DOT Pipeline Compliance News

August 2012 Issue

In This Issue

PHMSA ADB-2012-08 Pipeline Safety: Inspection & Protection of Pipeline Facilities after Railway Accidents

[Docket No. PHMSA–2012–0176]

The Pipeline and Hazardous Materials Safety Administration (PHMSA) issued an advisory bulletin to alert all pipeline owners and operators of the circumstances of the Cherry Valley, Illinois derailment and remind them of the importance of assuring that pipeline facilities have not been damaged either during a railroad accident or other event occurring in the right-of-way.

Further, the advisory bulletin reminds pipeline owners and operators of the importance of providing pertinent information to rail operators and emergency response officials during an incident. This information should include the presence, depth and location of the pipelines so that the movement of heavy equipment and debris on the right-of-way does not damage or rupture the pipeline or otherwise pose a hazard to people working in, and around, the accident location.

The advisory also encourages pipeline owners and operators to inform rail operators and emergency response officials of the benefits of using the 811 “Call Before You Dig” program to identify and notify underground utilities that an incident has occurred in the vicinity of their buried facilities.

For a copy of this Advisory Bulletin ADB-2012-08, contact Jessica Roger.

PHMSA Request for Comments on IMP Requirements & Response Plans

[Docket No. PHMSA–2012–0094]

The Pipeline and Hazardous Materials Safety Administration (PHMSA) is seeking comments on two information collections that will be submitted to the Office of Management and Budget (OMB) for renewal:

  1. Pipeline Integrity Management in High Consequence Areas Gas Transmission Pipeline Operators. OMB Control Number: 2137–0610. Current Expiration Date: 9/30/2012. 49 CFR 192.947 requires operators of gas transmission pipelines located in or near high consequence areas to maintain a written integrity management program and records showing compliance with 49 CFR part 192, subpart O. Operators must also submit documentation relative to their integrity management program to PHMSA as applicable.
  2. Response Plans for Onshore Oil Pipelines. OMB Control Number: 2137–0589. Current Expiration Date: 9/30/2012. 49 CFR part 194 requires an operator of an onshore oil pipeline facility to prepare and submit an oil spill response plan to PHMSA for review and approval.

Original notice was published in the Federal Register on May 9, 2012, (77 FR 27279) under Docket No. PHMSA–2012–0094. No comments were received. The purpose of this notice is to allow the public an additional 30 days to submit comments on or before September 4, 2012. Comments may be submitted via the E–Gov Website. Reference Docket No. PHMSA–2012–0094.

For a copy of this notice, contact Jessica Roger.

Introducing MaxOp*

RCP is extremely proud to announce the launch of a web-based version of our popular MAOP calculator model. Just like the model we built to conduct MAOP studies as a service, MaxOp* is the most comprehensive MAOP tool on the market. Through a secure web service, our customers can now push their MAOP data sets into RCP’s MaxOp* tool, link documentation to MAOP algorithm variables, dynamically segment their data, run MAOP calculations, identify potential discrepancies between the established and calculated MAOP values, and export calculated data sets and customizable reports back to their own native data sets. The tool will accept common pipeline database formats including Excel, PODS, APDM and others.

MAOP Validation Services

RCP has developed a turnkey process by which pipeline operating companies will have a traceable, verifiable and complete MAOP dataset. It starts with our MAOP document review services where RCP conducts detailed reviews of relevant MAOP documents, extracts the necessary data onto our MaxOp* cover sheets and posts the data into the database for future dynamic segmentation and calculation. For each document, a MaxOp* cover sheet is attached and re-filed, awaiting digitization by the market leading document management services company, Iron Mountain. Once these documents are scanned and posted, MaxOp* will retain a permanent link from the data set to the document image. Finally, once the document review is complete, MaxOp* will dynamically segment any spatially related data and run the MAOP calculations. The resulting values and data sets can then be exported to our customer’s in-house pipeline data set (ex. Excel, PODS, APDM, other). At the completion of this effort, the basis for an MAOP management of change has been established and our customers can be confident that their MAOP values are capable of being traced back to source documentation, the calculated values have been validated with the most comprehensive calculator tool on the market, and the MAOP values have been completely evaluated and any potential deficiencies identified.

For more information about RCP’s MAOP services or the MaxOp* calculator, please contact Jessica Roger.

* MaxOp is a US Trademark and property of RCP Inc

Retirement of ODES 1 – pre-2010 submittal of Annual, Accident, and Incident Reports

Due to dated technology and support expenses compared to the amount of activity, PHMSA is retiring the Online Data Entry System (ODES 1) on December 31, 2012. After retirement, operators will no longer be able to submit supplement reports for CY 2009 and earlier annual, accident, and incident reports. Operators are encouraged to review all reports from 2002 through 2009 to ensure they are complete and accurate. If not, operators should submit supplemental reports online before December 31, 2012. The Pipeline Data Mart (PDM) provides easy access to all reports within this timeframe.

After December 31, 2012, operators can still change pre-2010 reports by emailing requests to PHMSA will “manually” make the requested changes in the appropriate database. PHMSA encourages operators to submit supplemental reports online before December 31, 2012 to minimize the number of “manual” data changes in 2013 and beyond.

PHMSA updates Control Room Management FAQ’s

PHMSA has revised or added several control room management frequently asked questions related to shift schedules and testing of backup manual operations plans.

C.14 With respect to testing and verification of backup manual operations, is the intent to test every manual operation or to test the capability to execute the backup plans, procedures, and processes?
Operators must test and verify that its internal communications plan can effectually implement backup manual operations in the event of a SCADA system failure. The test and verification process must be designed to confirm that the operator has adequate personnel, procedures, processes, communications infrastructure, and manual command-and-control capabilities to assure safe, reliable operations and pipeline integrity when operating manually. Such testing should (i) verify the sufficient and timely deployment of qualified personnel to field locations necessary to adequately operate equipment and monitor pipeline integrity, (ii) establish, supplement, and/or verify performance of its communications or command center, and (iii) exercise critical decision-making processes. Testing and verification should address all types of actions necessary to mobilize manual operations. Testing and verification should be performed on at least a representative sampling of the processes and equipment intended to be used during backup operations.
[§§ 192.631(c)(4) and 195.446(c)(4)]

D.14 If an operator doesn’t have shift lengths, schedule rotations, and maximum limit on hours of service explicitly noted in their fatigue mitigation related procedures, is an operator’s actual shift schedule and related records adequate to demonstrate compliance with (d)(1) and (d)(4)?
No. The rule requires operators to have written procedures that implement the fatigue mitigation requirements. PHMSA would expect an operator’s fatigue mitigation related procedures to describe the bounding parameters in shift lengths and schedule rotations, and maximum hours of service limits they have established as the general framework for their program. PHMSA would then expect to see examples of actual schedules, timesheets and other records to show how those procedures are implemented, including if/how any changes to those schedules are managed in the context of the procedures. Schedules and timesheets alone are likely not adequate, as they are subject to change in the case of call-outs, vacation, etc. and would only give a certain snapshot in time. Written procedures would provide the framework in which those schedules can be changed and managed to reduce the risks associated with fatigue.
[§§ 192.631(d)(1) and (d)(4) and 195.446(d)(1) and (4)]

D.15 Does the information presented in the other CRM FAQs and inspection criteria account for schedules of 7 consecutive day or night shifts followed by 7 consecutive days off, generally referred to as 7 on/7 off type shift schedules?
Control Room Management regulations do not exclude the use of 7 on/7 off type schedules. The regulations do, however, require the implementation of methods, including establishing shift lengths and schedule rotations, to reduce the risk associated with controller fatigue for any and all schedules. As part of fatigue mitigation strategies, PHMSA expects operators to have a scientific basis for the schedules and limits they select, and consider circadian effects, different types of shifts, the need for rest, and other factors highlighted by relevant research. As part of an overall fatigue mitigation program, operators need to take into account the relative fatigue risks of whatever schedule and limits they select, and ultimately be able to demonstrate how either the limits they select reduce the risk of fatigue, or how fatigue mitigation tactics (countermeasures) and other aspects of their overall program are sufficient to reduce the risk for fatigue.

There is an increased risk for fatigue as the number of successive shifts increase, particularly successive shifts involving night work. PHMSA’s CRM website is a resource for information about fatigue management and related mitigation strategies. FAQs provide some reasonable limits to consider, along with shifts/times where fatigue risks are elevated and where fatigue mitigation tactics should be implemented. Still other FAQs provide some examples of fatigue mitigation tactics (countermeasures.) The level of risk appears to increase in shift plans with periods that approach 7 successive shifts in a row, particularly if the 7 successive shifts all involve night work.

If an operator chooses to use limits past those recommended in FAQs and Inspection Guidance material, including 7-on/7-off schedules, an operator would need to provide sufficient justification on how their overall program reduces the risk for fatigue. Such justification may require different or additional countermeasures or a more comprehensive fatigue risk management approach.

There are a number of trade-offs in considering any schedule rotation, including 7-on/7-off type schedules. In addition to other guidance already provided, a white paper entitled “Shift Plans with Seven Consecutive Shifts (Miller, April 2012)” discusses the pros and cons behind such schedules, including some countermeasures that should be considered above and beyond those already included in other FAQs.

Operators should expect that inspectors would be more inquisitive about how they protect against fatigue risks on the 6th and 7th successive days of work (if day only), and on the 4th through 7th successive nights of work.

[§§ 192.631(d) and 195.446(d)]

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.

8-11: A Day for Damage Prevention

For the 4th consecutive year, the Common Ground Alliance (CGA) encourages all stakeholders to make August 11 (8/11) a day for damage prevention, with a focus on spreading the “Call 811” message. Find additional information at the CGA website.

TRRC Amendment to 16 TAC Chapter 8 – Pipeline Safety Regulations

GUD No. 10149

On July 17, 2012, the Railroad Commission of Texas (TRRC) adopted a number of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pipeline safety rules that were issued between February 12, 2010, and October 1, 2011, including the:

  • 2010 update to the standards incorporated by reference
  • Drug and alcohol testing rule changes
  • “One Rule” updates and new gas, hazardous liquid and LNG reporting requirements
  • Fitting failure reporting
  • Control room management deadline changes
  • “Low Stress II” rule that applied additional safety regulation to rural low-stress hazardous liquid pipelines

This amendment to 16 Texas Administrative Code §8.1, relating to General Applicability and Standards changes the date in subsection (b) of the rule to update the effective date of the adoption of all amendments to Federal pipeline safety regulations that have become effective since February 12, 2010. This change was necessary to maintain compliance with the program and funding requirements of PHMSA. The adoption will be published in the Texas Register on August 3, with an effective date of August 6, 2012.

For a copy of the TRRC amendment, contact Jessica Roger.

API Damage Prevention Workshop September 12 -13, Houston, TX

Registration is now open for API’s Damage Prevention Workshop that will be held at the Doubletree Hotel, 15747 John F. Kennedy Boulevard in Houston. Click here for registration information and preliminary agenda. The deadline for pre-registration is September 5.

Day One – September 12 1PM – 5PM
A team has been formed to collect industry damage prevention practices into a virtual toolbox. The toolbox and the practices in it will be presented and discussed. Who can contribute to the toolbox? What sorts of practices are in it? How can the toolbox be accessed?

Day Two – September 13 8AM – 12:00 PM
There will be discussion of excavation damage incidents and near miss events that resulted from existing exemptions from the use of one-call laws and what the strategies that have and may be employed to reduce the occurrence of such accidents. Would laws simply eliminating or severely limiting such exemptions be desirable? What are the pros and cons? What additional burdens may be placed on industry to screen and respond to additional one calls if existing exemptions are eliminated? Are there certain exemptions that the pipeline industry wants to retain? What industry practices have been particularly effective?
API has arranged a discounted room block at the Doubletree Hotel at George Bush Intercontinental Airport for $159/night. Reservations can be made by calling 281-848-4001. Please be sure to mention the API meeting. The cut-off date for making room reservations is August 29, 2012.

For more information, contact Madeleine Sellouk.

Damage Prevention Plans

RCP can develop or update your Damage Prevention plan. For more information about how RCP can assist you with your Damage Prevention Plan, click here.

Meet me at the Conference

Western Region Gas Conference
Tempe, AZ / August 21 & 22
Stop by RCP’s Booth for a MaxOp* Demo; and, mark your agenda to attend:
Tuesday (Aug 21) Morning Session: “Best Practices for MAOP Validation” – Presented by Chris Foley

International Pipeline Conference
Calgary, Canada / September 24 – 28
In September 2012, members of the pipeline industry from around the world will gather in Calgary for the 9th International Pipeline Conference (IPC 2012). Organized by volunteers representing international energy corporations, energy and pipeline associations and governments, the IPC has become internationally renowned as the world’s premier pipeline conference. This is a not for profit conference and proceeds continue to support educational initiatives in the pipeline industry.

We invite you to stop by RCP’s Booth #527 at the IPE Expo.

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