DOT Pipeline Compliance News

July 2012 Issue

In This Issue

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DOT Pipeline Compliance Workshop – August 7-9, 2012

Join us August 7-9, 2012 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 (August 7): 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 (August 8): 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 (August 9): 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.

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PHMSA Advisory Bulletin (ADB–2012–07) Mechanical Fitting Failure Reports

[Docket No. PHMSA–2012–0079]

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) issued Advisory Bulletin ADB-2012-07 to all Gas Distribution Operators regarding instructions on completing the Mechanical Fitting Failure Report Form, Leak Causes. As specified in §192.1009, operators of all gas distribution pipeline facilities are required to report the failure of any mechanical fitting that results in a hazardous leak on a Mechanical Fitting Failure Report Form (PHMSA F 7100.1–2).

The report is required for all failures regardless of the material composition, type, manufacturer, or size of the fitting. Operators are to report all mechanical fitting failures regardless of the cause. Reporting requirements also apply to failures resulting from the use of a fitting and may include failures in the body of mechanical fitting, failures in the joints between the fitting and the pipe, indications of leakage from the seals associated with the fitting, and partial or complete separation of the pipe away from the fitting.

PHMSA does not seek information related to failures of cast iron bell and spigot joints unless the leak resulted from a failure of a mechanical fitting used to repair or reinforce a joint. The apparent cause options under Part C, Question 15 (Apparent Cause of Leak) on PHMSA F 7100.1–2 contain two potential options for a failure that apparently results from incorrect installation of the mechanical fitting. One option is “Material or Welds/ Fusions” with a subcategory of “Construction/Installation Defect.” The other option is “Incorrect Operation.” PHMSA prefers that failures resulting from an installation defect be reported using “Incorrect Operation” as the apparent cause.

For a copy Advisory Bulletin ADB-2012-07, contact Jessica Roger.

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PHMSA Pipeline Act 2011 / Section 24 Workshop July 13, 2012 – Washington, DC

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) is conducting a free, public workshop to discuss Section 24 of the recently passed Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 and PHMSA’s implementation challenges with Section 24. (See related article in the January Edition of the DOT Pipeline Compliance News.)

Per Section 24, within one year of enactment (January 2013), PHMSA will be required to cease the incorporation of voluntary consensus standards by reference into its regulations unless those standards have been made publicly and freely available on the Internet.

The workshop will be held on Friday, July 13, from 8:00 a.m. to 3:00 p.m. in the West Building, Oklahoma Room of the U.S. Department of Transportation, 1200 New Jersey Avenue SE, Washington, DC 20590. The public workshop will also be Webcast.

To register for this workshop, go to the PHMSA website. The preliminary agenda and link to the Webcast can be found there, too. Name badge pickup and onsite registration will be available starting at 7:30 a.m.

Copies of the presentations will be available on the public workshop Website and in the docket PHMSA–2012– 0142 at http://www.regulations.gov, within 30 days following the workshop.

For more information, contact: Jewel Smith at 202–366–4400.

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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.

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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

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Office of Inspector General Report about IMP Oversight

Report Number: AV-2012-140

On June 18, the Office of Inspector General (OIG) issued a report on the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) oversight of hazardous liquid pipeline operators’ integrity management (IM) programs. These programs include plans, processes, and procedures aimed at reducing the likelihood and severity of pipeline accidents in High Consequence Areas. PHMSA initiated an inspection program to oversee operators’ implementation of their IM programs in 2002. Since then, the program has accomplished much, but still faces challenges that impact the Agency’s oversight of operators’ IM programs. These challenges include:

• managing a growing backlog of inspections,
• identifying IM weaknesses through field inspections, and
• onsite accident investigations, and transitioning to a new risk-based inspection program.

In addition, PHMSA’s oversight of non-line pipe facilities (such as valves, pump and meter stations, and storage tanks) is limited by less rigorous IM requirements, despite recent technological advances that would allow more rigorous oversight of these facilities. Although PHMSA has established a corrective action plan to address long-standing data management deficiencies, the Agency has not yet resolved key deficiencies or established meaningful analysis capabilities to improve its oversight. The OIG made 9 recommendations to improve PHMSA’s oversight; PHMSA concurred with seven and partially concurred with two. However, PHMSA’s responses did not fully meet the intent of six of the recommendations, and the OIG is requesting additional information for these recommendations:

1. Categorize IM requirements as a high priority within the Agency’s integrated inspection and enforcement program. (Did not meet the intent of OIG’s recommendations.)
2. Establish target dates for resolving remaining data system and risk analysis issues affecting PHMSA’s inspection program. (Did not meet the intent of OIG’s recommendations.)
3. Implement a pilot program to determine whether the IM Field Implementation Directive provides sufficient onsite field testing of operator’s IM program implementation. (Resolved but open pending completion of PHMSA’s planned actions.)
4. Expand accident investigation criteria to conduct more Agency onsite reviews of significant accidents potentially involving IM-detectable causes. (Did not meet the intent of OIG’s recommendations.)
5. Update IM requirements to mandate baseline and recurring assessments for non-line pipe facilities, given the availability of new assessment technologies and methodologies. (Resolved but open pending completion of PHMSA’s planned actions.)
6. Establish additional quality assurance procedures to verify the accuracy of operator annual reports and accident data. (Did not meet the intent of OIG’s recommendations.)
7. Develop and implement a program of systematic analyses to better assess pipeline risks, identify safety trends, and focus oversight activities. (Did not meet the intent of OIG’s recommendations.)
8. Create a database of pipeline physical characteristics, accidents, and inspections-including geographic location-of individual pipeline units in order to identify and monitor at-risk pipelines. (Did not meet the intent of OIG’s recommendations.)
9. Develop and implement specific performance measures to assess the impact of the IM program and its individual components on pipeline safety. (Resolved but open pending completion of PHMSA’s planned actions.)

For a copy of Report Number: AV-2012-140 on PHMSA’s IMP Oversight, contact Jessica Roger.

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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.

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PHMSA’s Request for Comments on 811 Public Service Announcement

[Docket PHMSA-2012-0137]

PHMSA invites comments on a new information collection to help determine the effectiveness of PHMSA’s 811 Public Service Announcement (PSA) campaign. In calendar year 2012, as part of a campaign to raise awareness of 811 as the national “Call Before You Dig” toll-free telephone number, PHMSA produced a 30-second video PSA, a 30-second radio PSA and a 60-second radio PSA. All were produced in both English and Spanish and are available in several formats for downloading and broadcasting. PHMSA seeks to measure the effectiveness of the campaign through an online survey. After the comments to this notice are addressed, PHMSA will request approval for this new information collection from the Office of Management and Budget.

Submit comments on or before September 4, 2012 via the E-Gov Website and include docket number PHMSA-2012-0137. For further information, contact Angela Dow at 202-366-1246. Or, for a copy of this notice from the Federal Register, contact Jessica Roger.

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Revised Louisiana Dig Laws Effective August 1!

For the third consecutive year the 2012 Louisiana Legislature has amended Louisiana’s Underground Utilities and Facilities Damage Prevention Act. On the surface, the changes that take effect August 1st don’t sound “earthshaking” but a closer look reveals important new information for everyone involved in excavation. (See related article in the May 2012 Edition of the DOT Pipeline Compliance News.)

An updated version of the law is available on Louisiana One Call’s website where you’ll also find this handy link to the legislature’s markup of the law as enrolled, with new wording underscored and deleted sections struck through.

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Public Awareness Effectiveness Program Inspections

In October, 2009, the NTSB issued a Safety Recommendation that PHMSA initiate a program to evaluate pipeline operators’ public education programs, including pipeline operators’ self-evaluations of the effectiveness of their public education programs. Since then, PHMSA organized an ad hoc team which developed inspection forms and guidance information regarding these inspections, which are scheduled to begin soon.

These two-day public awareness effectiveness inspections will take a close look at the administration and development of operator public awareness programs; program implementation; and the program evaluation process ( including annual audits and effectiveness evaluations). RCP can help you prepare for these inspections. For more information, contact Jessica Roger.

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Advisory Committee Meetings – July 2012

[Docket No. PHMSA–2009-0203]

The Technical Pipeline Safety Standards Committee (TPSSC) and the Technical Hazardous Liquid Pipeline Safety Standards Committee (THLPSSC) will meet on July 11 and 12 to discuss a proposed rulemaking to make miscellaneous changes to the pipeline safety regulations and to discuss several future regulatory initiatives. The agenda will include committee discussions and vote on the proposed rule: “Pipeline Safety: Miscellaneous Changes to Pipeline Safety Regulations” published in the Federal Register on November 29, 2011 (76 FR 73570). PHMSA staff will also brief the committees on several regulatory and policy initiatives.

The TPSSC and the THLPSSC will meet in joint session on Wednesday, July 11, 2012, from 9:00 a.m. to 5:00 p.m. The TPSSC and THLPSSC will meet separately but simultaneously on Thursday, July 12 from 9:00 a.m. to 12:00 Noon followed by a second joint session from 1:00 p.m. to 4:00 p.m. EDT.

The meeting will not be web cast; however, presentations will be available on the meeting website and posted in the E-Gov Website under docket number PHMSA–2009-0203 within 30 days following the meeting.

The meeting will be held at the Marriott at Metro Center, 775 12th Street, NW, Washington, DC 20005. The telephone number is 1-800-228-9290: the local telephone number is (202) 737-2200. Click here for additional information about the hotel. For additional information about the meeting, contact Cheryl Whetsel by phone at 202-366-4431 or by e-mail at cheryl.whetsel@dot.gov.

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Pipeline Regulations for iPhone

There’s an app for that! In 2009, at our request, Tekk Innovations developed an iPhone application containing the federal pipeline safety regulations (49 CFR 40, and 190-199). It has keyword search and the capability to e-mail excerpts of the regulations to others. There have been several updates since the original app was released. The current version 1.6.1 was updated on June 21, 2012. The app can be found in the iTunes store. The cost is $19.99.

Tekk Innovations has also developed apps for all the other CFRs, including all of 49 CFR for those who want all the transportation regulations, not just the pipeline ones; Louisiana Law, California Law and FAA FAR for Pilots.

Editor’s Note: I like the app with just the pipeline parts of 49 CFR, since I can search the pipeline regulations easier that way without getting hits from the other transportation regulations.

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RCP’s DOT Workshop Survey

Have you attended an RCP DOT Compliance workshop recently? We are considering modifying the format of the workshop to prevent duplication of material and to provide more time for special topics. Gas and liquid regulations for each topic would be covered at the same time. For example, pressure testing regulations for gas and liquid pipelines would be discussed on the same day at the same time. Topics such as Operator Qualification and Public Awareness would be discussed once, rather than on both Day 1 and Day 3. However, during a combined workshop, some time will be spent discussing issues that only pertain to gas (or to liquid) operators, which may waste time for operators of only one type of pipeline.

The new format might replace the existing format or we could alternate old and new formats throughout the year.

If you would like to let us know your thoughts, contact Deb Brunt at dbrunt@rcp.com.

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Summer / Fall Industry Conferences

Have you planned your Summer / Fall agenda yet? RCP will have representatives attending these upcoming conferences. Mark your calendar and come join us!

LGA 191/192 & 195 Pipeline Safety Conference
New Orleans, LA / July 23 -27
Stop by RCP’s Booth for a MaxOp* Demo

SGA Operating Conference & Exhibits
Ft. Worth, TX / July 23 – 25
Visit RCP Booth #211 for a MaxOp* Demo

Western Region Gas Conference
Tempe, AZ / August 21 & 22
Stop by RCP’s Booth for a MaxOp* Demo; and, mark your agenda to attend:
Tuesday (Aug 21) Morning Session: “Best Practices for MAOP Validation” – Presented by Chris Foley

International Pipeline Conference
Calgary, Canada / September 24 – 28
Visit RCP Booth #527 at the IPE Expo

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API Damage Prevention Workshop September 12 -13, Houston, TX

Registration is now open for API’s Damage Prevention Workshop that will be held at the Doubletree Hotel, 15747 John F. Kennedy Boulevard in Houston. Click here for registration information and preliminary agenda. The deadline for pre-registration is September 5.

Day One – September 12 1PM – 5PM
A team has been formed to collect industry damage prevention practices into a virtual toolbox. The toolbox and the practices in it will be presented and discussed. Who can contribute to the toolbox? What sorts of practices are in it? How can the toolbox be accessed?

Day Two – September 13 8AM – 12:00 PM
There will be discussion of excavation damage incidents and near miss events that resulted from existing exemptions from the use of one-call laws and what the strategies that have and may be employed to reduce the occurrence of such accidents. Would laws simply eliminating or severely limiting such exemptions be desirable? What are the pros and cons? What additional burdens may be placed on industry to screen and respond to additional one calls if existing exemptions are eliminated? Are there certain exemptions that the pipeline industry wants to retain? What industry practices have been particularly effective?
API has arranged a discounted room block at the Doubletree Hotel at George Bush Intercontinental Airport for $159/night. Reservations can be made by calling 281-848-4001. Please be sure to mention the API meeting. The cut-off date for making room reservations is August 29, 2012.

For more information, contact Madeleine Sellouk.

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