Nothing in these FAQs alters the content of the rule, constitutes new requirements, or represents interpretations of the rule. Requests for official written interpretations of the Hazardous Liquid Pipeline Integrity Management Rule may be requested in accordance with 49 CFR 190.11.

What criteria must an operator consider in determining whether enhancements to leak detection are required?

Operators are required to have a means of detecting leakage on their pipelines. Operators must evaluate that capability and improve it, if necessary, to protect the high consequence area. The evaluation must include at least the following factors:

  • Length and size of the pipeline
  • Type of product carried
  • The pipeline's proximity to the high consequence area
  • The swiftness of leak detection
  • Location of nearest response personnel
  • Leak history, and
  • Risk assessment results

In addition, PHMSA Pipeline Safety believes the operator should consider:

  • System operating characteristics (e.g., steady state operation, high transient pressure and flow)
  • Current leak detection method for the HCA areas
  • Use of SCADA
  • Thresholds for leak detection
  • Flow and pressure measurement
  • Specific procedures for lines that are idle but still under pressure
  • Specific consequences related to sole source water supplies regarding additional leak detection means
  • Testing of leak detection means, such as physical removal of product from the pipeline to test the detection
  • Any other characteristics that are part of the system leak detection

What is the minimum acceptable leak detection system in order to comply with 195.452 (i) (3), which states "an operator must have a means to detect leaks on its pipeline system."?

PHMSA Pipeline Safety will address leak detection capability with each operator according to the requirements of the regulation. This includes a "means to detect leaks" and an evaluation of the capability of the leak detection means. The rule specifies several factors that the evaluation must consider. These and additional factors that PHMSA Pipeline Safety believes the operator should consider are outlined in FAQ 9.4.

PHMSA Pipeline Safety will evaluate the operator’s process for considering these factors and making decisions about the adequacy of leak detection during integrity management inspections.

49 CFR 195.134 and 195.444 require that computational pipeline monitoring (CPM) leak-detection systems on hazardous liquid pipelines must comply with API Standard 1130 for design and operations/maintenance respectively. Paragraph (i) (3) of the integrity management rule requires that operators must have a means to detect leaks on pipelines that can affect HCAs. Must leak detection means used to satisfy 49 CFR 195.452 (i) (3) meet API-1130?

There are many ways that an operator may detect leaks. The operator must conduct a risk analysis, per §195.452 (i) (2) to identify the need for additional preventive and mitigative features. Leak detection capability must be evaluated, per §195.452 (i) (3), using the results of this risk analysis and other factors listed in that paragraph. An operator must determine if modifications to its leak detection means are needed to improve the operator's ability to respond to a pipeline failure and protect HCAs. An operator may determine, on an individual pipeline segment basis, that a CPM system is needed to meet this need. If a CPM system is employed, its implementation and operation must satisfy the requirements of §195.134 and §195.444, which reference certain aspects of API-1130.

What preventive and mitigative actions must be taken to protect HCAs?

Operators must conduct risk analyses for the line segments that could affect HCAs. These analyses should identify and evaluate the need for additional preventive and mitigative actions to protect HCAs. The rule does not specify which actions must be taken. A list of some measures which might be taken includes:

  • Implementing damage prevention best practices
  • Enhanced cathodic protection monitoring
  • Reduced inspection intervals
  • Enhanced training
  • Installing EFRDs
  • Modifying the systems that monitor pressure and detect leaks
  • Conducting drills with local emergency responders
  • Other management controls

An operator must implement the appropriate preventive and mitigative actions to address the risks unique to each specific line segment or facility.

Leak detection is applied to an entire system, which generally contains both HCA and non-HCA segments. Therefore, how do you compare leak detection between the HCA and non-HCA segments?

The rule requires that operators have leak detection on their pipeline systems. This detection provides protection against leaks in segments that can affect HCAs and in those that cannot. The rule also requires, however, that operators evaluate the capability of their leak detection means and modify, as necessary, to protect high consequence areas. This does not imply that new/improved leak detection capability must be installed only in segments that can affect HCAs, but rather operators assure that whatever leak detection is provided for the system is adequate to provide the level of protection appropriate for HCAs that the system can affect.

Some States have adopted or are considering, integrity management rules including requirements similar to those in the federal rule. If a company operates both intra- and interstate pipelines in such a State, which integrity management rules apply to each type of pipeline?

A state certified to inspect an intrastate pipeline is required to have safety standards that are at least as stringent as the federal Pipeline Safety rules. If a State rule is less stringent or has not been adopted as State law, the federal rule would apply to both intrastate and interstate pipelines.

Once a State has adopted integrity management program standards, then those standards, including any provisions that may be more restrictive than the federal rule, would be enforced by the State for intrastate pipelines.

Questions about applicability and enforcement of rules in specific States should be directed to the appropriate State agency.

If a state establishes a definition that expands upon the HCAs defined in 195.450, do the requirements of 195.452 apply to line segments that affect these additional state-defined HCAs?

For both intra- and interstate pipelines, the requirements of §195.452, as a minimum, apply to HCAs as defined in §195.450. States may apply more restrictive requirements, including a broader definition of HCAs to intrastate lines, but those requirements do not affect interstate pipelines. (It should be noted that the Texas rule does not define HCAs. The Texas rule applies to all pipe.)


Categories: Best practice advice , Industry update

By: Atmos International
Date: 15 April 2019