DOT Pipeline Compliance News

March 2006 Issue

In This Issue

Public Awareness Workshop: ** Attention **

All pre-workshop surveys for attendees are due by Monday, May 8th.We have added additional speakers to the roster.
Andrew Cober – Market Strategies
Tom Calabro – TFCC
Jack Garret – Dig Tess *New
John Funderburk – Paragidm
Hal Bentley – Celeritas *New
Susan Waller – RCP
This public awareness workshop is packed with good information and we look forward to seeing all of you there!

How to Measure Your Program’s Effectiveness

PHMSA has this to say about API RP 1162: “Of significance is the requirement that operators must review their [public awareness] programs for effectiveness and enhance the programs as necessary.”

How will you measure the effectiveness of your public awareness program?

Ask any three operators how to evaluate the public’s “understanding” of pipeline issues, and you’ll receive at least three different answers. Measuring understanding and developing benchmarks are challenges operators face in meeting the requirement to determine the effectiveness of their public awareness programs. Yet in order to comply with API RP 1162, every operator must implement some type of methodology to benchmark the program and begin measuring understanding.

Now you have the chance to cut through the confusion and the
buzzwords at an important one-day seminar that brings together
experts in the field of measurement effectiveness.

– Is your message understood?
– Does your message motivate stakeholders to respond in alignment with the information?

Because your company MUST answer these questions and more to be in compliance with the federal requirements, RCP will bring together experts in the field of measurement effectiveness for a seminar on May 9aimed at de-mystifying the process of meeting the evaluation requirement of API RP 1162.

What: Public Awareness Workshop — How to Measure Your Program’s Effectiveness
When: May 9, 2006
Where: Houston, Texas
Link: Registration

Why Attend:
This unique experience focuses on the current topics in the field of measuring effectiveness. Come to Houston and receive:
– Results-Oriented Solutions
– Practical Benchmarking Tools
– New Insights into Best Measurement Practices
– Return on Investment Industry-Relevant Methodologies

Who Should Attend:
Operators of transmission, gathering and local distribution companies, public awareness communicators, engineers, safety personnel, public relations staff, and anyone involved in public awareness compliance activities.

What You Will Learn:
– Learn multiple approaches to measuring effectiveness.
– Analyze the validity of measurement techniques.
– Separate fact from fiction.
– Unlock the secrets of measuring the “unmeasurable.”

Who Are the Speakers?
Market Strategies, Inc. (MSI) specializes in providing research and consulting services that address RP 1162. Andrew Cober will discuss:
– The science of measuring effectiveness
– How to address the research needs surrounding RP 1162
– Different research methodologies
Andrew brings hands-on experience in designing operator’s surveys that provide a benchmark for measurable results over time.

Paradigm is a leader in Community Awareness direct mail programs and in identifying the stakeholders along an operator’s right-of-way. Paradigm’s John Funderburk will:
– provide an overview of identifying stakeholder audiences
– explain resources for contacting those stakeholders
– list the challenges in reaching stakeholder audiences
– offer geo-coding techniques that allow operators to communicate with targeted audiences

Twenty First Century Communications (TFCC) specializes in conducting telephonic surveys that can assist operators in surveying stakeholders for the effectiveness of their public awareness material. Tom Calabro, Senior Vice President of Twenty First Century’s International Services will provide an overview of TFCC’s capabilities and solutions that can help operators determine their program’s effectiveness. TFCC also performs outbound telephone notifications that increase the effectiveness of direct mail programs.

Regulatory Compliance Partners (RCP) provides operators assistance as they plan and execute their public awareness programs ensuring that operators comply with RP 1162. Susan Waller, one of the original contributors to RP 1162, will provide a brief overview of RP 1162 and the implications of “continual program improvement.” She will also share operators’ leading practices and methods to continually improve public awareness programs.

Register Now

Need to make sure your Public Awareness Program meets API RP 1162 standards?

RCP can conduct a gap analysis of your current program that includes a self assessment of your Public Awareness Programs. This final product will help you to meet API RP 1162 standards. We can provide turnkey implementation, mail-outs, evaluations, and tracking of your program.

Final Rule Amendment: SPCC Compliance Dates Extended

On Feb. 10, 2006, EPA Administrator Stephen L. Johnson signed a final rule amending the Spill Prevention, Control, and Countermeasure (SPCC) Rule. This action extends the SPCC compliance dates for all facilities until Oct. 31, 2007. This final rule extends the dates in §112.3 by which owners and operators of facilities must prepare or amend their SPCC Plans as proposed.

– Under the new §112.3(a), a facility that was in operation on or before Aug. 16, 2002, must make any necessary amendments to its SPCC Plan, and implement that Plan, on or before Oct. 31, 2007.
– Under the new §112.3(b), a facility that came into operation after Aug. 16, 2002, must also prepare and implement an SPCC Plan on or before Oct. 31, 2007.
– Finally, under the new §112.3(c), a mobile facility must prepare or amend and implement an SPCC Plan on or before Oct. 31, 2007.

This extension will allow the Agency time to take final action on proposed amendments to the SPCC requirements before owners and operators are required to prepare, amend, and implement their SPCC Plans. It will also allow owners and operators to take advantage of any modifications that would be provided by a final SPCC amendment rule.

In addition, the extension will allow the regulated community the opportunity to understand the material presented in the newly released guidance, “SPCC Guidance for Regional Inspectors,” before preparing or amending their SPCC Plans. Finally, the extension provides additional time for facilities that might have difficulty meeting the upcoming compliance dates because they were adversely affected by the recent hurricanes. It should be noted that theses compliance date extensions affect only requirements of the July 2002 final SPCC rule that impose new or more stringent compliance obligations than did the 1973 SPCC rule.

RCP has developed hundreds of SPCC plans for all types of facilities and is intimately familiar with all the relevant regulations and guidance documents. For assistance with your SPCC plan revisions, contact Jessica Roger at RCP.

Will your SPCC Plan pass an EPA inspection based on the new SPCC Inspectors’ Guidance document?

RCP can conduct a gap analysis of your current SPCC Plan and provide updates and recommendations based on the new SPCC Guidance for Regional Inspectors that was published Dec. 2, 2005. The new guidance document includes more detail than is in many of the plans in use today.

RCP can review and update your plan so that you will be prepared for an Inspection.

Gas Integrity Management FAQ Updates

Several questions have been answered by OPS within the past couple months and posted on their website.

FAQ-244: “Should” in standards

Question: What is the OPS position with regard to implementation of “should” statements in industry standards that are invoked by the rule?

Answer: OPS expects operators to implement “should” statements in industry standards that are invoked by the rule. Operators may choose to implement an alternative approach in meeting the recommendations of invoked standards. If this approach is taken, program requirements for the alternative approach must exist in IM Program documents and records must be generated by the alternative approach. The IM Program documents must also technically justify that the alternative approach provides an equivalent level of protection. If an operator chooses not to implement a “should” statement in an invoked standard, a sound technical basis for why it has not been implemented must be documented in the IM Program documents.

FAQ-207: 7-years as minimum reassessment requirement

Question: For pipeline operating below 30% SMYS and that is pressure tested, Table 3 of ASME/ANSI B31.8S indicates that reassessment intervals must be 5 years if test pressure was 1.7 times MAOP. Subpart J would require lower test pressures. If I conduct my assessments in accordance with Subpart J, must I reassess more frequently than once every seven years?

Answer: No. If a hydrostatic pressure test was performed per Subpart J requirements, then the operator may use a seven-year reassessment interval, unless its risk analysis indicates that reassessment is necessary at more frequent intervals.

FAQ-236: Interpolating ASME intervals

Question: If I have hydrostatically tested my pipeline to a test pressure different than those listed in table 3 of ASME/ANSI B31.8S, how can I determine an extended reassessment interval?

Answer: Operators may use straight-line interpolation to determine acceptable intervals between the 5, 10, 15, and 20 year intervals listed in Table 3. In no case must operators reassess more frequently than once every seven years unless such frequent reassessments are determined necessary by risk assessment.

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.

OPS Releases Gas Distribution IMP Report

A collaborative effort of regulatory agencies, gas distribution operators, and public stakeholders have published “Integrity Management for Gas Distribution – Report of Phase I Investigations.” Four multi-stakeholder work/study groups were established to collect and analyze available information and to reach findings and conclusions to inform future work by the PHMSA relative to implementing integrity management principles for gas distribution pipelines. The groups have concluded that current pipeline safety regulations (49 CFR Part 192) do not now convey the concept of a risk-based distribution integrity management process and that it would be appropriate to modify the regulations to do so.

The groups found that the most useful option for implementing distribution integrity management requirements is a high-level, flexible federal regulation, in conjunction with implementation guidance, a nationwide education program expected to be conducted as part of implementing 3-digit dialing for One-Call programs, and continuing research and development.

Differences between gas distribution pipeline operators and the pipeline systems they operate make it impractical to apply the integrity management requirements for transmission pipelines to distribution. The significant diversity among gas distribution pipeline operators also makes it impractical to establish prescriptive requirements that would be appropriate for all circumstances. Instead, the groups concluded that it would be appropriate to require that all distribution pipeline operators, regardless of size, implement an integrity management program including seven key elements, namely that each operator:

  1. Develop and implement a written integrity management plan.
  2. Know its infrastructure.
  3. Identify threats, both existing and of potential future importance.
  4. Assess and prioritize risks.
  5. Identify and implement appropriate measures to mitigate risks.
  6. Measure performance, monitor results, and evaluate the effectiveness of its programs, making changes where needed.
  7. Periodically report a limited set of performance measures to its regulator.

For a copy of the report or to obtain more information about RCP’s pipeline integrity management services, please contact Jessica Roger at RCP.

2006 API Pipeline Conference and Cybernetics Symposium

The American Petroleum Institute will hold its 2006 Pipeline Conference and Cybernetics Symposium at the Renaissance Worthington Hotel located in downtown Fort Worth April 25–27, 2006. The pipeline conference begins on Tuesday morning, April 25, and continues through lunch on April 26. The cybernetics symposium begins after lunch on April 26, and continues until noon on April 27. This year’s theme is “The Future is Now: Dealing with a Nation’s Needs.”

The conference will feature tracks and sessions dealing with such topics as Business, Operations, Safety, Emergency Response, Security, Regulations and Standards and Communications/Public Awareness. The keynote speaker will be Charlie Morecraft, who survived a devastating fire in a refinery and lived to tell about it.

If you are engaged in the operation, business, or any of the many facets of pipelines, then you should join us in Fort Worth and listen to experts present issues that are timely and of immediate use in your daily work environment. Additional information is available on API’s website at

Need to Update your Response Plan (FRP, ICP or OSRP)?

We have the expertise to update your Facility Response Plan, Integrated Contingency Plan, or Oil Spill Response Plan to include new guidance and lessons learned from recent incidents and natural disasters.

NTSB Publishes Oil Pipeline SCADA Systems Study

The National Transportation Safety Board has published its study of SCADA systems in the liquid pipeline industry. This study includes the NTSB’s five recommendations to PHMSA concerning liquid pipeline SCADA systems (see our December, 2005 newsletter for additional information). The recommendations are:

  1. Require operators of hazardous liquid pipelines to follow the American Petroleum Institute’s Recommended Practice 1165* for the use of graphics on the SCADA screens. (P-05-1)
  2. Require pipeline companies to have a policy for the review/audit of alarms. (P-05-2)
  3. Require controller training to include simulator or non-computerized simulations for controller recognition of abnormal operating conditions, in particular, leak events. (P-05-3)
  4. Change the liquid accident reporting form (PHMSA F 7000-1) and require operators to provide data related to controller fatigue. (P-05-4)
  5. Require operators to install computer-based leak detection systems on all lines unless engineering analysis determines that such a system is not necessary. (P-05-5)

The full findings and recommendations are available at

*Note that API RP 1165 is still in DRAFT form, and has not yet been published. Thus, it is not currently available for purchase.

O&M; Manual Up-To-Date?

RCP has the tools and expertise to develop comprehensive procedures that you need to protect your employees, facilities, and environment. Click here to request more information.

Salt Dome Storage in Texas – Proposed Amendments

The Railroad Commission of Texas has proposed extensive amendments to Title 16, Chapter 3 of the Texas Administrative Code, §3.95, relating to Underground Storage of Liquid or Liquefied Hydrocarbons in Salt Formations, and §3.97, relating to Underground Storage of Gas in Salt Formations. These proposed amendments are lengthy and are not summarized here. A link to the proposed rulemaking is given below:

The Commission will accept comments for 30 days after publication in the Texas Register (note: publication date was 2/24/2006). Comments should refer to Oil and Gas Docket No. 20-0245837. For further information, call Dr. Steve Seni at (512) 475-4439.

API Hurricane Conference

On March 1st and 2nd the API sponsored a Hurricane Preparedness Conference in Houston, Texas. Attended by representatives from dozens of pipeline and energy companies, the purpose of the conference was to gather and share the “lessons learned” after the unprecedented hurricane season of 2005 in order to better prepare for the possibility of another active season beginning in June, 2006.

Along with some innovative new ideas presented by both government and industry personnel, there were several themes that recurred in all presentations – preparing for family needs, redundant communication systems, the possibility of a “mutual assistance” or equipment co-op between various companies, locating your response center and sourcing material needs far from the expected storm activity, and the need to become familiar with and exercise your storm plan prior to the start of hurricane season. For more information, please call Jessica Roger at (713) 655-8080.

RCP Services Spotlight — Hurricane Preparedness Planning

The Gulf Coast region was hit hard by hurricanes Katrina and Rita. However, the damage to the oil and gas infrastructure had far-reaching impacts beyond the Gulf Coast. Production, pipelines and refining facilities were shut down and many operators scrambled to find the necessary resources to quickly and efficiently bring their facilities back on line. Since these events have passed, many key lessons have been learned that will help minimize the impact of these types of events in the future. Nobody knows when or what the next natural disaster will bring, but 2005 served as a strong reminder that careful planning and preparedness up front will help minimize the effects of these events when they occur.

RCP is in the process of helping oil and gas companies update their hurricane preparedness and response plans. Taking key lessons learned across the industry as well as specific learnings from your experience, RCP can update your hurricane preparedness and response plan. A few examples of issues commonly being addressed in these updates include:

  1. Identification of operational goals and priorities following a hurricane event
  2. Assessment of available resources and assignments for both pre- and post-event activities
  3. Development of effective preparedness strategies for communications and key logistical needs
  4. Planning for the humanitarian assistance needs of employees, family, and local communities

If you are interested in how RCP can help you become better prepared for the next hurricane event, give Jessica Roger a call at (713) 655-8080.

Hurricane season is fast approaching, but there is still time to update and implement changes to your plan.

Need to Update Your Current Operator Qualification Program?

We have the expertise to update your current operator qualification program to satisfy the upcoming regulation change and inspection protocols. Click Here to request more information.

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