In This Issue

Pipeline Safety: Safety of Hazardous Liquid Pipelines

[Docket No. PHMSA–2010–0229; Amdt. No. 195–102] RIN 2137–AE66

The new hazardous liquids rule was published in the Federal Register on October 1, 2019.  It was originally published in the Federal Register in February 2017 but was quickly pulled back following issuance of two Executive Orders on regulatory reform.  This rulemaking addresses several congressional mandates, and NTSB and GAO recommendations.  The effective date of the rule is July 1, 2020, with several requirements that extend out as much as 20 years to complete.  This is also a significant rulemaking with a lot to digest, but we have tried to provide a brief summary of the highlights below.  For more information about how RCP can assist pipeline operators with integrating these new rules into your existing operations and integrity programs, contact Jessica Foley.

  • Additional reporting for gravity and exempt rural gathering pipelines
    • PHMSA expanded the annual reporting and accident requirements to cover both gravity lines and rural gathering lines that are not considered regulated gathering pipelines.
  • Leak Detection
    • Leak detection will be required on all new pipelines, and by October 1, 2024 for pipelines constructed prior to October 1, 2019. Regulated rural gathering and offshore gathering pipelines have been exempted from this leak detection requirement.
  • Post abnormal weather event assessments
    • A pipeline facility that could be damaged or adversely affected by an abnormal weather event (e.g., flooding, tropical storms, landslide, earthquake) must be assessed within 72 hours after cessation of the event.  The assessment will check for abnormal damages due to the natural force events. If pipeline integrity was impacted, additional integrity reviews and efforts may be warranted to ensure pipeline integrity is stable.
  • Pipeline integrity assessment for Non-HCA pipelines
    • For onshore pipelines located outside of an HCA that can pass an in-line inspection device, integrity assessments must be conducted (ILI, pressure test, etc.).  The initial assessment must be completed by October 1, 2029, with periodic reassessments completed every 10 years after the last assessment.  Operators will have 180 days from the assessment to determine if there are any conditions that warrant remedial actions.
  • HCA pipelines capability to pass internal inspection devices
    • All HCA pipe must be modified to accommodate an internal inspection device by July 2, 2040. New pipelines must be constructed to accommodate internal inspection devices. The amount of the HCA miles capable of being inspected with internal inspection devices will be required to be reported annually. Newly identified HCAs will have 5 years to be made piggable.
  • Data Integration
    • PHMSA outlines several types of data sets that will need to be integrated within an operator’s integrity management program (ex. MOP, coating, casing locations, integrity assessment data, CIS, depth of cover, interference surveys, etc.).