August 2010 Issue
In This Issue
- Technical Pipeline Safety Advisory Committee Teleconference Meetings
- PHMSA Advisory Bulletin ADB–10–06 Personal Electronic Device (PED) Related Distractions
- Standard Operating Procedure Updates
- PHMSA Updates DIMP FAQ’s August 2, 2010
- RCP’s Web-Based Compliance Management Systems
- DIMP Integration
- Key Features
- SPCC Extension Proposed for some Facilities
- Maine Safety & Operation Standards for LPG Distribution Systems
- Misc. Ohio Pipeline Safety Regulation Changes
- Pending Audits?
- Underground Pipeline Damage Prevention Workshop August 18, 2010 – Austin, Texas
- DOT Pipeline Compliance Workshop – October 19 – 21, 2010
- WRGC Regional Gas Conference August 24 & 25, 2010 Tempe, AZ
Technical Pipeline Safety Advisory Committee Teleconference Meetings
[Docket No. PHMSA-2009-0203]
The Technical Pipeline Safety Standards Committee (TPSSC) and the Technical Hazardous Liquid Pipeline Safety Standards Committee (THLPSSC) will meet via teleconference on Thursday, August 19, 2010, from 1 p.m. to 4 p.m. EST. The purpose of the meeting is to keep the members updated on current safety concerns, proposed rules, and future proposals. The PHMSA staff will brief the committees on several regulatory and policy initiatives including:
- Pipeline safety reauthorization.
- PHMSA accomplishments (National Transportation Safety Board, General Accounting Office, Congressional mandates).
- PHMSA priorities (new construction, damage prevention), and the status of PHMSA rulemaking initiatives.
- Administrative matters of the committee (charter, how we can best conduct business).
These two statutorily-mandated committees advise PHMSA on proposed
safety standards, risk assessments, and safety policies for natural gas
pipelines and for hazardous liquid pipelines. Each committee consists of 15
members-with membership evenly divided among the Federal and State Government,
the regulated industry, and the public. The committees advise PHMSA on
technical feasibility, practicability, and cost-effectiveness of each proposed
pipeline safety standard.
PHMSA will post any new information or changes on the PHMSA/Office of Pipeline
Safety web page about 15 days before the meeting
takes place. For further information contact: Cheryl Whetsel by phone at
202-366-4431 or by e-mail.
To participate in this meeting:
- The public may attend the meeting at the U.S. Department of Transportation, 1200 New Jersey Avenue, SE., Washington, DC 20590, Room E27-302. Attendees should register in advance at http://primis.phmsa.dot.gov/meetings/MtgHome.mtg?mtg=66.
- Or, you may join us at RCP’s office at 801 Louisiana, Ste. 200, Houston, TX to watch and listen via LiveMeeting. Click here to participate at RCP’s office.
PHMSA Advisory Bulletin ADB–10–06 Personal Electronic Device (PED) Related Distractions
The
Department of Transportation/Pipeline Hazardous Materials Safety Administration
(PHMSA) issued ADB-10-06 on July 27, 2010 to gas and liquid pipeline operators
regarding the use of PEDs by pipeline employees who are performing operations
and maintenance activities. PHMSA reminds owners and operators of natural gas
and hazardous liquid pipeline facilities that there may be increased risks
associated with the use of PEDs by individuals performing activities that
affect pipeline operation or integrity. Pipeline operations and maintenance
tasks require a critical level of attention and skill, which may be compromised
by visual, manual, and cognitive distractions caused by the use of PEDs. Such
distractions may also hinder their prompt recognition and reaction to abnormal
operating conditions and emergencies.
Owners and operators of natural gas and hazardous liquid pipeline facilities
should integrate into their written procedures for operations and maintenance
appropriate controls regarding the personal use of PEDs by individuals
performing pipeline tasks that may affect the operation or integrity of a
pipeline. PHMSA is not discouraging the use of PEDs as a part of normal
business operations. Owners and operators should also provide guidance and
training for all personnel about the risks associated with the use of PEDs
while driving and while performing activities on behalf of the company if that
use poses a risk to safety.
For a copy of ADB-10-6 on Personal Electronic Device (PED) Related
Distractions, contact Jessica Roger.
Standard Operating Procedure Updates
RCP has developed standard operating procedures for hundreds of pipeline operators ranging from gas transmission, hazardous liquids, gas distribution, reservoir and salt dome gas storage facilities, oil terminals, regulated onshore gathering and offshore oil & gas facilities. Our procedure development process goes well beyond the typical cookie-cutter generic templates that you can buy off the shelf. We have a strong track record with successful PHMSA and state inspection performance. Our procedure development process integrates with the daily operating processes that your personnel and contractors currently follow. When complete, you will have a comprehensive set of procedures that are easy to manage and comply with federal and state regulatory requirements. For more information, contact Jessica Roger.
PHMSA Updates DIMP FAQ’s August 2, 2010
PHMSA
has posted Frequently Asked Questions for the recently finalized Distribution
Integrity Management Program regulation. We have inserted a few noteworthy
FAQ’s below. To view the entire list of FAQ’s, click here.
A.8 The regulation exempts the installation of EFVs on services which do not
operate at a pressure of 10 psig or greater throughout the year. Can you give
examples of types of documentation that would be acceptable in demonstrating
this issue?
Two possible methods to demonstrate that services operate at a pressure less
than 10 PSIG include; (1) distribution system design documents, validated with
actual pressure readings, which show that the main and therefore the associated
services are designed to operate below 10 PSIG, or (2) actual pressure
recordings or readings on all feeds which are upstream of the service(s) which
are less than 10 psig.
B.2.2 Will operators be compared against other operators or national leak or
safety data?
PHMSA recognizes that operators need to develop a DIMP plan appropriate for the
applicable threats, the operating characteristics of their specific
distribution delivery system, and the customers that they serve. PHMSA and
State partners intend to focus on each individual operator’s performance
trends.
C.3.7 Are operators required to include “farm taps” in their
distribution integrity management plan?
In the past, distribution, gathering, and transmission operators connected
landowners directly to transmission and gathering pipelines often in exchange
for the right to install the pipeline across a landowner’s property. This
connection to the gas pipeline is commonly referred to as a “farm tap”.
Although new farm taps are not installed nearly as frequently as they were in
the past, “farm taps” are very common. The vast majority of “farm taps” meet
the definition of a distribution line given that they do not meet the criteria
to be classified as a gathering line or a transmission line.
The “farm tap” is pipeline upstream of the outlet of the customer meter or
connection to the customer meter, whichever is further downstream, and is
responsibility of the operator. The pipeline downstream of this point is the
responsibility of the customer. Some States require the operator to maintain
certain portions of customer owned pipeline. The pipeline maintained by the
operator must be in compliance with 49 Part 192.
Operators of distribution, gathering, and transmission lines with “farm taps”
must have a distribution integrity management program meeting the requirements
of Subpart P for this distribution pipeline. The DIMP plan is not required to
include the customer-owned pipeline (unless required otherwise by State law).
The operator having responsibility for operations and maintenance activities
for the facility is responsible for developing and implementing the DIMP plan.
C.4.c.2 From which date are operators required to collect data for their
Plan?
Operators should use the information they already have and start keeping
additional data to develop their plan (e.g., assess the threats) as soon as
possible. They need to assemble and evaluate enough data to be able to evaluate
the risk. Useful and usable historical data is needed to identify threats and
trends.
C.4.g.5 Are multiple tickets for a single job counted as single excavation
ticket?
Some state laws require excavators to call in additional requests for on-going
jobs prior to the life of the first excavation request expiring. In reporting
data these additional requests for excavation projects of extended duration may
be counted since there is excavation work associated with those requests.
However, operators do not need to change the criteria for counting excavation
tickets for the purpose of reporting performance measures. If they currently
count multiple tickets for a single job, they may continue that practice. The
definition of “ticket” should remain consistent with State law and one-call
center definition.
C.5.5 Must operators report to PHMSA mechanical fitting failures that
occurred historically (i.e., before a final DIMP rule became effective)?
Currently the DIMP rule states that operators need to collect data about
mechanical fitting failures that result in hazardous leaks starting January 1,
2010 but PHMSA published a Federal Register notice on June 28, 2010 to inform
operators that the portion of the Annual Report relative to mechanical fitting
failures will be delayed by one year and will take effect starting with the
2011 calendar year. PHMSA is developing a final rule to revise the dates in the
regulation.
C.7.2 What will PHMSA (or States) require for proposals for alternate
inspection intervals?
Proposals must be submitted to each applicable oversight agency (usually the
State). Each State will implement this provision under the State’s procedures.
State authorities and regulatory structures differ. Requirements for
consideration of an alternative interval may differ among State regulatory
authorities. The regulatory authority will be responsible for reviewing each
proposal, determining safe intervals based on the information in the operator’s
proposal, and approving or rejecting the proposal.
Proposed alternative inspection intervals must demonstrate an equal or improved
overall level of safety including the effect of the reduced frequency of
periodic inspections. A quantitative estimate of risk is not required. PHMSA is
developing criteria for evaluating an operator’s alternative interval proposal
in the states where PHMSA exercises enforcement authority over distribution pipelines.
RCP’s Web-Based Compliance Management Systems
CP’s Compliance Management System (CMS) is an invaluable tool for managing all aspects of regulatory workflow. Some examples of how our clients are using the CMS include:
- O&M Scheduling and Data Acquisition;
- Cathodic Protection Inspection and Data Management;
- One-Call Screening and Ticket Management;
- Repair / Replacement Programs;
- Operator Qualification Administration and Workflow Integration;
- Leak Life Cycle Management;
- Environmental, Health and Safety Compliance;
- Audit Action Item Tracking; and
- Customer Data Management.
DIMP Integration
For gas distribution operators looking for a powerful tool to implement DIMP, the RCP CMS integrates O&M data captured from field personnel along with inherent system attributes to provide real-time risk analysis, performance reporting, as well as track additional and accelerated actions taken to mitigate risks.
Key Features
- GIS integrated workflow management
- Custom tailored e-mail notifications and reporting
- Runs on any web-enabled device, no software to download
- Powerful reporting and custom query functionality
- Multiple security and user privilege settings
- Document storage and control (ex. procedures, maps, images, and completion documentation)
- Automatic recurrence setting for routine tasks (example: leak surveys, CP surveys, etc.)
- Create work orders for unscheduled / unplanned activities (ex. release reporting)
To request a demonstration or to request more information, please contact Jessica Roger.
SPCC Extension Proposed for some Facilities
[Docket ID No. EPA-HQ-OPA-2009-0880]
The
EPA has proposed to amend the dates in 40 CFR §112.3(a), (b) and (c) by which
the owners/operators of facilities must prepare or amend their SPCC Plans, and
implement those Plans, to November 10, 2011, which is one year from the current
SPCC compliance date of November 10, 2010.
This proposed extension of the compliance date does not apply to drilling,
production or workover facilities that are completely offshore or that have
both onshore and offshore components (e.g., an oil production facility with
offshore wellheads connected to an onshore tank battery by submerged
flowlines).
This proposed extension of the compliance date also does not apply to onshore
facilities required to have and submit Facility Response Plans (FRPs, also
known as OPA-90 Plans). FRP facilities are those with storage capacities of 1
million gallons or more that meet certain criteria, or those with storage
capacities at or above 42,000 gallons and that transfer oil to or from a vessel
over water (40 CFR Part 112.20 and 112.21). It should also be noted the Agency
has not changed any compliance dates with respect to the FRP regulations.
Comments on this proposed rule must be received by August 18, 2010. Please
submit your comments on the proposed amendments at http://www.regulations.gov. Follow the online
instructions to comment on Docket ID No. EPA-HQ-OPA-2009-0880.
Maine Safety & Operation Standards for LPG Distribution Systems
Adopted Rule Number: 2010-219
The
State of Maine, Public Utilities Commission adopts this rulemaking of a new
Chapter 421, Safety and Operation Standards for Liquefied Petroleum Gas (LPG)
Distribution Systems, that sets forth safety and operation standards
specifically for jurisdictional liquid propane gas transmission and distribution
systems. Additionally, the new Chapter 421 expands and clarifies the
requirements for the operation, installation, and maintenance of liquid propane
gas transmission and distribution systems.
EFFECTIVE DATE: June 9, 2010
For more information, contact: Paula J. Cyr, Public Utilities Commission, 18 State House
Station, Augusta, ME 04333-0018. Telephone: (207) 287-3831. E-mail: Paula.Cyr@Maine.gov.
For a copy of Chapter 421, contact Jessica Roger.
Misc. Ohio Pipeline Safety Regulation Changes
The Ohio Public Utilities Commission has made several miscellaneous changes to their gas pipeline safety regulations, such as revising the definition of Master Meter System; updating the date of incorporated federal regulations; modifying their leak classification and repair requirements; and giving the commission the right to waive any requirement of their regulations with good cause.
Pending Audits?
Has the DOT notified you of a pending audit? RCP can provide confidential internal auditing to help ensure that your facilities are up to the agency’s latest standards.
Click Here.
Underground Pipeline Damage Prevention Workshop August 18, 2010 – Austin, Texas
The
Texas Railroad Commission is planning a Regulatory Workshop on Title 16 – Texas
Administrative Code, Chapter 18 – Underground Pipeline Damage Prevention rule
provisions that relate to prevention of damage to pipeline facilities resulting
from movement of earth, including safety standards and best practices. The
public and industry are invited to attend and provide comments. At this time
there is not a set agenda for this meeting. The format is an informal gathering
where interested parties, stakeholders, regulated industry and the general
public will have an opportunity to present suggestions on Chapter 18 rule
revisions for consideration.
The workshop will be held in Austin, Texas on August 18, 2010, at 10:00 a.m. at
the William B. Travis Bldg., 1701 N. Congress Ave, Room 1-111.
Please provide the number of persons attending along with individual names and
whom you are representing, and if you and/or your company, association or group
would like to give a presentation on suggested rule revisions during the
workshop to the RRC and meeting attendees.
Please reply with response via email to TDRFInfo@rrc.state.tx.us
or 512-463-9119.
DOT Pipeline Compliance Workshop – October 19 – 21, 2010
Join us October 19 – 21 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 (October 19): 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 (October 20): 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:
- Control Room Management
- PHMSA reporting requirements and enforcement activities
- DIMP implementation strategies
- Public Awareness effectiveness evaluation & updates to RP 1162
- Crude oil gathering & low stress liquid lines regulatory developments
- Oil spill response plan developments
Each attendee will receive general training materials and
speaker’s PowerPoint presentation handouts.
Day 3 (October 21): 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.
WRGC Regional Gas Conference August 24 & 25, 2010 Tempe, AZ
Join us at the 2010 Western Regional Gas Conference at the Tempe Mission Palms Hotel & Conference Center in Tempe, Arizona. RCP representatives will be attending the conference and look forward to meeting you. Chris Foley (RCP Vice President) will be giving a presentation on “Effective Compliance Assessment Methods & Successful Agency Audit Strategies Forum” on Tuesday, August 24. Click here to check for updates on the conference agenda and registration. (WRGC is a non-profit and volunteer-organized event to provide a venue for discussion of natural gas distribution and transmission issues.)
W. R. (Bill) Byrd, PE
President
RCP Inc.