Frequently-Asked Question FAQ #150

FAQ-150: Requirements for Operators with No HCAs

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Question: What requirements must an operator meet if there are no high consequence areas on any of its transmission pipelines.

Answer: An operator need not develop an integrity management program if there are no high consequence areas on its system. The operator must have completed an evaluation to determine that no high consequence areas exist, and this evaluation must be maintained available for inspection. Even if no HCAs exist, however, there are some requirements in Subpart O with which an operator must comply:

- An operator must have a process to periodically evaluate its pipeline to determine if new HCAs have been created. Changes along the pipeline route, including housing construction and creation of new facilities meeting criteria in the definition of identified sites could cause HCAs to come into existence. An operator must be able to demonstrate that it has periodically evaluated its pipeline to assure that there continue to be no HCAs.
- For transmission pipelines operating below 30 percent of SMYS in class 3 or 4 locations but not in an HCA, enhanced protection against third-party damage must be implemented in accordance with 192.935(d).

- An operator must submit semi-annual "performance measure" reports in accordance with 192.945(a) indicating that there are no HCAs on its system.

If the periodic evaluation identifies that a new HCA exists, then the operator must prepare an integrity management plan and meet all the requirements of subpart O.