Pipeline Safety Update

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Erin McKay

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PHMSA Amendment No. 195-102 was issued October 1, 2019
this rulemaking went in to effect July 1, 2020.


There are many factors that should be considered when discussing risks to pipeline safety. These include manufacturing issues, external weather and environmental factors, land-use activities near pipelines, other
operational issues such as leak detection and age-related integrity issues.


The recent rulemaking addresses many of these risk factors by making changes in several key areas:


Key Areas


Scope and Definitions

  • In order to collect data, extend reporting requirements to certain hazardous liquid gravity and rural
    gathering lines not currently regulated by PHMSA. §195.1
  • The definition of “hazardous liquid” has been modified to include biofuels. §195.2


Hazardous Liquids Reporting

  • Pipelines transporting hazardous liquids by gravity will be subjected to the same annual, accident and safety related conditions reporting requirements as other hazardous liquid pipelines. §195.13
  • Otherwise unregulated rural gathering lines and certain offshore pipelines in State waters are subject to the annual, accident and safety related conditions reporting requirements as other hazardous liquid pipelines. §195.15


Safety Data Sheets

  • Operators of hazardous liquid pipeline facilities, following an accident that results in a spill are to provide safety data sheets to the designated Federal on Scene Coordinator and appropriate State and local emergency responders within 6 hours of notification to NRC. §195.65


O & M
Passage of Internal Inspection Devices

  • The provisions in the regulations that allow an operator to petition the Administrator for a finding that the ILI compatibility requirement does not apply as a result of construction related constraints
    and problems has been repealed. The other provisions are reorganized without altering the existing substantive requirements. §195.120


Repair Requirements

  • The repair requirements are modified to include a new paragraph to clearly require operators to consider risk when prioritizing remediation of any abnormal condition that could adversely affect the safe operation of a pipeline system regardless of whether the conditions are in an HCA or non-HCA. §195.401(b)


Extreme Weather and Natural Disaster Inspections

  • Inspections of pipelines in areas affected by extreme weather or natural disasters within 72 hours. This provision affects all covered lines under §195.1, whether they be onshore or offshore, and in a high consequence area (HCA) or outside an HCA as defined in 49 CFR §195.450. §195.414


Integrity Assessments Outside HCAs

  • Requires integrity assessments at least once every 10 years, using inline inspection tools or other technology, as appropriate for the threat being assessed, of onshore, piggable, hazardous liquid pipeline segments located outside of HCAs. §195.416


LEAK DETECTION – Does not apply to Offshore or Regulated Rural Gathering

  • CPM has been removed from the title to read Leak Detection. All existing or newly constructed
    covered pipelines are designed to include leak detection. If CPM is used, must be in accordance with the requirements in Section 4.2 of API 1130, and any other applicable design criteria in the standard. §195.134
  • Extends the required use of leak detection systems beyond HCAs to all regulated hazardous liquid
    pipelines, except for offshore gathering and regulated rural gathering pipelines. This is to help mitigate the effects of hazardous liquid pipeline failures that occur outside of HCAs. Includes certain factors in determining what kind of system is necessary to protect public, property, and the environment. §195.444



Programs and Reporting

  • Deadlines for the development of a written IM program prior to the pipeline going into operation has been clarified. §195.452 (b)(1)
  • Amendments made to clarify the baseline assessment requirements for new or converted pipelines as well as newly identified HCA’s. Operators should keep the records they have to show compliance regarding the baseline assessments performed. §195.452(d)
  • Section is amended to require an operator to notify PHMSA and provide an expected date outside the 180 days when adequate information will be available. §195.452(h)(2)
  • Section is amended to establish that at least on an annual basis an operator will verify the risk factors used to identify covered segments that could affect an HCA, not to exceed 15 months. §195.452(j)


Integrity Assessments

  • Operators must consider the uncertainty in tool tolerances in reviewing the results of ILI assessments. An operator must use an ILI tool or tools capable of detecting crack anomalies if a pipeline segment has an identified risk or threat related to cracks. §195.452(c)(1)(i)(A)
  • All pipelines in or affecting HCAs be capable of accommodating in-line inspection tools within 20
    years, unless the basic construction of a pipeline cannot be modified to permit that accommodation. §195.452(n)
  • New annual assessment requirements for operators of any underwater hazardous liquid pipeline facility located in an HCA that is not offshore pipeline facility and any portion of which is located at depths greater than 150 feet under the surface of the water. These operators must complete assessment not less often than once every 12 months using ILIs appropriate for the threats. §195.454


Risk Assessment

  • Seismicity is added to factors that must be considered regarding assessment schedules per (e),
    performing information analysis per (g), for implementing preventive and mitigative measures under paragraph (i). §195.452
  • Criteria an operator must consider in performing the informational analysis are prescribed per
    §195.452(g) and include:


1. Pipe diameter, wall thickness, grade, and seam type
2. Pipe coating, including girth weld coating
3. Maximum operating pressure (MOP) and temperature
4. Endpoints of segments that could affect high consequence areas (HCAs)
5. Hydrostatic test pressure including any test failures or leaks – if known
6. Location of casings and if shorted
7. Any in-service ruptures or leaks – including identified causes
8. Data gathered through integrity assessments required under this section
9. Close interval survey (CIS) survey results
10. Depth of cover survey
11. Corrosion protection (CP) rectifier reading
12. CP test point survey readings and locations
13. AC/DC and foreign structure interference surveys
14. Pipe coating surveys and cathodic protection survey
15. Results of examinations of exposed portions of buried pipelines (i.e., pipe and pipe
coating condition, see § 195.569)
16. Stress corrosion cracking (SCC) and other cracking (pipe body or weld) excavations and
findings, including in-situ non-destructive examinations and analysis results for failure
stress pressures and cyclic fatigue crack growth analysis to estimate the remaining life of
the pipeline.
17. Aerial photography
18. Location of foreign line crossings
19. Pipe exposures resulting from repairs and encroachments
20. Seismicity of the area
21. Other pertinent information derived from operations and maintenance activities and any
additional tests, inspections, surveys, patrols, or monitoring required under this part.



Click here to download the PHMSA Amdt. No. 195-102 – Recommended Activities Summary

Click here to download the Hazardous Liquid Final Rule Code Changes