DOT Pipeline Compliance News

May 2018 Issue

In This Issue


PHMSA’s Proposed Rule for Gas Transmission and Gathering Pipelines

[Docket No. PHMSA-2011-0023]

The industry trade associations filed joint comments to the “congressional mandates” rulemaking to amend the federal safety regulations applicable to gas transmission and gathering pipelines. (See related article in the April 2018 Edition of the DOT Pipeline Compliance Newsletter.) Their comments and the GPAC Slide Presentation on the Gas Rule are posted on the regulations.gov website.

PHMSA plans to break-up the mega-rule into three smaller rulemakings. This first rulemaking is associated with the 2011 congressional mandates, including: MAOP reconfirmation, pipeline integrity for non-HCA’s and O&M. Most believe it will be published in the federal register as a final rule before the end of the year.

The second rulemaking will deal with the remaining mega-rule proposals, minus gas gathering. And, the third rulemaking will deal with new regulations applicable to gas gathering pipelines. These rulemakings are expected sometime in 2019.

RCP has been closely following this rulemaking since its inception and published a Special Edition Newsletter devoted entirely to this mega-rule.


DOT Pipeline Compliance Workshop

JUNE 5 – 7, 2018

Join RCP on June 5-7, 2018 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, 196, 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 PIPES Act of 2016; 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.


Meeting of the Voluntary Information-Sharing System Working Group

[Docket No. PHMSA-2016-0128]

PHMSA has announced a public meeting of the Voluntary Information-sharing System (VIS) Working Group on June 20, 2018, from 8:30 a.m. to 5:00 p.m. ET at a location yet to be determined in the Washington, DC Metropolitan area. The VIS Working Group will convene to discuss and identify recommendations to establish a voluntary information-sharing system. The VIS Working Group agenda will include briefings on topics such as mandate requirements, integrity management, data types and tools, in-line inspection repair and other direct assessment methods, geographic information system implementation, subcommittee considerations, lessons learned, examples of existing information-sharing systems, safety management systems, and more. As part of its work, the committee will ultimately provide recommendations to the Secretary, as required and specifically outlined in Section 10 of Public Law 114-183, addressing:

  • The need for, and the identification of, a system to ensure that dig verification data are shared with in-line inspection operators to the extent consistent with the need to maintain proprietary and security-sensitive data in a confidential manner to improve pipeline safety and inspection technology;
  • Ways to encourage the exchange of pipeline inspection information and the development of advanced pipeline inspection technologies and enhanced risk analysis;
  • Opportunities to share data, including dig verification data between operators of pipeline facilities and in-line inspector vendors to expand knowledge of the advantages and disadvantages of the different types of in-line inspection technology and methodologies;
  • Options to create a secure system that protects proprietary data while encouraging the exchange of pipeline inspection information and the development of advanced pipeline inspection technologies and enhanced risk analysis;
  • Means and best practices for the protection of safety and security-sensitive information and proprietary information; and
  • Regulatory, funding, and legal barriers to sharing the information described in paragraphs (a) through (d).

The Secretary will publish the VIS Working Group’s recommendations on a publicly available DOT website and in the docket. The VIS Working Group will fulfill its purpose once its recommendations are published online.

Additional information can be found on PHMSA’s meeting website.


TSA Updated Pipeline Security Guidelines

REV. MARCH 2018

The Transportation Security Administration (TSA) released an updated version of its “Pipeline Security Guidelines” which outlines the measures that should be taken to protect pipeline cyber assets. These Guidelines had not been updated since 2011. TSA has oversight over more than 2.6 million miles of natural gas and hazardous liquid pipelines. While the Guidelines are not mandatory, the threat of cyberattacks on critical infrastructure sectors, including the energy sector, has increased in volume, sophistication, and magnitude over the last seven years. The updated Guidelines can be found on the TSA website.


Updated Pipeline Safety Management System Resources

Check out the updated website and resources for Pipeline Safety Management System development, implementation, and evaluation at www.pipelinesms.org. This refreshed website includes the recently released tool and associated guidance document for Pipeline SMS evaluation. Come back often for news and updates about Pipeline SMS events and resources.


Kentucky Proposed Regulations

807 KAR 5:026 Gas Service; Gathering Systems

The Kentucky Public Service Commission has proposed amendments to KRS Chapter 278, 49 CFR 192 changing the engineering specifications of piping to conform with current industry standards. For a copy of the proposed changes, contact Jessica Foley.


2018 Industry Conference Schedule

2018 APGA ANNUAL CONFERENCE
July 22 – 25, 2018
Hilton Portland Downtown
Portland, OR

The American Public Gas Association (APGA) Annual Conference is the largest gathering of municipal natural gas professionals across the nation. From the educational sessions with key industry figures generating new ideas to networking opportunities with hundreds of colleagues from across the nation, the APGA Annual Conference is the event of the year for city- and community-owned natural gas utility professionals and industry experts.

SGA OPERATING CONFERENCE & EXHIBITS
July 30 – August 1, 2018
Tampa Marriott Waterside Hotel & Marina
Tampa, Florida

The SGA Operating Conference format is a focused round table discussion. Attendees learn smart practices and lessons learned from their peers with 22 concurrent facilitated sessions to choose from. Breakout sessions with presentations from subject matter experts open the conference following the keynote address. Make plans to visit the exhibit hall, which will include over 100 services and product service organizations showcasing the latest products and services available to the industry.

LGA PIPELINE SAFETY CONFERENCE
July 30 – August 3, 2018
Astor Crowne Plaza, New Orleans

RCP is once again a proud sponsor and exhibitor at this year’s conference, which has been referred to as the “Premier Pipeline Safety Conference.” We are excited to showcase our newest developments and all our services for Pressure Test support.

WESTERN REGIONAL GAS CONFERENCE
August 28 – 29, 2018
(Note: Updated conference dates!)
M Resort in Henderson, Nevada

The Western Regional Gas Conference provides a forum for the free exchange of information between natural gas companies and their state and federal regulators, and with associated industry organizations, consultants, manufacturers and vendors that serve the pipeline industry.

2018 RRC REGULATORY CONFERENCE
August 21 – 22, 2018
AT&T Conference Center in Austin, TX

This year the Railroad Commission of Texas (RRC) combines its two largest regulatory conferences, the Pipeline Safety Conference and the Oil & Gas Regulatory Conference, into one event. Registration is now open for the 2018 RRC Regulatory Conference: Environmental Protection, Pipeline Safety and Well Filings. Early bird registration ends July 23rd. For additional conference information and to register, visit the RRC’s website.

PIPELINE SMS INDUSTRY TOOLS WORKSHOP
October 10, 2018
San Luis Hotel, Galveston

PIPELINE SAFETY TRUST ANNUAL CONFERENCE
October 18-19, 2018
Hotel Monteleone, New Orleans

Each year since 2006, the Pipeline Safety Trust has hosted pipeline safety conferences. What makes them unique among pipeline conferences is the mix of attendees, who come with experience as the affected public, the pipeline industry, and government regulators. All these people come together to discuss barriers to safer pipelines.

2018 APGA OPERATIONS CONFERENCE
October 30 – Nov 1, 2018
The Chattanooga Hotel
Chattanooga, TN


Pressure Testing Webinar – Advantages of Using TestOp®

RCP will be hosting webinar presentations to discuss pipeline pressure testing practices and demonstrate the advantages of utilizing new technology for planning, designing, and capturing real-time data to validate and document whether it was a successful test. The same technology that RCP has used for the past six years to validate our customer’s pressure tests has been greatly enhanced and is now being made available as a web-hosted solution for operators to use themselves.

TestOp® takes the confusion out of pressure testing by providing real-time determination of whether the test segment is experiencing potential issues, such as yielding or air entrapment volume absorption, all while modeling the mass balance relationship of pressures, volumes and temperatures of the test. TestOp® will provide real-time indicators and corresponding data to confirm whether the test is successfully performing to plan or if there might be a small pin-hole leak that would otherwise go undetected before taking the line segment off test. TestOp® generates comprehensive and consistent reports, including a certification letter, pressure test plan versus actual test results, pressure/spike test log, test instrument and pump calibrations, pipe volume calculations sheet, stress/strain and pressure/volume plots as well as upload capability for pictures and other document scans associated with the test.

We encourage any liquid or gas pipeline operator who has upcoming projects that involve replacement, integrity verification, new construction, uprates, conversions and/or reversals to sign up for the 45 minute webinar. Some of the largest and most respected pipeline operators are now using TestOp® because they see the value it brings to their overall pipeline integrity assurance program and we are confident you will too once you have seen it in person.

Mark your calendar and plan to attend one of these sessions or request an individual demonstration for your company at a date convenient to you.


RCP’s 2019 Workshop Schedule

Last Call for 2019!

DateEventLocation
Oct 29 2019 – Oct 31 2019DOT Gas & Liquid WorkshopHoustonMore Info
Nov 12 2019Mega Rule and Spike Testing WebinarOnlineMore Info
Nov 14 2019Pressure Test Design & AnalysisHoustonMore Info
Nov 21 2019Understanding MAOP Reconfirmation Requirements WebinarOnlineMore Info
Jan 9 2020What can TaskOp do for you? WebinarOnlineMore Info
Jan 28 2020 – Jan 30 2020DOT Gas & Liquid WorkshopHoustonMore Info

Visit our events page for updates, registration, and hotel information.

RCP Safety Management System
RCP has experience assisting our clients implement API RP 1173 – Pipeline Safety Management Systems (PSMS) as the basis for their safety management system.  RCP can perform gap assessments and prepare project plans to close the identified gaps with the goal of having a fully functional safety management system. RCP continues to work with the joint industry group, developing much of the material on the PipelineSMS.org website and is currently working to create a formal auditing program for RP 1173.  For more information on how RCP can assist with your company’s PSMS implementation, contact Jessica Foley.


We would welcome the opportunity to discuss our services with you. 

Sincerely,

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