The U.S. Department of Transportation Office of Pipeline Safety (OPS) administers the pipeline safety regulations in the Code of Federal Regulations, specifically 49 CFR Part 192 for the natural gas industry and Part 195 for the petroleum industry. In response to the severity of leaks and collateral damages incurred on an aging infrastructure in recent years, the U.S. Department of Justice and OPS have enacted stricter regulatory enforcement and new integrity management programs for each industry. Industry response and compliance definition have been diverse: Part 195 defines a high-consequence area (HCA) to include commercially navigable waterways, high population areas, other populated areas and unusually environmentally sensitive areas; this places most of the northeastern United States in the HCA classification for petroleum pipelines. The natural gas industry, as regulated by Part 192, defines an HCA based on the area classification and the potential-impact radius of a worst-case incident. These differences have resulted in two distinct approaches to obtaining and maintaining compliance. In addition, total repair costs and permitting requirements vary widely across the United States, and the time necessary to acquire permits in the Northeast can easily exceed the 60-day or 180-day time limits under Part 195, with some agencies having no emergency permit process. To offset these critical issues, the integrity management program should incorporate the permitting lead times into the repair plans, and repair site access plans for equipment and materials should allow for requirements imposed by the permitting agencies as a condition of issuing the permit. This paper identifies environmental permitting requirements relative to pipeline facilities and describes key steps that can be taken to avoid compliance conflicts among regulatory agencies. Also, environmental permitting issues and requirements to minimize the impacts on pipeline repair plans that cause compliance conflicts with the pipeline safety regulations are discussed.
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