DOT Pipeline Compliance News

November 2020 Issue

In This Issue


In Memory

It is with sadness that we share the news that Larry Decker passed away last month.  Larry spent 40 years in the pipeline industry providing engineering, design, and construction management for many high profile pipeline projects in the U.S., Algeria, Bolivia, Colombia, Ecuador, and Africa, including the Trans Alaska Pipeline System.  His friends and associates will remember him as highly competent, occasionally difficult, frequently opinionated, and almost always right.  And a proud Aggie.  I remember advising him before attending a meeting with VIPs “Larry, you can’t wear your A&M cap”.  We are honored that he chose to spend the last several years of his career at RCP as an Executive Consultant. He will be missed.  RIP.


PHMSA NPRM Class Location Change Requirements

[Docket No. PHMSA–2017–0151]

On October 14, 2020, PHMSA published a Notice of Proposed Rulemaking (NPRM) to address the requirements for gas transmission pipeline segments that experience a change in class location. 

Public comments are due by December 14, 2020, and may be submitted via the Federal eRulemaking Portal. Include Docket No. PHMSA–2017–0151. 

Under the existing regulations, pipeline segments located in areas where the population density has significantly increased must perform one of the following actions:

  • Reduce the pressure of the pipeline segment,
  • pressure test the pipeline segment to higher standards, or
  • replace the pipeline segment.

This NPRM would add an alternative set of requirements operators could use, based on implementing integrity management principles and pipe eligibility criteria, to manage certain pipeline segments where the class location has changed from a Class 1 location to a Class 3 location. Proposed changes include:

  • Notification to PHMSA within 60 days of a change in class location from class 1 to class 3 if the operator chooses to follow the new alternative to confirm or revise the segment’s MAOP.
  • New definitions for Class 1 to Class 3 location segment, In-Line inspection segment and Predicted failure pressure
  • Added Class 1 to Class 3 location segment to the definition of High Consequence Areas
  • New §618 Class 1 to Class 3 location segment requirements
    • Requirements for adding Class 1 to Class 3 location segments to the operator’s Integrity Management Program
    • Limit what types of pipe are allowed to be classified as Class 1 to Class 3 location segments
    • Integrity assessments must be performed using in-line inspection tools or using alternative assessments or pressure testing following notification to PHMSA under §18.
    • Specifies repair criteria and remediation schedule for Class 1 to Class 3 location segments
    • Additional preventative and mitigative actions for Class 1 to Class 3 location segments
    • Additional remote control or automatic shutoff valve requirements for Class 1 to Class 3 location segments
  • Added dents to §712 Analysis of predicted failure pressure and critical strain level

For a copy of this NPRM, or to discuss how RCP can assist with preparations for the final rule, contact Jessica Foley at jfoley@rcp.com.


PHMSA Posts Draft FAQ’s for Midstream Processing Facility Jurisdiction

PHMSA posted a draft set of FAQ’s requesting comment as to the federal jurisdictional delineation points for gas processing facilities to which there may be overlapping authority between PHMSA and OSHA. The two agencies agreed to delineate where they each would perform regulatory oversight activities for midstream processing facilities based on the predominate use of the facilities in question.   Public comments are due by January 4, 2021, and may be submitted via the Federal eRulemaking Portal. Include Docket No. PHMSA–2019–0199. 

Q 1–A: What is Processing?

For the purposes of this guidance document, ‘‘processing’’ is defined as the treatment of products including, but not limited to dehydration, removal of contaminants by separation or filtration, blending with other products, and heating or cooling units that separate or purify products and remove condensates by distillation. These FAQs do not cover facilities used for the chemical conversion of crude oil into refined petroleum products (i.e. refining facilities).

Q 1–B: What is a Processing Facility?

A ‘‘processing facility’’ comprises one or more individual units that perform a processing operation (see Q 1–A) and meets the criteria for applicability of the Occupational Safety and Health Administration(OSHA) process safety management regulations (29 CFR 1910.119).

Q 2: How does one delineate the boundary between pipeline transportation and a processing facility?

PHMSA policy indicates that, in deference to OSHA’s exercise of its authority, it will not conduct inspection and enforcement activities (‘‘regulatory oversight  activities’’) under 49 CFR part 192 and 195 for pipelines downstream of the first pressure control device entering a processing facility, and upstream of the last pressure control device leaving that processing facility, except as described in provisions of FAQ 4.

Q 3: How does PHMSA’s policy apply to regulatory oversight of a pipeline entering a processing facility that bypasses a pressure control device?

A pipeline that predominantly (more than 50% of the time during the preceding calendar year) bypasses a pressure control device will be subject to PHMSA regulatory oversight activities under 49 CFR part 192 or 195. Further, if a pipeline bypasses a pressure control device that is permanently no longer in service, the pipeline will be subject to PHMSA regulatory oversight activities under 49 CFR part 192 or 195.

Q 4: How does PHMSA’s policy apply to regulatory oversight of piping that bypasses processing downstream of the first pressure control device?

Piping that is downstream of the first pressure control device that is not predominately (more than 50% of the time during the previous calendar year) used to bypass processing will be subject to regulatory oversight activities by OSHA under its process safety management regulations. Piping that is downstream of the first pressure control device that is predominantly (more than 50% of the time during the previous calendar year) used to bypass processing will be subject to PHMSA regulatory oversight activities under 49 CFR part 192 or 195.

Q 5: What if a given section of piping located on the grounds of a processing facility served by PHMSA-regulated pipelines connects two processing units or is otherwise used for a processing function?

If the piping is located downstream of the first pressure control device entering the facility and upstream of the last pressure control device leaving the facility, it would be subject to regulatory oversight activities by OSHA under its process safety management regulations. PHMSA policy indicates that in deference to OSHA’s exercise of its authority, this section of piping would not be subject to PHMSA regulatory oversight activities under 49 CFR part 192 or 195.

Q 6. How is underground storage and associated piping located on the grounds of a processing facility regulated?

Piping associated with underground storage used for the ‘‘purpose of managing processing facility inventory’’ will be subject to regulatory oversight activities by OSHA under its process safety management regulations. Piping associated with storage caverns used for transportation will be subject to PHMSA regulatory oversight activities under 49 CFR part 192 or 195. Additionally, underground natural gas storage facilities, as defined in § 192.3, must comply with the applicable reporting requirements in 49 CFR part 191 and underground natural gas storage safety requirements in § 192.12.

Q 7. How are pipelines connecting storage or processing facilities regulated when traversing public or private lands (outside the grounds of storage or processing facilities)?

Pipelines exiting a pressure control device of storage or processing facilities and traversing public or private lands outside the grounds of storage or processing facilities will be subject to PHMSA regulatory oversight activities under 49 CFR part 192 or 195.

For a copy of the notice, or to discuss how RCP can assist with performing a jurisdictional delineation study of your midstream facilities, contact Jessica Foley.


Oklahoma Underground Gas Storage Regulations

As of October 1, 2020, the Oklahoma Corporation Commission has added 165:20-6-1 to Title 165, Chapter 20 – Gas and Hazardous Liquid Pipeline Safety, to adopt all of the provisions of 49 CFR Parts 191 and 192, as such exist on January 1, 2020, pertaining to Intrastate Underground Natural Gas Storage Facilities. 


Underwater Inspection Procedures & Inspection Interval Risk Model Updates

2020 has been a hurricane season we all can agree we wish had never happened. For many operators with assets in the Gulf of Mexico and its inlets subject to 49 CFR 192.612 and 195.413, there has been not only a named storm, but several named storms that crossed those assets. You did your initial inspection for damage under 49 CFR 195.414, but has your risk profile changed?

Now with this very active hurricane season coming to an end, it is a good time for you really cool people to make plans to evaluate how these numerous storms may have impacted your shallow water pipelines and if their risk profiles have changed. The number and proximity of hurricanes are typically the largest inputs for the risk profiles. In addition to the latest storm data tabulated by the National Hurricane Center, RCP’s proprietary Underwater Inspection Interval Risk Model analyzes key operator information as well as National Oceanic and Atmospheric Administration charts and state game and fisheries department maps for additional hazards and associated risks. 

For more information on RCP’s Underwater Inspection Procedure or Inspection Interval Risk Model, contact Jessica Foley.


What makes RCP’s online training different?

Our online training has been built from the ground up to make the most use of the virtual learning environment. We’ve re-organized our training material into 5-10 minute* bite-sized topics, and made them all available in a format that allows students to take them in any order and at any time. Topics include a video presentation, as well as external reference links and thumbnails of the slides. At the close of each lesson we will have a short quiz. The class includes live Q&A sessions each day to address questions, work through example problems, and review the quizzes.

Students will have the ability to browse the material in the manner that best suits their learning style. They can choose to watch all the topic videos, click-through the slides to skip topics they already know, browse through the reference materials and links, or a combination of all those things. They can spend more time on topics of bigger interest and skip the ones they don’t need to review (a liquid transmission operator probably isn’t interested in gas distribution topics). A three-day in-person course can be done in three days online by watching the appropriate videos each morning and attending the live Q&A sessions in the afternoon. Or, students can review the online materials in advance as their schedule allows and just log on for the live Q&A sessions when scheduled.

While there is no substitute for in-person training, we have done our best to create the next-best thing. We hope you will agree, and here’s what past attendees are saying:

“The course was great. I really think that the course setup is helpful for comprehending the information. The biggest benefit is having “homework” and being able to look back at the information to help solidify the learning. I would recommend this layout for information delivery in the future with more “homework” and videos walking through the results.”

“I appreciated the visuals accompanied by an explanation, especially with the mouse pointer to guide where to look/which section was being explained.”

“The presentation was great – at a good pace and with enough background that I understood what he was presenting.  Thank you.”

“I liked all of the details that Nathan provided. I learned a lot about the different types of testing for each of the properties. I knew generally what was available before but now I have a lot more knowledge. This will be helpful when sourcing vendors for material testing.”


*Truth in advertising – some of the recorded topics are 40 minutes.  It must be true that the older people are, the more long-winded they become.  But it’s all good.  Honest! 


RCP’s 2021 Workshop Schedule

The virtual format for this is unlike anything you have experienced before.  Attendees will receive links to workshop materials two weeks prior to live stream Q&A sessions with the trainers and other attendees.

DateEventLocation
Feb 16 2021 – Feb 18 2021DOT Gas & Liquid Virtual WorkshopOnlineMore Info

Registration is now open for the February workshop. For more info visit our events page.


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

Sincerely,

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