• Extend the required use of leak detection systems beyond high consequence areas, except for offshore gathering and regulated rural gathering pipelines.

• All pipelines in or affecting HCAs must be capable of accommodating inline inspection tools within 20 years.

There have been further regulatory changes, and more changes can only be expected.

How operators can comply

The recent interim final rule was designed to protect from hazardous liquid pipeline accidents similar to the 2010 Marshall, MI, and the 2015 Refugio Beach, CA, oil spills. Furthermore, ensuring that events like an anchor strike that damaged the Line 5 pipeline in the Straits of Mackinac are quickly identified and remediated before they result in environmental damage.

Although the newly regulated 2,900 miles of pipeline seem minor in comparison to the nation’s more than 2.6 million miles of pipelines, they are in some of the most sensitive areas that, if something goes wrong, have a significant impact on a finite resource. Operators with pipelines now blanketed by federal regulations have the challenging task of adjusting current Integrity Management Plans (IMP) or developing and following an entirely new IMP. The IMP must consist of the following elements:

1. A process for identifying pipelines that could affect an HCA, including USAs (see §§ 195.6, 195.450, Appendix C to part 195, “Guidance for Implementation of an Integrity Management Program”).
2. An analysis of pipeline safety risks that integrates all available information about pipeline integrity and potential consequences (§ 195.452(g)). Data integrity and accuracy are critical to the success of this stage and sometimes the most complex challenge of all.
3. A plan for scheduling and performing baseline assessments (§ 195.452(c)) - deciding how to inspect the pipelines for the threats a risk assessment has highlighted. The techniques available include In-Line Inspection (ILI), Direct Assessment, Hydrotest, and other emerging technologies.
4. Define the criteria for performing remedial action in response to pipeline integrity issues identified during assessments or other analyses (§ 195.452(h)).
5. A continuous process for scheduling, performing and interpreting integrity assessments and evaluations (§ 195.452(j)).
6. Identifying “preventative and mitigative measures” to protect the pipeline from identified integrity threats (§ 195.452(i)).
7. Developing and following procedures for evaluating the effectiveness of the IM program (§ 195.452(k)).
8. A process to ensure integrity assessment results and information analysis is performed by qualified personnel (§ 195.452(f)(8)).

While it does not change any existing integrity management requirements, the interim final rule extends the scope of the existing current IM requirements to additional mileages of hazardous liquid pipelines. The designated coastal waters and coastal beaches will now receive the same protection as was previously afforded to the Great Lakes.

Technology available for IM segments

Risk tools continue to advance, with an increasing move toward more quantitative methods instead of simple, qualitative, index-based methods. Indeed, the use of semi-quantitative methods yields the accuracy of quantitative methods together with the versatility of qualitative methods when quantitative data doesn’t exist. The increased use of quantitative data is expected to lead to a more efficient allocation of maintenance and repair resources and improved integrity. Although the revised regulations are not driving a surge of new technologies, liquid pipeline operators have some of the most advanced and effective ILI technologies to choose from, like Magnetic Flux Leakage tools (MFL) (shown in Figure 2, on next page), Transverse Field MFL, Ultrasonic Wall Measurement, and Ultrasonic Crack Detection. 

In-line-Inspection (ILI) tools are built to travel inside a pipeline and collect real-time data as they go, but which tool should be used for which defects? MFL technology is used to detect corrosion in a pipeline by measuring volumetric metal loss and accurately identifying imperfections, such as dents. Although the accuracy of MFL