January 2024 Issue
In This Issue
Changes to the Gas Transmission and Gathering Pipeline Systems Annual Report Form F 7100.2-1
Revised Announcement for Gas Transmission and Regulated Gas Gathering Annual Report Changes:
For the 2024 report to be filed in 2025, any modifications to the gas transmission and regulated gas gathering annual report, approved by the Office of Management and Budget (OMB), will come into effect. Currently, OMB approval has been granted for certain changes, while others are pending and expected to be requested during the next information collection renewal.
Approved Changes in Part F:
- Part F, Section 2 & 5.d: Report only conditions meeting the definitions in §192.714(d) that were repaired.
- Part F, Section 4.d: Report only conditions meeting the definitions in §192.714(d) or Appendix F that were repaired.
Approved Changes in Part M:
Part M4 and M5: Require reporting of gas transmission and regulated gas gathering excavation damages that were repaired in the Calendar Year, categorized by root cause. Also, report the number of excavation tickets received during the year.
Pending Changes in Part Q:
Pipelines subject to §192.624(a) must have their Maximum Allowable Operating Pressure (MAOP) reconfirmed using a method from §192.624(c). Specific instructions for these methods are included in the “§192.624(c) Completion Table.” Pipeline mileage reconfirmed under §192.624(c) methods will no longer be reported in the §192.319 section of Part Q but in the appropriate class location in the §192.624(c) section of Part Q. Accompanying this change is specific language outlining how mileage should be reported in each section of Part Q. Note that OMB approval for these changes is pending and expected during the next information collection renewal.
For more information about the changes to this annual report form or for assistance filing your annual report, contact Jessica Foley.
Unlocking the Power of Legacy Knowledge: A Knowledge Transfer Success Story
In 2023, RCP had the opportunity to collaborate with an Operator on a vital knowledge transfer project, aiming to preserve valuable insights from the client’s retiring staff. Below is a summary of the effort in the form of a case study:
This case study illuminates how ‘Operator,’ a prominent utility company, effectively confronted the challenge of retaining and leveraging knowledge from departing employees. Faced with the imminent loss of crucial expertise, ‘Operator’ initiated a robust knowledge transfer program. The comprehensive approach encompassed identifying key knowledge domains, fostering collaborative mentorship and documentation processes, revising standard operating procedures, and incorporating regular feedback and evaluation. The outcomes were transformative, resulting in a seamless transition, heightened productivity, enhanced collaboration, significant cost savings, and a newfound competitive advantage. The success of this initiative underscores the critical importance of strategic investment in knowledge preservation for sustained success amidst the dynamism of today’s business environment. The unwavering commitment to knowledge transfer not only ensured a smooth transition during a pivotal retirement but also elevated the company’s overall efficiency and competitiveness.
To read the full case study and for details of how RCP can help facilitate a knowledge transfer effort for you, please contact Jessica Foley.
Mississippi One-Call Regulation Changes
On January 5, 2024, Significant Revisions to Mississippi’s Title 77 – Public Utilities and Carriers Chapter 13: Regulation of Excavations Near Underground Utility Facilities of the Mississippi Statutes was revised. The biggest impact of these revisions changes the minimum time for providing notice of intent to excavate to Mississippi 811 from 2 days to 3 working days. Additionally, if the excavation is not concluded within 14 days of the initial notice, the renewal period has been adjusted to a minimum of 3 days and a maximum of 4 days before the markings expire, compared to the previous range of at least 2 and not more than 3 days. All deadlines requiring at least 2 days’ notice have been extended to 3 working days.
The regulations also introduce a reduction in the response time for operators notified through PRIS, requiring them to respond within 2 hours, down from the previous 4-hour window. Additionally, the revisions define ‘impeding emergencies’ and establish specific time constraints for excavations following these notifications.
For more information regarding this One Call Regulation change, please contact Jessica Foley.
Did you know?
DID YOU KNOW? INGAA members take several proactive steps to prepare for winter weather as part of their commitment to the safe, secure, and reliable transportation of natural gas throughout the country. INGAA members’ winterization plans generally focus on three key areas: asset integrity, stakeholder coordination, and personnel safety. Click here to read more.
The Enforcement Corner
The Enforcement Corner summarizes recent PHMSA enforcement actions, indicating where PHMSA is putting its enforcement efforts and the fines they are proposing for various types of violations.
In November 2023, PHMSA issued 5 NOAs, 5 NOPVs, and 6 WLs accompanied by $63,900 in proposed fines. Significant proposed fines were attributed to the following code sections:
- $30,100 49 CFR 192.465(b) External Corrosion Control
- $33,800 49 CFR 192.741(a) Pressure Limiting/Regulating Stations
Please note:
- Pipeline operators may disagree in whole or in part with each proposed violation cited by PHMSA.
- Proposed Civil Penalties (PCP) may be reduced or eliminated before an enforcement action becomes final.
- A Corrective Action Order (CAO) usually addresses urgent situations arising out of an accident, spill, or other significant, immediate, or imminent safety or environmental concerns.
- A Notice of Amendment (NOA) is frequently a result of a difference of opinion regarding written procedure requirements.
- A Notice of Proposed Safety Order (NOPSO) addresses pipeline integrity risks that may not constitute a hazardous facility requiring immediate corrective action (see Corrective Action Order described above), but do need to be addressed over time.
- A Notice of Probable Violation (NOPV) is not proof that a violation actually occurred.
- Proposed Compliance Orders (PCO) frequently document actions the pipeline operator already planned to do.
- Warning Letter (WL) is an official notice by PHMSA that an operator needs to make improvements but that no further enforcement is proposed for those findings at this time.
RCP maintains a detailed database of all PHMSA enforcement actions dating back to 2007 and is routinely asked for data analysis of various enforcement actions. For more information on how RCP can assist with enforcement action data analysis services, contact Jessica Foley.
Need to respond to a PHMSA enforcement action?
Need to know if your enforcement action is an outlier, or par for the course?
RCP maintains a detailed database of all PHMSA enforcement actions and their resolution which enables us to compare and contrast individual enforcement actions to nationwide actions and trends. We can help put things into context to ensure an effective reply for each citation. For more information on how RCP can assist with enforcement action data analysis services, contact Jessica Foley.
2024 Conference News
API Pipeline Conference and Expo: Pipeline, Control Room and Cybernetics
May 6-May 8, 2024 | Hyatt Regency Salt Lake City | Salt Lake City, Utah
Join over 700 industry professionals in Salt Lake City, Utah from May 6-8, 2024, as we explore the evolving landscape of energy sustainability and security. Discover how oil and gas companies are pioneering innovative solutions to climate challenges, sustaining resources today while securing the future through cutting-edge business models. Be sure to visit the RCP booth #306 to visit with our SMEs and snag some swag! Don’t miss out on this opportunity to connect, collaborate, and learn with global leaders shaping the future of energy evolution.
Click here to register for the API Pipeline Conference and Expo: Pipeline, Control Room and Cybernetics.
RCP Speakers:
Mr. Chris Foley, VP “What’s new with 192?”
Join Chris Foley as he discusses the latest changes to CFR 192, governing the transportation of natural gas by pipeline. Discover the updated safety measures, regulatory compliance requirements, and emerging challenges in the industry. Don’t miss this opportunity to stay informed and ensure the safety and reliability of natural gas transportation infrastructure.
When: Monday, May 6 at 2:50 PM | Where: Showbird
Super DUG
May 15-May 17, 2024 | Fort Worth Convention Center | Fort Worth, TX
Don’t miss SUPER DUG 2024, the premier event focusing on energy production in the U.S. shale plays, including the Permian, Eagle Ford, Midcontinent, Bakken, and the Rockies. Following last year’s successful launch, this year’s event is set to be even bigger, with over 2,000 industry professionals, 130+ exhibitors, and 10+ hours of networking opportunities. Connect with key decision-makers from public and private producers, midstream operators, and leading service and technology providers.
Click here to register for Super Dug 2024!
TGA Annual Operations and Management Meeting
June 23-June 27, 2024 | Margaritaville Lake Resort | Montgomery, TX
The TGA Annual Operations and Management Meeting, celebrating its 50th anniversary, stands as the premier event for industry professionals to explore cutting-edge trends and best practices in operations and management. Through engaging discussions, workshops, and networking opportunities, attendees collaborate to drive organizational excellence. Join us for insightful presentations and interactive sessions as we commemorate our rich history and shape the future of operational success together.
Click here to register for TGA’s Annual Operations and Management Meeting.
Florida Natural Gas Association (FNGA) Symposium & Expo
June 24-June 26, 2024 | The Westin Cape Coral Resort at Marina Village | Cape Coral, FL
Discover the latest developments in Florida and gain insights into prominent industry figures at the Florida Natural Gas Association Symposium & Expo. Engage with thought-provoking content presented by esteemed guests and participate in industry discussions designed to enhance your expertise. This event offers invaluable networking opportunities to foster connections crucial for sustaining natural gas’ prominence in energy dialogues. Explore a diverse array of industry suppliers showcasing cutting-edge technologies and innovations essential for efficient natural gas delivery to consumers. Join us to stay informed, connected, and at the forefront of advancements in the natural gas industry.
Click here to register for the FNGA Symposium & Expo.
SGA Operations Conference
July 22-July 24, 2024 | DoubleTree by Hilton Nashville Downtown | Nashville, TN
The SGA Operations Conference is a gathering for professionals in the natural gas industry, specifically tailored for individual contributors to the natural gas industry operations space. This conference provides a platform for industry leaders to share insights, discuss best practices, and explore the latest advancements in operations, asset management, gas control, and technology.
Click here to register for the SGA Operations Conference.