DOT Pipeline Compliance News

October 2011 Issue

In This Issue


Damage Prevention Workshop via LiveMeeting

Plan to log on and participate in the upcoming API/AOPL Damage Prevention “Workshop” via LiveMeeting. There will also be limited on-site seating at the RCP Offices at 801 Louisiana, Suite 200, Houston, Texas.

The LiveMeeting will occur Tuesday, October 11 from 2:00 pm to 4:00 pm eastern time and will focus on damage prevention program issues related to small and/or rural excavators. Incident data show that these types of excavators are less likely than most other excavators to comply with the One Call system requirements. Panelists during the LiveMeeting will share ideas and discuss issues related to this specific group of hard-to-reach excavators and how the pipeline industry can work better with them.

A nominal fee of $25 per person for API/AOPL Members and $50 per person for API/AOPL Non Members will be charged. Click here to register for the workshop. If you plan on participating at the RCP offices, please notify Donna Williams after you register.


DOT Pipeline Compliance Workshop – October 25 – 27, 2011

Join us October 25 – 27 in Houston at our new office and dedicated training facility for an informative, lively, and interactive workshop on DOT Pipeline Compliance and OPA Planning for DOT Pipelines. 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, who could use a refresher, or anyone who needs to know the latest information in these areas.

PROGRAM SCHEDULE:

Day 1 (October 25): Gas Pipeline Regulations (49CFR192)
The workshop will include an introduction to DOT/OPS pipeline compliance; State and Federal program variations; roles and responsibilities; design, construction, operations, maintenance, and emergency response requirements; how to monitor rulemaking activity and stay current with your compliance program; operator qualification, public awareness; with a specific emphasis on the gas integrity management regulations. Each attendee will receive general training materials which include the applicable DOT 49 CFR 192 regulations for gas pipelines (website), inspection checklists, and speaker’s PowerPoint presentation handouts.

Day 2 (October 26): Special Topics
Back by popular demand! RCP is conducting a special workshop day to discuss topics that many of our clients have expressed an interest in. The workshop topics will include: Control Room Management, Public Awareness Program Effectiveness Evaluations, MAOP Validation, Revised Reporting Requirements, PHMSA Enforcement Policies, PHMSA Reauthorization Legislation, NTSB Recommendations, and both Gas and Liquid Advanced Notice of Proposed Rulemakings.

Day 3 (October 27): Liquid Pipeline Regulations (49CFR195)
The workshop will include an introduction to DOT/OPS pipeline compliance; State and Federal program variations, roles and responsibilities; design, construction, operations, maintenance, and emergency response requirements; spill response planning requirements; how to monitor rulemaking activity and stay current with your compliance program; operator qualification and public awareness. Each attendee will receive general training materials which include the applicable DOT 49 CFR 195 regulations for hazardous liquid pipelines (website), inspection checklists, and speaker’s PowerPoint presentation handouts.

To register, or for additional information, click here.


Low Stress Liquid Pipeline Exemption Issues

PHMSA has recently assessed a penalty against a liquid pipeline operator who claimed the “low stress piping” exemption for delivery pipeline segments at the end of a transmission pipeline system. Even though the pipeline segments were located downstream of a delivery facility, individually operated at low stress, and could be operated independently from the remainder of the upstream pipeline system, PHMSA found that “each of the pipeline segments are a part of a larger system, serving either to introduce products into the system or take products from it. Low-stress pipeline means a hazardous liquid pipeline that is operated in its entirety at a stress level of 20 percent or less of the SMYS of the line pipe, 49 C.F.R. §195.2. I find that at least some parts of Respondent’s 14 inch pipeline system operated at a stress level in excess of 20 percent SMYS and therefore, the two delivery pipeline segments are not a “low stress pipeline” as defined in 49 CFR §195.2.”

Operators should evaluate their liquid pipeline systems to ensure that they fully understand the implications of the “low stress” piping exemption for any delivery and/or origination pipelines that might be considered to be part of a larger, non-low-stress system.


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.

AGA White Paper on MAOP Records Review

The American Gas Association (AGA) just released an “Industry Guidance on Records Review for Re-affirming Transmission Pipeline MAOPs.” The intent of the document is to provide general guidance to pipeline operators who are reviewing the MAOP for their existing transmission pipelines in response to recommendations made by the NTSB and PHMSA’s advisory bulletin issued January 10, 2011.

Operators may discover that some of the original records used to establish pipeline MAOP may now be missing or judged to be incomplete by today’s standards. This MAOP white paper offers a suggestion of practices when developing a plan or re-affirming their MAOP.

For a copy of AGA’s MAOP white paper, contact Jessica Roger.


ASME Pipeline Training – Downey, CA

October 31 – November 4, 2011

The Pipeline Systems Division of ASME is conducting 3 pipeline training courses aimed at early career pipeline engineers. The week of courses will include:

Participants will be immersed in lectures and exercises designed to build practical knowledge. Working in groups on these exercises in the evening is expected. Upon completion of exams, students will be awarded a Certificate of Completion, earning 6.5 PDH’s per day of classes taken, issued by the Pipeline Systems Division of ASME.

Register early because space is limited to 30 students per course. You can register on-line by clicking on each course name above for a link to the registration page. All courses will be held at the Energy Resource Center (ERC) in Downey, California. For questions, contact Lydia Serenil, (281) 493-3491 or www.asme-ipti.org. For hotel reservations, contact the Embassy Suites-Los Angeles/Downey, 8425 Firestone Boulevard, Downey, CA 90241, 562-861-1900.


RCP Input to NFPA 30, 2012 Edition

RCP is proud that Jonathan Barber, Senior Staff Consultant, has made significant contributions to the recent update of the National Fire Protection Association (NFPA) 30 Flammable and Combustible Liquids Code. NFPA 30 is widely used by the Oil, Gasified Liquids, Petrochemicals, Chemicals, Medical, Pharmaceutical, Insurance, and many other industries to ensure the safe storage, handling, and use of flammable and combustible liquids. Mr. Barber is a Subject Matter Expert on the “Technical Committee on Fundamentals”.

NFPA 30: Flammable and Combustible Liquids Code, 2012 Edition can be purchased from the National Fire Protection Association website.

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