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DOCKETS UNIT <br />PAGE EIGHTEEN <br />MARCH 24, 1987 <br />Questions: <br />(a) How would the class location criteria in part 192 <br />Improve the safety of hazardous liquid pipelines if <br />applied to the regulations in part 195. <br />Response: <br />The implementation of class locations containing CFR <br />192.5 is a good beginning to developing a more <br />sensitive set of siting criteria. These criteria <br />could improve safety by using less general and more <br />specific measures of determining the level of risk as it <br />relates to proximity of a land use to a pipeline. <br />(b) Should any of the part 192 standards based on class <br />location for which there is no comparable part 195 <br />requirement be added to part 195, and why? <br />Response: <br />g Most definitely yes, see response to 13 (a). <br />14. Proposal: <br />Require for hazardous liquid pipelines an increased safety <br />margin between test and operating pressure depending upon <br />population or environmental factors. (MN Rep. Rec 4.1) <br />Response: Studies of the phenomenon known as "pressure <br />reversals" clearly shows that a 20% safety margin does not. <br />provide an appropriate level of protection for the public <br />or the environment. <br />Questions: <br />(a) What would be the rationale for development and <br />selection of an increased safety margin for hazardous <br />liquid pipelines? <br />Response: <br />The rationale for determining safety margin standards <br />should be whatever is needed to reduce the risk of <br />pipeline accidents including, but not limited to, the <br />incidents of a failure among the various type of pipe <br />manufacturer which would include an analysis of the <br />pipe's age and operating pressure and a complete <br />analysis of the data and information available on <br />pressure reversals. <br />