DOT Pipeline Compliance News

November 2006 Issue

In This Issue

DOT Pipeline Compliance Workshop – December 8, 2006

RCP will be hosting our very popular workshops on DOT Pipeline Compliance on December 8 in Park City, Utah. Join us for an informative, lively, and interactive workshop on DOT Pipeline Compliance. This workshop has been attended by hundreds of pipeline personnel, with excellent feedback. The workshop provides an overview of the DOT pipeline regulations, and is appropriate for people who are new to pipeline regulations, or who could use a refresher.

Introduction to DOT/PHMSA Pipeline Regulations

  • Agency jurisdictions – what does DOT/PHMSA regulate anyway?
    • Important definitions
    • Important letters of clarification from the agency
    • Recent EPA/DOI memorandums of understanding
  • State and Federal program variations, roles and responsibilities
  • Gas and liquid design, construction, operations, maintenance, and emergency response requirements
  • Spill response planning requirements
  • How to monitor rulemaking activity and stay current with your compliance program
  • Discussion of potential rulemaking – liquid gathering rules, controller certification, etc.

Your Instructor: As principal of RCP, Mr. Byrd enjoys a solid reputation for working with the public, corporate management, and regulatory agencies to resolve complex regulatory issues. He serves on various industry association committees, works as an expert witness and consulting expert, and is frequently called upon to comment on current or proposed rulemakings at public and private meetings and conferences.

For additional information, including a seminar brochure, go to our website here.

California: Hazardous Liquid Pipeline Excavation Bill Signed into Law

On Sept. 29, a bill was signed into law that establishes tougher safety procedures for excavation work that is conducted near high-risk pipelines carrying flammable fuels such as gasoline and natural gas. The legislation was inspired by the Nov. 9, 2004, pipeline excavation accident at a construction site in Walnut Creek, Calif., that killed five workers.

Among the bill’s requirements:

  • If an excavation is within 10 feet of a “high-priority subsurface installation,” the operator of the pipeline installation must notify the excavator of the installation and hold an onsite meeting to verify the location of the installation.
  • Only a “qualified person” – one who has completed a safety training program that meets the requirements of California law – is allowed to conduct “subsurface installation locating activities.”
  • A regional notification center must provide the excavator with the pipeline operator’s contact information, and the excavator must notify the pipeline operator – or call 9-1-1 – when the excavator discovers or causes damage to the pipeline installation.

ASME B31Q-2006 Pipeline Personnel Qualification Standard

The consensus process for approval of the ASME B31Q has been completed and ASME published the pipeline operator qualification standard on September 15, 2006. In all, over 100 people worked diligently to retain as much of the existing framework of OQ as was feasible and to develop a technically based standard, recognizing the diverse needs of the industry and regulators. The ASME B31Q Project Team included representatives from federal and state regulatory agencies, contractors, industry associations, labor and three industry sectors – hazardous liquid, gas transmission, and local distribution companies. The project team met regularly over a period of twenty months to reach consensus on the content of the standard. Additional resources, including Subject Matter Experts, industry associations and service providers were utilized regularly. A copy of the new standard can be purchased for $185 by clicking here

At this point, it is not clear what the Office of Pipeline Safety plans to do with this standard. OPS published a concept paper and held a public meeting on 12/15/05 that addressed Operator Qualification as it might relate to training, re-evaluation intervals, and new construction activities. Industry submitted their comments soon thereafter, but no formal action has been taken by OPS since.

Need to Update Your Current Operator Qualification Program?

Would you like RCP to compare how your current Operator Qualification Program Stacks up against the new ASME B31Q standard? For more information on how RCP can support your ongoing OQ Program needs.

Alaska to Create Artic Pipeline Technology Team

Alaska Governor Frank H. Murkowski directed the Department of Environmental Conservation to assemble an Arctic Pipeline Technology Team and called for a corrosion conference to ensure the integrity of oil pipeline infrastructure and continued crude oil production. The Arctic Pipeline Technology Team will be created by a Memorandum of Understanding between the Department of Environmental Conservation, the Department of Natural Resources, the Alaska Oil and Gas Conservation Commission and the federal Office of Pipeline Safety. The team will work with industry and other government or non-governmental professionals with expertise in arctic pipeline engineering on leak detection, corrosion prevention, monitoring and inspection. The team will share technical resources and information related to pipeline integrity in arctic and sub-arctic climates. It will troubleshoot design, construction, operation and maintenance problems, validate engineering approaches, examine the regulatory regime and recommend changes to reflect latest technologies, and ensure the best available technology is being applied to Alaska’s North Slope pipeline system. The governor also directed DEC to work with other agencies and industry to convene a conference in Alaska on pipeline integrity. The conference will convene the foremost experts in the world on pipeline integrity and management programs. The purpose of the conference is to gather information from across the globe on pipeline integrity technology including programs and equipment and to examine how proven or promising technologies could be applied to our pipelines. For more details, click here.

Common Ground Alliance Meeting

The Common Ground Alliance is holding a free informational Summit regarding the national 811 awareness campaign. The meeting will be held on November 17 at the offices of Northern Natural Gas Company 1111 South 103rd Street Omaha, Nebraska 68124.

Topics to be discussed include:

  • Results from a national market research survey conducted with:
    • General Population
    • Professional Excavators
    • One Call Center Executive Directors
    • CGA Membership
  • Strategic Plan for introducing 811
  • Sample Creative Campaign Elements
  • National Launch Concepts and opportunities for regional launch events
  • Websites for additional information
  • Overview of 811 implementation on a national scale
  • What you can do to support 811

Please RSVP by November 3rd, as seating is limited. RSVP via email to

PHMSA Gas Gathering Workshops

PHMSA has published several more dates and locations for the gas gathering definition workshops. The first few workshops have been very informative and have provided an opportunity for lively exchanges among federal, state, and industry stakeholders. Workshop schedule and registration information can be found by clicking here.

Nov 14, 2006Evansville Convention Center, Evansville, INIndiana Utility Regulatory Commission
Nov 16, 2006Sheraton – Denver West (Union Street), Denver, COColorado Public Utilities Commission
Nov 28, 2006Cambridge, OH (exact facility yet to be determined)Public Utilities Commission of Ohio
Nov 30, 2006Embassy Suites, Charleston, WVWest Virginia Public Service Commission
Dec 7, 2006Port Allen Convention Center, Port Allen, LA (Baton Rouge)Louisiana Department of Natural Resources

The topics to be discussed include:

  • Identify the beginning and endpoints of gathering by applying American Petroleum Institute’s (API) Recommended Practice (RP) 80 and its supplemental definitions
  • Identify a “regulated” segment of a gathering line
  • Identify and understand which compliance activities are required for certain gathering lines
  • Apply and enforce significant dates for various compliance activities
  • Recognize, identify and define equipment and processes associated with production
  • Explain processing and treatment of gas stream constituents in gathering systems
  • Interpret and apply PHMSA enforcement policies and significant opinions

Has the new Gas Gathering definition affected your pipelines?

RCP can conduct a detailed analysis of your gas pipelines to determine end points of production and gathering based upon the recently finalized definition of gas gathering pipelines. The analysis will also determine whether your gathering pipelines are regulated and whether they are classified as Type A or B regulated gas gathering.

PHMSA Issues Revised Liquid IMP Protocols

The Pipeline and Hazardous Materials Safety Administration’s (PHMSA) Integrity Management Inspection Protocols for hazardous liquid pipeline operators have been revised to reflect experience obtained during the first round of Integrity Management inspections. The inspection forms were updated in December 2004, and will be used beginning with the second round of Integrity Management inspections for hazardous liquid operators. An additional minor update was implemented in October 2006 to incorporate the external corrosion direct assessment (ECDA) rule change and add integrity management-related Annual Report data reviews. These protocols are being used to inspect operators for compliance with all aspects of the Integrity Management Rule §195.452. To help illustrate updates and organizational changes to the protocols, a cross-reference table table between the updated protocols and the protocol set used for the first round of Integrity Management inspections is also available.

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, click here.

Gas IMP Revised FAQ-174: Considering GIS accuracy in locating HCAs Back to Top

Question: The centerline of a pipeline may not be accurately determined via GIS or other method. The locations of structures (e.g., from aerial photography) may also involve inaccuracies. What provisions must be taken to address for inaccuracies in these measurements, in order to accurately determine the relative location of structures with respect to the pipeline?

Answer: The rule does not explicitly address mapping/measurement inaccuracies. Instead, it specifies the use of distances that apply to pipelines, and distances from those pipelines, as they actually exist in the field. The research behind the C-FER equation used to estimate potential impact circles was based on actual measurements of the distances affected by pipeline accidents.

PHMSA recognizes that mapping and measuring technologies involve some level of inaccuracy/tolerance. Operators must take these into account and consider the uncertainties in the distances they measure or infer when evaluating potential impact circles (PICs). Each operator’s approach must be technically sound, must account for the uncertainties as they exist in the mapping/measurement methods used by the operator, and must be documented in its IM plan or related procedures. Operators may use a combination of techniques in order to account for these inaccuracies. For instance, aerial photography may be used as an initial screen. Field measurements (such as pipeline locators along with chainage measurements or survey quality range finders) may be used to verify if structures near the edge of the PIC (i.e., within the range of mapping/GIS inaccuracies) are actually inside or outside the PIC. PHMSA will inspect each operator’s approach to assure that the operator’s process is adequate to identify all covered segments.

New Oil Spill Response Guidance From The MMS

A new Notice to Lessees (NTL) has been released by the MMS, superseding NTL 2002-G09. The new NTL 2006-G21, which is effective as of October 26, 2006, provides additional guidance on the review and update of Oil Spill Release Plans (OSRP), recognizes the National Incident Management System (NIMS), adds a new Section 22 to the OSRP regarding prevention measures for facilities in State waters, updates regulatory citations, and makes a few minor technical amendments.

As with NTL 2002-G09, this NTL provides clarification, guidance and information concerning facilities, leases, and pipeline rights-of-way (ROW) located seaward of the coastline with regard to who is required to submit a regional OSRP and how to prepare and submit a regional OSRP in the MMS Gulf of Mexico OCS Region. While much of the guidance remains unchanged, there are significant differences with the addition of Section 22 regarding State waters, and with the requirement that the OSRP must be consistent with NIMS as well as the National Contingency Plan and appropriate Area Contingency Plans.

This NTL also addresses regional OSRPs when referenced in an Exploration Plan or a Development Operations Coordination Document. When the state of Florida is an ‘affected State’, the MMS GOMR will not allow reference to a regional OSRP. In this instance, a site-specific OSRP must be submitted, or with MMS GOMR approval, an approved subregional OSRP may be referenced.

For assistance with your OSRP preparation under these new guidelines, contact RCP.

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