Do you own or operate 500 miles of hazardous liquid pipeline? The answer may surprise you! The new OPS Implementing Integrity Management website (see article) contains the following Q&As; from the August Integrity Management workshop, concerning how the “500 mile” criteria should be applied when determining if the “Large Liquid” PIM rule applies to a pipeline operator:

Q – What is meant by “operator who owns or operates a total of 500 or more miles of pipeline” in 195.452 (a)? For example, if a large operator who operates more than 500 miles of pipeline also owns a small percentage of a small pipeline (less than 500 miles) that is operated by a different organization – does that smaller operator have to comply with the large operator rule – even if its O&M; manual, management processes, etc. are totally separate from the large operator?

A – The current rule applies to operators who own or operate a total of 500 or more miles of pipeline. This means that if an operator also is part owner of another pipeline operating company, the mileage of that other company is included in determining whether or not the 500 mile criteria is met. If the total pipeline mileage is equal to or greater than 500 miles, then the requirements of the current rule apply to both companies’ pipeline systems – even if they have totally distinct O&M; manuals, etc.

Q – If the operator of a small pipeline system (i.e. less than 500 miles) is partially owned by a large operator (i.e., one who operates more than 500 miles of pipeline), who is responsible for preparing the Baseline Assessment Plan and complying with the provisions of this rule – the operator, or the company that is part owner?

A – The operator is required to comply with OPS regulations, and thus is responsible for preparing a Baseline Assessment Plan that meets all of the requirements in 195.452 (c). Operators may use outside resources, including adopting management plans prepared by parent companies, but that does not relieve the operator of responsibility for having an acceptable plan.

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