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DOCKETS UNIT <br />PAGE NINE <br />MARCH 24, 1987 <br />6. Proposal: <br />Require integrity testing at least every two years, with <br />frequency and type of test determined case -by -case in <br />light of certain pipeline and environmental factors <br />(H.R. 262) <br />Require tests every three years to determine release <br />potential. (92780) <br />Require increased use of "smart pigs" to detect flaws, <br />based on population density and certain pipeline and <br />environmental factors. (Subcommittee, Fossil and <br />Synthetic Fuels; Mr. Sikorski) <br />Response: <br />Once a pipeline is constructed and/or pressure tested <br />pursuant to Federal regulations, the line is allowed to <br />continue to operate for an indefinite period of time without <br />retesting to demonstrate the continuing structural integrity <br />of the pipeline. Since nothing lasts forever no matter how <br />carefully it is taken care of, to allow a pipeline to operate <br />without testing its structural integrity on a regular basis <br />ignores that fact and places the public and environment at <br />risk. <br />Questions: <br />(a) Should the 1.25 safety margin mandated for existing <br />HVL pipeline be required for existing pipelines <br />carrying other petroleum products or natural gas? <br />Response: <br />A safety margin should be required for all pipelines, <br />new or existing; product, HVL or gas. it —is the opinion <br />of the City that the mandated 1.25 margin is wholly <br />inadequate and that a safety margin of at least 3 to 1 <br />should be required. <br />d for <br />(b) product_, HVL, oruld periodic lgas gpipelines rity lin populatedng be areas? <br />all <br />areas? <br />Response: <br />Periodic integrity testing is the only means currently <br />available to determine whether or not a pipeline is <br />prone to failure. Corrosion testing is neither 100 <br />percent accurate nor does it measure the structural <br />integrity of a pipeline. Also, as evidenced by the <br />Mounds View incident, the results of corrosion testing <br />