DOT Pipeline Compliance News

October 2012 Issue

In This Issue

PHMSA Strategic Plan – 2012-2016

The Pipeline and Hazardous Materials Safety Administration (PHMSA) released its “Strategic Plan for 2012-2016” outlining their mission and vision for the coming years. The Plan was produced for the public and stakeholders to explain their vision for ensuring the safe transportation of hazardous materials and how they plan to achieve those goals.

PHMSA states that their mission is to “protect people and the environment from the risks inherent in the transportation of hazardous materials by all modes including pipeline, rail, motor carrier, ship and aircraft.” Over the past 25 years, the overall risk of hazardous materials incidents has been significantly reduced, due in large part to efforts to improve the safe transportation of hazardous materials and dangerous goods. However there is still much work to do. These strategic goals not only focus on the primary mission of public and environmental safety, but also organizational excellence.

For a copy of PHMSA’s Strategic Plan 2012-2016, contact Jessica Roger.

Pipeline Safety Update

Have you seen PHMSA’s new website? The U.S. Department of Transportation has unveiled a new website for Pipeline Safety Awareness. This new website contains information about pipeline regulations, pipeline safety issues, and the role of stakeholders in pipeline safety.

The new site was developed because of recent pipeline disasters, which caused Transportation Secretary Ray LaHood to instruct DOT to examine the nation’s pipeline infrastructure and report the findings to the public.

Visitors will find links to the National Pipeline Mapping System, information about One-Call and 811 programs to utilize before beginning any excavation, and recent reports regarding Cast Iron Pipe and Hydrostatic Testing.

Besides posting regulatory updates on the new website, PHMSA will be providing them on Twitter using #PipelineUpdate.

Pipeline Regulations – New & Emerging

November 5 – Houston, TX

For everyone interested in regulatory issues, the topic at the Pipeliners Association of Houston monthly meeting will be “Pipeline Regulations – New & Emerging,” presented by Chairman Barry T. Smitherman, Railroad Commission of Texas. Registration is required to attend this meeting:

Date: November 5, 2012 – Monday
Time: 5:30 p.m.
Place: HESS Club / 5430 Westheimer Road, Houston, Texas 77056

On-line registration and more information can be found on The Pipeliners Association of Houston website.

DOT Pipeline Compliance Workshop – November 6 – 8, 2012

Join us November 6-8, 2012 in Houston at our new office and dedicated training facility for an informative, lively, and interactive workshop on DOT Pipeline Compliance topics . The workshop provides an overview of the DOT pipeline regulations in 49 CFR 191, 192, 194, 195, and 199. It also describes pipeline operations and engineering concepts. It is appropriate for people who are new to pipeline regulations, who could use a refresher, or anyone who needs to know the latest developments in these areas. This workshop will be a combined format (unlike our previous workshops), addressing both gas and liquid pipeline topics in parallel. This will eliminate some redundancy of materials, and will allow more time for in-depth discussions for each topic.

Topics to be addressed in the workshop include:

  • An overview of DOT/OPS pipeline compliance requirements
  • State and Federal agency roles for pipeline safety
  • PHMSA Jurisdiction
  • PHMSA Inspections and Enforcement Processes
  • Engineering Concepts and Stress – Strain Relationships; %SMYS
  • Design Requirements
  • Construction Requirements
  • Corrosion Control Concepts and Requirements
  • Operations and Maintenance Requirements
  • Emergency Response Requirements (including spill response planning requirements for liquid pipelines)
  • Damage Prevention Programs
  • Operator Qualification Programs
  • Drug and Alcohol Programs
  • Public Awareness Programs
  • Integrity Management (gas and liquid) Programs
  • Control Room Management Programs

We will also discuss the recently enacted Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 (pipeline reauthorization bill), recent Advisory Bulletins from PHMSA, and new, pending and proposed rulemakings.

Each attendee will receive speaker’s PowerPoint presentation handouts in hard copy, and electronic copies of the applicable regulations and voluminous reference materials including rulemakings, letters of interpretation, and other guidance documents. The workshop will adjourn at 2 p.m. on the third day, for those who need to fly out Thursday evening.

To register for our workshop, click here.

To register, or for additional information, click here.

PHMSA Data Workshop

October 29 & 30 – Washington, DC

The Pipeline and Hazardous Materials Safety Administration (PHMSA) is holding a 2-day workshop in Washington DC on October 29 & 30 to discuss PHMSA’s current and future data collection needs for its pipeline safety program. Government, industry and public representatives will describe how they currently use PHMSA’s data, how data quality could be improved and what additional data is needed. The workshop will also discuss best methods for collecting, analyzing, and ensuring transparency of additional data needed to improve performance measures. Goals of the workshop include:

  1. How do Stakeholders, including OPS, industry, and the public use the data?
  2. Performance Measures – how industry and PHMSA currently measure performance – how could these be improved and what additional data is needed
  3. Discuss best method(s) for collecting, analyzing, and ensuring transparency of additional data needed to improve performance measures.
  4. Summarize the data OPS collects, who we collect it from, and why we collect it
  5. Data quality improvement – past efforts and future opportunities – universally understood definitions

PHMSA Administrator, Cynthia Quarterman will give the keynote address, followed by presentations from PHMSA, the National Transportation Safety Board, the National Association of Pipeline Safety Representatives, and the Pipeline Safety Trust.

The meeting will be held at the Hyatt Regency on Capitol Hill. The workshop will also be webcast. To attend in person or via webcast click here to register. The event webpage also has a preliminary agenda. For additional information, contact Blaine Keener.

Revised PHMSA Reporting Requirements – 2nd Notice & Request for Comments

Docket PHMSA–2012–0024

In April 2012, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a notice in the Federal Register regarding proposed revisions to its (1) gas transmission and gathering annual report form; (2) gas transmission and gathering incident report form; and (3) hazardous liquid accident report form. (See related article in the May Edition of the DOT Compliance News.)

PHMSA issued this September notice to respond to the comments received, and provide the public with an additional 30 days to comment on the proposed revisions to the forms and the instructions. PHMSA will now submit the revised forms to the Office of Management and Budget (OMB) for approval, and OMB will consider any further comments received.

Highlights of PHMSA’s clarifications and comments include:

Gas Transmission and Gathering Annual Report Form

  • PHMSA rejected public comments seeking additional time to report the methods used to establish gas transmission pipeline Maximum Allowable Operating Pressure (MAOP), and whether pipelines are without records.
  • PHMSA clarified how to report MAOP determination methods.
  • PHMSA clarified the form and the instructions related to commodity types, inter-and intrastate designations, inspection methods, repair reporting, year of installation, pipeline piggability, pressure test levels and test mediums, and other issues.

Gas Incident and Liquid Accident Report Forms

  • PHMSA clarified how to report incident causes.
  • PHMSA reinstated certain guidance in the liquid accident form instructions, and made additional clarifications in response to public comments.

Submit comments by October 22, 2012, identified by docket number PHMSA–2012–0024, via email to: Office of Information and Regulatory Affairs, OMB.

For further information contact Blaine Keener by telephone at 202–366–0970, by fax at 202–366–4566, or by email. For a copy of PHMSA’s notice on these revised reporting requirements, or a copy of the revised forms (gas annual report, gas incident report or liquid accident report), contact Jessica Roger.

Introducing MaxOp*

RCP is extremely proud to announce the launch of a web-based version of our popular MAOP calculator model. Just like the model we built to conduct MAOP studies as a service, MaxOp* is the most comprehensive MAOP tool on the market. Through a secure web service, our customers can now push their MAOP data sets into RCP’s MaxOp* tool, link documentation to MAOP algorithm variables, dynamically segment their data, run MAOP calculations, identify potential discrepancies between the established and calculated MAOP values, and export calculated data sets and customizable reports back to their own native data sets. The tool will accept common pipeline database formats including Excel, PODS, APDM and others.

MAOP Validation Services

RCP has developed a turnkey process by which pipeline operating companies will have a traceable, verifiable and complete MAOP dataset. It starts with our MAOP document review services where RCP conducts detailed reviews of relevant MAOP documents, extracts the necessary data onto our MaxOp* cover sheets and posts the data into the database for future dynamic segmentation and calculation. For each document, a MaxOp* cover sheet is attached and re-filed, awaiting digitization by the market leading document management services company, Iron Mountain. Once these documents are scanned and posted, MaxOp* will retain a permanent link from the data set to the document image. Finally, once the document review is complete, MaxOp* will dynamically segment any spatially related data and run the MAOP calculations. The resulting values and data sets can then be exported to our customer’s in-house pipeline data set (ex. Excel, PODS, APDM, other). At the completion of this effort, the basis for an MAOP management of change has been established and our customers can be confident that their MAOP values are capable of being traced back to source documentation, the calculated values have been validated with the most comprehensive calculator tool on the market, and the MAOP values have been completely evaluated and any potential deficiencies identified.

For more information about RCP’s MAOP services or the MaxOp* calculator, please contact Jessica Roger.

* MaxOp is a US Trademark and property of RCP Inc

PHMSA 811 Effectiveness Notice & Request for Comments

[Docket No. PHMSA—PHMSA–2012–0137]

PHMSA is seeking comments on a new information collection to help determine the effectiveness of PHMSA’s 811 Public Service Announcement (PSA) campaign. A Federal Register Notice with a 60-day comment period soliciting comments on this information collection was published on July 5, 2012 (77 FR 39797). Since no comments were received, the comment period has been extended to on or before October 22, 2012. (See related article in the July Edition of the DOT Pipeline Compliance News.)

PHMSA is conducting a survey of awareness of 811 as the national “Call Before You Dig” toll-free telephone number, the importance of calling 811 before beginning an excavation project and the extent to which the newly-released PHMSA PSA is effective in raising awareness about this topic. This data is necessary to measure the effectiveness of the PSA campaign and plan future educational and outreach efforts.

PHMSA has estimated 1,000 responses with an annual burden of 120 hour for this one time collection. Comments are invited on:

  • Whether the proposed collection of information is necessary for the proper performance of the functions of the Department, including whether the information will have practical utility;
  • The accuracy of the Department’s estimate of the burden of the proposed information collection;
  • Ways to enhance the quality, utility and clarity of the information to be collected; and,
  • Ways to minimize the burden of the collection of information on respondents, including the use of automated collection techniques or other forms of information technology.

Send comments regarding the burden estimate, including suggestions for reducing the burden, to OMB, Attn: Desk Officer for PHMSA, 725 17th Street NW, Washington, DC 20503.

For further information contact: Angela Dow by telephone at 202–366–1246 or by fax at 202–366–4566.

For a copy of this notice from the Federal Register, contact Jessica Roger.

CGA DIRT Report for 2011 Released September 2012

The Common Ground Alliance (CGA) has issued its Damage Information Reporting Tool (DIRT) Report for 2011, providing a summary and analysis of the pipeline damage, near miss, and downtime events that occurred in 2011. The DIRT Report identifies the importance of calling 811 as most critical to safety. When an excavator notifies a one call center before digging, damage occurs less than 1 percent of the time, according to the report. The report also estimates that the total number of damages could be reduced by 31 percent if all digging was preceded by a locate request. The number of events submitted to DIRT for 2011 totaled nearly 208,000 for Canada and the U.S., up significantly from the previous year. CGA attributes the increase to more robust reporting. The complete DIRT Annual Report for 2011 is available for download at the CGA website.

Damage Prevention Plans

RCP can develop or update your Damage Prevention plan. For more information about how RCP can assist you with your Damage Prevention Plan, click here.

Canadian NEB Safety Paper

The Canadian National Energy Board (NEB) has released a paper identifying three emerging issues requiring the investment of effort and resources to demonstrate continual improvement of safety and environmental protection outcomes in the oil and gas industry. The 3 key issues identified are:

  1. Corporate leadership and safety culture,
  2. Effective management systems, and
  3. Performance metrics in hazard identification and risk mitigation.

The NEB will hold a safety forum June 5-6, 2013, and has posted questions for discussion to stimulate discussion within your company and at the safety forum:

  • How does your organization (CEO, executive team, frontline staff) measure the safety of its operations? What is included? What is excluded?
  • What leading and lagging indicators would provide the greatest visibility of overall safety?
  • What does your choice of safety performance indicators communicate to frontline staff? Are there possible cultural implications to your use of certain measures?
  • How can your company better detect latent threats to safety such as those posed by organizational factors? Can your organizational structure be modified to improve safety outcomes?
  • How could the performance indicators currently used by your regulator be improved to reflect appropriate safety performance measurement?

The NEB is interested in your feedback. Comments on and responses to the paper can be sent via email to Dana Cornea at any time leading up to the forum; or by phone: 1-800-899-1265.

For a copy of the NEB Safety Paper, contact Jessica Roger.

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