All natural gas pipeline operators are required to begin baseline integrity assessments of the sections of their pipeline systems located in high-consequence areas by no later than June 17, according to a Washington, DC-based law firm that specializes in energy law.

This action is required by the Pipeline Safety Improvement Act of 2002 and the new gas pipeline integrity management regulations, which were issued by the Department of Transportation’s Office of Pipeline Safety (OPS) earlier this year. The OPS integrity rule requires inspections of gas interstate and intrastate pipes in the riskiest high-consequence areas to be completed within five years and in less-risky areas in the next five years, as well as re-inspections every seven years. All baseline inspections are required to be completed by 2012. High-consequence areas are places where the most injuries and/or property damage could occur if a pipeline ruptured and exploded.

The law firm of Van Ness Feldman said the OPS expects gas pipeline operators to have taken several steps toward this goal prior to June 17 in order to be considered in compliance with the statute, including:

The OPS expects that by June 17 each gas pipeline operator will have begun preparing to conduct a baseline assessment on at least one high-risk pipe segment already identified by the operator, according to Van Ness Feldman. A baseline assessment means an operator must:

Van Ness Feldman identified the types of actions that would place an operator in compliance with the requirements of the OPS integrity assessment rule by June 17. These include:

However, the law firm stressed that these activities “are not the only ones that OPS will accept as meeting the intent of the statute.”

Other key deadlines for gas pipeline operators are Aug. 31 and Dec. 17. By Aug. 31, operators must submit their first overall performance reports to the OPS, Van Ness Feldman said. And by Dec. 17, operators must identify all high-consequences areas along their pipeline systems, and must develop their written gas pipeline integrity management programs, it noted. For more information, go to the law firm’s web site at

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