DOT Pipeline Compliance News

May 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.

Gas Gathering Workshop

On March 15, 2006, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published its final rule on the definition of gas gathering lines. This rule completely changes the previous regulations for gas gathering. Pipelines that were previously considered to be regulated gas gathering may now be exempt. Likewise, other pipelines that were previously considered to be exempt gas gathering will now be regulated.

The new definition depends largely on API RP 80 to define the lines that are “gas gathering,” with a few modifications. For those lines that are regulated, there will be two levels of compliance requirements. Confused? You are not alone. Join us in Houston as we delve into the details of the new regulations.

What: Gas Gathering Jurisdiction Workshop
When: May 10, 2006
Where: Houston, Texas
Link: Registration

Why Attend
We’ll cover the following topics:

  • How does RP 80 distinguish Production from Gathering?
  • How does RP 80 distinguish Gathering from Transmission?
  • What are the criteria for determining regulated onshore gathering lines?
  • What are the compliance requirements and deadlines for regulated onshore gathering lines?
  • How should operators proceed under these new regulations?

The presentation will include specific examples and case studies, and will include time for questions and answers.

Bill Byrd of RCP, Inc., is a nationally recognized pipeline safety expert and experienced workshop leader. He has conducted dozens of pipeline jurisdictional determinations that consider the intricacies of federal and state pipeline safety regulations in complex operating environments.

Register Now!

Utility Accommodation for Rail Facilities in Texas State ROWs

The State of Texas recently published new regulations governing the accommodation, location, method of installation, adjustments, removal, relocation, and maintenance of utility facilities within state railroad right of way. These new regulations were developed in the interest of safety, protection, utilization, and future development of state railroad right of way with due consideration given to public service afforded by adequate and economical utility installations. These regulations are required because of the Texas DOT’s newly enhanced statutory authority to own and operate rail facilities. They include maintenance requirements for existing crossings. The new regulations can be found in:

Subchapter 21O – Utility Accommodation for Rail Facilities

Contact Jessica Roger for additional information

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.

Texas Damage Prevention

On March 28, the Texas Railroad Commission held its first information-gathering meeting to prepare for developing new damage prevention regulations for pipelines in Texas. The informal meeting was used to explain the recent legislation in Texas that provides for new TRRC regulations and to gather suggestions from the audience about potential regulatory issues that should be addressed. An official docket has not yet been established for this issue, but will be by the time a proposed rulemaking is developed. For now, suggestions and comments can be sent directly to Mary McDaniel, Pipeline Safety Director at the TRRC, for her consideration in developing a proposed rule. The next meeting will be at the William B. Travis Bldg. – Room 1-100 in Austin, Texas, on May 23.

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. For more information on how RCP can support your ongoing IMP needs.

Technical Advisory Committee Meetings – Workshops

Dockets: PHMSA-98-4470 / PHMSA-2004-18938 / PHMSA-2004-18584

PHMSA will hold public meetings of the Technical Pipeline Safety Standards Committee (TPSSC) and Technical Hazardous Liquid Pipeline Safety Standards Committee (THLPSSC), and 2 public workshops, on June 26-28, 2006. PHMSA will hold a half day public workshop on Hazardous Liquid Low Stress Pipelines to solicit comments on a risk-based approach to protecting unusually sensitive areas from risks associated with low stress lines. PHMSA also will conduct an all-day public workshop to discuss the effectiveness of pipeline control room operations and to obtain comments on ways to enhance the effectiveness of pipeline control room operations and on findings from the Controller Certification Project (CCERT). Lastly, the Committees will discuss regulatory issues and vote on two rulemaking proposals: integrity management program changes and clarifications, and design and construction standards to reduce internal corrosion in gas transmission pipelines.

The dates and times are as follows:

  • Monday, June 26 from 1:00 p.m. to 5:00 p.m. – THLPSSC and Public Workshop on Hazardous Liquid Low Stress Pipelines
  • Tuesday, June 27 from 8:00 a.m. to 5:00 p.m. – THLPSSC/TPSSC Public Workshop on Effectiveness of Pipeline Control Room Operations
  • Wednesday, June 28 from 8:00 a.m. to 9:00 a.m. – THLPSSC Meeting to vote on the NPRM to address integrity management modifications
  • Wednesday, June 28 from 9:30 a.m. to 4:30 p.m. – Joint meetings of the THLPSSC and TPSSC
  • Wednesday, June 28 from 5:00 p.m. to 6 p.m. – TPSSC meeting to vote on the NPRM to address internal corrosion in gas transmission pipelines

The meetings will be at the Hilton Alexandria Old Town, 1767 King Street, Alexandria, Virginia, 22314. Telephone: 1-703-837-0440, Fax 1-703-837-0454. Attendees staying at the hotel must make reservations by Friday, May 26. The phone number for reservations at the hotel is 1-800-HILTONS (445-8667). The hotel will give priority to the Committee members and State Pipeline Safety Representatives for rooms blocked under “DOT Technical Advisory Committee Meetings.”

O & M Manual Up-To-Date?

RCP has the tools and expertise to develop comprehensive procedures that you need to protect your people, facilities, and environment.

OPS issues revised FAQ’s for Public Awareness Programs

On April 10th, the OPS posted revised FAQ’s for Public Awareness Programs on their website. Some of the topics addressed in the FAQ’s include:

  1. When must programs be complete?
  2. What constitutes a complete program?
  3. When must an operator complete the initial distribution of RP 1162-compliant communications to stakeholders.
  4. Are operators required to sample stakeholder audience awareness levels before June 20, 2006?
  5. When must an operator complete the first evaluation of program effectiveness?
  6. Must a public awareness program include supplemental elements (enhancements)?
  7. What is a significant percentage of non-English speaking populations and how can that percentage be determined?
  8. How will PHMSA provide detailed instructions for operators to submit written programs?

For a copy of the FAQ’s or to obtain more information about RCP’s public awareness services, please contact Jessica Roger at RCP.

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.

PHMSA Response to NTSB on SCADA Issues

On April 26th, PHMSA submitted their response to the National Transportation Safety Board (NTSB) regarding recommendations resulting from their study entitled “Supervisory Control and Data Acquisition Systems (SCADA) in Liquid Pipelines”. The NTSB recommended the following:

  • P-05-1: Require operators of hazardous liquid pipelines to follow the American Petroleum Institute’s Recommended Practice 1165 [API RP 11651 for the use of graphics on the SCADA screens.
  • P-05-2: Require pipeline companies to have a policy for the review / audit of alarms.
  • P-05-3: Require controller training to include simulator or non-computerized simulations for controller recognition of abnormal operating conditions, in particular, leak events.
  • P-05-4: Change the liquid accident reporting form (PHMSA F 7000-1) and require operators to provide data related to controller fatigue.
  • P-05-5: Require operators to install computer-based leak detection systems on all lines unless engineering analysis determined that such a system is not necessary.

The first four recommendations are being addressed through communications of the CCERT Study and public workshops as mentioned in the article above (Technical Advisory Committee Meetings – Workshops)

“This week PHMSA intends to announce in the federal Register a public workshop in June to discuss opportunities to enhance the safety of pipeline control and findings from the CCERT Project. The workshop is a forum to discuss the adequacy of current regulations, some new concepts for improvement of control room management and operations, and for industry to provide feedback on any enhancements PHMSA offers for discussion on the topic. PHSMA would like to hear from the public and industry its experiences related to pipeline management processes, human fatigue issues, controller qualification training and other programs to assure the effective control of pipelines.”

PHMSA has addressed the Computer-Based Leak Detection recommendation (P-05-5) as follows:

“The integrity management rule for hazardous liquid pipelines requires operators to have a means to detect leaks on its pipelines system. To the extent an operator uses a computer-based leak detection system., the operator’s system must comply with API Recommended Practice 1 130. Forty-six percent of PHSMA7s first round of inspections of integrity management programs revealed inadequate use of prevention and mitigation measures, including leak detections, in the program elements. As a result, our second of inspections will include discussion of mandated use of computer-based leak detection at the public meeting on the CCERT Project this coming summer. This discussion will enable us to provide a more informed response to this recommendation at a later date.”

RCP Services Spotlight — Gas Gathering Jurisdictional Determination

On March 15, 2006, PHMSA published its final rule on the definition of gas gathering lines. This rule depends largely on API RP 80 to define the lines that are “gas gathering” with a few modifications. Of these lines, some are classified as “regulated onshore gathering” of either Type A or Type B.

Type A regulated onshore gathering lines are required to comply with the transmission pipeline regulations, except for the requirements for making a line smart-piggable and for Pipeline Integrity Management. In addition, Type A lines in class 2 areas can meet their Operator Qualification obligations simply by describing their qualification process.

Type B lines are required to meet certain requirements for corrosion control, damage prevention, public education, line marking, and establishing the MAOP of the line. Any new, replaced, relocated, or otherwise changed lines will need to comply with current design, installation, construction, initial inspection and initial testing requirements.

The final rule takes effect April 14, 2006. Compliance dates for both Type A and B lines vary by topic and range from 10/15/2007 to 4/15/2009.

RCP is in the process of helping gas production, gathering and transmission pipeline operators update their jurisdictional determinations for these lines.

If you are interested in how RCP can help you evaluate the jurisdictional classification of your pipelines, give Jessica Roger a call at (713) 655-8080.

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.

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