November 2023 Issue
In This Issue
National Pipeline Mapping System (NPMS) Phase 0 for Breakout Tanks
The approaching NPMS Phase 0 deadline, set for June 2024, marks an important moment for operators in the energy and infrastructure sector. This deadline requires operators to submit vital data regarding breakout tanks, which are integral to the management of hazardous liquids within our energy infrastructure. Furthermore, pipeline data, such as pipeline diameter, which was optional before, is now mandated for submission. The deadlines for pipeline data are March 15 for gas pipelines and June 15 for liquid pipelines.
The inclusion of breakout tanks within NPMS Phase 0 is a significant shift toward enhanced safety, greater regulatory transparency, and increased oversight. This mandatory reporting requirement for both breakout tanks and pipeline data will empower regulatory agencies to uphold safety standards, respond promptly to incidents, and bolster emergency preparedness. Operators will need to adapt to these new reporting mandates, ultimately contributing to the overall safety and resilience of our nation’s energy infrastructure.
To speak with an SME for assistance with this new standard, contact Jessica Foley.
Underwater Inspection Procedures & Inspection Interval Risk Model Updates
As a reminder, this is a good time to evaluate your pipelines in the waters of the Gulf of Mexico and see if their risk profiles have changed. It has been a quiet year for hurricanes this year, but it has been a busy year for several of the other hazards for underwater pipelines. RCP’s proprietary Underwater Inspection Interval Risk Model analyzes key operator information as well as National Oceanic and Atmospheric Administration charts, state game and fisheries department maps and published project information for additional hazards and associated risks.
For more information on RCP’s Underwater Inspection Procedure or Inspection Interval Risk Model, contact Jessica Foley.
Alabama GPS Rules for Operators
Alabama Public Service Commission has incorporated a new regulation (900-7-15 (GPS Rule 15)) concerning calibration of testing and equipment. The regulation requires natural gas and hazardous liquid pipeline operators to make sure all equipment used to verify regulatory compliance is properly calibrated on a timely basis. This includes equipment used in construction, operation, maintenance of pipelines and facilities if the equipment is used to gather correct readings/ measurements and determine safety levels. The rule requires calibration to follow manufacturer’s recommended instructions and lists instances when it must be considered. If the equipment is sent to a facility for calibration, it must be one that is approved by the manufacturer. Individuals performing calibration must be properly trained. Regulation further requires calibration procedures / processes to be incorporated into the Operations and Maintenance (O&M) Plan. Calibration records must include the reason from regulation that required the calibration (Rule 900-7-15(3)) and verification of calibration. Maintain these records for a minimum of 10 years.
For a copy of the administrative code, contact Jessica Foley.
The Enforcement Corner
The Enforcement Corner summarizes recent PHMSA enforcement actions, indicating where PHMSA is putting its enforcement efforts and the fines they are proposing for various types of violations.
In September 2023, PHMSA issued 2 NOAs, 6 NOPVs, and 4 WLs accompanied by $445,000 in proposed fines. Significant proposed fines were attributed to the following code sections:
- $39,100 49 CFR 192.631(c)(3) Control Room Management
- $36,100 49 CFR 192.631(c)(4) Control Room Management
- $39,100 49 CFR 192.631(h) Control Room Management
- $83,000 49 CFR 192.631(j)(1) Control Room Management
- $17,100 49 CFR 195.402(a) Procedure Manual
- $18,600 49 CFR 195.402(c)(7) Control Room Management
- $20,400 49 CFR 195.440(b) Public Awareness
- $39,100 49 CFR 195.446(h)(6) Control Room Management
- $81,900 49 CFR 195.452(l)(1)(ii) Integrity Management
- $20,400 49 CFR 195.505(b) Operator Qualification
- $50,200 49 CFR 195.588(b)(4)(iii) Direct Assessments
Please note:
- Pipeline operators may disagree in whole or in part with each proposed violation cited by PHMSA.
- Proposed Civil Penalties (PCP) may be reduced or eliminated before an enforcement action becomes final.
- A Corrective Action Order (CAO) usually addresses urgent situations arising out of an accident, spill, or other significant, immediate, or imminent safety or environmental concerns.
- A Notice of Amendment (NOA) is frequently a result of a difference of opinion regarding written procedure requirements.
- A Notice of Proposed Safety Order (NOPSO) addresses pipeline integrity risks that may not constitute a hazardous facility requiring immediate corrective action (see Corrective Action Order described above), but do need to be addressed over time.
- A Notice of Probable Violation (NOPV) is not proof that a violation actually occurred.
- Proposed Compliance Orders (PCO) frequently document actions the pipeline operator already planned to do.
- Warning Letter (WL) is an official notice by PHMSA that an operator needs to make improvements but that no further enforcement is proposed for those findings at this time.
RCP maintains a detailed database of all PHMSA enforcement actions dating back to 2007 and is routinely asked for data analysis of various enforcement actions. For more information on how RCP can assist with enforcement action data analysis services, contact Jessica Foley.
Need to respond to a PHMSA enforcement action?
Need to know if your enforcement action is an outlier, or par for the course?
RCP maintains a detailed database of all PHMSA enforcement actions and their resolution which enables us to compare and contrast individual enforcement actions to nationwide actions and trends. We can help put things into context to ensure an effective reply for each citation. For more information on how RCP can assist with enforcement action data analysis services, contact Jessica Foley.
Q&A Section
Do you have questions? RCP’s SMEs have the answers. Information will be posted here for questions we often get from clients or discussions we have with regulators, interpretations and pending regulatory deadlines.
Q: Our company purchased a pipeline asset from another company, and hired the technicians that worked for the previous operator. Can our company use the previous operator’s OQ qualifications for those employees?
A: No. These employees will need to be requalified under your company’s OQ program, even if they are doing the same tasks they did for the previous operator.
Ask the Experts
Do you have a question for the experts at RCP? Submit your question using this form. If your question is selected for a future newsletter, you will be eligible for a gift of your choice from RCP’s online Store.
Upcoming Deadlines:
- The deadline to submit written comments in response to PHMSA’s forthcoming NPRM on Pipeline Safety: Safety of Gas Distribution Pipeline and Other Pipeline Safety Initiatives will have 60 days from the date of publication in the Federal Register. Comments may be filed at https://www.regulations.gov/ Docket No. PHMSA-2021-0046.
- And as a reminder, the “Stay of Enforcement” does not mean regulators don’t expect work toward getting compliance activities in place can be ignored.
If we can help, contact Jessica Foley.
Did you know?
Customer Efficiency Program Efficiency Program
DID YOU KNOW? About consumer efficiency programs…
- Whether it is decreasing emissions, preserving natural resources, or ensuring reasonable utility bills, the efficient use of energy will be critical in these goals.
- Residential customers might be able to get a rebate when switching to a tankless natural gas water heater. If appropriate for the homeowner based on need and house design, tankless natural gas water heaters, also known as demand-type or instantaneous water heaters, provide hot water only as it is needed. They don’t produce the standby energy losses associated with storage water heaters, which can save money.
- If new space heating equipment is needed, APGA member utilities may be able to provide a rebate for a natural gas furnace or boiler. With efficient natural gas space heating equipment, the homeowner can benefit from improved comfort, increased value of their home and property, contributions to a cleaner environment, and more for their money with lower heating bills.
- Many APGA member gas systems offer rebates to add insulation to their customers’ home attics. Upgrading the insulation in a home attic is one of the most cost-effective ways to increase comfort, lower heating bills, and improve a home’s energy efficiency.
- Homeowners can save money on heating bills by simply resetting the thermostat when asleep or away, and this can be done automatically without sacrificing comfort by installing an automatic setback or programmable thermostat. A programmable thermostat can adjust the times you turn on the heating according to a pre-set schedule.
- To help their customers have energy efficient homes, APGA members may be able to cover the cost of a programmable thermostat and the expense of installing it. Some APGA members may also help properly dispose of old thermostats that may contain mercury.
- Natural gas is an affordable and reliable domestic resource that is nearly three times as efficient when used directly inside the home as when it is used to generate electricity.
2024 Conference News
API Pipeline Conference and Expo: Pipeline, Control Room and Cybernetics
May 6-May 8, 2024 | Hyatt Regency Salt Lake City | Salt Lake City, Utah
Join over 700 industry professionals in Salt Lake City, Utah from May 6-8, 2024, as we explore the evolving landscape of energy sustainability and security. Discover how oil and gas companies are pioneering innovative solutions to climate challenges, sustaining resources today while securing the future through cutting-edge business models. Be sure to visit the RCP booth #306 to visit with our SMEs and snag some swag! Don’t miss out on this opportunity to connect, collaborate, and learn with global leaders shaping the future of energy evolution.
Click here to register for the API Pipeline Conference and Expo: Pipeline, Control Room and Cybernetics.
RCP Speakers:
Mr. Chris Foley, VP “What’s new with 192?”
Join Chris Foley as he discusses the latest changes to CFR 192, governing the transportation of natural gas by pipeline. Discover the updated safety measures, regulatory compliance requirements, and emerging challenges in the industry. Don’t miss this opportunity to stay informed and ensure the safety and reliability of natural gas transportation infrastructure.
When: Monday, May 6 at 2:50 PM | Where: Showbird
Super DUG
May 15-May 17, 2024 | Fort Worth Convention Center | Fort Worth, TX
Don’t miss SUPER DUG 2024, the premier event focusing on energy production in the U.S. shale plays, including the Permian, Eagle Ford, Midcontinent, Bakken, and the Rockies. Following last year’s successful launch, this year’s event is set to be even bigger, with over 2,000 industry professionals, 130+ exhibitors, and 10+ hours of networking opportunities. Connect with key decision-makers from public and private producers, midstream operators, and leading service and technology providers.
Click here to register for Super Dug 2024!
TGA Annual Operations and Management Meeting
June 23-June 27, 2024 | Margaritaville Lake Resort | Montgomery, TX
The TGA Annual Operations and Management Meeting, celebrating its 50th anniversary, stands as the premier event for industry professionals to explore cutting-edge trends and best practices in operations and management. Through engaging discussions, workshops, and networking opportunities, attendees collaborate to drive organizational excellence. Join us for insightful presentations and interactive sessions as we commemorate our rich history and shape the future of operational success together.
Click here to register for TGA’s Annual Operations and Management Meeting.
Florida Natural Gas Association (FNGA) Symposium & Expo
June 24-June 26, 2024 | The Westin Cape Coral Resort at Marina Village | Cape Coral, FL
Discover the latest developments in Florida and gain insights into prominent industry figures at the Florida Natural Gas Association Symposium & Expo. Engage with thought-provoking content presented by esteemed guests and participate in industry discussions designed to enhance your expertise. This event offers invaluable networking opportunities to foster connections crucial for sustaining natural gas’ prominence in energy dialogues. Explore a diverse array of industry suppliers showcasing cutting-edge technologies and innovations essential for efficient natural gas delivery to consumers. Join us to stay informed, connected, and at the forefront of advancements in the natural gas industry.
Click here to register for the FNGA Symposium & Expo.
SGA Operations Conference
July 22-July 24, 2024 | DoubleTree by Hilton Nashville Downtown | Nashville, TN
The SGA Operations Conference is a gathering for professionals in the natural gas industry, specifically tailored for individual contributors to the natural gas industry operations space. This conference provides a platform for industry leaders to share insights, discuss best practices, and explore the latest advancements in operations, asset management, gas control, and technology.
Click here to register for the SGA Operations Conference.
We would welcome the opportunity to discuss our services with you.
Sincerely,
W. R. (Bill) Byrd, PE
President
RCP Inc.