Trailblazer CO2 Pipeline Compliance with CFR 49 Part 195 Requirements

The Trailblazer CO2 Pipeline, LLC has filed a petition with the Iowa Public Utilities Commission for a hazardous liquid pipeline permit. The proposed pipeline will transport CO2 and is subject to compliance with the requirements set forth in CFR 49 Part 195. The compliance summary provided in the petition highlights the measures taken by Trailblazer to meet the requirements of the regulation.

Key Takeaways:

• Trailblazer will utilize a design factor of 0.72 throughout the pipeline system, which equates to required wall thicknesses for a maximum operating pressure (MOP) of 2,183 psi.
• The pipeline will be designed to mitigate the effects of fracture propagation, with Trailblazer engaging the services of ITI International to assist with fracture propagation and ductility analysis.
• Trailblazer will meet the requirements of CFR 195.112 by specifying pipelines to API 5L, PSL-2 standards, which mandate additional metallurgical requirements, inspections, and record retention.
• The pipeline will implement a multiphase flow computational pipeline monitoring system to meet the requirements of CFR 195.134 for leak detection.
• Trailblazer will exceed the requirements of CFR 195.248 by maintaining a minimum cover of 48 inches (4 feet) for industrial, commercial, and residential areas, and 60 inches (5 feet) for drainage ditches, public roads, and railroads.
• The pipeline will utilize a 24-inch clearance between the outside of the pipe and underground structures, including drain tiles, where feasible.
• Trailblazer will meet the applicable valve-location requirements of CFR 195.260, including spacing and location of valves.
• The pipeline will undergo pressure testing for 8 hours at 125% MOP, exceeding the requirements of CFR 195.304.

Statistics:

• Maximum operating pressure (MOP): 2,183 psi
• Required wall thickness: xxxx (to be calculated based on design factor and MOP)
• Number of pipelines to be manufactured to API 5L, PSL-2 standards: xxxx
• Length of pipeline to be installed with a minimum cover of 48 inches (4 feet): xxxx
• Number of pipeline crossings with a minimum cover of 60 inches (5 feet): xxxx
• Clearance between pipe and underground structures: 24 inches (minimum)
• Length of pipeline to be tested at 125% MOP: xxxx
• Test pressure: 125% MOP
• Test duration: 8 hours

Sources:

• CFR 49 Part 195 - Hazardous Liquids by Pipeline
• Trailblazer CO2 Pipeline, LLC, Petition for Hazardous Liquid Pipeline Permit, Docket No. HLP-2025-0001, Exhibit C, Attachment C-1, Filed with the Iowa Utilities Commission on May 12, 2025.