Question: If an operator develops a single Baseline Assessment Plan that covers both intra- and interstate pipelines, does the need to complete assessments on 50% of the pipeline mileage in HCAs apply to both intra- and interstate line segments, or just interstate line segment mileage? Should the companys Plan identify whether line segments are intra- or interstate?
Answer: Operators must comply with federal and, when applicable, state pipeline safety requirements. The 50% requirement in the federal integrity management program regulation applies to all pipeline systems that are covered under the rule - interstate and intrastate. Thus, an operator may develop a single Baseline Assessment Plan that covers both intrastate and interstate pipelines. An operator is to rank, assess and remediate its system as a whole, thus assuring that the highest risk-ranked HCAs will be addressed first, regardless of whether they are on interstate or intrastate segments of the system. Inspections for intrastate piping will be done by state agencies (if they are a certified to do so by OPS). To facilitate OPS and state pipeline safety program inspections, it is desirable that an operator s plan delineate which line segments are intrastate and which are interstate. This information will help to focus inspection activities by states and OPS to appropriate pipe segments.