DOT Pipeline Compliance News

May 2017 Issue

In This Issue

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PHMSA Inflation Adjustment of Maximum Civil Penalties

[Docket No. PHMSA-2016-0010; Amdt. No. 190-17]

The Pipeline and Hazardous Materials Safety Administration (PHMSA) is revising references in its regulations to the maximum civil penalties for violations of Federal pipeline safety laws, or any PHMSA regulations or orders issued thereunder. Under the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015, which further amended the Federal Civil Penalties Inflation Adjustment Act of 1990, Federal agencies are required to adjust their civil monetary penalties effective January 15, 2017, and annually thereafter, to account for changes in inflation.

The revised penalties are as follows: From $205,638 to $209,002 for each violation for each day the violation continues, with a maximum penalty not to exceed $2,090,022 for a related series of violations. And from $75,123 to $76,352 for an administrative civil penalty, which may be in addition to other penalties assessed under 49 USC 60101, et seq.

The effective date of this final rule is April 27, 2017. For a copy of this inflation adjustment notice, contact Jessica Foley .

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Texas Liquids Pipeline Regulation Change

The Texas Railroad Commission has published revisions to Title 16, Part 01 / 008; Subchapter 8D – Requirements for Hazardous Liquids and Carbon Dioxide Pipelines Only. The revisions include:

• Changing the e-mail address from Safety@rrc.state.tx.us to safety@rrc.texas.gov.
• Minor revisions to the Public Education and Liaison section 8.310 regarding annual liaison requirements with fire, police, and other appropriate public emergency response officials. The prior rule required the operator to attempt a face to face meeting, and if that could not be arranged to attempt a conference call, and if that could not be arranged, then mail the information. The revised rule requires the operator to attempt a face to face meeting, and if that cannot be arranged the operator can either set up a conference call or just mail the information.

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Underground Gas Storage Compliance

How does RCP deliver a comprehensive solution for natural gas storage operational integrity assurance?

Experienced Resources

• Highly respected underground storage & risk management SME’s (the past Chair of PRCI’s and AGA’s underground storage committees is on our staff)
• Professional engineering support
• Written program development / improvement from knowledgeable technical standards developers (Our lead technical writer was the editor for the API RP1170 development team.)

State-Of-The-Art Tools (TaskOp™)

• Program gap assessment and corrective action tracking
• Storage risk assessment
• Integrity assessment and remediation process tracking

For more information regarding our capabilities or to request an online demonstration of our TaskOp™ underground gas storage solution, visit our website or contact Jessica Foley.

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NEB Safety Advisory on Pipeline Fitting Materials Quality Assurance

On April 12, 2017, the National Energy Board (NEB) of Canada issued a Safety Advisory NEB SA 2016-01A – Pipeline Fitting Materials Quality Assurance. It states, in part:

“The National Energy Board (NEB or the Board) is aware of instances of pipe and components not meeting material specifications on pipelines under NEB or other regulatory bodies’ jurisdiction. In the cases examined, documentation from the manufacturers indicated that the materials met the required specifications when received by companies. Subsequent testing indicated that some of the pipe and fittings did not meet all of the required material specifications. In some instances, the materials were determined to have been a contributing factor to pipeline failure during pressure testing. Although the cases described below appear to have been isolated, the Board has subsequently identified additional cases on pipelines in Canada and the United States (US). The issue of substandard pipe and fittings entering the market place, and subsequently being installed on pipeline systems, is an industry wide concern, which must be addressed through improved quality assurance (QA) practices.”

The advisory notes that relevant industry standards may not address these issues comprehensively, and states “the Board expects pipeline operators to develop or enhance their own fitting specifications beyond the current standards, to ensure that the fittings they acquire and install meet material property requirements.” It reminds operators that “companies must have QA programs in place to ensure that the pipe and components meet the specifications developed by the company”, and “In this case, reviewing MTRs, without independent onsite verification, may not provide sufficient protection against the introduction of components that do not meet specifications. Companies are also expected to exert greater oversight in the manufacturing process directly and/or indirectly through third party QA”.

This is an amendment to NEB SA 2016-01 on the same topic. In the United States, PHMSA has noted the same problem in their advisory bulletin ADB-09-01.

The Safety Advisory on Pipeline Fitting Materials Quality Assurance can be found on the NEB website.

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EPA Soliciting Recommendations on Regulations that could be Repealed, Replaced or Modified to make them Less Burdensome

On February 24, 2017, President Donald Trump issued Executive Order 13777 on “Enforcing the Regulatory Reform Agenda.” The order establishes the policy of the United States to alleviate unnecessary regulatory burdens placed on the American people. Among other things, it requires each agency to create a Regulatory Reform Task Force to evaluate existing regulations and to identify regulations that could be repealed, replaced or modified to make them less burdensome.

As part of implementing the order, EPA is soliciting public comments and engaging in additional outreach to identify such regulations. The EPA is accepting comments through May 15, 2017 at Docket EPA-HQ-OA-2017-0190. Additional information, including how to submit comments, can be found on the EPA’s Laws & Regulations website.

In addition, EPA’s Office of Land and Emergency Management (OLEM), will host a public meeting to obtain additional stakeholder feedback on Tuesday, May 9, 2017, from 9:00am to 5:00pm EDT in Arlington, Virginia. The intent of the meeting is to provide an opportunity for interested parties to present recommendations specific to OLEM’s regulations. Click here on how to submit comments and participate in or listen to the OLEM public meeting. More information on OLEM programs can be found on the OLEM website . Please direct questions to EPA.OLEM.RegulatoryReform@epa.gov.

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Fundamentals of Pipeline Operations Workshop

May 17 – 18, 2017

Join us May 17-18, 2017 in Houston at our corporate office and dedicated training facility for this new workshop on the fundamentals of pipeline operations. This 2-day course is designed to give a comprehensive overview of gas and liquid energy transmission pipelines and how they are operated and maintained. It is appropriate for both technical and non-technical personnel who are new to the energy transmission pipeline industry, as well as those who need a broader understanding of pipeline operations and management in general. The course walks through the practical things that a typical pipeline company’s operations organization does on a regular basis to operate and maintain the pipeline system as a whole. Course topics include:

• Components of a pipeline system (types of pipe, coatings, tanks, valves, pumps, compressors, pressure vessels, pig traps, meters, instrumentation, control systems / SCADA)
• Operations activities (starting / stopping, batching, managing receipts and deliveries, measurement, monitoring, pressure control, leak detection)
• Inspection and Maintenance (valves, ROWs, tanks, pumps, compressors, instrumentation, pigging, cathodic protection)
• Repair (in-service repair techniques, welding, OOS repairs / replacements)
• Integrity Management (ILI, Pressure Tests, Direct Assessment), including assessment processes, analysis, follow-ups
• Emergency Response (planning, organization / ICS, drills, response)
• Public Awareness / Damage Prevention / One Calls

Each attendee will receive the presentation as well as applicable handouts in a hardcopy notebook.

The course involves many hands-on demonstrations and examples using RCP’s in-house Pipeline Flow Loop*. To promote an optimal learning environment, class size will be limited. To register for our workshop, click here .

*RCP’s in-house Pipeline Flow Loop is an engineering marvel (!). It is a working 2” diameter pipeline system incorporating many of the components of a transmission pipeline system including state-of-the-art SCADA control system and instrumentation for flow, pressure, temperature, and volume, as well as automated valves, pig traps, variable speed pump, and more. It also incorporates clear pipe segments so that students can see a pig in operation, see phase separation as it occurs, and understand the importance of elevation change. It occupies 2 walls outside our training room. Students can monitor and control the pipeline from the training room (“control room”), and then step into the hall to see the pipeline in action.

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Reminder – Registration by May 19 for Public Awareness Study (PAPERS)

Operators are encouraged to register by May 19 for participation in the 2017 Public Awareness Program Effectiveness Research Study (PAPERS). PAPERS is a national public awareness effectiveness survey developed and sponsored by API, AOPL and INGAA to assist pipeline operators in meeting the regulatory requirements for effectiveness measurement and evaluation of public awareness programs. The 2017 survey will begin data collection in July. More information on the 2017 PAPERS program, including a registration form, is available online at http://www.papers-program.com/ , and also by contacting Crystal Harrod, API, at 202-682-8492 or harrod@api.org or Karen Simon, API, at 202-682-8224 or simonk@api.org.

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Summer 2017 Pipeline Conference Schedule

Have you registered and confirmed your reservations for these upcoming conferences? RCP will be attending the following conferences. We hope to see you there!

ILTA’s 2017 International Operating Conference & Trade Show
June 12-14, 2017
George R. Brown Convention Center in Houston, Texas

The International Liquid Terminals Association (ILTA) annual international operating conference and trade show offers unparalleled opportunities for terminal professionals. It brings together more than 4,000 people from across the U.S. and around the world to learn, network, and share best practices. The conference features in-depth presentations by industry experts who provide insight on effective solutions for improving terminal operations. The trade show offers the latest in products, services and technologies that terminals need to stay competitive.

Make plans to attend and visit RCP’s Booth #481 to learn how TaskOp™ can keep your terminal on track. TaskOp is a web-based, modular system, capable of handling implementations from basic work orders through complex, asset-driven compliance and training management solutions.

LGA Pipeline Safety Conference
July 10-14, 2017
Astor Crowne Plaza / New Orleans, LA

RCP is once again a proud sponsor and exhibitor at this year’s conference, which has been referred to as the “Premier Pipeline Safety Conference.” We are excited to showcase our newest development (TestOp Plus) and all our services for Pressure Test support. Laissez les bons temps rouler! (Let the good times roll!)

SGA Operating Conference & Exhibits
July 17-19, 2017
Hilton Downtown Atlanta

The Operating Conference format is focused round table discussion. Attendees learn smart practices and lessons learned from their peers with 22 concurrent facilitated sessions to choose from. Make plans to visit the exhibit hall showcasing the latest products and services available to the industry.

Western Regional Gas Conference (WRGC)
August 29-30, 2017
Hyatt Regency Mission Bay in San Diego, CA

Who should attend? Regulatory and Code Compliance personnel, Gas Engineers, Pipeline Construction Supervisors, Technical and Standards Engineers/writers, Customer Service Supervisors, Measurement and Control personnel, Damage Prevention personnel, Integrity Management managers, Gas Control supervisors, operations and engineering personnel.

RCP’s Subject Matter Expert will be giving a presentation on Underground Storage: Developing a Comprehensive Underground Storage Integrity Management Plan, on Tuesday, August 29th, from 1:30 -2:15 pm. Click here for the preliminary conference agenda.

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Pressure Testing Webinar – Advantages of Using TestOp®

RCP will be hosting webinar presentations to discuss pipeline pressure testing practices and demonstrate the advantages of utilizing new technology for planning, designing, and capturing real-time data to validate and document whether it was a successful test. The same technology that RCP has used for the past six years to validate our customer’s pressure tests has been greatly enhanced and is now being made available as a web-hosted solution for operators to use themselves.

TestOp® takes the confusion out of pressure testing by providing real-time determination of whether the test segment is experiencing potential issues, such as yielding or air entrapment volume absorption, all while modeling the mass balance relationship of pressures, volumes and temperatures of the test. TestOp® will provide real-time indicators and corresponding data to confirm whether the test is successfully performing to plan or if there might be a small pin-hole leak that would otherwise go undetected before taking the line segment off test. TestOp® generates comprehensive and consistent reports, including a certification letter, pressure test plan versus actual test results, pressure/spike test log, test instrument and pump calibrations, pipe volume calculations sheet, stress/strain and pressure/volume plots as well as upload capability for pictures and other document scans associated with the test.

We encourage any liquid or gas pipeline operator who has upcoming projects that involve replacement, integrity verification, new construction, uprates, conversions and/or reversals to sign up for the 45 minute webinar. Some of the largest and most respected pipeline operators are now using TestOp® because they see the value it brings to their overall pipeline integrity assurance program and we are confident you will too once you have seen it in person.

Mark your calendar and plan to attend one of these sessions or request an individual demonstration for your company at a date convenient to you.

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We would welcome the opportunity to discuss our services with you.

Best regards,

W. R. (Bill) Byrd, PE
President
RCP Inc.