In This Issue

PHMSA Issues Hazardous Liquid IMP FAQ’s

PHMSA has published two new Frequently Asked Questions and updated a previously published FAQ regarding hazardous liquid integrity management.

FAQ # 6.32
Can the “ECDA” assessment option be applied to significant portions of above ground portions of pipelines that cannot be assessed with ILI tools or hydrostatic testing?

No. Per 195.588 (b) (1), the use of direct assessment on an onshore pipeline to evaluate the effects of external corrosion must follow the requirements of NACE Standard RP0502–2002. As stated in NACE RP0502-2002 Section 1.1.5 “ECDA as described in this standard is specifically intended to address buried onshore pipelines constructed from ferrous materials.” While the NACE standard (Section does, in certain cases, allow for the substitution of 100% direct examination at bellhole locations in lieu of a minimum of two indirect examination tools, PHMSA does not apply this exception to significant lengths of above ground piping. Operators may be able to technically justify a “direct” approach for assessing above ground lines, but such approaches are considered to be “other technology” that require a Notification to PHMSA per 195.452 (c) (1) (i) (D) and 195.452 (j) (5) (iv).

FAQ # 9.13
Can the evaluation of additional preventive and mitigative (P&M;) measures be excluded for portions of HCA-affecting lines determined to be sufficiently “low” in risk by an operator’s risk analysis process?

No. 195.452 (i) (1) requires that “An operator must take measures to prevent and mitigate the consequences of a pipeline failure that could affect a high consequence area. These measures include conducting a risk analysis of the pipeline segment to identify additional actions to enhance public safety or environmental protection.” Therefore, regardless of the perceived level of risk, additional P&M; measures must be identified and evaluated. This is particularly important when qualitative-oriented risk analysis approaches are utilized that classify risk levels on a relative basis. Risk that is judged to be “low” relative to other pipeline sections does not necessarily imply that risk cannot be reasonably lowered via additional or enhanced P&M; measures.

The rule, however, does not require that all identified measures be implemented. Once potential P&M; measures are identified, operators must exercise technical judgments in determining which to implement, and when. PHMSA recognizes that not all possible actions can be taken and that all actions taken may not be able to be completed immediately. PHMSA does not prescribe a specific set of criteria for P&M; measure implementation but expects that operators establish an adequate, documented basis for deciding which candidate measures are implemented and when based upon operational conditions.

FAQ # 5.10
What is the difference between the “periodic evaluation” required by 195.452 (j) (2) and the process for determining reassessment intervals required by 195.452 (j) (3)?

The “periodic evaluation” process is distinct from the reassessment interval process. Periodic “evaluations” involve a different process than “assessments.” Periodic evaluations are analytical reviews of a wide range of data and information regarding the pipeline integrity that includes but goes beyond simply “assessment” results. “Assessments” of pipelines on the other hand are tests, or actual measures of the pipeline’s condition and can be performed using a variety of tools or inspection techniques.

As specified in 195.452 (j) (2), the continual evaluation must, at a minimum, consider the results of the baseline and periodic integrity assessments, risk analysis, decisions about remediation, and preventive and mitigative actions. The rule does not specify if the continual evaluation process should be stand-alone or combined with other integrity management program processes; this is left to the discretion of each operator. The frequency at which periodic evaluations are performed must all be determined as required by the rule. The requirements for establishing reassessment intervals are separate from those for periodic evaluations and are listed in 195.452 (j) (3).