Frequently-Asked Question FAQ #246

FAQ-246: Identifying HCA for plastic pipe

Question: Section 192.901 lists the sections of Subpart O that apply to plastic transmission pipelines. Section 192.905, "How does an operator identify a high consequence area?" is not included. Do I need to define HCAs for my plastic transmission pipeline.

Answer: Yes.

Section 192.917(d) requires that "An operator of a plastic transmission pipeline must assess the threats to each covered segment using the information in sections 4 and 5 of ASME B31.8S, and consider any threats unique to the integrity of plastic pipe." (emphasis added). Other sections applicable to plastic pipelines also refer to "covered segments." The operator of a plastic transmission pipeline must identify its "covered segments" to comply with these requirements.

Section 192.903 defines a covered segment as a segment of a transmission line located in a high consequence area (HCA). Section 192.903 further defines an HCA as an area established by one of the two methods described in the definition. The definitions in section 192.903 "apply to this subpart," meaning they apply to all sections of the subpart, including those identified in section 192.901 as applicable to plastic transmission pipeline. Thus, in defining its "covered segments" to comply with the sections applicable to plastic transmission pipeline, an operator of a plastic transmission pipeline must identify those portions of its pipeline that are located in HCA.