# HL IM FAQs - **operation:** document - **citation:** PHMSA Guidance, HL IM FAQs - **title:** HL IM FAQs - **source type:** guidance - **agency:** Pipeline and Hazardous Materials Safety Administration - **status:** guidance - **official:** true - **published on:** 2025-09-12 - **effective on:** 2025-09-12 - **summary:** HL IM FAQs Document Liquid IM FAQs 9-12-25 revision.pdf (528.34 KB) Liquid Integrity Management Rule Frequently Asked Questions. Issued Date: Friday, September 12, 2025 - **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-guidance-hl-im-faqs-c9660cc0.json - **markdown:** https://regulus.evalyn.ai/document/phmsa-guidance-hl-im-faqs-c9660cc0.md - **app url:** https://regulus.evalyn.ai/document/phmsa-guidance-hl-im-faqs-c9660cc0 - **source url:** https://www.phmsa.dot.gov/pipeline/hazardous-liquid-integrity-management/hl-im-faqs **body:** HL IM FAQs Document Liquid IM FAQs 9-12-25 revision.pdf (528.34 KB) Liquid Integrity Management Rule Frequently Asked Questions. Issued Date: Friday, September 12, 2025 <<>> Liquid Integrity Management Rule Frequently Asked Questions Revision Date: September 12, 2025 LIQUID INTEGRITY MANAGEMENT RULE BASICS 1.1 What are the PHMSA’s objectives for the Liquid Integrity Management rule? The liquid integrity management rule has four primary objectives: • accelerating the integrity assessment of pipelines in High Consequence Areas • improving operator integrity management systems • improving government’s role in reviewing the adequacy of integrity programs and plans, and providing increased public assurance in Pipeline Safety Last Revision: 10/22/01 1.2 Who must comply with the rule? The Liquid Integrity Management rule, §195.452, applies to all operators of certain hazardous liquid pipeline facilities subject to Part 195 that could affect a high consequence area. The compliance dates for certain provisions are based on whether a particular pipeline was owned or operated by a company that had more or less than 500 total miles of hazardous liquid pipelines subject to Part 195 on May 29, 2001. These 500 miles need not be contiguous. With limited exceptions, every hazardous liquid pipeline segment that is subject to Part 195 as specified in § 195.1, and that can affect an HCA, regardless of length, is covered by the rule. Pursuant to recently adopted regulations, the Liquid Integrity Management rule also applies to low- stress pipelines in rural areas that are located in or within ½ mile of an unusually sensitive area (USA) as defined in § 195.6; and operate at a pressure of i) less than or equal to 20% SMYS; or ii) if stress level is unknown or it is not constructed with steel pipe, a pressure equal to or less than 125 psig. Last Revision: 5/10/12 1.3 Is integrity management simply inspection of pipe condition? No. While periodically assessing the pipe condition and correcting identified anomalies is an important part of the rule, there are other important requirements. Operators must develop improved management and analysis processes that integrate all available integrity-related data and information and assess the risks associated with segments that can affect HCAs. Furthermore, operators must implement additional risk control measures if needed to protect HCAs. Examples of these additional measures include: enhanced damage prevention programs, reduced inspection intervals, corrosion control program improvements, leak detection system enhancements, installation of Emergency Flow Restricting Devices (EFRDs), and emergency preparedness improvements. Last Revision: 2/18/03 1.3 What is a high consequence area (HCA)? High consequence areas are defined in the rule as either: • High population areas, defined by the Census Bureau as urbanized areas, • Other populated areas, defined by the Census Bureau as places that contain a concentrated population, <<>> • Unusually sensitive areas, or • Commercially navigable waterways. Last Revision: 2/18/03 1.6 What are recognized industry practices? Recognized industry practices include those found in national consensus standards or reference guides. Some standards currently invoked by Part 195 that are applicable to Liquid Integrity Management include, but are not limited to, NACE SP0502-2010; ASME/ANSI B31G-2004; and ASME/ANSI B31.4-2006. Last Revision: 8/31/16 1.6 When can an operator use an alternative to a recognized industry practice? An operator may elect to use an alternative to a recognized industry practice for any of several reasons. For example, an alternative practice could utilize new technology, such as a new generation of internal inspection device that has improved detection capabilities. An alternative technology could also be one that has been successfully used in other countries or by other pipeline companies but has not yet been codified into a national consensus standard. PHMSA Pipeline Safety wants to encourage operators to use innovative practices that are based on sound engineering judgment. Use of such alternatives helps improve the state-of-the-art in Pipeline Safety technology. The rule requires that the selection of an alternative must be based on a reliable engineering evaluation. Use of an alternative must provide an equivalent (or better) result than using the recognized practice. An operator must document its use of an alternative practice when the operator makes the decision to use the alternative. Last Revision: 2/18/03 1.7 What was DOT’s purpose for creating an Appendix C rather than placing this material in the regulation? Part 195 Appendix C was created to provide additional guidance and clarification for selected requirements in the rule. This was provided to assist operators in understanding the basic rule requirements and what might be necessary for compliance. Because the information in Part 195 Appendix C is guidance, it was determined that an Appendix was the appropriate location for this material. Last Revision: 10/23/01 RULE APPLICABILITY 2.1 Does the rule apply to more than line pipe? Yes. The continual evaluation and information analysis requirements of the rule apply to pipelines as defined in 49 CFR 195.2. This includes, but is not limited to, line pipe, valves and other appurtenances connected to line pipe, metering and delivery stations, pump stations, storage field facilities, and breakout tanks. The baseline integrity assessment and periodic re-assessment requirements apply only to line pipe. Last Revision: 2/18/03 2.2 Does the rule apply to low-stress lines? <<>> Yes. The Liquid Integrity Management rule applies to certain low-stress pipelines as required by §§ 195.1 and 195.12. Last Revision: 5/10/12 2.2A What are Category 1, 2, or 3 under the low-stress pipelines in rural areas, §195.12? A pipeline category under §195.12 is determined by the nominal diameter and whether the pipeline is located in or within 1/2 mile of an unusually sensitive area (USA). If the pipeline is equal to or more than 8.625 inch in nominal diameter and located in or within 1/2 mile of a USA, it is Category 1. If the pipeline is less than 8.625 inch in nominal diameter and is located in or within 1/2 mile of a USA it is Category 2. A pipeline of any nominal diameter not located in or within 1/2 mile of a USA is Category 3. Category 1 and 2 pipelines must comply with Integrity Management requirements according to the dates specified in § 195.12. Last Revision: 7/2/15 2.3 Do the requirements of the rule apply to “idle” pipe? (Deleted. See PHMSA Advisory Bulletin ADB-2016-05, Pipeline Safety: Clarification of Terms Relating to Pipeline Operational Status, 81 FR 54,512 (Aug. 16, 2016)) Last Revision: 8/31/16 2.4 Does the rule apply to offshore pipelines? Yes. The rule applies to those segments of offshore pipelines that could affect HCAs, principally commercially navigable waterways and unusually sensitive areas. Last Revision: 10/22/01 2.5 What is meant by ‘operator who owns or operates a total of 500 or more miles of pipeline’ in 195.452(a)? For example, if an operator who operates more than 500 miles of pipeline also owns a small percentage of a small pipeline (less than 500 miles) that is operated by a different organization - does that smaller operator have to comply with the deadlines for category 1 pipelines, even if its O&M manual, management processes, etc. are totally separate from the large operator? (Deleted. Applicable time frames for categorizing pipelines has passed.) Last Revision: 7/2/15 2.6 If the operator of a small pipeline system is partially owned by another company, who is responsible for preparing the Baseline Assessment Plan and complying with the provisions of this rule - the operator, or the company that is part owner? Any and all owners and operators of a pipeline facility are responsible for the facility’s compliance with applicable pipeline safety regulations. Normally, the primary operator will prepare the Baseline Assessment Plan under the requirements in §195.452 (c). Operators (or owners) may use outside resources, including adopting management plans prepared by parent companies, but that does not relieve the operator (or owner) of responsibility for having a Baseline Assessment Plan. Last Revision: 2/18/03 <<>> 2.7 If a company acquires additional pipeline in late 2001 that increases its total mileage over 500, are they covered by the rule? Are the compliance deadlines the same? (Deleted. The timeframes for completing Baseline Assessments for operator size Category 1 and 2 pipelines has passed. Re-assessment schedules are now set based on the completion dates of baseline assessment and previous re-assessments.) Last Revision: 7/9/02 2.9 If a pipeline subject to 195.452 is sold, does the new operator ‘inherit’ integrity management plans and deadlines from the original operator? No. Acquisition of a pipeline by an operator includes accepting obligations attendant upon that pipeline as a result of regulatory requirements. For purposes of integrity management, an operator acquiring a pipeline would be expected to integrate that pipeline into its integrity management program. Multiple, independent integrity management programs are neither required nor desirable. Compliance deadlines established in §195.452 for identifying segments that can affect HCAs have passed for all categories of pipeline, and all hazardous liquid pipeline segments that can affect HCAs should now have been identified. The acquiring company is, of course, responsible for the accuracy of its identification of segments that can affect HCAs and should assure itself that the identification performed by the selling company is adequate. The acquiring company should review and update the segment identification as it does for its other pipeline. The deadlines for completing Baseline Assessments continue to apply based on the category of the acquired pipeline, i.e., whether it was owned or operated on May 29, 2001, by an operator with more or fewer than 500 miles of pipeline. Integration of new assets into existing Baseline Assessment Plans may result in realigning schedules for future assessments based on the relative risk of the acquired pipeline and the operator’s existing pipeline(s). The regulatory deadlines for assessments (e.g., that re-assessments be scheduled within 5- year intervals) continue to apply, as well as the schedule requirements for any remediation required by §195.452(h) that may be pending at the time ownership of the pipeline is transferred. Last Revision: 12/19/07 2.10 Who will be held accountable for implementing Integrity Management requirements in a case where an operator transfers ownership of pipeline assets to another company but retains responsibility, by contract, for maintenance and integrity management activities until some later date? Any and all owners and operators of a pipeline facility are responsible for the facility’s compliance with applicable pipeline safety regulations. An operator (or owner) may use outside resources including, in this example, contracting with the prior owner of the pipeline. In this example, PHMSA Pipeline Safety would likely inspect the operator’s Integrity Management Program, including any activities conducted by contractors, but any enforcement action that results from noncompliance discovered during those inspections could be directed against either the operator, the owner, or both. Last Revision: 2/18/03 2.11 If a pipeline transports both gas and liquids (e.g., some offshore lines), does the hazardous liquid integrity management rule apply, or does the gas integrity management rule apply? Lines that transport both liquids and gas must meet requirements applicable to both. In practice, this means that the more stringent requirement must be met. (Note that the requirements for gas transmission <<>> integrity management in Subpart O of 49 CFR Part 192 apply only if the pipeline is classified as a gas transmission pipeline). Last Revision: 12/16/05 2.12 Does the rule apply to the operator of a marketing facility if that operator does not own or operate a pipeline but rather receives and delivers hazardous liquid from/to third-party pipelines? Yes, if the facility is otherwise covered by Part 195. (The integrity management rule, by itself, makes no changes to the applicability of Part 195 rules). Since Part 195 applies generally to pipeline facilities, not just to line pipe, the requirements of §195.452 for HCA identification also apply to facilities that fall under Part 195 jurisdiction. If the operator’s facilities could affect an HCA, then the operator would be required to have an integrity management program that implements all applicable requirements of the rule including, the need to identify risks to the facility and take preventive and mitigative actions to reduce these risks. Last Revision: 2/18/03 SEGMENT IDENTIFICATION 3.1 When must pipeline segments subject to the rule be identified? (Deleted. The deadline for segment identification for operator sized Category 1 and 2 has passed.) Last Revision: 5/10/12 3.2 Many operators have pre-defined segments on their pipeline (e.g., the length of pipe between two pump stations is considered a segment). When PHMSA Pipeline Safety refers to segments that can impact an HCA in the rule, in what context is the term segment used? As used in the rule, a segment that can affect an HCA refers to a continuous portion of a pipeline system in which the released commodity from a failure occurring anywhere between the two end points of the segment could migrate to and affect an HCA. The segment sizes should be defined by whether or not a spill could impact the HCA and not by pre-set definitions used by the operator. Last Revision: 2/18/03 3.3 How will an operator determine if a pipeline can affect an HCA? Part 195 Appendix C of the rule provides guidance on factors an operator should consider in determining whether a pipeline can affect an HCA. An example is provided in the Appendix. The factors are: • Potential physical pathways between the pipeline and the HCA. • Terrain surrounding the pipeline. An operator should consider the contour of the land profile and if it could allow the liquid from a release to enter an HCA. An operator can obtain this information from topographical maps such as U.S. Geological Survey quadrangle maps. • Drainage systems such as storm sewers, water crossings, small streams and other drainage systems that could serve as a conduit to an HCA. • Crossing of farm tile fields. An operator should consider the possibility of a spillage in the field following the drain tile into a waterway. • Crossing of roadways and railroad crossings with ditches along the side. The ditches could carry a spillage to a waterway. • Potential natural forces inherent in the area (flood zones, earthquakes, subsidence areas, etc.) <<>> • The nature and characteristics of the product the pipeline is transporting (refined products, crude oils, highly volatile liquids, etc.) Highly volatile liquids become gaseous when exposed to the atmosphere. A release could create a vapor cloud that could settle into the lower elevation of the ground profile. • Physical support of the pipeline segment such as by a cable suspension bridge. An operator should look for stress indicators on the pipeline (strained supports, inadequate support at towers), atmospheric corrosion, vandalism, and other obvious signs of improper maintenance. • Operating condition of pipeline (pressure, flow rate, etc.) and exposure of the pipeline to operating pressures exceeding the established maximum operating pressure. • The hydraulic gradient of pipeline. • The diameter of pipeline, the potential release volume, and the distance between the isolation points. • Response capability (time to respond, nature of response). Last Revision: 2/18/03 3.4 What is acceptable methodology and criteria for determining whether a segment could affect an HCA? (For example, what spill volume should be considered - Worst-case discharge? Most likely discharge? Most likely worst-case discharge?) Can an arbitrary safe distance be applied, or must location specific dispersion analyses be performed? Is air dispersion modeling expected or is spill trajectory adequate? PHMSA Pipeline Safety expects each operator to develop a process for identifying what portions of its pipeline system could affect an HCA in the event of a failure. This process is a required Integrity Management program element per §195.452 (f). Operators are responsible for selecting a methodology and establishing any criteria needed to determine where pipeline failures could affect HCAs. PHMSA Pipeline Safety will look for sound engineering judgment with a reasonable amount of conservatism to account for uncertainties in the assumptions and calculation methods used in the analysis. Operators should be able to justify the assumptions used in making these determinations. Companies that apply an arbitrary “safe distance” should justify how this distance was determined and provide convincing evidence that this “safe distance” is indeed bounding for its pipeline system. Air dispersion should be considered in instances where hazardous material could be transported by air (e.g., failures of HVL lines). For low-stress pipeline in rural areas that meet the requirements of §195.12, segments that could affect an HCA are those located in or within 1/2 mile of a USA or those determined by an analysis conducted in accordance with §195.452(a) that could affect an HCA. Last Revision: 5/10/12 3.5 Do operators need to perform detailed consequence analysis to determine the specific impacts on population or USAs? Yes. PHMSA Pipeline Safety expects that an operator will develop an understanding of the potential consequences of leaks and ruptures of its pipelines. The operator should be able to estimate the severity of releases in terms of volume of hazardous liquid that could be released, the physical pathways and dispersion mechanisms by which the commodity can be transported to an HCA, the amount of commodity that might actually reach the boundaries of the HCA, and the population and environmental resources that can be affected by such a release. <<>> The operator should develop a sufficient understanding of the severity and impact of potential releases to determine the appropriate preventive and mitigative actions required by 452 (i). Last Revision: 2/18/03 3.6 Can the identification of segments that “can affect” HCAs be refined after the December 31, 2001, (or November 18, 2002, as appropriate) deadline? Yes. PHMSA Pipeline Safety recognizes that some operators used methods with conservative assumptions in identifying which pipeline segments can affect HCAs to meet the initial compliance deadline. Refinement of these segments, potentially changing the boundaries of identified segments, may occur as more detailed analyses are performed later. This refinement process could result in a conclusion that some segments (or portions of segments) identified by the deadline cannot, in fact, affect an HCA. PHMSA Pipeline Safety expects operators to document their justification for any such elimination of an identified segment and may review the technical basis for these changes during inspections. The refinement process could also result in identification of new segments that can affect HCAs, not included in those identified initially. PHMSA Pipeline Safety would not consider failure to identify such segments by the deadline to be a noncompliance unless there is a pattern demonstrating significant weaknesses in the process used to identify segments by the deadline. Newly-identified segments must be scheduled for baseline and re-assessment in accordance with the provisions of the rule. Operators should not apply refinements which impact the definition of a segment that can affect an HCA once the process of conducting the baseline assessment for that segment has begun. The baseline assessment results must be evaluated, and repairs required by the criteria of paragraph (h) must be performed, for the entire segment as defined prior to conduct of the assessment. The boundaries of the segment can be reconsidered after conclusion of the baseline assessment and repair process. The results of the assessment should be taken into account, as appropriate, in such reconsideration. For new pipelines (i.e., operator size Category 3), PHMSA Pipeline Safety expects that segments that can affect high consequence areas will have been identified when the pipeline begins service. Subsequent refinement would not be expected to occur unless driven by outside circumstances (e.g., growth of a populated area). Last Revision: 2/18/03 3.7 How will HCAs be identified and communicated to the industry? PHMSA Pipeline Safety has developed a GIS dataset showing the locations of HCAs (as defined in §195.450) throughout the nation. This data is available to operators via the National Pipeline Mapping System. Last Revision: 5/21/12 3.8 What are PHMSA Pipeline Safety expectations for operators to determine new or changed HCAs? The One Rule requires operators to develop their own HCA dataset and use it in their IMP. Last Revision: 5/21/12 3.9 When must newly-identified HCAs be included in the program? <<>> Over time, new HCAs may be identified as population distributions change, or new drinking water or ecological resource data becomes available. Newly identified areas must be incorporated into the Baseline Assessment Plans within one year of identification. PHMSA Pipeline Safety will periodically update the HCA maps and make them available on the National Pipeline Mapping System for operator use. The operator reporting requirements, the information to be updated, and the frequency of updates can be found at https://www.npms.phmsa.dot.gov/ Operators must also look for new HCAs on their own by monitoring local population growth or through knowledge of environmental resources that becomes available to them. In either event, a newly- identified HCA must be incorporated into the integrity management program within one year of its identification. A baseline assessment for pipeline segments that could affect newly identified HCAs must be performed within five years of its identification. Last Revision: 12/16/05 3.10 On what frequency or schedule will changes to the HCA maps on the National Pipeline Mapping System be made? Will PHMSA Pipeline Safety announce or provide public notice of changes? Information on the frequency or schedule for changes to NPMS can be found at https://www.npms.phmsa.dot.gov/. Last Revision: 5/10/12 3.11 How will PHMSA Pipeline Safety track changes to HCA information over time? When data fields are changed, will operators be able to clearly distinguish the new information from the old in NPMS? PHMSA Pipeline Safety uses version numbers in naming HCA data layers. Visual comparison of different versions of the layers will reveal any differences in geographic information. Last Revision: 2/18/03 3.12 If OPS did not complete the Unusually Sensitive Area (USA) mapping for a state by December 31, 2001, what responsibility does an operator have to identify segments that could impact USAs in that state? Similarly, for those states for which the USA mapping was not completed until late 2001 (e.g., final quarter CY2001), will OPS grant some relief from meeting the December 31, 2001 segment identification requirement to operators with pipelines in those states? (Deleted. See https://www.npms.phmsa.dot.gov/ for PHMSA's plans for updating NPMS for USAs.) Last Revision: 5/10/12 3.13 For those states in which USA maps are not posted until after December 31, 2001, how long does an operator have to incorporate this new information into its segment identification and assessment planning process? (Deleted. See https://www.npms.phmsa.dot.gov/ for PHMSA's plans for updating NPMS for USAs.) Last Revision: 5/10/12 3.14 If an operator desires location and other information on a specific ecological or drinking water USA to use in risk analysis and determination of potential pipeline release impacts, how can this information be obtained? <<>> Those operators who desire to make accurate determinations of whether their system can affect a particular USA can obtain more specific information on the location of particular USAs from their drinking water providers and state heritage networks. Contact information for a particular USA is included in the USA data layers that operators can obtain from PHMSA Pipeline Safety. GIS-related software will be required to view this information. PHMSA Pipeline Safety will not act as an agent for purposes of gathering additional information. Last Revision: 2/18/03 3.15 Since the USA data in the National Pipeline Mapping System (NPMS) contains buffer zones around the actual drinking water or ecological resource, is it possible that an operator’s evaluation to determine whether a spill could impact an HCA might show a release reaching a USA depicted on the NPMS map when in reality such a release might not actually reach the sensitive area? Yes. In mapping USAs in the NPMS, buffers were used to account for the uncertainties in the species or drinking water location data. Thus, it is possible that spills “just reaching the edge” of a USA boundary (for instance) might not actually impact the drinking water or ecological resource. Those operators who desire to make accurate determinations of whether their system can affect a particular USA can obtain more specific information on the location of particular USAs by contacting the entities that supplied the drinking water and ecological data to PHMSA Pipeline Safety. Operators can find contact information for these drinking water and ecological data suppliers by clicking on the USA in the NPMS. Last Revision: 2/18/03 3.16 What mechanism is available for questioning or challenging HCA and USA identification once such identification has been posted on the National Pipeline Mapping System? HCAs and USAs have been defined in Part 195. These definitions were developed after considering significant public and industry input, and they are now final. PHMSA Pipeline Safety is using recognized organizations and data sources for mapping HCA information. Anyone having new information that they believe could affect the accuracy of the mapped HCAs (e.g., errors in data sources, or more recent data) should contact PHMSA Pipeline Safety. Last Revision: 10/22/01 3.17 Must non-pipe elements of a pipeline system that can affect HCAs (e.g., stations and facilities) have been identified? Yes. While the assessment requirements of 49 CFR 195.452 are applicable to line pipe, all other requirements, including segment identification, are applicable to the entire pipeline system as defined in 49 CFR 195.2. PHMSA Pipeline Safety expects operators to understand which pump stations, terminals, and other facilities might also affect HCAs in the event of a failure. Last Revision: 2/18/03 3.18 f an operator initially treated its entire system(s) as having the potential to affect an HCA (to meet the 12/31/01 deadline for segment identification) and then includes its entire system in its Baseline Assessment Plan, can they later refine this approach by defining only specific, smaller segments that can affect an HCA (e.g., when it comes time to make repairs after a tool run, or for the purposes of evaluating the need for EFRDs)? (Deleted. An operator, with justification, can refine its segment identification; however, an operator must implement the requirements of the Liquid Integrity Management rule as the segments are defined at the <<>> time an assessment is compete. For example, an operator cannot redefine segments after an assessment is complete for the purposes of not performing repairs.) Last Revision: 12/6/02 3.19 What types of considerations would PHMSA Pipeline Safety consider reasonable for determining whether pipelines can affect commercially navigable waterways in open water? PHMSA Pipeline Safety has elected to use the National Waterways Network database as the basis for identifying commercially navigable waterways in National Pipeline Mapping System. This database includes commercially navigable waterways in open water (i.e., offshore or in the Great Lakes) and those that are inland (rivers, canals, harbors, etc.). Vessels that use commercially navigable waterways in open water, typically called fairways, can be rerouted. Pipeline spills in such areas may therefore have a limited impact on commerce. This is not the case for inland waterways or for specific routes that provide sole access to a port (e.g., where water depth may limit ships to a specific approach), or where for other reasons vessels cannot be diverted. PHMSA Pipeline Safety recognizes that other databases may provide waterway information that is more comprehensive. Such information may be used by operators in evaluating whether a specific pipeline system could affect a high consequence area. Operators may make reasonable distinctions for commercially navigable waterways in open water based on whether or not shipping could be rerouted. If a spill from a particular segment of pipeline would not be expected to interfere with commercial navigation, then operators may conclude that the segment cannot affect a commercially navigable waterway. Operators must still consider whether spills could affect other HCAs (e.g., drinking water intakes on the Great Lakes). Operators may consult with agencies such as the U.S. Coast Guard and the U.S. Army Corps of Engineers for additional or more comprehensive information for conducting risk assessments. Such agencies can provide guidance on whether specific routes provide sole access to a port. Last Revision: 2/18/03 3.20 What assumptions would PHMSA Pipeline Safety find acceptable for analysis of spilled product transport by waterway or topographical features? Because the physical characteristics near pipelines can vary dramatically, PHMSA Pipeline Safety does not believe that any single set of assumptions would be applicable in all cases. For example, waterways may be broad, slow-moving rivers or fast-moving mountain streams. Topography near a pipeline can vary between a flat prairie and steep gullies. Ground cover can also affect the speed of product transport. Operators are responsible for considering the specific circumstances of their pipeline in the vicinity of high consequence areas and determining the analytical assumptions that are appropriate. Operators are expected to consider the effect of extreme conditions (e.g., floods), and to use recognized sources for data regarding stream flow rates, etc. Operators should assure their analyses are reasonably conservative. PHMSA Pipeline Safety may review the technical basis for these assumptions during integrity management inspections. Last Revision: 2/18/03 3.21 Why is it important that operators know the specific characteristics of high consequence areas their pipelines can affect? Operators need to know the characteristics of HCAs that their pipeline can affect to make decisions required by the integrity management rule. For example, the type of HCA can affect the consequences of a leak or rupture, and thus affect the relative risk ranking of a segment. The type of HCA, or even the <<>> specific ecological resource involved in a USA, could affect decisions regarding preventive and mitigative measures. Last Revision: 10/12/02 3.22 The National Pipeline Mapping System (NPMS) does not contain maps for ecological USAs in Pennsylvania. Are operators responsible for identifying USAs in Pennsylvania? Yes. Operators are responsible for having identified all pipeline segments that could impact HCAs in all states in which they operate, regardless of whether all of the HCAs have been mapped on NPMS. In those situations where USA maps are not available on NPMS, operators may use ecological and drinking water information used to prepare and maintain their spill response plans, as well as other resources from local and state agencies available to them to identify these USAs. Last Revision:12/16/05 3.23 Must concentrations of an operator’s own personnel, e.g., a work camp, be considered high consequence areas? Yes. The integrity management rule states that “other populated areas” are included in the definition of high consequence areas. “Other populated areas” are defined in §195.450 as “a place, as defined and delineated by the Census Bureau, that contains a concentrated population, such as an incorporated or unincorporated city, town, village, or other designated residential or commercial areas.” If the Census Bureau delineates work camps or other areas containing concentrations of an operator’s personnel as a Census Designated Place (treated as “other populated areas” in the HCA definition), they are clearly covered under the rule. Section 192.452(d)(3)(i) also requires that “When information is available from the information analysis…or from Census Bureau maps, that the population density around a pipeline segment has changed so as to fall within the definition in §195.450 of a … other populated area, the operator must incorporate the area into its baseline assessment plan as a high consequence area….” Thus, operators who are aware that work camps or other concentrations of their employees would meet the definition of other populated areas must also treat them as high consequence areas, regardless of whether they are listed on Census Bureau or NPMS maps. Last Revision: 9/21/04 3.24 Can operators exclude pipeline from consideration under the integrity management rule on the basis that any effect it could have on a high consequence area is small? No. Section 195.452(a) specifies that the rule applies to “…each hazardous liquid and liquid carbon dioxide pipeline that could affect a high consequence area….” The rule does not provide for excluding any pipeline based on the magnitude of the potential effect. Any pipeline segment that could affect a high consequence area is subject to the rule. Last Revision: 9/21/04 3.25 Must I assume that a leak from a propane pipeline can affect drinking water USAs? No. Operators can assume that propane is not soluble and will not affect drinking water supplies. Last Revision: 9/21/04 3.26 What HVLs should be assumed to affect drinking water? <<>> The effect of HVLs on potential could affect an HCA segment can be found in Report TTO1, "Consequences of HVL Releases," dated December 31, 2002. The report is on the PHMSA public website at https://www.phmsa.dot.gov/pipeline/hazardous-liquid-integrity-management/hl-im-key- documents. Last Revision: 5/10/12 BASELINE ASSESSMENT PLANS 4.1 What is an assessment? As used in the rule, assessment constitutes all of the actions that must be performed to determine the condition of the pipe. This includes conducting one or more internal inspections (e.g., metal loss plus geometry tools), performing hydrostatic tests or external corrosion direct assessment, or using other technology that provides an equivalent understanding of the condition of the line. Any anomalies identified by the assessment that meet criteria in §195.452(h) must be remediated in accordance with the schedules in that paragraph, but these remedial activities are not considered part of the assessment. The interval in which a pipe segment must be re-assessed is considered to start with the end of field activities of an assessment. For ECDA, this corresponds to the date when the last direct examination is made. Last Revision: 12/16/05 4.2 What must be in the Baseline Assessment Plan? The Baseline Assessment Plan must include a written plan for performing the baseline assessments necessary to assure pipeline integrity for each pipeline segment that could affect an HCA. It must include: • Identification of all the pipeline segments that can affect an HCA • The integrity assessment method, or methods, planned for use on each identified pipeline segment • A schedule for assessment of each identified segment • An explanation of the technical basis for the integrity assessment method(s) selected and the risk factors used in scheduling the assessments. Last Revision: 2/18/03 4.3 Under what conditions should the Baseline Assessment Plan be modified? The Baseline Assessment Plan must be modified whenever there are changes to the pipeline segments that can affect HCAs. For example, if an operator identifies a new HCA through the monitoring its right-of- way or through information analysis [as required by §195.452 (d) (3)] and determines that portions of its pipeline can affect this HCA, this newly identified pipeline segment must be included in the Plan. Pipeline that can affect newly-identified HCAs must be included in the Baseline Assessment Plan within one year after their identification. These pipeline segments must be assessed within five years of their identification. The Baseline Assessment Plan should also be modified if the operator gains knowledge from the initial (baseline) assessments that leads to a change in inspection priorities, assessment methods, or other improvements to its program. The operator must document Plan modifications and the reason(s) for the changes. This documentation must be available for PHMSA Pipeline Safety review during an inspection. <<>> Last Revision: 2/18/03 4.4 When must baseline assessments be completed? (Deleted. Applicable time frames for completing baseline assessments have passed.) Last Revision: 7/2/15 4.5 How do the required dates for completing 50 percent and 100 percent of assessments apply to a category 2 pipeline that is acquired by an operator that had more than 500 miles of pipeline on May 29, 2001? (Deleted. Applicable time frames for completing baseline assessments of Category 2 pipelines have passed.) Last Revision: 7/2/15 4.6 Can assessments performed before the effective date of the rule be relied on as baseline assessments? (Deleted. The timeframe for use of prior assessments has passed.) Last Revision: 5/10/12 4.7 What must an operator consider in prioritizing pipe segments for assessment and re- assessment? The risk posed by each pipeline segment covered by this rule must be considered in scheduling baseline assessments and periodic re-assessments. In scheduling assessments, an operator must consider all risk factors relevant to that pipeline segment. The rule requires that the following factors be included: • results of the previous integrity assessment, defect type and size that the assessment method can detect, and defect growth rate; • pipe size, material, manufacturing information, coating type and condition, and seam type; • leak history, repair history, and cathodic protection history; • product transported; operating stress level; • existing or projected activities in the area; • local environmental factors that could affect the pipeline (e.g., corrosivity of soil, subsidence, climatic); • transport to HCAs through storm sewers, water crossings, indirect transport through streams, ditches and water bodies; • roadway and railroad crossings; • geo-technical hazards; and • physical support of the segment such as by a cable suspension bridge. Additional factors relevant to particular pipelines should also be included. Examples are provided in Part 195 Appendix C of the rule. Last Revision: 10/22/01 4.8 The rule does not require the Baseline Assessment Plan to be developed until March 31, 2002; however, integrity assessments performed since January 1, 1996 can be used to satisfy the baseline integrity assessment requirement. Will operators be penalized for using prior assessments as a baseline assessment if their risk anal - **truncated:** true - **body characters:** 155342