February 2012 Issue
In This Issue
- DOT Pipeline Compliance Workshop – February 28, 29 & March 01, 2012
- PHMSA Advisory Bulletin (ADB–2012–01) Nat’l Pipeline Registry
- Introducing MaxOp*
- MAOP Validation Services
- PHMSA Misc. Changes to Pipeline Safety Regulations – Extension for Comments
- PHMSA Excess Flow Valves in Gas Distribution Systems to Applications Other Than Single-Family Residences – Extension for Comments
- EFRD Evaluation
- Pennsylvania Pipeline Safety Act 127 Tentative Implementation Order
- TRRC Proposed Rule Changes 16 TAC 8 & 18
- Pending Audits?
- 2012 Industry Conferences at a Glance
- PHMSA Leak Detection Workshop March 27 & 28 – Washington, DC
- Random Federal Register Notice That Has Nothing To Do With Pipelines
DOT Pipeline Compliance Workshop – February 28, 29 & March 01, 2012
Join us February 28, 29 & March 01 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 (February 28): 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 (February 29): 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. The workshop
topics will include a detailed review of the recently enacted Pipeline Safety,
Regulatory Certainty, and Job Creation Act of 2011 (pipeline reauthorization
bill).
Day 3 (March 01): 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.
PHMSA Advisory Bulletin (ADB–2012–01) Nat’l Pipeline Registry
[Docket No. PHMSA–2012–0001]
The Department of Transportation/Pipeline Hazardous Materials
Safety Administration (PHMSA) issued Advisory Bulletin ADB-2012-01 regarding
the Implementation of the National Registry of Pipeline and Liquefied Natural
Gas Operators which became effective on January 1, 2012. PHMSA has issued this
advisory bulletin to clarify the implementation of the national pipeline
operator registry.
PHMSA published a final rule in the Federal Register on November 26, 2010, (75
FR 72878), titled: “Pipeline Safety: Updates to Pipeline and Liquefied
Natural Gas Reporting Requirements.” The final rule added two new
sections, 49 CFR 191.22 and 195.64, to the pipeline safety regulations for the
establishment of a national pipeline operator registry. The national pipeline
operator registry is primarily applicable to operators that file electronic
reports.
The registry will be used by pipeline operators to obtain an Operator
Identification (OPID) Number and notify PHMSA of certain actions. Operators
will use the OPID number for electronic submissions such as incident and annual
reports. The national pipeline operator registry will also be used to provide
PHMSA with operator notifications related to actions such as company name changes,
certain construction activities, and project planning.
The table below identifies the expected submission dates for the various
submissions that are related to the national pipeline operator registry.
| Action | Submission Expected |
|
OPID
Assignment Requests: §§ 191.22(a) and 195.64(a) | Begins February 1, 2012 |
|
OPID
Validation: §§ 191.22(a) and 195.64(a) | As specified in §§ 191.22(b) and 195.64(b), respectively (June 30, 2012). |
|
Notification
Submissions: §§ 191.22(c) and 195.64(c) | |
| 60-day “before” notifications for events occurring between January 1, 2012, and March 30, 2012. | January 31, 2012 |
| 60-day “before” notifications for events occurring after March 30, 2012. | As specified in §§ 191.22(c)(1) and 195.64(c)(1), respectively. |
| 60-day “after” notifications for events occurring on and after January 1, 2012. | As specified in §§ 191.22(c)(2) and 195.64(c)(2), respectively. |
Details
on how to file submissions can be found on the DOT website. Any questions regarding the
filing of national pipeline operator registry submissions can be directed to
the Office of Pipeline Safety operator helpline at (202) 366–8075.
For a copy Advisory Bulletin ADB-2012-01, 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
PHMSA Misc. Changes to Pipeline Safety Regulations – Extension for Comments
Docket No. PHMSA-2010-0026
On November 29, 2011, PHMSA published in the Federal Register a Notice of Proposed Rulemaking titled: “Miscellaneous Changes to Pipeline Safety Regulations” seeking comments on the need for changes to the regulations covering pipeline safety regulations. (See related story in the December Edition of the DOT Compliance News.) The Committee on Pipe and Tube Imports Ad Hoc Large Diameter Line Pipe Producers Group Transportation Subcommittee and the Interstate Natural Gas Association of America petitioned PHMSA to extend the comment period. PHMSA is granting these requests and extending the comment period from February, 3, 2012, to March 6, 2012. Comments may be submitted to the E-Gov Web Site, and reference docket number PHMSA–2010–0026.
PHMSA Excess Flow Valves in Gas Distribution Systems to Applications Other Than Single-Family Residences – Extension for Comments
Docket No. PHMSA-2011-0009
On November 25, 2011, PHMSA published in the Federal Register an Advance Notice of Proposed Rulemaking (ANPRM), titled: “Pipeline Safety: Expanding the Use of Excess Flow Valves (EFVs) in Gas Distribution Systems to Applications Other Than Single-Family Residences.” (See related story in the December Edition of the DOT Compliance News.) The ANPRM sought public comment on several issues related to expanding the use of EFVs in gas distribution systems. On January 10, 2012, PHMSA received a request to extend the comment period to provide additional time to respond to the ANPRM. In light of that request, PHMSA is extending the comment period from February 18, 2012, to March 19, 2012. Comments may be submitted to the E-Gov Web Site, and reference docket number PHMSA-2011-0009.
EFRD Evaluation
RCP can assist pipeline operators (both gas and liquids) with performing an emergency flow restricting device (EFRD) evaluation based on the criteria, e.g. type of leak detection installed, product transported, quantity released, local topography, etc., identified in the Integrity Management rules. §192.179 requires that intermediate valves be installed along a cross country pipeline at the time of construction at specified intervals based on class location. Likewise, §195.260 identifies for liquids pipelines locations where valves must be installed at the time of construction but it is much less specific than for gas lines. For more information on an EFRD Study for your pipeline assets, contact Jessica Roger.
Pennsylvania Pipeline Safety Act 127 Tentative Implementation Order
Docket M-2012-2282031
The
Gas and Hazardous Liquids Pipelines Act (also known as “the Pipeline
Act” or Act 127 of 2011) was signed by Governor Corbett on Dec. 22, 2011
and goes into effect on Feb. 20, 2012. This law expands the Commission’s
authority to enforce federal pipeline safety laws as they relate to gas and
hazardous liquids pipeline equipment and facilities within the Commonwealth of
Pennsylvania. The Pipeline Act requires the Commission to develop and maintain
a registry of pipeline operators within Pennsylvania.
On Jan. 12, 2012, the PUC issued a tentative implementation order. It addresses
the Act 127 initiatives of creating a statewide registry for non-public utility
gas and hazardous liquids pipeline equipment and facilities within the
Commonwealth; conducting safety inspections to enforce Federal pipeline safety
laws on certain classifications of pipeline; and assessing entities for the
costs. The PUC has also prepared a list of frequently asked questions on Act
127 to assist interested parties, and has created a special website for this Pipeline Safety Act 127.
For a copy of Pennsylvania PUC’s Pipeline Safety Act 127, FAQs, or Tentative
Implementation Order, contact Jessica Roger.
TRRC Proposed Rule Changes 16 TAC 8 & 18
The
Texas Railroad Commission (TRRC) has proposed rule changes to Chapter 8 and 18
that would align all penalty guidelines with existing Pipeline Safety penalty
guidelines, creating consistency and transparency agency-wide.
16 TAC Chapter 8 – Pipeline Safety Regulations
TRRC proposes to amend §8.135, relating to Penalty Guidelines for Pipeline
Safety Violations. The proposed amendments would add violations for rules
adopted since the penalty guidelines were initially adopted, and will increase
penalties for some violations that are currently in the rule. The matrix will
include typical penalty amounts for violations of the statutes cited above or
the provisions of a rule adopted or an order, license, permit, or certificate
issued under those statutes, as well as guidelines for penalty enhancements
based on the severity of the violation, the culpability of the person charged,
any prior violations within past seven years, and the amount of previous
penalties for violations within the past seven years.
16 TAC Chapter 18 – Underground Pipeline Damage Prevention
TRRC proposes to amend §18.12 relating to Penalty Guidelines, to add new
violations to the current list, increase penalty amounts for some violations,
and to include provisions for penalty enhancements for certain types of
violations.
Comments for both Chapter 8 and 18 Rule changes are due before March 12, 2012
and can be submitted online at the TRRC website.
For a copy of TRRC’s Chapter 8 & 18 proposed rule changes, contact Jessica Roger.
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.
2012 Industry Conferences at a Glance
It’s not too early to make plans to attend these upcoming events.
RCP will have representatives and/or presentations at each of these
conferences. We hope to see you there!
SGA Spring Gas Conference and Expo
Charlotte, NC
March 19 – 22
API 2012 Pipeline Conference
Phoenix, AZ
April 17 – 19
AGA Operations Conference
San Francisco, CA
May 1 – May 4
LGA 191/192 & 195 Pipeline Safety Conference
New Orleans, LA
July 23 -27
SGA Operating Conference & Exhibits
Ft. Worth, TX
July 23 – 25
International Pipeline Conference
Calgary, Canada
September 24 – 28
PHMSA Leak Detection Workshop March 27 & 28 – Washington, DC
The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) is conducting a 2-day workshop on “Improving Pipeline Leak Detection System Effectiveness and Understanding the Application of Automatic/Remote Control Valves.” This event is to provide an open forum for exchanging information on leak detection systems and Automatic/Remote Control Valves for hazardous liquids and natural gas pipelines.
- March 27 will focus specifically on leak detection systems.
- March 28 will focus on automatic/remote control valves.
The 2-day workshop will be held at the Hilton Washington DC /
Rockville Hotel from 8:00 a.m. to 4:00 p.m. A draft Agenda, hotel and on-line
registration information can be found on PHMSA’s website.
The workshop will also be webcasted in its entirety and no prior registration
is required for the webcast.
Random Federal Register Notice That Has Nothing To Do With Pipelines
Your humble newsletter editor reviews a digest of the Federal Register on a daily basis. Some titles just grab my attention. For example, this notice on January 27, 2012 at 77 FR 4398 (Vol. 77, No. 18):
- Safety Advisory Notice: Return of Radioactively Contaminated Tissue Holders Purchased From Bed Bath and Beyond
I hope my bathroom tissues aren’t giving me brain cancer. Don’t say you weren’t warned!
W. R. (Bill) Byrd, PE
President
RCP Inc.