On June 27, 2001, RSPA published a request for comments concerning gas pipeline integrity management program requirements. RSPA has previously published the final pipeline integrity management rule for large liquid pipeline operators, and has already proposed the rule for small liquid pipeline operators. However, discussions concerning the appropriate pipeline integrity management requirements for gas transmission pipelines are still in progress. The June 27 document gives a very good description of the unique challenges and special considerations that must be incorporated into a final rule for gas transmission pipeline integrity management programs, such as:

• gas is not easily stored, and some communities are served by only one gas transmission pipeline. Thus, downtime due to integrity management tests could have serious supply (and possibly price) repercussions.
• many gas pipelines are not currently capable of accommodating smart pigs, so other forms of assessment may be more appropriate.
• failures of gas pipelines can result in serious fires, with resulting personnel and property damage, but do not tend to have severe environmental consequences. Thus, the definitions of High Consequence Areas should be different than for liquid pipelines.

To facilitate the discussion process, an electronic public discussion forum on gas pipeline integrity management issues has been developed on the office of Pipeline Safety’s internet home page at http://ops.dot.gov/forum. Interested persons are invited to submit written comments by August 13, 2001, Docket No. RSPA-00-7666. The full notice is available on RSPA’s website at http://assn.cycla.com/opsforum/docs/GasIMP_FR_Notice_mi_06_14_01.pdf.