Presentation Slides: PHMSA Final Rule (Part 1) for Hazardous Liquid Pipelines
- 1. PIPELINE INTEGRITY PHMSA Final Rule for Hazardous Liquid Transmission Pipelines – Part 1 May 2020 WEBINAR SERIES:
- 2. Table of Contents Slide 3 Slide 4 Slide 5 Slide 6-7 Slide 8-9 Slide 10-11 Slide 12-13 Slide 14-15 Slide 16-17 Slide 18-19 Slide 20-21 Slide 22-23 Slide 24-25 Slide 26 Speaker Bio Agenda The Rule Effective Date Unregulated Gravity Line Reporting Requirements Unregulated Gathering Line Reporting Requirements Weather Related Event (WRE) 72 Hour Inspection Non-IMP Segment Assessments Leak Detection ILI Tool Accommodation Pipes Act Provisions Pipeline HCA Segment Annual Identification IM Program Data Integration Future Rulemakings Q & A
- 3. TODAY’S SPEAKER Bryan Louque has over 25 years of experience in the pipeline industry. He has been involved with the design, construction, and O&M of pipeline systems with an emphasis on corrosion control, pipeline integrity and regulatory compliance programs on hazardous liquids (Part 195) and natural gas (Part 192) pipeline systems. Bryan Louque, P.E. Vice President of Asset Integrity and Corrosion Audubon Companies
- 4. Agenda When is the Hazardous Liquids Rule Effective? What’s in the Hazardous Liquids Rule? What’s not in the Hazardous Liquids Rule? What’s Next? WHY AM I HERE? July 2010 October 2019
- 5. WHEN IS THE RULE EFFECTIVE? Effective Date – July 1, 2020 TICK TOCK
- 6. WHAT’S IN THE RULE? 1.0 Unregulated Gravity Line Reporting Requirements What’s New? Submit annual (195.49), accident (195.50), and safety-related condition reports (195.55) to PHMSA • Accident and SRCR Report Effective Date – January 1, 2021 • Annual Report Effective Date – March 31, 2021 Telephonic (195.52), NPMS filings and SDS furnishing not required Key Exceptions Low-stress gravity lines < 1 mile from facility and do not cross commercially navigable waters
- 7. WHAT’S IN THE RULE? What is the Impact? The impact is LOW Primarily applies to flow lines upstream of LACT units 1.0 Unregulated Gravity Line Reporting Requirements
- 8. WHAT’S IN THE RULE? 2.0 Unregulated Gathering Line Reporting Requirements What’s New? Submit annual (195.49), accident (195.50), and safety-related condition reports (195.55) to PHMSA • Accident and SRCR Report Effective Date – January 1, 2021 • Annual Report Effective Date – March 31, 2021 Telephonic (195.52), NPMS filings and SDS furnishing not required Key Exceptions None
- 9. WHAT’S IN THE RULE? 2.0 Unregulated Gathering Line Reporting Requirements What is the Impact? The Impact is HIGH Update procedures to address new reporting requirements Train personnel Maintain accurate maps and records for all unregulated pipelines
- 10. WHAT’S IN THE RULE? 3.0 Weather Related Event (WRE) 72 Hour Inspection What’s New? Pipelines subject to damage by scouring or movement of surrounding soil • Tropical storms, hurricanes, floods, landslides, or earthquakes Inspection method determined by Operator Appropriate remedial action must be taken based on inspection results • Pressure reduction, repair / replacement, shut down (195.452) Key Exceptions Notify PHMSA if inspection is impeded / delayed due to lack of personnel or equipment
- 11. WHAT’S IN THE RULE? 3.0 Weather Related Event (WRE) 72 Hour Inspection What is the Impact? The Impact is HIGH Update procedures to address new inspection requirements Train personnel Identify all pipeline segments susceptible to WRE damage (195.452) Take pre-emptive measures where necessary
- 12. WHAT’S IN THE RULE? 4.0 Non-IMP Segment Assessments What’s New? Segments not subject to IMP must be assessed every 10 years • Initial assessments due by October 1, 2029 Assessment methods (195.452) • ILI, Hydrotest, ECDA Dig and repair anomalies per existing 195 criteria Key Exceptions None
- 13. WHAT’S IN THE RULE? 4.0 Non-IMP Segment Assessments What is the Impact? The Impact is HIGH All pipeline (inside and outside of HCAs) must be assessed
- 14. 5.0 Leak Detection What’s New? Regulated lines must have leak detection system inside & outside of HCAs • Lines built before October 1, 2019 – Effective October 1, 2024 • Lines built after October 1, 2019 – Effective October 1, 2020 Operators must evaluate leak detection system ability to protect the public, property, and the environment (195.452) Key Exceptions Offshore gathering and onshore regulated gathering lines WHAT’S IN THE RULE?
- 15. 5.0 Leak Detection What is the Impact? The Impact is MEDIUM Applies to regulated non-gathering lines, most of which should already have formal leak detection program (API RP 1175) WHAT’S IN THE RULE?
- 16. 6.0 ILI Tool Accommodation What’s New? Pipelines located in or could affect HCAs must accommodate ILI tools • 20 year implementation window • Potential waiver for pipelines that would be abandoned due to the cost of compliance Key Exceptions Manifolds, station piping, tank farm, storage piping, cross-overs, or select offshore piping WHAT’S IN THE RULE?
- 17. 6.0 ILI Tool Accommodation What is the Impact? The Impact is MEDIUM Design & construction standards require all new pipelines be piggable (195.120) Develop and implement legacy pipeline make-piggable programs for those located in or could affect HCAs WHAT’S IN THE RULE?
- 18. 7.0 PIPES Act Provisions What’s New? Provide Federal On-Scene Coordinators and emergency responders with product safety data sheets (SDS) for spilled hazardous liquids • Within six hours of notice to the NRC Conduct annual integrity assessments of underwater pipeline facilities located in HCAs and depth is greater than 150 feet Key Exceptions Offshore pipeline facilities WHAT’S IN THE RULE?
- 19. 7.0 PIPES Act Provisions What is the Impact? The impact is LOW Update Oil Spill Response Plan (194.101) to include SDSs for all pipeline products transported WHAT’S IN THE RULE?
- 20. 8.0 Pipeline HCA Segment Annual Identification What’s New? Verify all HCA direct or could affect line segments annually • Identify the factors in the original HCA analysis • Determine whether any of those factors have changed • Assess whether change will affect the results of the initial HCA segment identification Effective date – July 1, 2021 Key Exceptions Unregulated pipelines WHAT’S IN THE RULE?
- 21. 8.0 Pipeline HCA Segment Annual Identification What is the Impact? The Impact is HIGH Essentially requires direct or could affect HCA analysis for all regulated pipelines be performed annually Similar to what is required for gas lines WHAT’S IN THE RULE?
- 22. 9.0 IM Program Data Integration What’s New? Integration of IM program information and consideration of spatial relationships among anomalous information • For example, evidence of potential corrosion in an area with foreign pipeline crossings, interference from power lines, or evidence of land movement Effective date – October 1, 2020 Compliance date – October 1, 2022 Key Exceptions None WHAT’S IN THE RULE?
- 23. 9.0 IM Program Data Integration What is the Impact? The Impact is HIGH Essentially requires use of geospatial data integration and storage platform (ArcGIS) to operate IM program WHAT’S IN THE RULE?
- 24. Pipeline Repair Requirements: Operators will NOT be required to comply with the new criteria and remediation schedules for performing pipeline repairs. PHMSA will be considering that issue in a separate rulemaking proceeding. Future Rulemakings: The rule does NOT include two changes to Part 195 that PHMSA proposed at earlier points in the proceedings WHAT’S NOT IN THE RULE?
- 25. Future Rulemakings: The rule does NOT include two changes to Part 195 that PHMSA proposed at earlier points in the proceedings Engineering Critical Assessments: Operators will NOT be required to perform engineering critical assessments (analytical procedures to determine maximum tolerable flaw sizes in steel pipe to maintain safe operations) in relation to the remediation of certain defects. PHMSA will be considering that issue in a separate rulemaking proceeding. WHAT’S NOT IN THE RULE?
- 26. Bryan Louque, P.E. Vice President, Asset Integrity & Corrosion D: 918.514.5879 C: 913.221.3446 blouque@auduboncompanies.com auduboncompanies.com Any Questions?