NGPL, a company previously selected to participate in the Risk Management Demonstration Program, has identified five pipeline segments in its system (all changing from Class 2 to Class 3) where it proposes to conduct risk control alternatives to the class location change requirements in 49 CFR §192.611. OPS seeks public comment on the proposed demonstration project modification so that it may consider and address these comments before modifying the order to approve the proposed risk control alternatives (the "Alternatives"). OPS requests that comments to this Notice or about this environmental assessment be submitted on or before September 17, 2001 so they can be considered before the modifications are approved. However, comments on this or any other demonstration project will be accepted in the Docket throughout the demonstration period (docket number RSPA-98-4034).
NGPL identified outside force damage and corrosion as the principal risks to the pipeline in the class location segments and the surrounding sections and defined the following risk control alternatives to achieve superior safety and environmental protection along these five segments:
- Internally inspecting class location change segments (and an extended length of pipe bordering each class change segment) using geometry and magnetic flux leakage in-line inspection tools, and repairing indications of corrosion or existing construction and outside force damage identified by the internal inspection.
- Performing close-interval surveys on the five class location segments and an extended length of pipe bordering each class location segment.
- Pressure testing the five class location change segments, an extended length of pipe that encompasses each class location segment, and additional segments on the same pipelines.
- Enhancing damage prevention activities in the class location change segments and an additional length of pipe bordering each class location segment.
- Increasing contacts with local emergency planners and emergency responders to ensure preparation for more effective and coordinated response to emergencies.
- Conducting public education on the subject of pipeline safety; part of this education program will be specifically developed for students in schools in the immediate vicinity of the Gulf Coast line class location segments.
- Continuing the NGPL current investigation, analysis, and mitigation program for Stress Corrosion Cracking (SCC). This company program, initiated in response to recent experience on the NGPL system, involves integration of data regarding soil, coating, and pipe characteristics to identify areas of probable susceptibility to SCC. These areas are then investigated further to determine if SCC is present; any detected SCC is mitigated.
As part of the company's risk evaluation, NGPL has compared the risk reduction produced by these alternatives to that achieved by the current regulations. OPS has reviewed this evaluation in detail and concluded that the alternative risk control activities can be expected to reduce safety and environmental risk below that which would be achieved by compliance with 49 CFR 192.611. Furthermore, because of the resources saved by not having to replace pipe in these five locations, NGPL is able to conduct internal inspections and pressure tests on additional portions of its system.
