DOT Pipeline Compliance News

February 2011 Issue

In This Issue

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PHMSA Released Control Room Management FAQs

PHMSA has released a draft copy of the FAQs that were developed by the PHMSA/NAPSR workgroup to clarify regulatory expectations for the Control Room Management (CRM) rule. The FAQs provide additional information on the facilities and personnel intended. In addition, an explanation is provided for “safety-related” operators and parameters.

For a copy of the CRM FAQs (Draft copy dated February 1, 2011) contact Jessica Roger.

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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.

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PHMSA Final Rule on Mechanical Fitting Failure Reporting

[Docket No. PHMSA–RSPA–2004–19854, Amdt. Nos. 191–22; Amdt. 192–116]

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (DOT/PHMSA) issued a final rule that amends PHMSA’s DIMP regulation. This final rule revises the pipeline safety regulations to clarify the types of pipeline fittings involved in the compression coupling failure information collection; changes the term “compression coupling” to “mechanical fitting,” aligns a threat category with the annual report; and clarifies the Excess Flow Valve (EFV) metric to be reported by operators of gas systems. This rule also announces the OMB approval of the revised Distribution Annual Report and a new Mechanical Fitting Failure Report. Finally, this rulemaking clarifies the key dates for the collection and submission of the new Mechanical Fitting Failure Report.

This final rule is effective April 4, 2011.

For a copy of the Final Rule on Mechanical Fitting Failure Reporting, contact Jessica Roger.

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PHMSA Notice of Extension for Comments on Collection of Safety Related Conditions

Docket No. PHMSA–2010–0354

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (DOT/PHMSA) issued a notice to allow the public an additional 30 days to submit comments on the Reporting Safety-Related Conditions on Gas, Hazardous Liquid, and Carbon Dioxide Pipelines and Liquefied Natural Gas Facilities. Each operator of a pipeline facility (except master meter operators) must submit to DOT a written report on any safety-related condition that causes or has caused a significant change or restriction in the operation of a pipeline facility or a condition that is a hazard to life, property or the environment. (Affects Parts 192, 193, 195.)

Send comments regarding the burden estimate, including suggestions for reducing the burden, to the Office of Management and Budget, Office of Information and Regulatory Affairs, Attn: Desk Officer for DOT/ PHMSA, 725 17th Street, NW, Washington, DC 20503.

Comments are due on or before March 7, 2011.

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PHMSA Free Webinar on Portal Registration February 9 – Noon (EST)

This free webinar will provide operators with training on the new PHMSA Portal Registration, Gas Distribution Annual Report and Mechanical Fitting Failure Report forms. PHMSA will provide a step by step virtual tour of the new application for submitting your Gas Distribution Annual Report and Mechanical Fitting Failure forms, as well as the new registration process. This event will guide users through the features that have been added to improve data quality and reduce the amount of data entry. The webinar will occur on Wednesday, February 9, 12:00 to 1:30 pm EST. Click here to register online.

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API Pipeline Conference April 12 – 13

The 62nd annual API Pipeline Conference is being held April 12th and 13th at the Hyatt Regency Hill Country in San Antonio, Texas. The API Pipeline Environmental and Safety Awards will be presented during the luncheon on Wednesday, April 13th. For the Conference program, advance registration, and hotel information click here.

For award program and application information, please go to this API website and scroll down to “API Environmental and Safety Award Program.”

RCP will be there. How about you?

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Gas Industry Conferences at a Glance

SGA Spring Gas Conference & Expo
March 15 – 17 at the Charlotte Convention Center in Charlotte, NC
A technical conference for natural gas operators.

AGA Ops Conference & Biennial Exhibit
May 24 -27 at the Gaylord Opryland in Nashville, TN
The annual AGA Operations Conference is the natural gas industry’s premier gathering of natural gas utility and transmission company operations management from across North America and the world for the sharing of technical knowledge, ideas and practices to promote the safe, reliable, and cost-effective delivery of natural gas to the end-user.

RCP will have exhibits at both conferences and hope to see you there!

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Advisory Committee Meetings

The Technical Pipeline Safety Standards Committee (TPSSC) and the Technical Hazardous Liquid Pipeline Safety Standards Committee (THLPSSC) will meet on Thursday, March 24, 2011 from 9:00 a.m. to 4:00 p.m. and the TPSSC will meet on Friday, March 25, from 9 a.m. to 12:00 p.m. EST. The meetings will occur in the Washington, DC area, but the exact location has not yet been determined. Meeting times are tentative. The meeting will not be web cast.

Attendees, click here to register in advance. On-site registration will be available starting at noon on Wednesday at 11:30 a.m. Presentations will be available on the meeting website within 30 days following the meeting.

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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.

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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.

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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.

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CGA Excavation Safety Conference & Expo March 8 -10

The CGA Excavation Safety Conference & Expo will take place on March 8 – 10, 2011 in Orlando, Florida. Excavation safety and the protection of buried infrastructure is the shared responsibility of all stakeholder groups. This Conference brings together stakeholders from throughout the industry to share ideas, learn from the experts and gather information on industry trends and technologies. RCP’s Director of Communications, Amber Pappas, will attend this conference and speak on Wednesday, March 9th at 3:00 PM about using GPS for damage prevention purposes.

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PHMSA Advisory Bulletin ADB -11-01: MAOP / MOP and IMP

Editor’s Note: Due to the importance of this advisory bulletin, we felt it was worth repeating one more time.

On January 3, 2011, The National Transportation Safety Board (NTSB) issued recommendations to PHMSA, CPUC, and PG&E related to the San Bruno pipeline incident (see related article in this month’s newsletter). NTSB’s preliminary findings indicate that the pipeline operator did not have an accurate basis for the MAOP calculation.

PHMSA issued ADB-11-01 on January 4, 2011 entitled: Pipeline Safety: Establishing Maximum Allowable Operating Pressure or Maximum Operating Pressure Using Record Evidence, and Integrity Management Risk Identification, Assessment, Prevention, and Mitigation. The ADB states that operators “must assure that the records used are reliable” when calculating MOP / MAOP, and that “these records shall be traceable, verifiable, and complete”. It further states that “If such a document and records search, review, and verification cannot be satisfactorily completed, the operator cannot rely on this method for calculating MAOP or MOP.”

It further states: “Any operator of a hazardous liquid or gas transmission pipeline that is not fully cognizant of the location, pipe material and seam type, coating, cathodic protection history, repair history, previous pressure testing, or operational pressure history, and other assessment information, incident data, soil type and environment, operational history, or other key risk factors of a pipeline operating at or above 30% SMYS should 1) institute an aggressive program as soon as possible to obtain this information, 2) assess the risks, and 3) take the proper mitigative measures based upon the operator’s IM program risk findings. In addition, if these operators do not have verified information on key risk factors, an immediate and interim mitigation measure that should be strongly considered is a pressure reduction to 80 percent of the operating pressure for the previous month, hydro testing the pipeline or creating a remediation program to identify threat risks.”

This is a very significant advisory, and indicates a policy shift within PHMSA that could have profound implications for some pipeline operators. For example, operators that have relied upon “default” values for key risk factors in the integrity management program or when calculating their MOP / MAOP (in the absence of data about particular line segments) may now be required to determine the actual values for each factor; and, they may be expected to take interim pressure reductions until that data is obtained. This could require a significant data-gathering and analysis effort – especially for older pipeline systems.

The advisory states that “Future PHMSA inspections will place emphasis on the areas noted in this Advisory Bulletin.” The advisory also mentions that PHMSA and its state partners intend to sponsor a public workshop on these issues, but the date for this workshop has not yet been determined. We will inform you of the details once they are established.

For a copy of ADB-11-01, or for help in addressing these issues, contact Jessica Roger.

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MAOP Analysis Services

RCP has developed the most comprehensive MAOP analysis model on the market. Using this model, RCP has successfully conducted MAOP analysis for dozens of complex onshore/offshore gathering, transmission, and distribution pipeline systems. The analysis can be performed as a service with the results delivered on a system-by system basis as well as detailed individual record MAOP reports that indicate the regulatory code citation or letter of interpretation that is driving the calculated MAOP value. The MAOP model can also be purchased and configured to run by your personnel using your in-house data sets. For more information, visit www.rcp.com/serv_maop.asp or contact Jessica Roger.

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