Pipelines regulated under U.S. Code of Federal Regulations (CFR) Title 49, Parts 1921 and 195,2 must meet specific requirements when transporting potentially corrosive gas or liquids. In particular, operators must have adequate documentation to demonstrate that the pipeline is not in "corrosive" service, or that effective mitigative and preventive measures are in place to address corrosive conditions. Over the past 12 years, advisory bulletins issued by the Pipeline and Hazardous Materials Safety Administration (PHMSA) have repeatedly emphasized the need for pipeline operators to conduct periodic reassessments of their internal corrosion programs. Based on escalating regulatory emphasis on internal corrosion management, pipeline operators would be wise to anticipate increased oversight in this area.
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