In This Issue

Hazardous Liquid Rulemaking FAQ’s Released

PHMSA released Frequently Asked Questions (FAQ) related to the final rule “Pipeline Safety: Safety of Hazardous Liquid Pipelines,” published on October 1, 2019.  Although FAQ’s are not enforceable, they do provide pipeline operators important guidance on how PHMSA interprets certain gray areas of code.  In this batch of final FAQ’s, PHMSA provides their response to the following questions.  For a copy of these FAQ’s or to inquire about RCP services, please contact Jessica Foley.

  • FAQ-1.0 What is the effective date for the new § 195.65 safety data sheets section?
  • FAQ-1.1 How can I provide a copy of the safety data sheets per § 195.65?
  • FAQ-2. Must I perform inspections and assessments required by these new regulations on “idled” pipelines?
  • FAQ-3. Can I proceed with using other technology without receiving a response from PHMSA when performing an assessment under § 195.416(d)?
  • FAQ-4. Is “discovery” of a condition for non-HCAs (§ 195.416(f)) the same as for “could affect” HCAs (§ 195.452(h)(2))?
  • FAQ-5. Must I use the same procedures for conducting assessments and making repairs on anomalies discovered by assessments performed under the new regulation § 195.416 as I use for § 195.452?
  • FAQ-6. For purposes of § 195.416(b), how often must assessments be performed for piggable, non-gathering, onshore line pipe not subject to IM requirements of § 195.452?
  • FAQ-7. Do I need to have a computational pipeline monitoring (CPM) leak detection system over all of my pipelines?
  • FAQ 7.1 Is patrolling alone a sufficient leak detection system per § 195.444?
  • FAQ-8. Do I necessarily have to redo my segment analysis under § 195.452(j)(2)?
  • FAQ-9. If the endpoints of covered segments are revised during the annual verification of covered segments required by § 195.452(j)(2), does that mean a baseline assessment is now required for pipe previously not identified as covered by IM?
  • FAQ-10. What is the effective date for the new § 195.454 Underwater Assessment section?
  • FAQ 10.1. If my onshore pipeline meets the requirement of § 195.454 do I need to assess the entire pipeline?
  • FAQ-11. Is the operator required to inspect its facilities under § 195.414 following a heavy rain?
  • FAQ-12. Is the operator required to perform inspections under § 195.414 following every extreme weather event or natural disaster?