DOT Pipeline Compliance News

March 2012 Issue

In This Issue

PHMSA ADB-2012-02 Pipeline Safety: Post Accident Drug & Alcohol Testing

[Docket No. PHMSA-2011-0335]

PHMSA issued Advisory Bulletin ADB-2012-02 to Operators of Gas, Hazardous Liquid, and Carbon Dioxide Pipelines and Liquefied Natural Gas Facilities. Operators and contractors are encouraged to review and update, where necessary, plans and procedures governing post-accident substance abuse/misuse testing and train all those involved with ensuring that such testing is performed promptly and in an effective manner.

PHMSA regulations in Part 199 require pipeline operators and operators of Liquefied Natural Gas (LNG) facilities to conduct post-accident drug and alcohol tests of covered employees. Within the mandated timelines after a reportable pipeline accident or incident, operators must drug and alcohol test each covered employee whose performance either contributed to the accident or cannot be completely discounted as a contributing factor to the accident or incident. Operators must make the determination of employee contribution to the accident or incident promptly to meet the timelines for testing required by the regulations. This was further emphasized by the National Transportation Safety Board (NTSB) in its report of the September 9, 2010, incident in San Bruno, California.

For a copy of ADB-2012-02, contact Jessica Roger.

PHMSA ADB 2012-03 Driscopipe® 8000 High Density Polyethylene Pipe Potential Material Degradation

[Docket No. PHMSA–2012–0044]

The Pipeline and Hazardous Materials Safety Administration (PHMSA) issued Advisory Bulletin ADB 2012-03 to alert operators using Driscopipe® 8000 High Density Polyethylene Pipe (Drisco8000) of the potential for material degradation. Degradation has been identified on pipe between one-half inch to two inches in diameter that was installed between 1978 and 1999 in desert-like environments in the southwestern United States. However, since root causes of the degradation have not been determined, PHMSA cannot say with certainty that this issue is isolated to these regions, operating environments, pipe sizes, or pipe installation dates. While the manufacturer has attempted to communicate with known or suspected users, PHMSA and the National Association of Pipeline Safety Representatives (NAPSR) have identified several operators currently using Drisco8000 pipe who had not received communications about the issue. PHMSA is issuing this advisory bulletin to all operators of Drisco8000 pipe in an effort to ensure they are aware of the issue and communicating with the manufacturer and their respective regulatory authorities to determine if their systems are susceptible to similar degradation.

For a copy of ADB 2012-03, contact Jessica Roger.

US Coast Guard PREP Guidelines Update Notice

[Docket No. USCG-2011-1178]

The National Preparedness for Response Exercise Program (PREP) is designed to facilitate the periodic testing of oil spill response plans of certain vessels and facilities. The Coast Guard, Environmental Protection Agency (EPA), Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA), and Department of the Interior’s Bureau of Safety and Environmental Enforcement (BSEE) are working to revise the PREP Guidelines to reflect changes to regulations, agency reorganizations, and lessons learned from past preparedness activities and recent response activities. The PREP Guidelines were last revised in 2002.

The USCG is requesting comments and suggestions for updating the PREP Guidelines. Comments can be submitted online using the Federal eRulemaking Portal> before April 23, 2012. Include docket number USCG-2011-1178. If you have questions regarding this notice, contact LTJC Nicole Tourot, Office of Incident Management & Preparedness, Oil and Hazardous Substances Division at 202-372-2230, or email.

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

Misc. Changes to New York State PL Regulations

The PSC in New York has recently made numerous changes to their pipeline safety regulations. The State of New York has chosen to re-codify the pipeline safety regulations into the NY regulatory code (as opposed to simply adopting the federal pipeline regulations by reference, and then adopting specific changes). This approach makes it much more difficult to explain how the NY pipeline safety regulations differ from the federal pipeline safety regulations, as it requires a word-by-word comparison of the NY State versus federal regulations in every section of each code. A detailed comparison of this type isn’t within the scope of our monthly newsletter – but anyone with pipelines regulated by the NYPSC who is interested in a detailed comparison should let us know by contacting Jessica Roger.

PHMSA Leak Detection and RCV Workshops March 27 & 28 – Washington, DC

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) is conducting a 2-day workshop on “Improving Pipeline Leak Detection System Effectiveness and Understanding the Application of Automatic/Remote Control Valves.” This event is to provide an open forum for exchanging information on leak detection systems and Automatic/Remote Control Valves for hazardous liquids and natural gas pipelines.

  • March 27 will focus specifically on leak detection systems.
  • March 28 will focus on automatic/remote control valves.

The 2-day workshop will be held at the Hilton Washington DC / Rockville Hotel from 8:00 a.m. to 4:00 p.m. A draft Agenda, hotel and on-line registration information can be found on PHMSA’s website.

The workshop will also be webcasted in its entirety and no prior registration is required for the webcast.

2012 Industry Conferences at a Glance

It’s not too early to make plans to attend these upcoming events. RCP will have representatives and/or presentations at each of these conferences. We hope to see you there!

SGA Spring Gas Conference and Expo
Charlotte, NC
March 19 – 22

API 2012 Pipeline Conference
Phoenix, AZ
April 17 – 19

AGA Operations Conference
San Francisco, CA
May 1 – May 4

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

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

International Pipeline Conference
Calgary, Canada
September 24 – 28

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