DOW HYDROCARBONS AND RESOURCES LLC — Integrity Assurance Notification

ALTERNATIVE PIPE SAMPLINGThe OpIDs that are included in this notification: 3527, 18156, 3535, 19892, 31307, 19890, 3532 Pursuant to 49 CFR 192.18, Dow is submitting this notification with intent to use ILI for the purposes of measuring material properties and attributes, and delineating populations as described in the attached procedure ‘PIM 1.58 Measuring Material Properties and Attributes Using ILI’ [1]. Dow is using ILI to delineate populations as permitted in FAQ 21 [2] and ILI to measure material properties and attributes as permitted in FAQ 22 [2]. Dow intends to use this approach as part of its §192.607 process described in ‘PIM-1.01a Verification of Pipeline Materials and Attributes’ [3]. Additionally, when verifying pipeline material properties and attributes in accordance with §192.607(e)(5), Dow will use the alternative sampling procedures detailed in ‘PIM 1.59 Alternative Sampling Method for Measuring Material Properties & Attributes’ [4]. This request is to apply the use of ILI for delineating populations and applying alternative sampling approaches for the pipelines that are located in Texas and Louisiana under the OpIDs listed above. The status of material property verification will be documented in a separate Material Property Verification (MPV) report for each line segment. The procedures and alternative sampling approaches detailed above are the same methods that were submitted by Dow for the 8” UCAR and 6” UCAR pipeline segments in the 192.18 submissions numbered 23-265820 and [23-277538], respectively. Both of these previous submissions received no objections from PHMSA.#