November 2007 Issue
In This Issue
- DOT Gas Pipeline Compliance Workshop – December 6, 2007
- DOT Pipeline Compliance Workshop – January 29 & 30, 2008
- Oil Pollution Prevention; Spill Prevention, Control, and Countermeasure Rule Requirements–Amendments [Federal Register: October 15, 2007 (Volume 72, Number 198)
- Need to Update your SPCC Plan?
- Texas Pipeline Safety Regulations – Proposed Revisions
- Direct Assessment Services
- API RP 1113 – New Recommended Practice on Control Centers
DOT Gas Pipeline Compliance Workshop – December 6, 2007
RCP will be hosting our very popular one-day workshop on DOT Pipeline Compliance for Gas Pipelines on December 6 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.
Gas Pipeline Regulations (49CFR192): Covering all the topics below but special emphasis will be placed on the changes in **GAS GATHERING** regulations.
- PHMSA Overview
- PHMSA Jurisdictional Boundaries
- Production / Gathering / Transmission
- Onshore / Inlets to the Gulf of Mexico / Offshore
- Compliance Requirements:
- Design
- Construction
- Operation
- Maintenance
- Corrosion
- Testing
- Integrity Management
- Operator Qualification
- Emergency Response
- Reporting
- New/Proposed Regulations
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 go to our website here.
DOT Pipeline Compliance Workshop – January 29 & 30, 2008
RCP will be hosting our very popular 2-day workshop on DOT Pipeline Compliance on January 29 & 30, 2008, in Houston, TX. Join us for an informative, lively, and interactive workshop on DOT Pipeline Compliance.
Day 1 (January 29): Gas Pipeline Regulations (49CFR192): Covering all the topics below but special emphasis will be placed on the changes in **GAS GATHERING** regulations.
Day 2 (January 30): Liquid Pipeline Regulations (49CFR195)
Each day of the workshop will address the following issues as they specifically relate to either Gas or Hazardous Liquid pipelines:
- PHMSA Overview
- PHMSA Jurisdictional Boundaries
- Production / Gathering / Transmission
- Onshore / Inlets to the Gulf of Mexico / Offshore
- Compliance Requirements:
- Design
- Construction
- Operation
- Maintenance
- Corrosion
- Testing
- Integrity Management
- Operator Qualification
- Emergency Response
- Reporting
- New/Proposed Regulations – including liquid rural low stress and new gas production pipeline rules in Texas and other states.
For additional information, including a seminar brochure, go to our website here.
Oil Pollution Prevention; Spill Prevention, Control, and Countermeasure Rule Requirements–Amendments [Federal Register: October 15, 2007 (Volume 72, Number 198)
On October 1, 2007, EPA Administrator Stephen L. Johnson signed a proposed rule to amend the Spill Prevention, Control, and Countermeasure (SPCC) rule at 40 CFR part 112 in order to provide clarity, and tailor and streamline the requirements.
Proposed changes relevant to the oil and gas industry include: clarity on the general secondary containment requirements; flexibility in the security requirements; flexibility in the use of industry standards to comply with integrity testing requirements; additional flexibility in meeting the facility diagram requirements; and clarification on the flexibility provided by the definition of “facility.”
In addition, EPA is proposing to: define “loading/unloading rack;” exclude oil production facilities from the loading/unloading requirements; and streamline requirements to allow the use of an SPCC Plan template for a subset of qualified facilities known as “Tier 1” qualified facilities. Also, several requirements for oil production facilities, including: modifying the definition of “production facility;” extending the timeframe by which a new oil production facility must prepare and implement an SPCC Plan; exempting flow-through process vessels at oil production facilities from the sized secondary containment requirements, while requiring other measures; exempting flowlines and intra-facility gathering lines at oil production facilities from all secondary containment requirements; and clarifying the definition of “permanently closed” as it applies to an oil production facility are proposed.
EPA is also taking comment on approaches that could be used to establish alternative criteria for an oil production facility to be eligible to self-certify an SPCC Plan as a qualified facility, and approaches to address produced water containers at oil production facilities.
Comments must be received on or before December 14, 2007 (docket ID No. EPA-HQ-OPA-2007-0584) to: http://www.regulations.gov .
For a full copy of the proposed changes, contact Jessica Roger at jroger@your-rcp.com.
Need to Update your SPCC Plan?
RCP has created and/or updated over 200 Spill Prevention Control & Countermeasures Plans. We have the expertise to update your SPCC Plan. Please email Jessica Roger for more information.
Texas Pipeline Safety Regulations – Proposed Revisions
The Texas Railroad Commission (TRRC) has proposed several revisions to 16 TAC Chapter 8 – Pipeline Safety Regulations to address new risk management\ initiatives for the Commission’s pipeline safety evaluation program and to remove outdated or duplicative rule requirements. The amendments include new language to address onshore pipelines and gathering and production facilities. In Subchapter A, §8.1 (a) (1), new language concerning applicability of these regulations has been added that states:
The rules in the chapter… apply to:
(B) onshore pipeline facilities, including production lines and flow lines, beginning at the first point of measurement and ending as defined by 49 CFR Part 192 as the beginning of an onshore gathering line;
This appears to be intended to apply TRRC pipeline safety regulations to virtually all production and gathering pipelines downstream of the first point of measurement, and would be a potentially significant expansion of TRRC’s jurisdiction.
The other proposed revisions are relatively minor in comparison. TRRC proposes amendments in §8.1(b) to update the minimum safety standards and to adopt by reference the DOT’s pipeline safety standards found in 49 CFR Parts 191, 192, 193, 195, and 199 as of August 16, 2007. The federal safety rule amendments that will be captured include:
- requirements for direct assessment
- definition and requirements for onshore gathering lines
- updates to incorporated standards
- approval of a new breath tube alcohol screening device
- requirements for gas transmission pipelines to use design and construction features to reduce the risk of internal corrosion
- allowance for an 8 month window to the period for reassessing hazardous liquid pipelines; modifications for notification requirements for operators of hazardous liquid and natural gas pipelines, and allowance for alternatives in calculating pressure reduction when making immediate repairs on hazardous liquid pipelines.
TRRC proposes to repeal §8.245, relating to Penalty Guidelines for Pipeline Safety Violations in order to propose the same rule under new §8.135 with the same title – moving the penalty guidelines for pipeline safety violations from Subchapter C, which applies to requirements for natural gas pipelines only, to Subchapter B, so that the guidelines will apply to all pipelines.
Some recordkeeping requirements are proposed to be removed from the rules, and to reduce the number of incident reports telephonically reported to TRRC. However, there will be an increased cost of compliance for natural gas operators for the proposal to require the semi-annual reporting of identified and repaired leaks in their pipeline system.
Under §8.210(b)(1), TRRC proposes to add that each operator must file an annual report for its intrastate systems located in Texas in the same manner as required by 49 CFR 195 using forms supplied by the DOT. In addition, a new subsection (e) on Leak Reporting is proposed requiring natural gas operators to submit a report (semiannually) regarding repaired and unrepaired leaks on their pipeline system, including a description of the leak and the method of repair. A second report will also be required that will list the number of unrepaired leaks on the pipeline system. Reports will be submitted online into TRRC’s Pipeline Safety Integrity system on June 30 and December 31 of each calendar year.
Other proposed amendments include:
- clarifying wording in §8.205 to state that supervisory review of leak complaints must be completed and documented by 10:00 a.m. each day for calls received by midnight on the previous day.
- requiring that gas odorization must be verified by the supplier using commercially available odorization equipment.
- requiring that commercially available malodorants must be used, and clarification that malodorant tests must be done at intervals not exceeding 15 months, but at least once each calendar year.
- clarifiying that school facility pipe testing must include all gas piping from the outlet of the purchase meter to each inlet valve of each appliance.
- deleting from §8.305 the requirement for atmospheric corrosion control and changing the requirements for cathodic protection test stations.
Comments on the proposal are due by 5:00 p.m. on November 26 and may be submitted online at www.rrc.state.tx.us/rules/commentform.html; or by email to rulescoordinator@rrc.state.tx.us.
For a complete copy of TRRC’s proposed revisions, contact Jessica Roger.
Direct Assessment Services
RCP can provide written direct assessment procedures to comply with DOT 195 and 192 Regulatory requirements for stress corrosion cracking, internal corrosion and external corrosion threats. The procedures are custom written to meet the individual client needs, threats and operating philosophy in accordance to NACE RP 502, ASME B31.8S and other NACE recommended practices. The advantage of utilizing direct assessment is the ability to be performed without affecting the operations of the pipeline and does not require any modification to the pipeline. Please click here if you would like information on RCP’s Direct Assessment Services.
API RP 1113 – New Recommended Practice on Control Centers
API has published the first edition of Recommended Practice 1113, “Developing a Pipeline Supervisory Control Center.” Previously issued as an informational publication, the document was reclassified as a “Recommended Practice” during this recent revision due to the importance of the information contained therein. The focus of the document is on the design aspects that may be considered appropriate for developing or revamping a pipeline supervisory control center where the function of centralized monitoring and controlling of a pipeline system occurs. It is intended to cover best practices and provide guidelines for developing a control center only, but does not dictate operational control philosophy or overall SCADA system functionality.
The document is available for purchase at IHS. (Click on the API logo and search for document number 1113).
W. R. (Bill) Byrd, PE
President
RCP Inc.