of NTL 2009-G28, contact Jessica Roger.

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