Frequently-Asked Question FAQ #7

FAQ-7: Idle Line Applicability

Question: Do the requirements of the rule apply to "idle" pipe?

Answer: The regulations do not define "idle" pipe. Pipe is considered either active or abandoned. OPS understands "idle" pipe, as used in the context of this question, as pipe not currently being used to move gas but that could be put back in service at a future date. All pipe is subject to the requirements of the integrity management rule. However, idle pipe presents different risks and different treatment is appropriate.

In-service pipe (i.e., that contains gas, but is not presently being used to transport gas) represents a potential hazard to public health and the environment, even though idle. If such pipe leaks or ruptures, an explosion could result. Leaks may go undetected for some time, since idle pipe may not be covered by operator's SCADA systems. For these reasons, operators must meet all requirements and deadlines for pipe that contains gas. Such pipe must be included when determining if the requirement to assess 50% of covered pipeline mileage by December 17, 2007, has been met.

Out-of-service pipe (i.e., pipe laid up with nitrogen) represents much less hazard. Degradation of such pipe can occur, but is not likely to result in safety impacts. OPS will accept deferral of activities required by the rule for out-of-service pipe. All deferred activities must be completed as part of any later return of that line to service. A baseline assessment need not be run immediately if the deadline for completing baseline assessments (i.e., December 17, 2012) has not yet expired, unless the risk posed by the line would require an earlier assessment. The baseline assessment plan should be modified to assure that a baseline assessment is completed by the appropriate deadline. If the deadline has expired, then a baseline assessment must be completed as part of returning the line to service.

Adding an idle line into the IM program would be considered a substantive program change and would require notification under 192.909(b).