April 2011 Issue

In This Issue

DOT Pipeline Compliance Workshop – May 10-12, 2011

Join us May 10 – 12 in Houston at our new office and dedicated training facility for an informative, lively, and interactive workshop on DOT Pipeline Compliance and OPA Planning for DOT Pipelines. This workshop has been attended by hundreds of pipeline personnel, with excellent feedback. The workshop provides an overview of the DOT pipeline regulations, and is appropriate for people who are new to pipeline regulations, who could use a refresher, or anyone who needs to know the latest information in these areas.

PROGRAM SCHEDULE:

Day 1 (May 10): Gas Pipeline Regulations (49CFR192)
The workshop will include an introduction to DOT/OPS pipeline compliance; State and Federal program variations; roles and responsibilities; design, construction, operations, maintenance, and emergency response requirements; how to monitor rulemaking activity and stay current with your compliance program; operator qualification, public awareness; with a specific emphasis on the gas integrity management regulations. Each attendee will receive general training materials which include the applicable DOT 49 CFR 192 regulations for gas pipelines (cd-rom), inspection checklists, and speaker’s PowerPoint presentation handouts.

Day 2 (May 11): Special Topics
Back by popular demand! RCP is conducting a special workshop day to discuss topics that many of our clients have expressed an interest in. The workshop topics will include: Control Room Management, Public Awareness Program Effectiveness Evaluations, and Revised Reporting Requirements.

Day 3 (May 12): Liquid Pipeline Regulations (49CFR195)
The workshop will include an introduction to DOT/OPS pipeline compliance; State and Federal program variations, roles and responsibilities; design, construction, operations, maintenance, and emergency response requirements; spill response planning requirements; how to monitor rulemaking activity and stay current with your compliance program; operator qualification and public awareness. Each attendee will receive general training materials which include the applicable DOT 49 CFR 195 regulations for hazardous liquid pipelines (cd-rom), inspection checklists, and speaker’s PowerPoint presentation handouts.

To register, or for additional information, click here.

PHMSA Updates DIMP FAQ’s

The following Distribution Integrity Management Frequently Asked Questions were updated or added on March 10, 2011.

C.3.8 What do operators need to have implemented by August 2, 2011?

By August 2, 2011, operators of gas distribution systems (other than a master meter or small LPG operator) must have developed and implemented an integrity management program that includes a written integrity management plan. The plan must include the operator’s procedures used to develop the seven elements listed in § 192.1007(a)-(g) At a minimum, an operator must have taken the following actions:

Developed and demonstrated an understanding of their system;
Identified and considered threats to each gas distribution facility
Completed a risk evaluation and ranking of their distribution system;
Developed criteria for deciding when risks require measures to reduce them;
Determined the measures to reduce risk;
Begun implementing the measures to reduce risk or have a plan to implement measures to reduce risk which includes an implementation schedule;
Assessed the effectiveness of their leak management program and taken steps, if necessary, to correct deficiencies;
Established a baseline measurement for each performance measure required by 192.1007(e)(1)(i)-(v);
Developed performance measures to evaluate the effectiveness of measures to reduce risk, have a plan to collect the performance measure data, and begun collecting data to establish a baseline measurement;
Determined the appropriate period for conducting DIMP program evaluations;
Reported performance measures required by 192.1007(g) for calendar year 2010;
Collected data as needed for mechanical fitting failures resulting in hazardous leaks beginning January 1, 2011; and
Identified records requiring retention and have maintained them.

C.4.a.5 What comprises “reasonably available” information?

PHMSA does not intend that operators expend excessive effort, review every record available in their archives, or explore every nuance about their pipelines. At the same time, PHMSA expects that operators will devote sufficient effort to develop as thorough an understanding of their pipelines as they can while using reasonable effort.

The availability of records will vary among operators. Some operators may retain records for many years and others only for the length of time required by Part 192. Some data is stored electronically and some is paper based. Additionally, some records are stored on-site and other records may be stored off-site, such as at regional offices or long term storage facilities. Any record which the operator can access is reasonably available. All records required by Parts 191 and 192 are reasonably available. Operators need to review all records that are relevant to the current condition of the pipe or have a significant impact on the integrity of the pipe. For example, a steel pipe may have been brought under adequate cathodic protection five years ago but was not under cathodic protection in prior years. Any records showing that the pipe was not under cathodic protection, is relevant to the current condition of the pipe.

Operators must identify additional information that is needed to fill gaps due to missing, inaccurate, or incomplete records and develop a plan to collect it. They may collect this information through their normal activities including those that go beyond those activities specified in Part 192. For example, missing facility location, material and condition data can be gained when the pipe is located and/or exposed.

Operators could involve maintenance personnel in their information collection activities, surveying them about unusual circumstances they have encountered in their activities and/or asking them to review resulting system descriptions and identify any information they believe is useful that is not already included.

C.4.a.6 Must an operator’s plan include the sources used to demonstrate an understanding of its gas distribution system?

An operator needs to be able to demonstrate to regulators that they have an understanding of their gas distribution system developed using sources of information that are “reasonably available”. The plan should identify the information sources. Examples of sources that are reasonably available include documents, records, field notes, maps, historical procedures and design standards, bill of materials, procurement records and specifications, and information obtained from subject matter experts. These sources are used to identify the characteristics of the pipeline’s design, operations and environmental factors that are necessary to assess the applicable threats and risks to the distribution system. Operators also need to consider information gained from past design, operations, and maintenance. In order to verify that an operator has met this requirement, the inspector may ask the operator for information about the sources such as: the name of the documents, the time period covered by the documents, the document’s location and format (e.g. electronic, paper, or subject matter expert interview, etc.), the forms used to collect data, the fields on the forms, the instructions used to complete the forms, and a history of how this information collection changed over time.

C.4.b.3 The DIMP requirements include knowing the condition of facilities that are at risk for potential damage from external sources. Cross bores of gas lines in sewers have been reported at 2-3 per mile in high risk areas – predominately where trenchless installation methods were used for gas line installs and where sewers and gas lines are in the proximity of each other. Does the potential for cross bore of sewers resulting in gas lines intersecting with sewers need to be determined?

Yes, the threat of excavation damage includes consideration of potential or existing cross bore of sewers which have resulted in gas lines intersecting with sewers. Pursuant to § 192.1007(a)(2), the operator must consider information gained from past design, operations, and maintenance. If operators used trenchless technologies without taking measures to locate sewer laterals and other unmarked facilities during construction, there may be a risk that their facilities were installed through the foreign facility. If this excavation damage threat applies to the operator, they must evaluate its risk to their system. Depending on the results of the risk evaluation, they may need to identify and implement measures to reduce this risk to existing and future facilities.

C.5.4 Since there is a new form for mechanical fitting failures which result in a hazardous leak, do these failures still need to be reported under Part C of the Annual Report?

Yes, operators need to include all mechanical fitting failures which result in hazardous leaks eliminated or repaired as part of the total leaks reported on the Annual Report in Part C – TOTAL LEAKS AND HAZARDOUS LEAKS ELIMINATED/REPAIRED DURING YEAR. Additionally, they must report detailed information about each mechanical fitting failure which results in a hazardous leak on a separate Gas Distribution Mechanical Fitting Failure Form (PHMSA F–7100.1–2).

PHMSA created the new Mechanical Fitting Failure Report form [PHMSA F 7100.1-2] to address the new annual reporting requirement established by DIMP for hazardous leaks on mechanical fittings. Operators may submit data at anytime and at any frequency throughout the year (preferred), or they may submit all mechanical fitting failure reports in one submission. Regardless of the method they select, the reports must be submitted by March 15, 2012 for failures which occurred in calendar year 2011. If an operator does not experience any mechanical fitting failure which results in hazardous leaks, they do not need to submit a Mechanical Fitting Failure Report form. The online system for the new Mechanical Fitting Failure Report form [PHMSA F 7100.1-2] is now in operation.

NOTE: Online submission via PHMSA Portal is required unless an alternative reporting method is granted by PHMSA. More information is available at PHMSA’s, Office of Pipeline Safety web site, Pipeline Safety Community, located at http://www.phmsa.dot.gov/pipeline and click the “Online Data Entry” hyperlink listed in the first column.

C.8.3 What do master meter and small LPG operators need to have implemented by August 2, 2011?

By August 2, 2011, master meter operators and small LPG operators must have developed and implemented a written integrity management program that includes a written integrity management plan. The plan must include the operator’s procedures used to develop the elements listed in §192.1015(b)-(c). At a minimum, these operators must have taken the following actions:

Developed and demonstrated an understanding of their system;
Identified and considered threats to each gas distribution facility;
Completed a relative risk ranking of each identified threat to the distribution system;
Developed criteria for deciding when risks require measures to reduce them;
Determined the measures to reduce risk;
Begun implementing the measures to reduce risk or have a plan to implement measures to reduce risk which includes an implementation schedule;
Are monitoring the number of leaks eliminated or repaired on its pipeline and their causes.
Determined the appropriate period for conducting DIMP program evaluations; and
Identified records requiring retention and have maintained them.

Control Room Management – Deadline Modifications

On September 17, 2010, PHMSA published a Control Room Management/Human Factors notice of proposed rulemaking (NPRM) proposing to expedite the program implementation deadlines to August 1, 2011, for most of the requirements, except for certain provisions regarding adequate information and alarm management, which would have a program implementation deadline of August 1, 2012. That proposed rulemaking is still pending, leaving operators uncertain about which deadlines they must meet. On Thursday, March 24, the PHMSA technical advisory committees for both liquid and gas pipelines voted unanimously to support an accelerated schedule that requires plans to be completed August 1, 2011, while fatigue management and training will be implemented by August 1, 2012. PHMSA is expected to move expeditiously to finalize the rulemaking using those deadlines.

Control Room Management Services

RCP is able to provide pipeline operators with fully compliant, customized Control Room Management Programs that take advantage of any existing processes that are currently in place and develop new processes that are tailored to your organization’s ability to successfully implement.

RCP also has the expertise to conduct readiness assessments as well as compliance analysis of your existing Control Room Management programs. This independent analysis will take into consideration what others within the industry are doing as a benchmark as well as what the final regulations require.

For more information on how RCP can help with your Control Room Management Program, contact Jessica Roger.

Transmission Annual Report Deadlines

During a recent webinar on how to complete the revised annual report for gas transmission pipelines, PHMSA announced the deadline to submit this year’s gas transmission annual report has been moved back to August 15th. Annual reports for 2012 and beyond will revert to the March 15 deadline. PHMSA will be providing some additional webinars on the new online reporting form for gas transmission. Operators can register for these sessions here. The sessions are scheduled for:

June 21, 2011 from 1:00 – 2:30 pm ET for intrastate operators
June 22, 2011 from 1:00 – 2:30 pm ET for interstate operators
June 23, 2011 from 1:00 – 2:30 pm ET for interstate and intrastate operators

PHMSA Pipeline Safety Executive Forum April 18 – Washington, DC

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (DOT/PHMSA) is hosting a half-day Forum to bring together safety experts, researchers, industry representatives, State partners, other Federal agency officials as well as members of the public to share their expertise, experiences, research, and ideas regarding the status of the nation’s pipeline infrastructure and to address pipeline safety concerns that have arisen following recent pipeline incidents. The forum’s goal is to accelerate the “rehabilitation, repair, and replacement of critical pipeline infrastructure with known integrity risks.” This includes bare steel, cast iron, copper, PE or plastic pipe; pipelines with unknown or uncertain material specifications or longitudinal seams; and pipelines with questionable and unconfirmed integrity.

Space at this event will be limited, and attendance could easily exceed the meeting room capacity. Industry associations are coordinating participation in order to ensure attendance to the most pertinent representatives. We recommend that industry representatives, contractors, and consultants only register if they have been asked to do so by PHMSA or on behalf of an industry association. For more information on this Forum, contact: pipelineforum@dot.gov or click here to register.

API Pipeline Conference April 12 – 13

The 62nd annual API Pipeline Conference is being held April 12th and 13th at the Hyatt Regency Hill Country in San Antonio, Texas. The API Pipeline Environmental and Safety Awards will be presented during the luncheon on Wednesday, April 13th. For the Conference program, advance registration, and hotel information click here.

For award program and application information, please go to this API website and scroll down to “API Environmental and Safety Award Program.”

RCP will be there. How about you?

AGA Ops Conference & Biennial Exhibit May 24 -27 at the Gaylord Opryland in Nashville, TN

The annual AGA Operations Conference is the natural gas industry’s premier gathering of natural gas utility and transmission company operations management from across North America and the world for the sharing of technical knowledge, ideas and practices to promote the safe, reliable, and cost-effective delivery of natural gas to the end-user. RCP invites you to visit us at Booth # 1018. Also plan to attend a presentation by RCP’s President entitled MAOP Process Management on May 26th from 2:35-3:05pm. We hope to see you there!

Public Awareness Effectiveness Program Inspections

In October, 2009, the NTSB issued a Safety Recommendation that PHMSA initiate a program to evaluate pipeline operators’ public education programs, including pipeline operators’ self-evaluations of the effectiveness of their public education programs. Since then, PHMSA organized an ad hoc team which developed inspection forms and guidance information regarding these inspections, which are scheduled to begin soon.

These two-day public awareness effectiveness inspections will take a close look at the administration and development of operator public awareness programs; program implementation; and the program evaluation process ( including annual audits and effectiveness evaluations). RCP can help you prepare for these inspections. For more information, contact Jessica Roger.

Common Ground Alliance Publishes Best Practices Version 8.0

The Common Ground Alliance has published Version 8.0 in field manual form. The entire book is also available to download (PDF) here. The new practices and modifications incorporated into the latest version include:

Practice 4-21, “Service Connection,” was added to chapter 4.
Practice 5-23 was updated to include a second paragraph within the Practice Statement that emphasizes generating the “minimum number of locate request updates necessary for the duration of the project.”
Practice 5-32, “Vacuum Excavation,” was added to chapter 5. A new definition for Vacuum Excavation was included within the Glossary.
Practice 6-16 was modified to include use of digital imagery as a method of identifying facility locations.
Appendix B, “Marking Guidelines,” was modified to include additional clarification on Tolerance Zone on page 79 and a modification to item 2a within the “Guideline for Operator’s Facility Field Delineation.”

National Safe Digging Month

April 2011 will once again be National Safe Digging Month (NSDM), the time of year when all Common Ground Alliance (CGA) stakeholders come together to communicate how important it is that professionals and homeowners alike call 811 and follow the safe digging process to help prevent injuries, property damage and inconvenient outages.

To assist damage prevention stakeholders in the promoting NSDM, the CGA has created a full suite of tools. For more information on how you can participate, see the call811 website.

PHMSA Technology Transfer Workshop June 23 – Columbus, OH

The PHMSA R&D Program is pleased to announce the up-coming Free R&D Technology Transfer Workshop: Matrix Phased-Array (MPA) Ultrasonic Testing for Pipeline Inspection. The purpose of this PHMSA funded workshop is to transfer MPA knowledge to the U.S. pipeline industry. During the recent NTSB hearing on the San Bruno, California incident this technology was one of the promising technologies described by the PHMSA Pipeline Safety R&D Program capable of finding and sizing similar defects.

The Workshop is scheduled by EWI for June 23, 2011 in Columbus, OH. It is designed to transfer the knowledge gained and technology developed at EWI under a PHMSA Pipeline Safety R&D funded Project. The research project is titled “Enhanced Defect Detection and Sizing Accuracy Using Matrix Phased Array Ultrasonics Tools.” Additional information on the research Project is available here.

Attendance is limited to the first 40 registrations. Deadline for registration is June 17, 2011. For more information contact Debra Knight with EWI or click here to register on-line.

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

Contact

Recent Newsletters

Subscribe to our DOT Pipeline Compliance Newsletter