DOT Pipeline Compliance News

December 2012 Issue

In This Issue

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PHMSA Advisory Bulletin (ADB–2012–10) Pipeline Safety: Using Meaningful Metrics in Conducting Integrity Management Program Evaluations

[Docket No. PHMSA–2012–0279]

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) issued Advisory Bulletin ADB-2012-10 to remind operators of gas transmission and hazardous liquid pipeline facilities of their responsibilities, under Federal integrity management regulations, to perform evaluations of their integrity management programs using meaningful performance metrics. ADB-2012-10 outlines 11 key elements for these evaluations.

A critical program element of an operator’s integrity management program is the systematic, rigorous evaluation of the program’s effectiveness using clear and meaningful metrics. When executed diligently, this self-evaluation process will lead to more robust and effective integrity management programs and improve overall safety performance. This process is critical to achieving a mature integrity management program and a culture of continuous improvement. Program evaluation is a required integrity management program element as established in §§192.911(i) and 195.452(k) for gas transmission and hazardous liquid pipelines, respectively.

In light of NTSB’s findings following the San Bruno gas transmission incident, PHMSA is reminding operators about the importance of these requirements. Operators are advised to critically review their processes and methods for evaluating integrity management program performance and take action to strengthen these processes where warranted.

In addition, operators must keep records supporting the decisions, analyses, and processes developed and used in their evaluation of integrity management program effectiveness. These records should include those justifying the selection of performance metrics, the performance metric data and trends, and how these metrics are used to improve the integrity management program.

For a copy of the Advisory Bulletin ADB-2012-10, contact Jessica Roger.

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MAOP Exceedance Reporting

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) has requested that States share the information below to those operators with gas transmission assets in the pipeline industry. Please review your internal reporting procedures and modify to capture the information outlined below.

The passage below was included in Section 23 of the federal “Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011” passed by Congress and effective January 3, 2011.

“(2) EXCEEDANCES OF MAXIMUM ALLOWABLE OPERATING PRESSURE.—If there is an exceedance of the maximum allowable operating pressure with respect to a gas transmission pipeline of an owner or operator of a pipeline facility that exceeds the build-up allowed for operation of pressure-limiting or control devices, the owner or operator shall report the exceedance to the Secretary and appropriate State authorities on or before the 5th day following the date on which the exceedance occurs.”

PHMSA is reportedly working on an electronic filing system for submission of these reports, and is also reportedly working on an Advisory Bulletin to explain its expectations. For a time, PHMSA suggested that operators hold information on an overpressure event until that system was operational. However, these actions have been delayed. PHMSA is now requesting that overpressure events be reported to InformationResourcesManager@dot.gov using the same format as a Safety Related Condition Report (SCRC).

The format for a Safety Related Condition Report is found in the federal regulations at 49 CFR §191.25(b). With a few modifications to make that format appropriate for MAOP exceedance reporting, the report should contain the following content: The report should be titled “Gas Transmission MAOP Exceedance” and provide the following information:

1. Name and principal address of operator.
2. Date of report.
3. Name, job title, and business telephone number of person submitting the report.
4. Name, job title, and business telephone number of person who determined that the condition exists.
5. Date condition was discovered and date condition was first determined to exist.
6. Location of condition, with reference to the State (and town, city, or county) or offshore site, and as appropriate, nearest street address, offshore platform, survey station number, milepost, landmark, or name of pipeline.
7. Description of the condition, including circumstances leading to its discovery, and any significant effects of the condition on safety.
8. The corrective action taken before the report is submitted and the planned follow-up future corrective action, including the anticipated schedule for starting and concluding such action.

This list does not specifically ask for the cause of the overpressure, but that should certainly also be included in the report, if known. Also include basic pipeline information such as pipeline size, length, normal operating pressure, and MAOP. It is presumed the “build-up allowed” will be based on 49 CFR 192.201.

NOTE: These reports are required for gas transmission pipelines only.

The law states that such reports must be filed within five (5) days. You are reminded that if a report like this is made to PHMSA, an intrastate operator must concurrently file a copy with the appropriate State Agency.

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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

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PHMSA Technical Advisory Committee Meetings December 11-13, Washington, DC

On November 27, 2012, in the Federal Register, the Pipeline and Hazardous Materials Safety Administration (PHMSA) announced meetings of the Liquid Pipeline Advisory Committee and the Gas Liquid Advisory Committee, also known as the Technical Hazardous Liquid Pipeline Safety Standards Committee and the Technical Pipeline Safety Standards Committee.

The meetings will be held at the Westin Alexandria, 400 Courthouse Square, Alexandria, VA 22314, Phone: 703-253-8600. Meetings scheduled as follows:

• Tuesday (Dec 11): 1:00 pm to 4:00 pm – Liquid Pipeline Advisory Committee Meeting.
• Wednesday (Dec 12): 9:00 am to 5:00 pm – Joint Committee Meeting (Liquid and Gas)
• Thursday (Dec 13): 9:00 am to 1:00 pm- Gas Pipeline Advisory Committee Meeting

The committees will meet to discuss two proposed rules, the first to implement changes to the administrative procedures in Part 190 Enforcement Procedures, and the second to establish criteria and procedures for determining the adequacy of state pipeline excavation damage prevention law enforcement programs; to establish an administrative process for making adequacy determinations and Federal requirements PHMSA will enforce in states with inadequate programs; and to establish the adjudication process for administrative enforcement proceedings against excavators where Federal authority is exercised.

For more information, contact Cheryl Whetsel, Advisory Committee Manager by phone at 202-366-4431 or by email.

The meetings will not be Web cast; however, presentations will be available on the meeting website and posted in the E-Gov website: http://www.regulations.gov under docket number PHMSA-2009-0203 within 30 days following the meeting.

Click here for more detailed information and a PDF copy of the notice.

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API/AOPL Pipeline Performance Tracking System (PPTS) Workshop January 29, 2013 – Houston, TX

The API/AOPL Data Mining Team (DMT) will host the bi-annual Pipeline Performance Tracking System (PPTS) workshop on January 29, 2013 in Houston, TX. The workshop will be hosted at the RCP offices in Houston, TX and also via Live-Meeting. The PPTS workshop is open to all current and prospective PPTS participants. Covered topics include: what is reportable to PPTS, how to report to PPTS, benefit of reporting to PPTS, how does PPTS relate to PHMSA report data, and how the data is used for industry purposes. Registration information will be sent out as the event approaches. For further information, please contact Bukky Adefemi at adefemia@api.org.

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