The upcoming deadline for hazardous liquid pipelines
Otherwise known as the “Pipeline Safety: Safety of Hazardous Liquid Pipelines” (84 FR 52260) Final Rule, the Liquids Mega Rule was introduced in response to congressional mandates, lessons learned and public input.
Extending beyond high consequence areas (HCAs), the Liquids Mega Rule aims to include more pipelines transporting hazardous liquids within its reporting requirements.1
Part of this ruling requires specific pipelines in the USA to have leak detection in place by October 1 2024,2 which is covered predominantly in § 195.134 and § 195.444. In this blog, find out who will be impacted by this ruling, what’s involved in meeting these requirements from the Pipeline and Hazardous Materials Safety Administration (PHMSA) and how Atmos’ solutions can provide support.
Who will be impacted?
Owners and operators of hazardous liquid pipelines which are subject to and constructed before October 1 2019 are responsible for meeting the requirements of the Liquids Mega Rule before October 1 2024.
§ 195.1 refers to the transportation of hazardous liquids and conditions for being subject to Part 195. In addition to transporting liquid in single phase, the pipeline must include one or more of the below:
1. Pipelines transporting a highly volatile liquid
2. Any pipeline segment crossing a waterway currently used for commercial navigation
3. Any pipeline located in a rural or non-rural area of any diameter regardless of operating pressure, with the exception of gathering lines not covered in 4.
4. An onshore gathering line transporting petroleum under any of the following conditions:
a. The pipeline is located in a non-rural area
b. It is a rural gathering line regulated under §195.11
c. A pipeline located in an inlet of the Gulf of Mexico and subject to 195.413
5. Any gathering line not already covered by 1., 2., 3. and 4.
Pipelines with exceptions to Part 195 can be found here but broadly they include non-HCA gathering lines, regulated rural gathering lines and offshore lines.
What’s involved?
To avoid penalties, it’s crucial for pipeline operators to understand what’s involved in meeting the leak detection requirements of the Liquids Mega Rule, but also what’s not involved.
For example, while patrols can be useful as an external method of monitoring for leaks as part of a multimethod approach to leak detection, patrolling alone doesn’t provide a high enough standard of leak detection to meet the requirements of the Liquids Mega Rule. PHMSA cite limitations such as the capability of detecting leaks only when a patrol is ongoing and a patrol’s ability to only detect observable leaks as reasons for this leak detection method being incapable of meeting the requirements of § 195.444 in particular.3
195.134 and § 195.444 detail what’s expected of a leak detection system for pipeline facilities used in the transportation of hazardous liquids.
Single phase hazardous liquid pipelines falling under the conditions of § 195.1 and built before October 1 2019 must have a leak detection system in place by October 1 2024 that complies with § 195.444.
While it’s not a requirement for the solution to be a computational pipeline monitoring (CPM) system, PHMSA offers guidance on requirements for pipeline operators opting for this route. A new CPM leak detection system or replaced component of an existing CPM system must have at least one of the features listed in section 4.2 of API RP 1130.
PHMSA states that an effective system for detecting leaks must be in place on pipelines that complies with §§ 195.134 or 195.452, depending on which ruling is more appropriate to the pipeline.
195.452 refers to pipeline integrity management in high consequence areas (HCAs) and is relevant to hazardous liquid and carbon dioxide pipelines that could affect an HCA.
An HCA can generally be described as a location where a pipeline release, such as a leak or rupture, would have significantly more impact on the health and safety of the surrounding area than in other, lower risk locations.4 There are many criteria for meeting the definition of an HCA which all depend on what’s contained within the class location of a pipeline section (See Figure 1).
Figure 1: Criteria for a high consequence area in relation to liquid pipelines, as defined in §§ 195.450 and 195.6
For more information on HCAs
For a leak detection system that complies with either §§ 195.134 or 195.452, pipeline operators must evaluate and be able to demonstrate the system’s capability for protecting the public, property and environment and make necessary modifications as needed.
An operator’s evaluation should consider, as a minimum:
- The pipeline’s length and size
- Type of product carried
- Speed of the leak detection system
- Location of the nearest responders
- Leak history
CPM leak detection systems installed on the hazardous liquid pipelines must complete operations, maintenance, testing, record keeping and dispatcher training of the system in line with API RP 1130.
Satisfying the Liquids Mega Rule leak detection requirements
Software
With technology that has been successfully applied to over 1,500 pipelines across more than 60 countries, Atmos is the world’s leading leak detection provider and has a suite of solutions available to help operators meet the leak detection requirements of the Liquids Mega Rule.
While patrols can only locate observable leaks, Atmos Pipe can detect onset, slow opening and existing leaks when used in conjunction with existing instrumentation.
Hardware
For pipelines without existing instrumentation, a range of hardware options are available that can support as part of a leak detection system. For example, Atmos JSP integrates flow, pressure, temperature and SOS to provide real-time leak detection, all held within an enclosed unit made to fit project specifications and a non-intrusive design that reduces the risk of further damage to the pipeline integrity.
Regulation compliance support
To demonstrate compliance, operators of hazardous liquid pipelines must stay up to date on the latest requirements, especially the fast approaching deadlines like the Liquid Mega Rule on October 1 2024. Atmos’ Regulation Compliance Service is available for all leak detection systems, regardless of vendor.