June 2011 Issue
In This Issue
- Low Stress Liquid Pipeline Jurisdiction Final Rule
- Jurisdictional Determination
- PHMSA Advisory Bulletin (ADB-11-03) Deadline for 2010 Mapping Reports
- DIMP Inspection Forms Updated
- Pending Audits?
- Advisory Committee Meetings & New Subcommittee Meetings
- State of the National Pipeline Infrastructure Report
- Public Awareness Effectiveness Program Inspections
- Public Meetings on Managing Challenges with Pipeline Seam Welds and Improving Pipeline Risk Assessments and Recordkeeping
- Control Room Management Services
- PHMSA Hazardous Liquid Annual Report Webinar
- Summer Gas Conferences
Low Stress Liquid Pipeline Jurisdiction Final Rule
[Docket PHMSA-2008-0186; Amdt. 195-96]
On
May 5, 2011, PHMSA finalized their Phase II rulemaking for low stress liquid
pipelines, as required by the PIPES Act. This rulemaking creates 3 (actually 4)
categories of low stress pipelines. Low stress pipelines that are in non-rural
areas or which cross navigable waters have long been regulated by PHMSA. That
is the 4th category of low stress liquid pipelines, in your editor’s humble
opinion, which he has taken the liberty of calling Category 0 pipelines.
Category 1 pipelines are those that are greater than or equal to 8″ o.d.
and within 1/2 mile of a USA. These pipelines were regulated by the earlier
Phase I rulemaking (see related article in the June 2008 edition of the DOT Pipeline
Compliance News for additional details). The latest rulemaking creates
Category 2 pipelines, which are identical to Category 1 pipelines but are less
than 8″ o.d., and with later compliance deadlines. The latest rule also
establishes Category 3 pipelines, which are any low stress pipelines that are
not Categories 0, 1 or 2. Category 3 pipelines have the same compliance
deadlines as Category 2 pipelines, but are not required to develop a pipeline
integrity management plan.
It is important to note that, while the deadlines for compliance may be in the
future, these newly regulated low stress pipelines are required to comply with
the complete set of DOT pipeline safety regulations (except for IMP, for
Category 3 pipelines). This includes Control Room Management, Public Awareness,
Corrosion Control, and O&M procedure manuals.
Contact Jessica Roger for a simplified table that
contains all the compliance deadlines for each category of low stress pipeline
and a copy of the Final Rule.
Jurisdictional Determination
Is there uncertainty as to whether a pipeline meets the applicability of 49 CFR 195 or 192? RCP can answer your questions regarding the jurisdictional status related to pipelines that may be regulated by the Department of Transportation Pipeline and Hazardous Materials Safety Administration (DOT/PHMSA). Click here to request more information on how RCP can help.
PHMSA Advisory Bulletin (ADB-11-03) Deadline for 2010 Mapping Reports
[Docket No. PHMSA–2011–0121]
The
Department of Transportation/Pipeline Hazardous Materials Safety Administration
(PHMSA) recently published advisory bulletin (ADB-11-03) advising owners and
operators of gas transmission and gathering systems and Liquefied Natural Gas
(LNG) facilities that they have until August 15 to submit their Calendar Year
2010 Annual Reports.
The Pipeline and Hazardous Materials Safety Administration (PHMSA) published a
final rule on November 26, 2010, under Docket No. PHMSA 2008-0291 [75 FR
72878], titled: “Pipeline Safety: Updates to Pipeline and Liquefied Natural Gas
Reporting Requirements” (One Rule). This rulemaking revised the Pipeline Safety
Regulations (49 CFR Part 190-199) to improve the reliability and utility of
data collections from operators of natural gas pipelines, hazardous liquid
pipelines, and LNG facilities. As a result of the rulemaking, several annual
and incident report forms were created while other forms were revised. Included
among these forms, PHMSA created a new Annual Report for LNG facilities (LNG
Annual Report; PHMSA F-7100.3-1) and revised the Annual Report for Natural or
Other Gas Transmission and Gathering Systems (Gas Transmission and Gathering
Annual Report; PHMSA F-7100.2-1). The One Rule revised §191.17 to specify that
these reports should be submitted no later than March 15 for the preceding
year, except for Calendar Year 2010, where reports should be submitted by June
15, 2011. This delayed reporting date for Calendar Year 2010 was added to allow
companies time to update their information for submission according to the
revised form.
After the One Rule was published, PHMSA received a petition from the American
Gas Association (AGA) on December 22, 2010, asking for reconsideration of the
information collected on the LNG Annual Report form. PHMSA reviewed the
petition and has revised the form based on AGA’s recommendation. PHMSA is using
this notice to extend the reporting date for the LNG Annual Report form to
August 15, 2011, to allow further time to prepare the electronic system PHMSA
will use to collect the information. Next year, the filing date will go back to
the March 15 date specified in the regulation.
PHMSA also received a number of questions regarding NPMS submissions. The NPMS
consists of geospatial data, attribute data, public contact information, and
metadata pertaining to the interstate and intrastate hazardous liquid
trunklines and hazardous liquid low-stress lines as well as gas transmission
pipelines, LNG plants, and hazardous liquid breakout tanks regulated by PHMSA.
Most operators submit their NPMS data to PHMSA at the same time they file their
annual report. Although PHMSA is extending the filing date for annual report
submissions, operators are encouraged to file their NPMS data at their
regularly scheduled times.
For a copy of ADB-11-03, contact Jessica
Roger.
DIMP Inspection Forms Updated
PHMSA has issued newly released inspection forms for the Distribution Integrity Management Program (DIMP) from the DIMP Implementation team:
- DIMP Inspection Form for 192.1015: For Master Meter and Small LPG Operators of Gas Distribution Systems – Version 4/11/2011
- DIMP Inspection Form for 192.1005 – 192.1011: For Operators of Gas Distribution Systems – Version 5/2/2011
Contact Jessica Roger for more information.
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.
Advisory Committee Meetings & New Subcommittee Meetings
[Docket No. PHMSA-2011-0127]
PHMSA
has announced meetings of the Technical Pipeline Safety Standards Committee
(TPSSC) and the Technical Hazardous Liquid Pipeline Safety Standards Committee
(THLPSSC) and the creation of a subcommittee to assist PHMSA in the preparation
of a pipeline safety report to the nation. PHMSA will host a series of meetings
with a newly formed subcommittee to review and consider information gathered in
response to the U.S. Department of Transportation’s and PHMSA’s action plan and
information related to a recent pipeline safety forum. PHMSA is also requesting
general public comments including comments on a report titled, “The State
of the National Pipeline Infrastructure-A Preliminary Report.” (See
related article in this issue of the DOT Pipeline Compliance News.)
Following several major pipeline accidents, the Secretary of Transportation
issued a “Call to Action” and held a pipeline safety forum to engage
pipeline safety experts, researchers, industry representatives, state partners,
other Federal agency officials, and members of the public to identify actions
to address America’s pipeline transportation infrastructure. In response to the
“Call to Action,” the U.S. Department of Transportation and PHMSA
published a report titled: “State of the National Pipeline Infrastructure-Preliminary
Report” and launched a website for public engagement and regular
reporting to the public. This website includes information such as ongoing
pipeline rehabilitation, replacement and repair initiatives along with all
forum-related comments. PHMSA continues to invite comments on the Preliminary
Report in addition to any other ideas that may be relevant to pipeline safety.
Following the forum, a subcommittee of the TPSSC and THLPSSC was established to
work with PHMSA staff to assist in the creation of a pipeline safety report to
the nation. The subcommittee is made up of six members, three each from the
TPSSC and THLPSSC, with equal representation from government, industry, and the
public. At the joint advisory committee meeting in August, the subcommittee
will present its recommendations and a draft of the pipeline safety report to
the nation for the joint committees’ review and deliberation.
The meeting dates are as follows:
- June 15, 2011, 9 a.m. to 4 p.m., subcommittee kick-off meeting, Washington, DC. The agenda includes an introduction of the subcommittee and discussion of the subcommittee’s task. This meeting will provide the public an opportunity to participate in an exchange of ideas and recommendations, including a discussion of the report outline, prior to the subcommittee’s preparatory meetings.
- June 16, 2011, 9 a.m. to 4 p.m., subcommittee preparatory meeting, Washington, DC (no public statements accepted).
- July 13-14, 2011, 9 a.m. to 4 p.m., subcommittee preparatory meeting, Washington, DC (no public statements accepted).
- August 2-3, 2011, 9 a.m. to 5 p.m., TPSSC and THLPSSC joint public meeting, Washington, DC. The agenda will include an overview of the subcommittee’s deliberations and summary of the draft final report. Public statements can be accepted.
The meeting locations and any new information or changes will be
posted on the PHMSA/Office of Pipeline Safety “Pipeline Safety
Awareness” website 15 days before the meeting takes
place. The public is encouraged to attend the subcommittee kick-off meeting and
the joint Advisory Committee meetings. Members of the public may make a
statement during the public committee meetings. Statements previously submitted
at the forum should not be repeated. If you intend to make a statement, please
notify the relevant contact at least 15 days prior to the meeting date. The
meetings’ presiding officer may deny a nonscheduled request to make a statement
and may also limit the time of any speaker.
Attendees should register for the June 15 and August 2-3 meetings in advance
at: http://primis.phmsa.dot.gov/meetings/. On-site
registration for each meeting will be available 30 minutes prior to the meeting
start time. The meetings will not be webcast; however, presentations will be
available on the meeting Web site and posted in the E-Gov website under docket number
PHMSA-2011-0127 within 30 days following the meeting.
Comments on “The State of the National Pipeline Infrastructure-A
Preliminary Report” must be received on or before July 13, 2011, to be
considered by the subcommittee members prior to submission of their draft
recommendations to the parent committees.
For further information contact:
- Technical Advisory Committee Meeting Details: Cheryl Whetsel 202-366-4431 or by e-mail.
- Report to the Nation on Pipeline Safety: Linda Daugherty 202-366-4595 or by e-mail.
State of the National Pipeline Infrastructure Report
[Docket No. PHMSA–2011–0127]
The
Department of Transportation/Pipeline Hazardous Materials Safety Administration
(PHMSA) issued a Preliminary report on the “State of the National Pipeline
Infrastructure.” This preliminary report serves as an introduction to what
is known about our nation’s pipeline infrastructure, what we need to know
better, and what PHMSA is already doing and planning to do to address pipelines
of concern.
The report states that, “The vast majority of pipelines are in good
condition. . . And the overall trend in pipeline safety has been steadily
improving.” The report goes on to state that, “The percentage of pipe
that is or has become unfit for service is small, and the vast majority of
pipelines are well built, monitored, inspected, assessed, operated, and
maintained.”
Their statistics indicate that corrosion is the leading cause of releases on
gas transmission and hazardous liquid pipelines, followed by material/weld
failures, equipment failures, and excavation damage. For gas distribution
pipelines, which are concentrated in populated areas where excavation activity
is particularly active, excavation damage and other outside force damage are
the major causes.
Recent accidents in San Bruno, California and Allentown, Pennsylvania have
raised questions in the public’s mind about the safety of older pipelines.
PHMSA is taking a hard look at the causes and characteristics of these failures
to see how future incidents can be prevented. PHMSA is assessing how to
accelerate the replacement of pipe to ensure public safety and the reliability
of our critical pipeline system into the future.
The Department of Transportation has issued a call for action to identify pipe
with the poorest performing characteristics within our nation’s pipeline system
and to determine the course of action needed regarding the repair,
rehabilitation, or replacement of these pipelines; which may include the need
to:
- oversee the replacement of this pipe to ensure that it is being replaced
- oversee operators and take interim actions to step up the monitoring of these facilities to reduce the risk of incidents while the pipe is being replaced.
- expand funding for research and development of new tools to improve pipeline assessments.
- ensure through inspections that operators are performing these practices and performing them effectively.
PHMSA is planning a broad-based workshop in August to discuss
these issues, share experiences, and improve knowledge. This workshop may lead
to new or more stringent requirements for assessing and reducing pipeline
risks.
For a copy of this 12-page preliminary report, contact Jessica Roger.
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.
Public Meetings on Managing Challenges with Pipeline Seam Welds and Improving Pipeline Risk Assessments and Recordkeeping
[Docket ID PHMSA-2011-0125]
Recent
pipeline incidents involving seam weld anomalies and gaps in data and
recordkeeping are driving a stronger focus on better managing these challenges.
PHMSA is holding important public meetings to discuss its review of inspection
reporting and incident findings in these areas. In addition, these public
meetings are part of PHMSA’s efforts to address the Secretary of
Transportation’s “Call to Action” to address pipeline infrastructure
risks, drive for more aggressive safety efforts and to be more transparent when
executing these safety measures. These public meetings are designed to provide
an open forum for exchanging information on the challenges associated with
pipeline seam welds and improving pipeline risk assessments and recordkeeping.
On July 20, 2011, from 8 a.m. to 4 p.m. EDT, PHMSA will host a meeting on Managing
Challenges With Pipeline Seam Welds. This meeting will not be
webcasted. The objectives for the meeting include:
- Further determining the nature and extent of the seam weld issue from industry and government data.
- Presenting perspectives on how anomalies in seam welds are identified and managed employing risk assessments, technology and standards or best practices.
- Presenting the scope of a recently awarded PHMSA research study on seam welds.
- Providing specifically designed working groups to further craft the scope for this PHMSA research study and other related topics.
Preliminary Agenda:
8 a.m. Welcome
8:10 a.m. Panel 1: What is the Nature/Extent of the Issue?
9:40 a.m. Break
9:55 a.m. Panel 2: Identifying/Managing Seam Weld Challenges
11:10 a.m. Presentation: Seam Weld Research Project and Input/Refinement of
this Targeted Research
12 p.m. Lunch-On your Own
1:30 p.m. (Concurrent Sessions)
- Working Group 1: Identifying Gaps in Risk Assessments
- Working Group 2: Identifying Gaps in Technology
- Working Group 3: Identifying Gaps with Assessment Methods
4 p.m. Adjournment
On July 21, 2011, from 8 a.m. to 4:30 p.m. EDT, PHMSA will host a meeting on Improving
Pipeline Risk Assessments and Recordkeeping. This meeting will
be webcasted. The objectives for the meeting include:
- Provide a U.S. and International regulatory perspective on pipeline integrity risk assessments.
- Provide an operator overview of the challenging factors with conducting risk assessments, canvassing effective approaches, and case studies.
- Identify options with addressing interactive threats, legacy pipelines and approaches for dealing with recordkeeping gaps.
Preliminary Agenda:
8 a.m. Welcome
8:10 a.m. Panel 1: U.S. & Canadian Regulatory Perspective on Risk
Assessments
9:30 a.m. Panel 2: Pipeline Operator Perspective on Risk Assessments
Break taken during panel 2
11:30 a.m. Lunch-On your Own
1 p.m. Panel 3: How Should Recordkeeping Gaps Influence Risk Assessments?
2:30 p.m. Break
2:45 p.m. Panel 4: Identifying Interactive Threats and Understanding Options
4:30 p.m. Summary and Adjournment
Please visit http://primis.phmsa.dot.gov/meetings/ and
click on these public meetings to register.
These public meetings will be held at The Westin Arlington Gateway, 801 North Glebe
Road, Arlington, VA 22203, Phone: 703-717-6200. Please contact the Westin to
reserve a room using “USDOT/PHMSA” for the room block name at the
rate of $157/night. This room rate is available for Tuesday night July 19 and
Wednesday night July 20 until the reserved rooms at this rate are taken. A very
limited number of rooms are available at this rate on July 21.
For further information contact: Robert Smith by e-mail
or by phone at 919-238-4759.
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.
PHMSA Hazardous Liquid Annual Report Webinar
June 9, 2011 1:30 PM – 3:00 PM EDT
PHMSA
has scheduled a webinar to demonstrate its online reporting system for the new
hazardous liquids pipeline operator annual report (Form PHMSA F 7000-1.1): June
9, 1:30 – 3:00 PM EDT. You can register at http://opsweb.phmsa.dot.gov/webinars. PHMSA
welcomes your questions in advance of the event to assure that operator issues
are addressed by subject matter experts during the webinar or in FAQs. Send
them to Roger Little, Team Lead – Data Analysis, at roger.little@dot.gov.
An archived copy of the webinar will also be available in early July.
The June 9 webinar for hazardous liquids operators will be followed by a series
of webinars for gas transmission and gathering operators, as noted in RCP’s May DOT Compliance Newsletter:
- Intrastate operators only
6/21/2011 1:00 PM – 2:30 PM EDT Gas Transmission Annual Report Training – This webinar will show operators with only INTRAstate miles how to complete the new Transmission Annual Report - INTERstate operators only
6/22/2011 1:00 – 2:30 PM EDT Gas Transmission Annual Report Training – This webinar will show operators with only INTERstate miles how to complete the new Transmission Annual Report. - Gas Gathering operators only
6/22/2011 3:00 – 4:30 PM EDT Gas Transmission & Gas Gathering Annual Report Training – This webinar will show operators with only gas gathering miles how to complete the new Transmission Annual Report. - INTERstate & INTRAstate operators (and/or gas gathering miles too)
6/23/2011 1:00 PM EDT – 2:30 PM EDT Gas Transmission Annual Report Training – This webinar will show operators with both INTERstate & INTRAstate miles how to complete the new Transmission Annual Report. If you have INTERstate & INTRAstate and gathering miles as well, attend this session.
REMINDER: the annual report filing deadline as required
by the U.S. Department of Transportation, Pipeline and Hazardous Materials
Safety Administration (PHMSA) Pipeline Safety Regulations is extended until
August 15, 2011 for the CY 2010 submission.
Important Changes: The Hazardous Liquid Annual Report form [PHMSA
F 7000-1.1] was revised in 2010. A new online data entry tool will be
demonstrated at the Webinar, and we will also answer questions about the new
filing format.
You can register for the webinar by going to the following URL: http://opsweb.phmsa.dot.gov/webinars and
clicking on “June 9 – PHMSA Hazardous Liquid Operator Annual Report Webinar”.
What if I have questions? If you have any questions about the Webinar, please
contact Roger Little at (202) 366-4569 or via email.
If you have questions you want to submit in advance of the webinar for
consideration during the webinar, please send them to me at the email provided.
Summer Gas Conferences
RCP
will be exhibiting or attending several gas conferences this summer. We would
love the opportunity to discuss the regulatory compliance services we have to
offer — including solutions to your MAOP and Control Room Management issues.
When it comes to pipeline regulatory compliance, we are the experts. We hope to
see you there!
Texas Gas Association – Operations &
Management Annual Conference
June 12 – 15, 2011 at La Torretta Lake Conference Center & Hotel on Lake
Conroe in Montgomery, Texas
Southern Gas Association – Operating
Conference
July 12 – 14, 2011 at the Hyatt Regency Jacksonville Riverfront, Jacksonville,
Florida
Louisiana Gas Association – 49 CFR 191/192
& 195 Pipeline Safety Conference
July 25 – 29, 2011 at the Royal Sonesta Hotel, in New Orleans, Louisiana
W. R. (Bill) Byrd, PE
President
RCP Inc.