DOT Pipeline Compliance News

March 2015 Issue

In This Issue

DOT Pipeline Compliance Workshop – Gas & Liquid

March 10 – 12, 2015

Join us March 10-12, 2015 in Houston at our corporate office and dedicated training facility for an informative, lively, and interactive workshop on DOT Pipeline Compliance topics . The workshop provides an overview of the DOT pipeline regulations in 49 CFR 191, 192, 194, 195, and 199. It also describes pipeline operations and engineering concepts. It is appropriate for people who are new to pipeline regulations, who could use a refresher, or anyone who needs to know the latest developments in these areas. This workshop will be a combined format, addressing both gas and liquid pipeline topics in parallel. This will eliminate some redundancy of materials, and will allow more time for in-depth discussions for each topic.

Topics to be addressed in the workshop include:
  • An overview of DOT/OPS pipeline compliance requirements
  • State and Federal agency roles for pipeline safety
  • PHMSA Jurisdiction
  • PHMSA Inspections and Enforcement Processes
  • Engineering Concepts and Stress – Strain Relationships; %SMYS
  • Design Requirements
  • Construction Requirements
  • Corrosion Control Concepts and Requirements
  • Operations and Maintenance Requirements
  • Emergency Response Requirements (including spill response planning requirements for liquid pipelines)
  • Damage Prevention Programs
  • Operator Qualification Programs
  • Drug and Alcohol Programs
  • Public Awareness Programs
  • Integrity Management (gas and liquid) Programs
  • Control Room Management Programs

We will also discuss the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 (pipeline reauthorization bill), recent Advisory Bulletins from PHMSA, and new, pending and proposed rulemakings.

Each attendee will receive the presentation as well as applicable handouts in a hardcopy notebook, and electronic copies of the applicable regulations and voluminous reference materials including rulemakings, letters of interpretation, and other guidance documents. The workshop will adjourn at 2 p.m. on the third day, for those who need to fly out Thursday evening.

To register for our workshop, click here.

Introducing TestOp®

The software that RCP utilizes on-site to validate our customer’s pressure tests is now available to license. The license allows operators to create, plan, simulate, execute and generate comprehensive reports of pressure tests using a web-based platform with optional offline data upload capabilities. Some key features of TestOp® include:

  1. Useful for any pressure test conducted under
    • 49 CFR 192 Subpart J Test Requirements
      • Gas transmission
      • Gas distribution
      • Regulated gas gathering
    • 49 CFR 195 Subpart E Pressure Testing
    • ASME B31.3 Process Piping, Section 345 Testing
  2. All allowable test mediums
    • Water
    • Nitrogen
    • Air
    • Natural gas
  3. Applications
    • New construction
    • Repairs & replacements
    • Uprates
    • Conversion of service
    • Integrity / MAOP verification
    • Grandfathered pipe
    • Spike / elevated pressure testing
    • Pipeline integrity assessments, including ASME B31.8S, Table 3
Pressure Test Services

RCP is a leading industry expert on pressure testing. We design and validate pressure tests using a proprietary web-based program (TestOp®) that calculates the allowable pressure/temperature change for a particular test segment, confirming or denying the presence of pin-hole leaks while also detecting possible pipe yielding or air entrapment during a spike. RCP also offers Pressure Test Workshops that teach you how to plan for a pressure test from start to finish, and how to determine/prove if the test was successful.

To request a demonstration or obtain more information on RCP’s pressure test services, contact Jessica Foley.

Updated PREP Guidelines

[USCG Docket number USCG-2011-1178]

PHMSA requires that certain oil pipeline operators prepare oil spill response plans, including drill programs. Per 49 CFR 194.107 (c)(1)(ix), the operator must follow the USCG’s National Preparedness for Response Exercise Program (PREP) Guidelines, or have an equivalent drill program. On February 27, 2015 the USCG announced their updated PREP guidelines. Significant changes for pipeline operators include:

  • The frequency of deployment exercises for equipment that is owned by the facility, operated by an OSRO and listed in EPA-regulated plans has been changed from annually to semi-annually.
  • Oil spill surveillance and tracking systems should be identified as a type of response equipment to be exercised during internal equipment deployment exercises in order to test the policy holder’s abilities to effectively support and direct other response activities and equipment, such as the use of dispersants, in-situ burning, mechanical recovery, shoreline protection or wildlife recovery.

Comments must reach USCG by April 28, 2015. For a complete copy of the Federal Register Notice, please contact Jessica Foley.

Florida Gas Pipeline Siting Regulations Revisions

The State of Florida has made numerous changes to their Chapter 807 – Natural Gas Transmission Pipeline Siting regulations. The changes include definitions, application contents and timing, requirements for studies, and information meetings and reports.

RCP Acquisition Support / Due Diligence

RCP’s experience in acquisition due diligence has proven that this investment is money well spent. Problems identified in the due diligence phase can provide the buyer with leverage at closing time. After the sale is closed, it is difficult to obtain any compensation for prior liabilities that went unidentified. RCP has conducted dozens of due diligence efforts ranging from large crude gathering and transmission pipeline systems to small gas gathering systems. RCP can identify issues important to the acquisition decision making process (i.e. significant compliance gaps, significant future regulatory liabilities/costs, other “deal-killers”). Highlights of a typical due diligence project could include:

  • Jurisdictional determination review of existing pipeline facilities
  • Review of permitting and associated agency notifications
  • Phase I environmental assessments
  • Fit-for-purpose analysis
  • MAOP / MOP analysis
  • Regulatory compliance program reviews
  • Data room reviews, including critical design, construction, testing, repair, and inspection records acquisition
  • API 653 inspection and repair reviews
  • Physical inspections of pipeline facilities, as appropriate.

For more information, contact Jessica Foley.

Pause and Reflect During This Century’s Pi Second

Every 100 years, the months, days, years, hours, minutes, and seconds all align to form the first 10 digits of the irrational number known as Pi. Count your lucky stars that you can experience this rare event on March 14, 2015, at 9:26:53 am (3.141592653…..). If you pause for an entire second, you’ll certainly have paused during the EXACT number of Pi – although being an irrational number you could never know when that happened during the Pi Second. No matter. Do it anyway. You can brag about it for the next 100 years.

Spring 2015 Conference Schedule

March – May 2015

Have you registered and confirmed your reservations for these upcoming conferences? RCP will be attending. We hope to see you there!

AGA 2015 Transmission Pipeline Workshop
March 18 -19, 2015
Omni San Diego Hotel, San Diego, CA

This workshop will feature presentations and case studies from pipeline operators, regulators and service providers. Presentations will focus on areas where transmission pipeline operators are going beyond current regulations in light of existing proposed federal rulemakings. Regulators, pipeline operators, and service providers are all invited to participate in this forum.

Western Energy Institute Operations Conference
April 21 -24, 2015
Red Rock Resort / Las Vegas, NV

WEI’s Operations Conference unites almost 400 electric and natural gas energy operations managers, supervisors and front line employees for 3 days of education and networking across ten different tracks. This conference is a must for any upper-level manager and many choose to bring their direct reports for team and skill-building.

API Pipeline Conference
April 28 & 29, 2015
Savannah International Trade & Convention Center, Savannah, GA

API’s one and one-half day conference program features a keynote address by Alex Epstein, author of The Moral Case for Fossil Fuels, an Executive Roundtable focusing on which issues Pipeline Company Presidents and CEO’s view as the most challenging issues facing our industry as well more than 50 technical sessions featuring topics such as Business, Natural Forces, Safety Culture, Human Resources and a host of other timely subjects.

AGA Conference & Biennial Exhibition
May 19 – 22, 2015
Gaylord / Grapevine, TX

The annual AGA Operations Conference is the natural gas industry’s premier gathering of natural gas utility and transmission company operations management from across North America and the world for the sharing of technical knowledge, ideas and practices to promote the safe, reliable, and cost-effective delivery of natural gas to the end-user. Be sure to mark your calendar and plan to attend Bill Byrd’s presentations on May 20:

  • “Thermal Stabilization During Hydrostatic Testing” [Transmission Pipeline Operations Track A7 (10:15 am – 11:00 am)]
  • “Monte Carlo Methods for Pipeline Site Risk Assessment” [Distribution Measurement/ Engineering Track B3 (3:50 pm – 4:35 pm)]

Breckenridge, CO

The Midwest Energy Association (MEA) is holding a summit designed specifically for legal and regulatory professionals working with energy delivery companies and will include candid, practical information from those in the know. The summit will be held from September 29 – October 1, 2015 at the DoubleTree by Hilton Hotel in Breckenridge, CO. Visit the MEA website for more information regarding registration, agenda, and hotel.

Save the Dates!

RCP Workshop Schedule for 2017

  • DOT Gas & Liquid Pipeline Workshop: March 21-23 (Tuesday, Wednesday & Thursday)
  • Fundamentals of Pipeline Operations Workshop: May 24-25 (Wednesday & Thursday)
  • Pressure Test Workshop: June 20-21 (Tuesday & Wednesday)

Visit our training website for updates, registration, and hotel information.

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