January 2011 Issue
In This Issue
- PHMSA Advisory Bulletin ADB -11-01: MAOP / MOP and IMP
- NTSB Recommendations on San Bruno Incident: Records and MAOP Calculations
- MAOP Analysis Services
- DOT Pipeline Compliance Workshop – January 18-20, 2011
- Extension of Comment Period for Liquid Pipeline ANPRM
- Integrity Management Services
- PIPA Report Published
- O&M Manual Up-To-Date?
- Texas Damage Prevention Summit January 31 — San Marcos, Texas
- Control Room Management Services
- RCP Continues to Add More Firepower to its Staff
- PHMSA Webinar on Annual and Incident Reporting Forms from the One Rule and DIMP
- RCP’s Web-Based Compliance Management Systems
- DIMP Integration
- Key Features
PHMSA Advisory Bulletin ADB -11-01: MAOP / MOP and IMP
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.
NTSB Recommendations on San Bruno Incident: Records and MAOP Calculations
The
National Transportation Safety Board (NTSB) has made several Urgent safety
recommendations to PHMSA, the California Public Utilities Commission, and
Pacific Gas & Electric (the pipeline operator) regarding the San Bruno, CA
pipeline incident. The focus of these recommendations is to ensure that
PG&E specifically, and pipeline operators in general, have adequate
documentation of their pipeline systems, and that they have accurately
calculated the maximum allowable operating pressure (MAOP) of those systems.
The NTSB’s recommendation to PHMSA was:
P-10-1 (Urgent): Through appropriate and expeditious means such as advisory
bulletins and posting on your website, immediately inform the pipeline industry
of the circumstances leading up to and the consequences of the September 9,
2010, pipeline rupture in San Bruno, California, and the National
Transportation Safety Board’s urgent safety recommendations to Pacific Gas and
Electric Company so that pipeline operators can proactively implement
corrective measures as appropriate for their pipeline systems. (emphasis
added)
The NTSB’s Urgent recommendations to PG&E
were:
P-10-2 (Urgent): Aggressively and diligently search for all as-built
drawings, alignment sheets, and specifications, and all design, construction,
inspection, testing, maintenance, and other related records, including those
records in locations controlled by personnel or firms other than Pacific Gas
and Electric Company, relating to pipeline system components such as pipe
segments, valves, fittings, and weld seams for Pacific Gas and Electric Company
natural gas transmission lines in class 3 and class 4 locations and class 1 and
class 2 high consequence areas that have not had a maximum allowable operating
pressure established through prior hydrostatic testing. These records should be
traceable, verifiable, and complete.
P-10-3 (Urgent): Use the traceable, verifiable, and complete records located by
implementation of Safety Recommendation P-10-2 (Urgent) to determine the valid
maximum allowable operating pressure, based on the weakest section of the
pipeline or component to ensure safe operation, of Pacific Gas and Electric
Company natural gas transmission lines in class 3 and class 4 locations and
class 1 and class 2 high consequence areas that have not had a maximum
allowable operating pressure established through prior hydrostatic testing.
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.
DOT Pipeline Compliance Workshop – January 18-20, 2011
Join us January 18 – 20 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 (January 18): 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 (January 19): 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: Control Room Management, Public Awareness Program
Effectiveness Evaluations, and Revised Reporting Requirements.
Day 3 (January 20): 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.
Extension of Comment Period for Liquid Pipeline ANPRM
Docket ID PHMSA-2010-0229
On October 18, 2010, (75 FR 63774) the Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) published an advanced notice of proposed rulemaking (ANPRM) seeking comments on the need for changes to the regulations covering hazardous liquid onshore pipelines. In particular, PHMSA is interested in knowing whether:
- it should extend regulation to certain pipelines currently exempt from regulation;
- other areas along a pipeline should be identified for extra protection or be included as additional high consequences areas (HCAs) for Integrity Management (IM) protection;
- to establish and/or adopt standards and procedures for minimum leak detection requirements for all pipelines;
- to require the installation of emergency flow restricting devices (EFRDs) in certain areas;
- revised valve spacing requirements are needed on new construction or existing pipelines;
- repair timeframes should be specified for pipeline segments in areas outside the HCAs that are assessed as part of IM; and
- whether to establish and/or adopt standards and procedures for improving the methods of preventing, detecting, assessing and remediating stress corrosion cracking in hazardous liquid pipeline systems.
On November 15, 2010, the American Petroleum Institute and the
Association of Oil Pipe Lines requested PHMSA to extend the ANPRM comment
period deadline a minimum of 60 days to give their members sufficient time to
respond to this ANPRM. Likewise, on November 29, 2010, Texas Oil and Gas
Association requested extension of the comment period a minimum of 60 days.
PHMSA has concurred, in part, with these requests and has extended the comment
period from January 18, 2011, to February 18, 2011. This extension will provide
sufficient time for submission of comments concerning this ANPRM.
For further information contact Mike Israni at 202-366-4566 or by e-mail.
Integrity Management Services
| RCP can assist pipeline operators with ongoing compliance management and engineering associated with your IMP. This includes direct assessment strategies, tool and vendor selection, ILI/ECDA report analysis, corrosion control programs, repair strategies, and IMP/risk model updates. For more information on how RCP can support your ongoing IMP needs, Click Here. |
PIPA Report Published
PHMSA
officially released the Pipelines & Informed Planning Alliance (PIPA)
report. A press release was posted to the PHMSA web site. The PIPA Report is available
in its entirety on the Land Use Planning page within PHMSA’s Stakeholder Communications website;
or, you can access these pages more directly by visiting pipelineinformedplanning.com.
PIPA was sponsored by the United States Department of Transportation; Pipeline
and Hazardous Materials Safety Administration, Office of Pipeline Safety
(PHMSA). This report was the result of approximately 130 stakeholder
participants who worked to develop land use practices for consideration of
local governments, property developers and owners, transmission pipeline
operators and real estate boards. The stakeholder participants were divided among
three task teams which addressed issues based on a consensus approach:
- Protecting Communities – Issues relating to land use planning and development on lands adjacent to transmission pipeline ROW
- Protecting Transmission Pipelines – Issues relating to land use and development activities on the pipeline ROW
- Communication – Issues relating to communication of information among pipeline safety stakeholders
O&M Manual Up-To-Date?
RCP has the tools and expertise to develop comprehensive procedures that you need to protect your people, facilities, and environment. Click Here
Texas Damage Prevention Summit January 31 — San Marcos, Texas
The Texas Damage Prevention Summit (a CGA regional event) will be held on January 31, 2011 at the Embassy Suites, San Marcos Conference Center, in San Marcos, Texas. On-line registration and event details can be found on the Texas811 website.
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.
RCP Continues to Add More Firepower to its Staff
David Knoelke, who recently retired from BP Pipelines (North America) as their Sr. Regulatory Compliance Coordinator, has joined RCP as a Senior Advisor. Dave brings a wealth of pipeline industry knowledge and regulatory expertise, particularly in DOT program development and effective implementation of compliance management systems that have withstood tough scrutiny from PHMSA. We are looking forward to his valuable contributions to RCP and our clients.
PHMSA Webinar on Annual and Incident Reporting Forms from the One Rule and DIMP
January 12, 2011
PHMSA
staff will conduct a FREE webinar to discuss the forms that have been approved
by the Office of Management and Budget as part of the “One Rule” final
regulation and the draft distribution annual report changed for DIMP. To ensure
operators are aware and familiar with the revised form, PHMSA will hold this
webinar in conjunction with the American Gas Association (AGA) to demo the IT
system currently under development and to go through the new form to answer any
questions operators may have regarding the new form, online system, and/or the
DIMP requirement.
The Webinar will be held on Wednesday, January 12, 1:30 to 3:00 pm EST and will
include changes to the incident reporting criteria, the national registry for
pipelines and LNG facilities, mechanical coupling failure reporting.
Operators can register for the webinar by going to the following URL http://www.phmsa.dot.gov/pipeline/calendar and
clicking on “Event Details” for the January 12, 2011 “New PHMSA Gas
Distribution Annual Report and Mechanical Fitting Failure Reporting Webinar.”
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.
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.
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.
W. R. (Bill) Byrd, PE
President
RCP Inc.