DOT Pipeline Compliance News

June 2012 Issue

In This Issue

DIMP Implementation Workshop

June 27 – Fort Worth, TX

The Pipeline and Hazardous Materials Safety Administration (PHMSA) and the National Association of Pipeline Safety Representatives (NAPSR) are jointly sponsoring a public meeting on Implementing Integrity Management of Gas Distribution Pipelines. The meeting will be held on June 27, 2012, at the OMNI Hotel in Fort Worth, Texas.

At the meeting, PHMSA/NAPSR will discuss observations from initial inspections of operators’ implementation of integrity management requirements for gas distribution pipelines and current regulatory topics affecting distribution pipeline operators. The meeting will also include panel and breakout session discussions involving gas distribution pipeline industry representatives on topics relating to their experiences implementing the distribution integrity management regulation.

Click here for on-line registration, hotel information and preliminary agenda.

PHMSA Information Collection on Excess Flow Valve

[Docket No. PHMSA–2012–0086]

PHMSA is seeking comments on a new one-time Information Collection on Excess Flow Valves (EFVs). The collection involves a census of gas operators to gather data on operators’ experiences, practices, benefits, and costs associated with the use of EFVs. To comply with Congress’s recent mandate and address NTSB’s prior safety recommendation, PHMSA needs comprehensive data on the operations, costs, and benefits of EFVs, as well as information on how those operations, costs, and benefits may vary for other customer classification service lines (in addition to single family residence service lines). This information collection will provide the data necessary to conduct a cost-benefit analysis of EFVs for different customer classification service lines. PHMSA is proposing to use an online census for this information collection. A copy of the census will be placed in the docket for comment.

Submit comments on or before July 16, 2012 via the E-Gov Web Site and Reference Docket No. PHMSA–2012–0086.

EFRD Evaluation

RCP can assist pipeline operators (both gas and liquids) with performing an emergency flow restricting device (EFRD) evaluation based on the criteria, e.g. type of leak detection installed, product transported, quantity released, local topography, etc., identified in the Integrity Management rules. §192.179 requires that intermediate valves be installed along a cross country pipeline at the time of construction at specified intervals based on class location. Likewise, §195.260 identifies for liquids pipelines locations where valves must be installed at the time of construction but it is much less specific than for gas lines. For more information on an EFRD Study for your pipeline assets, contact Jessica Roger.

Comment Extension: NPRM on Pipeline Damage Prevention Programs

[Docket No. PHMSA-2009-0192] RIN 2137–AE43

On April 2, 2012, PHMSA published a Notice of Proposed Rulemaking (NPRM) seeking to revise the Pipeline Safety Regulations to: establish criteria and procedures for determining the adequacy of state pipeline excavation damage prevention law enforcement programs; establish an administrative process for making adequacy determinations; establish the Federal requirements PHMSA will enforce in states with inadequate excavation damage prevention law enforcement programs; and establish the adjudication process for administrative enforcement proceedings against excavators where Federal authority is exercised. See related article in the April Edition of the DOT Pipeline Compliance News.

PHMSA has received a request to extend the comment period to allow stakeholders more time to evaluate the NPRM. PHMSA has concurred in part with this request and has extended the comment period from June 1, 2012, to July 9, 2012. Submit comments on this NPRM by July 9, 2012, and reference Docket Number PHMSA–2009–0192. Comments may be submitted via the Federal eRulemaking Portal.

PHMSA Releases New Emergency Response Guidebook

On May 30, 2012, PHMSA released its 2012 Emergency Response Guidebook, which offers “first responders with a newly revised go-to manual to help deal with hazmat accidents [including pipeline releases] during the first 30 minutes.” View Deputy Administrator Tim Butters narrated a five-minute video on the topic here. The PHMSA press release is available here.

Damage Prevention Plans

RCP can develop or update your Damage Prevention plan. For more information about how RCP can assist you with your Damage Prevention Plan, click here.

Pennsylvania Pipeline Safety Act 127 Amended / Tentative Order

[Docket M-2012-2282031]

On May 24, 2012, The Pennsylvania PUC issued a Tentative Order amending Act 127 to include the registration of Class 1 transmission pipelines. The February 16, 2012 Act 127 Implementation Order was revised to indicate that all pipeline operators in the Commonwealth of Pennsylvania of Class 1 transmission lines must register such lines with the Commission. (See related article in the February Edition of the DOT Pipeline Compliance News.)

All entities with Class 1 transmission lines that have not previously filed must now file with the Commission by June 22, 2012. The Pipeline Operator Registration Form has been revised to include a column for Class 1 transmission lines. The Commission will not assess pipeline operators for the Commission’s current fiscal year that ends on June 30, 2012.

For a copy of this Tentative Order or the revised Pipeline Operator Registration Form, contact Jessica Roger.

Government/Industry Pipeline R&D Forum July 18-19 – Arlington, VA

The Pipeline and Hazardous Materials Safety Administration (PHMSA) and the National Association of Pipeline Safety Representatives are pleased to announce the next Pipeline Research & Development Forum is this July. These events are held periodically to generate a National research agenda that will foster solutions for the many challenges with pipeline safety and with protecting the environment.

The forum allows public, government and industry pipeline stakeholders to develop a consensus on the technical gaps and challenges for future research. It also reduces duplication of programs, factors ongoing research efforts, leverages resources and broadens synergies. 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.

For on-line registration, hotel information and preliminary agenda, visit the PHMSA event page.

RCP Continues to Add More Firepower to Its Staff

RCP is pleased to announce that John T. Schmidt has joined our team as an Executive Consultant. John has over thirty-nine years experience in corrosion control and pipeline integrity. In addition to project management and leadership responsibilities, John actively participated in the development of the NACE curriculum for “Pipeline Corrosion Integrity Management,” served as instructor for current courses and has been appointed as instructor for several new courses under development. John has served as member and chair of standards development committees pertaining to pipeline integrity, such as ECDA and In-Line Inspection. For more information about John or inquiries about RCP’s pipeline integrity services, contact Jessica Roger.

DOT Workshop Survey

Have you attended an RCP DOT Compliance workshop recently? If so, watch your email for a survey from us about the workshop format!

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 do not receive a survey but would like to let us know your thoughts, contact Deb Brunt at

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.

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

Summer / Fall Industry Conferences

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

TGA Operations & Management Conference
San Marcos, TX
June 10 – 13

LGA 191/192 & 195 Pipeline Safety Conference
New Orleans, LA
July 23 -27

SGA Operating Conference & Exhibits
Ft. Worth, TX
July 23 – 25

Western Region Gas Conference
Tempe, AZ
August 21 & 22

Oklahoma Gas Association Annual Conference & Expo
Norman, OK
August 27 – 29

International Pipeline Conference
Calgary, Canada
September 24 – 28

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