DOT Pipeline Compliance News

February 2008 Issue

In This Issue

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DOT Pipeline Compliance News February 2008 Edition

DOT Gas Pipeline Compliance Workshop – March 27, 2008

RCP will be hosting our very popular one-day workshop on DOT Pipeline Compliance for Gas Pipelines on March 27th in Denver, Colorado. 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.

NEW! Guest Speaker: Steve Pott, with the Colorado Public Utilities Commission, will be joining us to discuss the potential rule changes in Colorado.

Gas Pipeline Regulations (49CFR192): Covering all the topics below but special emphasis will be placed on the changes in **GAS GATHERING** regulations.

• PHMSA Overview
• PHMSA Jurisdictional Boundaries
  • Production / Gathering / Transmission
  • Onshore / Inlets to the Gulf of Mexico / Offshore
• Compliance Requirements:
  • Design
  • Construction
  • Operation
  • Maintenance
  • Corrosion
  • Testing
  • Integrity Management
  • Operator Qualification
  • Emergency Response
  • Reporting
• New/Proposed Regulations

Your Instructor: As principal of RCP, Mr. Byrd enjoys a solid reputation for working with the public, corporate management, and regulatory agencies to resolve complex regulatory issues. He serves on various industry association committees, works as an expert witness and consulting expert, and is frequently called upon to comment on current or proposed rulemakings at public and private meetings and conferences.

For additional information go to our website here.

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Colorado Pipeline Regulation Proposals

At our March 27 DOT workshop in Denver, Steve Pott, the Chief of Pipeline Safety in Colorado, will make a presentation concerning recently proposed changes to gas pipeline jurisdiction and regulation within the State of Colorado. These changes are expected to impact gathering pipelines.

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Comments Posted by the TRRC on Proposed Pipeline Regulations

Comments have been posted in the Railroad Commission of Texas website in response to recently proposed pipeline regulations (16 TAC §§8.206, 8.207, 8.208) regarding risk-based leak inspection, leak grading, and mandatory removal and replacement program for compression couplings used for gas distribution pipelines. A public meeting was held in January to discuss the proposed rule. Some of the comments request a delay in in the final rulemaking process to ensure there are no conflicts with the pending federal regulations on gas distribution integrity management. Other comments were concerned that the repair and leak classification criteria are more strenuous than the GPTC standards. To read the comments submitted, go to the following website: http://www.rrc.state.tx.us/rules/comments/Ch8-new206-207-208-comments.html

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PIPA Kickoff

The Pipeline Informed Planning Alliance (PIPA) held its public kickoff meetings in January. PIPA was formed as a result of an earlier Transportation Research Board recommendation that DOT develop “risk informed” guidance for property development in the vicinity of transmission pipelines. Representatives of local government planning departments, home builders, property developers, transmission pipeline operators, Local, State, and Federal officials, and others are involved in PIPA as either voting (representing a larger organization of stakeholders) or participating members. There is a PIPA Steering Committee, and three separate Task Teams. The Teams are:

• Protecting Communities (addressing issues primarily outside the ROW),
• Protecting Transmission Pipelines (addressing issues primarily inside the ROW), and
• Communication (tasked with packaging and communicating PIPA’s results to all stakeholders).

PHMSA has developed a collaborative website for the task team members to share information, and they will communicate frequently during the year mostly by email and conference calls. There will be at least two more face-to-face plenary meetings in July and December 2008.

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Public Awareness Programs and Line Markers Workshop

[Docket ID PHMSA-RSPA-2003-15852]

PHMSA will host a workshop on February 20-21, 2008 to provide stakeholders with an update on public awareness programs for pipeline operators and to discuss the location of line markers.

On the first day, PHMSA will share the findings from its review of written public awareness programs. Between August 8, 2006, and October 15, 2007, pipeline operators submitted 1,568 public awareness programs to PHMSA for a centralized review. PHMSA will present summary statistics from the centralized review of the programs. The workshop will also include discussion of potential revisions to the first edition of the American Petroleum Institute (API) Recommended Practice (RP) 1162. The API typically publishes new editions of recommended practices every five years. The workshop will include discussion about potential revisions to API RP 1162 for the second edition. Pipeline operators will also share some lessons learned from their implementation of public awareness programs based on RP 1162.

On the second day, PHMSA will lead a discussion on the location of line markers. The workshop will include discussion about the appropriate interval between markers and conditions which make it impractical to use markers.

The workshop will be held at the Hotel Derek, 2525 West Loop South, Houston, TX 77027. Hotel reservations under the Department of Transportation room block can be made at (713) 297-4323. The meeting room will be posted at the hotel on the day of the workshop. Members of the public may attend this free workshop. To register for a workshop, select Public Awareness and Pipeline Marker Workshop from http://primis.phmsa.dot.gov/meetings/. Hotel reservations must be made by contacting the hotel directly. The part of the workshop on public awareness programs will be web cast and available for viewing for two months after the workshop. The web cast will be accessible at http://primis.phmsa.dot.gov/comm/PublicAwarenessWorkshops.htm. For further information contact: Blaine Keener at (202) 366-0970, or by e-mail at blaine.keener@dot.gov.

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Need to make sure your Public Awareness Program meets API RP 1162 standards?

RCP can conduct a gap analysis of your current program that includes a self assessment of your Public Awareness Programs. This final product will help you to meet API RP 1162 standards. We can provide turnkey implementation, mail-outs, evaluations, and tracking of your program. For more information, contact Jessica Roger.

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2008 API Pipeline Conference and Cybernetics Symposium

Mark your calendars for the 2008 Pipeline Conference and Cybernetics Symposium at the Florida Hotel and Conference Center in Orlando, Florida on April 8 – 10, 2008. Conference registration can be made here, and hotel reservations can be made at The Florida Hotel Orlando. We hope to see you all there!

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Alberta Energy and Utility Board Splits

Effective January 1, 2008, the Alberta Energy and Utilities Board (EUB) has been realigned into two separate regulatory bodies:

• the Energy Resources Conservation Board (ERCB), which regulates the oil and gas industry, and
• the Alberta Utilities Commission (AUC), which regulates the utilities industry.

The ERCB regulates the safe, responsible, and efficient development of oil, natural gas, oil sands, and coal, and as well as the pipelines to move the resources to market. Regulation is done through two core functions: adjudication and regulation, and information and knowledge. ERCB approval must be given at almost every step of an energy project’s life.

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ERCB Issues Directive 057: Fencing and Site Access Requirements for Oil and Gas Facilities

Directive 057 introduces new requirements for fencing and security that are applicable to ERCB-regulated oil and gas facilities. These new requirements are in addition to existing ERCB fencing and security requirements; together they will ensure an increased level of protection for Albertans. The intent of the directive is to reduce the possibility of incidents of vandalism or accidents involving the public at facilities by increasing security at those facilities.

Facilities that this directive applies to are identified by the volumetric production/throughput as set out by the licensed design rate where available. If a licensed design rate is not available, the previous year’s production/throughput applies. The volumetric production/throughput thresholds for the purpose of this directive are as follows:

• gas batteries and compressor stations—facilities over 100 000 thousand cubic metres (103 m3) of gas per year
• oil facilities—facilities over 60 000 m3 of oil per year
• gas plants—facilities over 100 000 103 m3 of gas per year

Unless otherwise directed by the ERCB, licensees of facilities that meet the above criteria must comply with at least one of the following requirements:

• install an adequate fence, in accordance with the OGCR, Section 8.170; or
• ensure that the entire geographic area where the facility is located is a controlled access area (i.e., fenced, gated and locked; or manned 24 hours per day); or
• ensure that the facility is attended 24 hours per day; or
• close and lock doors on all process buildings while the facility is not attended.

The ERCB also requires that licensees display signs limiting access to authorized personnel at all the facilities defined above.

The following facilities are exempt from this directive:

• facilities that presently have access control measures consistent with the intent of this directive,
• facilities at which the hydrogen sulphide concentration is less than 10 moles per kilomole, and
• facilities where circumstance exist such that compliance with the directive could result in a greater risk to the operator or the public (e.g., a facility located immediately adjacent to a road or highway, thus requiring an operator to park on the road or highway to access the site).

Notwithstanding the above, the ERCB recommends that licensees of exempt sites implement one of the fencing or site access options listed above where the level of risk warrants. All requirements of this directive must be implemented by January 31, 2009. For a copy of this directive, please contact Jessica Roger.

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ERCB Draft Directive 71 – Emergency Preparedness and Response Requirements for the Petroleum Industry

The ERCBH2S dispersion model software program is a new method for emergency planning zone (EPZ) calculation for sour wells, pipelines and facilities. A significant change incorporated into the draft Directive is a new computer software program (ERCBH2S) required for calculating emergency planning zones (EPZs) for sour wells, pipelines and facilities. On January 2, 2008, a revised draft of the ERCBH2S program and supporting documentation were posted on the ERCB website for stakeholder review. The revised program can be downloaded at the following website.

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