DOT Pipeline Compliance News

February 2020 Issue

In This Issue

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PHMSA NPRM Valve Installation and Minimum Rupture Detection Standards

[Docket No. PHMSA-2013-0255]

PHMSA’s Notice of Proposed Rulemaking (NPRM), “Amendments to Parts 192 and 195 to Require Valve Installation and Minimum Rupture Detection Standards” is scheduled to be published in the Federal Register on February 6^th.  PHMSA is proposing to revise the Pipeline Safety Regulations applicable to newly constructed and entirely replaced onshore natural gas transmission and hazardous liquid pipelines with nominal diameters greater than or equal to 6 inches by requiring operators of these lines to install remote-control or automatic shutoff valves, or equivalent technology in order to mitigate ruptures.

PHMSA is also proposing to revise the regulations regarding rupture detection for certain pipelines in high-consequence and select non-high-consequence areas to shorten pipeline segment isolation times; requirements for valve maintenance and inspection, valve spacing, rupture-mitigation valve risk analysis, post-incident investigation and review, and local 911 notification to help operators achieve better rupture response and mitigation.

Comments will be due 60 days after the NPRM publishes in the Federal Register. For a copy of this NPRM (once it’s published in the Federal Register), contact Jessica Foley.

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PHMSA Houston-area Meetings February 25-27

Marriott Hotel in sugar land, Texas

PHMSA is holding 3 days of Operator and public meetings at the Marriott Hotel in Sugar Land, Texas on February 25-27. If you wish to attend the Operator meeting, please RSVP no later than February 12, 2020. Registration, agenda and hotel information can be found on the PHMSA meetings webpage.

• Operators Meeting, February 25 (Tuesday):  An operator-only meeting for pipeline and LNG operators, from 8:00 AM to 5:00 PM. This meeting is an open discussion on a variety of subjects including how PHMSA develops its annual inspection plans, how each system-specific inspection protocol is created, general enforcement processes, and lessons-learned from incidents and accidents. PHMSA intends to answer your questions, and provide you with an opportunity to speak with PHMSA outside of the inspection environment. The Operators Meeting is only open to pipeline and LNG company employees, excluding contractors, and reservations are limited to a maximum of two representatives per company. Due to the meeting format, the Operators Meeting will not be webcast. Space is limited to 350 attendees and will be available on a first-come, first-served basis. If you wish to attend, please click here to RSVP no later than February 12, 2020. Registration at the door will not be available.

• Implementing the Gas Transmission & Hazardous Liquid Final Rules, February 26-27, (Wednesday & Thursday): Public meetings are being held related to implementation of the newly issued Final Rules for Gas Transmission and Hazardous Liquid pipelines, published in the Federal Register on October 1, 2019. During the afternoon of Wednesday, February 26th, PHMSA will also host a forum to discuss Safety Management Systems (SMS) principles, inclusive of highlighting the benefits of developing an effective safety culture. Online registration is closed; however, both meetings will be webcast. Go to the PHMSA meeting webpage for more information.

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PHMSA publishes final rule: Safety of Underground Natural Gas Storage Facilities

On February 12^th, PHMSA published a final rule to amend its minimum safety standards for underground natural gas storage facilities (UNGSFs). On December 19, 2016, PHMSA issued another final rule establishing regulations in response to the 2015 Aliso Canyon incident and the subsequent mandate in section 12 of the PIPES Act of 2016. The rule incorporated by reference two API Recommended Practices (RPs):

• API RP 1170, ‘‘Design and Operation of Solution-mined Salt Caverns Used for Natural Gas Storage’’ (First Edition, July 2015); and
• API RP 1171, ‘‘Functional Integrity of Natural Gas Storage in Depleted Hydrocarbon Reservoirs and Aquifer Reservoirs’’ (First Edition, September 2015).

Six key take-aways from this final rule:

1. PHMSA adopts the RPs without modification to the nonmandatory terms. In the final rule, PHMSA adopted the RPs by modifying the nonmandatory provisions (i.e., statements containing ‘‘should’’ and other nonmandatory terms) as mandatory requirements (i.e., ‘‘shall’’). PHMSA provided that operators could deviate from the modified statements by providing a justification in their procedure manuals as to why the provision was ‘‘not practicable and not necessary for safety’’ at their specific facility. The final rule no longer requires operators to provide written justifications as to why they would not have performed a ‘‘should’’ provision.
2. The final rule formalizes requirements and deadlines for operators to develop and implement their integrity management (IM) programs and to conduct their baseline risk assessments for UNGSFs. PHMSA is relaxing the timeline for completing initial assessments of the reservoirs, caverns, and wells.
3. The final rule includes a requirement for solution-mined salt caverns to follow the same risk management practices as depleted hydrocarbon reservoirs and aquifers that apply to the physical characteristics and operations of the facility (i.e., follow section 8 of API RP 1171). Section 8 of API RP 1171 provides more prescriptive practices than API RP 1170 for how an operator must develop, implement, and document a program to manage risks that could affect the functional integrity of the storage operation.
4. PHMSA is narrowing the scope of reportable events and changes at facilities. PHMSA is limiting notification of changes to a facility 60 days prior to the following events: (1) All plugging or abandonment activities (regardless of costs), and (2) construction or maintenance that requires a workover rig and costs $200,000 or more. PHMSA is also applying an emergency exemption to the 60-day notification requirements, which PHMSA overlooked in the IFR.
5. The final rule is revising the definition of an ‘‘underground natural gas storage facility’’ to exclude other components of a gas pipeline or gas pipeline facility covered elsewhere in part 192, and eliminate any potential overlap.
6. PHMSA is changing the name of the reporting portal to the ‘‘National Registry of Operators’’ (formerly the ‘‘National Registry of Pipeline and LNG Operators’’). Additionally, PHMSA is revising the name of the online portal’s web address from ‘‘http://opsweb.phmsa.dot.gov’’ to https://portal.phmsa.dot.gov. These changes are throughout parts 191, 192, and 195.

The effective date of the rule is March 13, 2020. For a copy of the final rule and/or to learn more about how RCP’s incredible group of UGS subject matter experts can assist UGSF operators with their integrity and risk management programs, contact Jessica Foley or click here.

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Changes to the PHMSA Incident forms for Gas Distribution, Gas Transmission & Gathering, and Liquified Natural Gas Reports

Several changes to the required incident forms for Gas Distribution, Transmission, and LNG unintentional releases will occur shortly. This article focuses on the Gas Transmission and Gathering incident form changes, though these changes will appear in each incident report. The changes include:

• Question and answer choices focusing on the chronological event log and operator actions.
• Selections for the item involved in the failure has also been updated to limit the number of “other” selections.
• Injuries that do NOT require overnight hospitalization, such as visits to a hospital for treatment or treatment onsite by Emergency Medical personnel will now be recorded.
• In addition to the cost of public private property damages, the number of buildings affected, residential and business, will also be recorded.
• Third party damages will now include a question about One-Call State law exemptions contributing to the event; and for outside force events caused by vehicles not engaged in excavation, several questions have been able to help describe the driver and circumstances of the accident.

There are two new sections, Part J and Part K. Part J combines and adds to the available list of In-line inspection tools that can be selected for integrity assessments. PHMSA will also require the most current inspection tool, what it was attuned to detect, and the previous inspection year for the same tool type. More up-to-date direct inspections choices, such as Stress Corrosion Cracking Direct Assessment (SCCDA), will also be included in Part J.

Part K considers contributing factors to an incident. Operators will select the root cause from the usual causes and then in Part K, can select any other cause or sub-cause(s) that were present and identified at the time of the failure and its subsequent investigation. Each contributing factor should be described briefly in Part H in the narrative of events.

These form changes will take place in the next month. Changes mirroring those for the Gas Transmission & Gathering Incident report form will likely occur to the Hazardous Liquids Accident report form soon as well.

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Gas Transmission & Hazardous Liquid Draft FAQs Posted

[Docket No. PHMSA-2019-0225]

PHMSA has released draft frequently asked questions (Gas FAQs and Hazardous Liquid Pipeline FAQs) with draft answers to guide implementation of both final rules issued on October 1, 2019.  PHMSA requests comments on the drafts by February 11, 2020 to facilitate discussion at the meetings on pipeline safety issues scheduled on February 25-27 in Sugar Land, Texas.  The public comment period on the FAQs will remain open until March 27, 2020. Submit comments on the regulations.gov website.

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OMB Public Comments on Improving / Reforming Regulatory Enforcement

[Docket No. OMB–2019–0006]

Have an opinion about regulatory enforcement, with supporting examples?  Here’s your chance to tell inspectors and regulators what you think! The Office of Management Budget (OMB) wants to hear from you. Interested parties should submit comments identified by Docket No. OMB–2019–0006, to www.regulations.gov. Comments are open until March 16. For a list of topics the OMB is interested in feedback on, contact Jessica Foley for the Federal Register notice.

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TRRC Pipeline Mileage Fees Due April 1

The Texas Railroad Commission (TRRC) is reminding pipeline operators that their 2020 pipeline mileage fees are due April 1, 2020. Operators will use the number of miles they have permitted as of December 31, 2019 to calculate their 2020 pipeline mileage fee. This year’s mileage charts and other information on the fees can be found here.

All mileage fees are required to be paid through the Pipeline Online Permitting System (POPS) in the TRRC online system. View POPS instructions here.

For additional information, contact TRRC’s Pipeline Safety Department at POPS@rrc.texas.gov or (512)463-6802.

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National Pipeline Mapping System Revisions

Every operator of a pipeline facility (except distribution lines and gas gathering lines) must provide PHMSA geospatial data, attributes, metadata, contact information and a transmittal letter appropriate for use in the National Pipeline Mapping System (NPMS). Operators submit this information each year on or before March 15 for gas transmission and LNG plant operators, or June 15 for hazardous liquid operators. PHMSA uses this data to maintain and improve the accuracy of the NPMS’ information.

PHMSA acknowledges operators’ concerns regarding the amount of time needed to compile, research, and/or prepare the data required for this information collection.  PHMSA is expanding the data attributes collected and will require these new data elements in three phases. Phase 1 data will be collected no earlier than March 15/June 15, 2022 (CY 2021 data) in the first submission year; Phase 2 data will be collected the second submission year; and, Phase 3 data will be collected in 2024. The data elements in each phase are listed below.

Phase 1 Data

• Pipe diameter
• Commodity detail
• Pipe material
• Pipe join method
• Onshore/offshore
• In-line inspection (yes/no)
• Class location
• Gas HCA segment
• Abandoned pipelines
• Breakout tanks
• LNG plants
• Coated (yes/no)

Phase 2 Data

• Seam type
• Pipe grade
• Wall thickness
• FRP Sequence Number
• Decade of installation
• Segment could affect an HCA
• Assessment method
• Assessment year

Phase 3 Data (Collected in 2024)

• New standards will be released for to improve positional accuracy of pipeline operator’s NPMS Submissions.

In addition, NPMS has recently released updates of the data utilized for determining High Consequence Areas (HCA) as follows:

• Version 5 of the Commercially Navigable Waterways (CNW) data is now available from NPMS.  This data is reviewed and updated as needed every two years.  (Released 11/2019)
• New Great Lakes Unusually Sensitive Area (USA) is now available.  This data can be viewed on a pipeline map in PIMMA or the NPMS Public Map Viewer. (Released 10/2019)
• High Population Area (HPA) and Other Population Area (OPA) data were updated and are available from NPMS. (Released 2/2018)

NPMS Drinking Water USA have not been updated since 1999.   Drinking water USA are defined by the following criteria:

• The surface water intake for Community Water Systems and Non-Transient Non-Community Water Systems that do not have an Adequate Alternative Drinking Water Source;
• The Source Water Protection Area for Community Water Systems and Non-Transient Non-Community Water Systems that obtain their water supply from a Class I or Class IIA aquifer and do not have an Adequate Alternative Drinking Water Sources, if available. If the Source Water Protection Area is not available, the Wellhead Protection Area (WHPA) becomes the USA; and
• The aquifer recharge area for sole source aquifers that are karst in nature

RCP has updated our Drinking Water USA data in 2020 for the state of Texas utilizing the above criteria with Texas Commission of Environmental Quality (TCEQ) water source data.  This data is utilized exclusively by RCP to provide our clients up to date/accurate HCA evaluations within their Integrity Management Plan.
For more information on this topic, please email Jessica Foley.

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Pipeline Research & Development Forum

February 19-20, 2020

The Pipeline and Hazardous Materials Safety Administration will hold their next Pipeline R&D Forum on February 19-20, 2020 in Arlington, VA from 8:00 a.m. to 4:30 p.m. ET. On-site registration will begin at 7:00 a.m. on both days. The forum allows public, government and industry pipeline stakeholders to develop recommendations on the technical gaps and challenges for future research. The national research agenda coming out of these events is aligned with the needs of the pipeline safety mission, makes use of the best available knowledge and expertise, and considers stakeholder perspectives. Specifically, the forum:

1. Identifies key pipeline technical challenges facing industry and government;
2. Disseminates information on current research efforts; and
3. Identifies new research that can help to meet known challenges.

The Pipeline R&D Forum will also provide an opportunity to discuss the potential need for establishing an integrated safety research, development, and testing facility at the Transportation Technology Center located in Pueblo, Colorado. This would create a world class national pipeline safety research facility used to accelerate innovation and bring new safety technologies to market more quickly than is currently possible.

Additional information can be found on PHMSA’s Public Meetings website.

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What can TaskOp™ do for you? Webinar

february 17, 2020

New Regulations have you Stressed Out…Don’t Panic…TaskOp™ has your back

This webinar will demonstrate how TaskOp™ can be used to track all of the complex activities associated with the new gas transmission and hazardous liquid regulations.

• Manage inventory of all segments with non-TVC records through the lifespan of MAOP reconfirmation and material verification efforts.
• This is done with easy-to-use dashboards to:
  • Track reconfirmation mileage progress.
  • Track all your scheduled projects to get your newly regulated pipelines in step with regulations.
  • Manage workloads across your compliance team.
• Track implementation progress of new regulatory requirements, including procedure updates, material verification digs, data analysis, assignments of responsibility.
• Utilize the calendar for upcoming agency audits and internal field training / audits:
  • Keep up to date with what is coming up and be better prepared for any type of audit.
  • Keeps track of all your audit details, findings, follow up records, etc.
  • Manage your audit findings by assigning them to personnel, track their progress, and keep track of documentation.
• After everything is in order, you can manage your new workflow tasks for all the newly regulated pipelines within TaskOp™.
  • Track inspections, maintenance, and other tasks related to your pipelines.
  • Keep everything traceable, verifiable, and complete all in one system.

Click here to register for our What can TaskOp™ do for you? webinar.

TaskOp now has the ability to track inventory and work with barcodes. 
We’re taking TaskOp to the next level with barcoding. Let TaskOp track your warehouse inventory of spare valves, meters, parts, etc. and track when they are pulled for projects in the field. Know when you need to reorder items, where items are used and track invoices for accounting purposes.  Barcode scanning allows users to quickly scan a barcode to find the part. If you are just starting a warehouse, or barcoding assets, TaskOp can generate those barcodes to print and stick to your inventory – the data required to find records quickly, via scanning the barcode, will already be in TaskOp.

As an added bonus, use barcodes to quickly pull up the latest field tasks without having to search the system.  If your assets have barcodes on them and that information is in the asset data in the system, you can scan the barcode and the latest active tasks for that asset will appear in a report,  greatly reducing the time needed to find those tasks that a field technician will be doing.

Visit www.rcp.com or contact Jessica Foley for more information.

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2020 Industry Conference Schedule

Have you registered and confirmed your reservations for these upcoming conferences? RCP will be attending the following conferences. We hope to see you there!

Pipeline Pigging and Integrity Management (PPIM) Conference
February 17-21, 2020
George R. Brown Convention Center; Houston, TX
RCP Booth #412 / Be our Guest and Click Here for a Free Exhibition Pass.

PPIM is the industry’s only forum devoted exclusively to pigging for maintenance and inspection, as well as pipeline integrity evaluation and repair. This event will draw engineering management and field operating personnel from both transmission and distribution companies concerned with improved operations and integrity management.

AIChE Spring Meeting & 16^th Global Congress on Process Safety
March 29 – April 2, 2020
Hilton Americas and George R. Brown Convention Center; Houston, TX

The AIChE Spring Meeting is the year’s key technical conference for practicing chemical engineers. A wide range of subjects relevant to the current needs of industry is covered. Plus, the Global Congress on Process Safety covers the critical needs of process safety practitioners more broadly and deeply than any other conference.

API Pipeline Conference, Control Room Forum and Cybernetics Symposium
April 28-30, 2020
Hyatt Regency Mission Bay; San Diego, CA

API’s Pipeline Conference is the premier event of its kind in the U.S.  Held every year in April, the conference provides attendees with an opportunity to hear about the latest in pipeline-related developments.  Once again, RCP is a proud sponsor of this event and we look forward to seeing you there.

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We would welcome the opportunity to discuss our services with you.

Sincerely,

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