DOT Pipeline Compliance News

August 2007 Issue

In This Issue

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DOT Pipeline Compliance Workshop – September 25 & 26

RCP will be hosting our very popular workshop on DOT Pipeline Compliance on September 25 and 26 in Houston, TX. Join us for an informative, lively, and interactive workshop on DOT Pipeline Compliance. 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, or who could use a refresher.

Day 1: Gas Pipeline Regulations (49CFR192)
Day 2: Liquid Pipeline Regulations (49CFR195)

Each day of the workshop will address the following issues as they specifically relate to either Gas or Hazardous Liquid pipelines:

• PHMSA Overview
• PHMSA Jurisdictional Boundaries
• Compliance Requirements:
  • Design
  • Construction
  • Operation
  • Maintenance
  • Corrosion
  • Testing
  • Integrity Management
  • Operator Qualification
  • Emergency Response
  • Reporting
• New/Proposed Regulations

For additional information, including a seminar brochure, go to our website here.

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PHMSA Associate Administrator Announcement

Our warmest congratulations go to Jeff Wiese, who was recently selected as PHMSA’s Associate Administrator for Pipeline Safety. Mr. Wiese has been the acting Associate Administrator since January 2007 and served as Acting Deputy Associate Administrator from August to December 2006. During this time he led the implementation of the newly enacted Pipeline, Inspection, Protection, Safety and Enforcement (PIPES) Act of 2006.

Mr. Wiese was Director for Program Development within the Office of Pipeline Safety for nearly 10 years. In that role he directed the design, development, and deployment of Integrity Management oversight and improved pipeline public awareness programs. Jeff was instrumental in building the Common Ground Alliance for preventing underground utility damage. Prior to joining DOT, Jeff worked for 15 years in the offshore oil and gas program of the Minerals Management Service (MMS). Over the course of his MMS career, Jeff directed several programs, including the offshore safety management program, and served for 5 years as Chief of Staff for Offshore Operations.

Mr. Wiese has an M.A. from the University of Rhode Island with interdisciplinary focus on science, policy, and economics and a B.S. in General Science from Grinnell College.

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PHMSA Issues Final Rule on Integrity Management Program Modifications and Clarifications (49 CFR Parts 192 & 195)

The Department of Transportation, Pipeline and Hazardous Materials Safety Administration (DOT / PHMSA) issued a final rule modifying the integrity management regulations for hazardous liquid and natural gas transmission pipelines. The modifications include.

• Adding an eight-month window to the period for reassessing hazardous liquid pipelines;
• Modifying notification requirements for operators of hazardous liquid and natural gas pipelines;
• Repealing a requirement for gas operators to notify local authorities;
• Allowing alternatives in calculating pressure reduction when making an immediate repair on a hazardous liquid pipeline.

The Final Rule is effective August 16, 2007.

This action is intended to improve pipeline safety by clarifying the integrity management regulations and providing operators with increased flexibility in implementing their integrity management programs (IMP). The affected sections include:

49 CFR Part 192– Transportation of Natural & Other Gas by Pipeline
§192.933 What actions must an operator take to address integrity issues?

Notification Requirements of Pressure Reduction: PHMSA has clarified that the notification requirements apply to certain pressure reductions for IMP remediation requirements, and has added a requirement for notification when a pressure reduction exceeds 365 days:

• §192.933(a)(1) Temporary Pressure Reduction
  If an operator is unable to respond within the time limits for certain conditions, they must temporarily reduce the operating pressures of the pipeline or take other action that ensures the safety of the covered segment. An operator must determine any temporary reduction in operating pressure by using one of the following: ASME/ANSI B31G; AGA Pipeline Research Committee Project PR-3-805 (“RSTRENG”); or reduce the operating pressure to a level not exceeding 80 percent of the level at the time the condition was discovered.
  
  An operator must notify PHMSA if the schedule for evaluation and remediation cannot be met; and they must also notify a State pipeline safety authority when either a covered segment is located in a State where PHMSA has an interstate agent agreement, or an intrastate covered segment is regulated by that State.
• §192.933(a)(2) Long Term Pressure Reduction
  If a pressure reduction exceeds 365 days, a gas transmission pipeline operator must notify PHMSA and provide technical justification that the continued pressure reduction will not jeopardize the pipeline’s integrity. The operator must also notify a State pipeline safety authority when either a covered segment is located in a State where PHMSA has an interstate agent agreement, or an intrastate covered segment is regulated by that State.
• §192.933(c) Schedule for evaluation and remediation
  PHMSA has modified the wording to be consistent with the wording in the IMP notification requirements. There is no change in the requirement. With the revised wording, this section will now require an operator to explain why it cannot meet its schedule for evaluation and remediation of a condition and that the changed schedule will not jeopardize public safety.
• Requirement for gas operators to notify local authorities has been repealed.

49 CFR Part 195 – Transportation of Hazardous Liquids by Pipeline
§195.452 Pipeline integrity management in high consequence areas.

Notification Requirements of Pressure Reduction: PHMSA has clarified that the notification requirements apply to certain pressure reductions for IMP remediation requirement, and has added a requirement for notification when a pressure reduction exceeds 365 days:

• §195.452(h)(1)(i) Temporary pressure reduction.
  An operator must notify PHMSA if they cannot meet the schedule for evaluation and remediation required under §195.452(h)(3) and cannot provide safety through a temporaryreduction in operating pressure.
• §195.452(h)(1)(ii) Long-term pressure reduction.
  When a pressure reduction exceeds 365 days, the operator must notify PHMSA and explain the reasons for the delay, in addition to taking remedial action to ensure the safety of the pipeline.
• §195.452(h)(3) Schedule for evaluation and remediation.
  PHMSA has modified the wording to be consistent with the wording in the IMP notification requirements. There is no change in the requirement. With the revised wording, this section will now require an operator to explain why it cannot meet its schedule for evaluation and remediation of a condition and that the changed schedule will not jeopardize public safety or environmental protection.
• §195.452(h)(4)(i) Immediate repair conditions.
  An operator must calculate the temporary reduction in operating pressure using the formula in section 451.7 of ASME/ANSI B31.4, if applicable. If not applicable to the anomaly, or if the formula results in a calculated pressure higher than the original operating pressure, an operator must use an alternative acceptable method to calculate a reduced operating pressure.
• §195.452(j)(3) Assessment intervals.
  PHMSA has added an eight-month window to the hazardous liquid pipeline five-year time frame for operators to complete reassessments – giving operators flexibility in scheduling and completing reassessments without compromising pipeline safety.

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PHMSA Issues Guidelines for Emergency Special Permits

Under the 2006 pipeline safety bill, the Pipeline and Hazardous Materials Safety Administration (PHMSA) has new authority to grant special permits in emergency situations. Emergency special permits will be granted under the following conditions:

• If it is in the public interest,
• is not inconsistent with pipeline safety, and
• is necessary to address an emergency caused by a natural or manmade disaster.

Permits will be considered on a case-by-case basis and will not be issued for a period of more than 60 days.

The guidelines and process on how to request an emergency special permit can be found on the PHMSA Website.

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PHMSA Revised Inspection Protocols

The Pipeline and Hazardous Materials Safety Administration (PHMSA) issued revised Gas Integrity Management Protocols, effective July 1, 2007. Minor changes were made to the following Protocols:

Protocol Area B. Baseline Assessment Plan

• B.01.a NEW — Added to emphasize connection of assessment methods to threats.
• B.05.a UPDATED to reflect that review of the operator’s program to minimize environmental and safety risks applies to both baseline assessments and reassessments.
• F.07 Consideration of Environmental & Safety Risks — DELETED

Protocol Area F. Continual Evaluation and Assessment

• F.07 Consideration of Environmental & Safety Risks — DELETED

Protocol Area G. – Confirmatory Direct Assessment

• G.01.a DELETED — Redundant to the other G.01 protocols.

References

• Updated Protocol references to reflect the Rule incorporation of ASME B31.8S-2004.

The revised protocols can be found on the DOT Website.

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RCP Services Spotlight Integrity Management Services

RCP can provide written direct assessment procedures to comply with DOT 195 and 192 Regulatory requirements for stress corrosion cracking, internal corrosion and external corrosion threats. The procedures are custom written to meet the individual client needs, threats and operating philosophy in accordance to NACE RP 502, ASME B31.8S and other NACE recommended practices that are currently being developed. The advantage of utilizing direct assessment is the ability to be performed without affecting the operations of the pipeline and does not require any modification to the pipeline.

RCP can provide the following pipeline integrity and direct assessment services:

• Custom written integrity management plans – RCP has the tools and expertise to develop comprehensive Integrity Management Plans for both liquid and gas pipelines.
• Pipeline Risk / Liability Assessments – RCP will evaluate the pipeline’s operating and maintenance history, its environment, and other factors to identify any unusual risks or liabilities. This can include, for example, problems identified during previous in-line inspections which have never been corrected.
• HCA Identification Analysis – RCP can provide HCA identification analysis for both liquid and gas pipelines to identify pipeline segments that could affect highly populated areas, other populated areas, ecologically sensitive areas, drinking water and navigable waterways that are defined as high consequence areas by DOT 192 and 195.
• ICDA/ECDA/SCCDA Plans – RCP can develop comprehensive written stress corrosion cracking, internal corrosion and external corrosion plans to perform direct assessments as an alternative to in-line inspections and pressure tests.
• Risk Modeling – RCP can provide pipeline risk modeling to address the identified threats for each pipeline segment and the risk prioritization of those pipeline segments to create baseline and ongoing integrity assessment plans.
• Baseline Assessment Plans – RCP can develop baseline assessment plan for those segments that fall under the High Consequence Area definition.
• Pre-Assessment Evaluations – RCP can provide pre-assessment evaluations for direct assessment of pipelines.
• Direct Assessment Inspections – RCP can manage and evaluate direct assessment inspections.

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