Learn about The PHMSA Hazardous Liquid Pipelines Mega Rule Part (1) revisions and new requirements. Discover what the new rule means for pipeline operators.

1. PIPELINE INTEGRITY
PHMSA Final Rule for Hazardous Liquid
Transmission Pipelines – Part 1
May 4, 2020
WEBINAR SERIES:

2. Table of Contents
Slide 3
Slide 4
Slide 5
Slide 6-7
Slide 8-9
Slide 10-11
Slide 12-13
Slide 14-15
Slide 16-17
Slide 18-19
Slide 20-21
Slide 22-23
Slide 24-25
Speaker Bio
Agenda
The Rule Effective Date
Unregulated Gravity Line Reporting Requirements
Unregulated Gathering Line Reporting Requirements
Weather Related Event (WRE) 72 Hour Inspection
Non-IMP Segment Assessments
Leak Detection
ILI Tool Accommodation
Pipes Act Provisions
Pipeline HCA Segment Annual Identification
IM Program Data Integration
Future Rulemakings

3. TODAY’S SPEAKER
Bryan Louque has over 25 years of
experience in the pipeline industry. He
has been involved with the design,
construction, and O&M of pipeline
systems with an emphasis on corrosion
control, pipeline integrity and
regulatory compliance programs on
hazardous liquids (Part 195) and
natural gas (Part 192) pipeline systems.
Bryan Louque, P.E.
Vice President of Asset Integrity and Corrosion
Audubon Companies

4. Agenda
 When is the Hazardous Liquids Rule Effective?
 What’s in the Hazardous Liquids Rule?
 What’s not in the Hazardous Liquids Rule?
 What’s Next?
WHY AM I HERE?
July 2010 October 2019

5. WHEN IS THE RULE EFFECTIVE?
Effective Date – July 1, 2020
TICK
TOCK

6. WHAT’S IN THE RULE?
1.0 Unregulated Gravity Line Reporting Requirements
What’s New?
 Submit annual (195.49), accident (195.50), and safety-related
condition reports (195.55) to PHMSA
• Accident and SRCR Report Effective Date – January 1, 2021
• Annual Report Effective Date – March 31, 2021
 Telephonic (195.52), NPMS filings and SDS furnishing not
required
Key Exceptions
 Low-stress gravity lines < 1 mile from facility and
do not cross commercially navigable waters

7. WHAT’S IN THE RULE?
What is the Impact?
 The impact is LOW
 Primarily applies to flow lines upstream of LACT units
1.0 Unregulated Gravity Line Reporting Requirements

8. WHAT’S IN THE RULE?
2.0 Unregulated Gathering Line Reporting Requirements
What’s New?
 Submit annual (195.49), accident (195.50), and safety-related
condition reports (195.55) to PHMSA
• Accident and SRCR Report Effective Date – January 1, 2021
• Annual Report Effective Date – March 31, 2021
 Telephonic (195.52), NPMS filings and SDS furnishing not
required
Key Exceptions
 None

9. WHAT’S IN THE RULE?
2.0 Unregulated Gathering Line Reporting Requirements
What is the Impact?
 The Impact is HIGH
 Update procedures to address new reporting requirements
 Train personnel
 Maintain accurate maps and records for all unregulated
pipelines

10. WHAT’S IN THE RULE?
3.0 Weather Related Event (WRE) 72 Hour Inspection
What’s New?
 Pipelines subject to damage by scouring or movement of
surrounding soil
• Tropical storms, hurricanes, floods, landslides, or
earthquakes
 Inspection method determined by Operator
 Appropriate remedial action must be taken based on
inspection results
• Pressure reduction, repair / replacement, shut down
(195.452)
Key Exceptions
 Notify PHMSA if inspection is impeded / delayed
due to lack of personnel or equipment

11. WHAT’S IN THE RULE?
3.0 Weather Related Event (WRE) 72 Hour Inspection
What is the Impact?
 The Impact is HIGH
 Update procedures to address new inspection
requirements
 Train personnel
 Identify all pipeline segments susceptible to
WRE damage (195.452)
 Take pre-emptive measures where necessary

12. WHAT’S IN THE RULE?
4.0 Non-IMP Segment Assessments
What’s New?
 Segments not subject to IMP must be assessed every 10 years
• Initial assessments due by October 1, 2029
 Assessment methods (195.452)
• ILI, Hydrotest, ECDA
 Dig and repair anomalies per existing 195 criteria
Key Exceptions
 None

13. WHAT’S IN THE RULE?
4.0 Non-IMP Segment Assessments
What is the Impact?
 The Impact is HIGH
 All pipeline (inside and outside of HCAs)
must be assessed

14. 5.0 Leak Detection
What’s New?
 Regulated lines must have leak detection system inside
& outside of HCAs
• Lines built before October 1, 2019 – Effective
October 1, 2024
• Lines built after October 1, 2019 – Effective October
1, 2020
 Operators must evaluate leak detection system ability to
protect the public, property, and the environment
(195.452)
Key Exceptions
 Offshore gathering and onshore regulated
gathering lines
WHAT’S IN THE RULE?

15. 5.0 Leak Detection
What is the Impact?
 The Impact is MEDIUM
 Applies to regulated non-gathering lines, most of which
should already have formal leak detection program
(API RP 1175)
WHAT’S IN THE RULE?

16. 6.0 ILI Tool Accommodation
What’s New?
 Pipelines located in or could affect HCAs must accommodate
ILI tools
• 20 year implementation window
• Potential waiver for pipelines that would be abandoned
due to the cost of compliance
Key Exceptions
 Manifolds, station piping, tank farm, storage piping,
cross-overs, or select offshore piping
WHAT’S IN THE RULE?

17. 6.0 ILI Tool Accommodation
What is the Impact?
 The Impact is MEDIUM
 Design & construction standards require all new
pipelines be piggable (195.120)
 Develop and implement legacy pipeline make-piggable
programs for those located in or could affect HCAs
WHAT’S IN THE RULE?

18. 7.0 PIPES Act Provisions
What’s New?
 Provide Federal On-Scene Coordinators and emergency
responders with product safety data sheets (SDS) for spilled
hazardous liquids
• Within six hours of notice to the NRC
 Conduct annual integrity assessments of underwater pipeline
facilities located in HCAs and depth is greater than 150 feet
Key Exceptions
 Offshore pipeline facilities
WHAT’S IN THE RULE?

19. 7.0 PIPES Act Provisions
What is the Impact?
 The impact is LOW
 Update Oil Spill Response Plan (194.101)
to include SDSs for all pipeline products transported
WHAT’S IN THE RULE?

20. 8.0 Pipeline HCA Segment Annual Identification
What’s New?
 Verify all HCA direct or could affect line segments annually
• Identify the factors in the original HCA analysis
• Determine whether any of those factors have changed
• Assess whether change will affect the results of the initial
HCA segment identification
 Effective date – July 1, 2021
Key Exceptions
 Unregulated pipelines
WHAT’S IN THE RULE?

21. 8.0 Pipeline HCA Segment Annual Identification
What is the Impact?
 The Impact is HIGH
 Essentially requires direct or could affect HCA analysis
for all regulated pipelines be performed annually
 Similar to what is required for gas lines
WHAT’S IN THE RULE?

22. 9.0 IM Program Data Integration
What’s New?
 Integration of IM program information and consideration of
spatial relationships among anomalous information
• For example, evidence of potential corrosion in an area
with foreign pipeline crossings, interference from power
lines, or evidence of land movement
 Effective date – October 1, 2020
 Compliance date – October 1, 2022
Key Exceptions
 None
WHAT’S IN THE RULE?

23. 9.0 IM Program Data Integration
What is the Impact?
 The Impact is HIGH
 Essentially requires use of geospatial data integration and
storage platform (ArcGIS) to operate IM program
WHAT’S IN THE RULE?

24. Pipeline Repair Requirements:
Operators will NOT be required to comply with the new criteria and
remediation schedules for performing pipeline repairs. PHMSA will be
considering that issue in a separate rulemaking proceeding.
Future Rulemakings: The rule does NOT include two changes to
Part 195 that PHMSA proposed at earlier points in the proceedings
WHAT’S NOT IN THE RULE?

25. Future Rulemakings: The rule does NOT include two changes to
Part 195 that PHMSA proposed at earlier points in the proceedings
Engineering Critical Assessments:
Operators will NOT be required to perform engineering critical
assessments (analytical procedures to determine maximum tolerable
flaw sizes in steel pipe to maintain safe operations) in relation to the
remediation of certain defects. PHMSA will be considering that issue in a
separate rulemaking proceeding.
WHAT’S NOT IN THE RULE?

26. Bryan Louque, P.E.
Vice President, Asset Integrity & Corrosion
D: 918.514.5879 C: 913.221.3446
blouque@auduboncompanies.com
auduboncompanies.com
Any Questions?