On December 1, 2000, DOT / OPS issued their final rule on Pipeline Integrity Management in High Consequence Areas for large liquid operators (docket 6355). Note that the final rule as published in the federal register is not identical to the "final" rule that was posted on the OPS website earlier in November! Interested persons are invited to submit comment on the provisions of the rule concerning actions an operator must take to address integrity issues on the pipeline (§195.452(h)) by March 31, 2001 . At the end of the comment period, OPS will publish a document modifying these remedial action provisions or a document stating that the provisions will remain unchanged.

RCP has created a document with diagrams that summarize the requirements of this regulation. Our summary and the actual regulation can be downloaded from RCP's website at http://www.your-rcp.com/downloads/Misc/Dec2000/PIM-HCASummary.PDF The actual regulation can be downloaded at http://www.your-rcp.com/downloads/Misc/Dec2000/65_FR_75378 _PIM_HCA_final_rule_120100.pdf. This final rule specifies regulations to assess, evaluate, repair and validate through comprehensive analysis the integrity of hazardous liquid pipeline segments that, in the event of a leak or failure, could affect populated areas, areas unusually sensitive to environmental damage and commercially navigable waterways. OPS is requiring that an operator develop and follow an integrity management program that provides for continually assessing the integrity of all pipeline segments that could affect these high consequence areas, through internal inspection, pressure testing, or other equally effective assessment means. The program must also provide for periodically evaluating the pipeline segments through comprehensive information analysis, remediating potential problems found through the assessment and evaluation, and ensuring additional protection to the segments and the high consequence areas through preventive and mitigative measures.

Through this required program, hazardous liquid operators will comprehensively evaluate the entire range of threats to each pipeline segment's integrity by analyzing all available information about the pipeline segment and consequences of a failure on a high consequence area. This includes analyzing information on the potential for damage due to excavation; data gathered through the required integrity assessment; results of other inspections, tests, surveillance and patrols required by the pipeline safety regulations, including corrosion control monitoring and cathodic protection surveys; and information about how a failure could affect the high consequence area.

The final rule requires an operator to take prompt action to address the integrity issues raised by the assessment and analysis. This means an operator must evaluate all defects and repair those could reduce a pipeline's integrity. An operator must develop a schedule that prioritizes the defects for evaluation and repair, including time frames for promptly reviewing and analyzing the integrity assessment results and completing the repairs. An operator must also provide additional protection for these pipeline segments through other remedial actions, and preventive and mitigative measures.

This final rule takes effect March 31, 2001. An operator must complete an identification of all pipeline segments that could affect a high consequence area no later than December 31, 2001. An operator must develop a written integrity management program no later than March 31, 2002.