Pipe in River

Advisory: Damage to Pipelines from Flooding

Have your assets checked after severe flooding! I cannot stress the potential impacts of flooding enough, including additional stresses, loss of support, accumulation of debris, and damage to safety valves, regulators, relief sets and other pipeline facilities that may be covered by water during flooding. Notably, in support of a requirement to respond to flooding impacts, PHMSA cites the general duty clauses of 49 C.F.R. Part 195.401(b) for liquid and Part 192.613(a) for gas, that require an operator who discovers a condition that could adversely affect the safe operation of a pipeline to correct that condition within a reasonable time.

PHMSA regulatory obligations that may require Operators to respond and address impacts from flooding conditions at river crossings:

(1) pipeline surveillance (Part 192.613(a));

(2) general obligations to correct conditions that may adversely impact safe operation of the pipeline, noting that flooding, river scour and channel migration are such conditions (Parts 192.613(b) and 195.401(b)(1)-(2));

(3) requirement for certain onshore oil pipelines to maintain a facility response plan, including resources for responding to a worst case discharged (Parts 194.107(a), 194.115); and

(4) requirement for certain pipelines located in “high consequence areas” to take measures to prevent and mitigate the consequences of a pipeline failure (Parts 192.935, 194.107(a), and 195.452(i)).