PHMSA ADB-2012-08 Pipeline Safety: Inspection & Protection of Pipeline Facilities after Railway Accidents
[Docket No. PHMSA–2012–0176]
The
Pipeline and Hazardous Materials Safety Administration (PHMSA) issued an
advisory bulletin to alert all pipeline owners and operators of the
circumstances of the Cherry Valley, Illinois derailment and remind them of the
importance of assuring that pipeline facilities have not been damaged either
during a railroad accident or other event occurring in the right-of-way.
Further, the advisory bulletin reminds pipeline owners and operators of the
importance of providing pertinent information to rail operators and emergency
response officials during an incident. This information should include the
presence, depth and location of the pipelines so that the movement of heavy
equipment and debris on the right-of-way does not damage or rupture the
pipeline or otherwise pose a hazard to people working in, and around, the
accident location.
The advisory also encourages pipeline owners and operators to inform rail
operators and emergency response officials of the benefits of using the 811
“Call Before You Dig” program to identify and notify underground
utilities that an incident has occurred in the vicinity of their buried
facilities.
For a copy of this Advisory Bulletin ADB-2012-08, contact Jessica Roger.
PHMSA Request for Comments on IMP Requirements & Response Plans
[Docket No. PHMSA–2012–0094]
The Pipeline and Hazardous Materials Safety Administration (PHMSA) is seeking comments on two information collections that will be submitted to the Office of Management and Budget (OMB) for renewal:
- Pipeline Integrity Management in High Consequence Areas Gas Transmission Pipeline Operators. OMB Control Number: 2137–0610. Current Expiration Date: 9/30/2012. 49 CFR 192.947 requires operators of gas transmission pipelines located in or near high consequence areas to maintain a written integrity management program and records showing compliance with 49 CFR part 192, subpart O. Operators must also submit documentation relative to their integrity management program to PHMSA as applicable.
- Response Plans for Onshore Oil Pipelines. OMB Control Number: 2137–0589. Current Expiration Date: 9/30/2012. 49 CFR part 194 requires an operator of an onshore oil pipeline facility to prepare and submit an oil spill response plan to PHMSA for review and approval.
Original notice was published in the Federal Register on May 9,
2012, (77 FR 27279) under Docket No. PHMSA–2012–0094. No comments were
received. The purpose of this notice is to allow the public an additional 30
days to submit comments on or before September 4, 2012. Comments may be
submitted via the E–Gov Website. Reference Docket No.
PHMSA–2012–0094.
For a copy of this notice, 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.
Retirement of ODES 1 – pre-2010 submittal of Annual, Accident, and Incident Reports
Due
to dated technology and support expenses compared to the amount of activity,
PHMSA is retiring the Online Data Entry System (ODES 1) on December 31, 2012.
After retirement, operators will no longer be able to submit supplement reports
for CY 2009 and earlier annual, accident, and incident reports. Operators are
encouraged to review all reports from 2002 through 2009 to ensure they are
complete and accurate. If not, operators should submit supplemental reports
online before December 31, 2012. The Pipeline Data Mart (PDM) provides easy
access to all reports within this timeframe.
After December 31, 2012, operators can still change pre-2010 reports by
emailing requests to InformationResourcesManager@dot.gov. PHMSA
will “manually” make the requested changes in the appropriate
database. PHMSA encourages operators to submit supplemental reports online
before December 31, 2012 to minimize the number of “manual” data
changes in 2013 and beyond.
PHMSA updates Control Room Management FAQ’s
PHMSA
has revised or added several control room management frequently asked questions
related to shift schedules and testing of backup manual operations plans.
C.14 With respect to testing and verification of backup manual operations,
is the intent to test every manual operation or to test the capability to
execute the backup plans, procedures, and processes?
Operators must test and verify that its internal communications plan can
effectually implement backup manual operations in the event of a SCADA system
failure. The test and verification process must be designed to confirm that the
operator has adequate personnel, procedures, processes, communications
infrastructure, and manual command-and-control capabilities to assure safe,
reliable operations and pipeline integrity when operating manually. Such
testing should (i) verify the sufficient and timely deployment of qualified
personnel to field locations necessary to adequately operate equipment and
monitor pipeline integrity, (ii) establish, supplement, and/or verify
performance of its communications or command center, and (iii) exercise
critical decision-making processes. Testing and verification should address all
types of actions necessary to mobilize manual operations. Testing and
verification should be performed on at least a representative sampling of the
processes and equipment intended to be used during backup operations.
[§§ 192.631(c)(4) and 195.446(c)(4)]
D.14 If an operator doesn’t have shift lengths, schedule rotations, and
maximum limit on hours of service explicitly noted in their fatigue mitigation
related procedures, is an operator’s actual shift schedule and related records
adequate to demonstrate compliance with (d)(1) and (d)(4)?
No. The rule requires operators to have written procedures that implement the
fatigue mitigation requirements. PHMSA would expect an operator’s fatigue
mitigation related procedures to describe the bounding parameters in shift
lengths and schedule rotations, and maximum hours of service limits they have
established as the general framework for their program. PHMSA would then expect
to see examples of actual schedules, timesheets and other records to show how
those procedures are implemented, including if/how any changes to those
schedules are managed in the context of the procedures. Schedules and
timesheets alone are likely not adequate, as they are subject to change in the
case of call-outs, vacation, etc. and would only give a certain snapshot in
time. Written procedures would provide the framework in which those schedules
can be changed and managed to reduce the risks associated with fatigue.
[§§ 192.631(d)(1) and (d)(4) and 195.446(d)(1) and (4)]
D.15 Does the information presented in the other CRM FAQs and inspection
criteria account for schedules of 7 consecutive day or night shifts followed by
7 consecutive days off, generally referred to as 7 on/7 off type shift
schedules?
Control Room Management regulations do not exclude the use of 7 on/7 off type
schedules. The regulations do, however, require the implementation of methods,
including establishing shift lengths and schedule rotations, to reduce the risk
associated with controller fatigue for any and all schedules. As part of
fatigue mitigation strategies, PHMSA expects operators to have a scientific
basis for the schedules and limits they select, and consider circadian effects,
different types of shifts, the need for rest, and other factors highlighted by
relevant research. As part of an overall fatigue mitigation program, operators
need to take into account the relative fatigue risks of whatever schedule and
limits they select, and ultimately be able to demonstrate how either the limits
they select reduce the risk of fatigue, or how fatigue mitigation tactics
(countermeasures) and other aspects of their overall program are sufficient to
reduce the risk for fatigue.
There is an increased risk for fatigue as the number of successive shifts
increase, particularly successive shifts involving night work. PHMSA’s CRM
website is a resource for information about fatigue management and related
mitigation strategies. FAQs provide some reasonable limits to consider, along
with shifts/times where fatigue risks are elevated and where fatigue mitigation
tactics should be implemented. Still other FAQs provide some examples of
fatigue mitigation tactics (countermeasures.) The level of risk appears to
increase in shift plans with periods that approach 7 successive shifts in a
row, particularly if the 7 successive shifts all involve night work.
If an operator chooses to use limits past those recommended in FAQs and
Inspection Guidance material, including 7-on/7-off schedules, an operator would
need to provide sufficient justification on how their overall program reduces
the risk for fatigue. Such justification may require different or additional
countermeasures or a more comprehensive fatigue risk management approach.
There are a number of trade-offs in considering any schedule rotation,
including 7-on/7-off type schedules. In addition to other guidance already
provided, a white paper entitled “Shift Plans with Seven Consecutive
Shifts (Miller, April 2012)” discusses the pros and cons behind such
schedules, including some countermeasures that should be considered above and
beyond those already included in other FAQs.
Operators should expect that inspectors would be more inquisitive about how they
protect against fatigue risks on the 6th and 7th successive days of work (if
day only), and on the 4th through 7th successive nights of work.
[§§ 192.631(d) and 195.446(d)]
8-11: A Day for Damage Prevention
For the 4th consecutive year, the Common Ground Alliance (CGA) encourages all stakeholders to make August 11 (8/11) a day for damage prevention, with a focus on spreading the “Call 811” message. Find additional information at the CGA website.
TRRC Amendment to 16 TAC Chapter 8 – Pipeline Safety Regulations
GUD No. 10149
On July 17, 2012, the Railroad Commission of Texas (TRRC) adopted a number of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pipeline safety rules that were issued between February 12, 2010, and October 1, 2011, including the:
- 2010 update to the standards incorporated by reference
- Drug and alcohol testing rule changes
- “One Rule” updates and new gas, hazardous liquid and LNG reporting requirements
- Fitting failure reporting
- Control room management deadline changes
- “Low Stress II” rule that applied additional safety regulation to rural low-stress hazardous liquid pipelines
This amendment to 16 Texas Administrative Code §8.1, relating to
General Applicability and Standards changes the date in subsection (b) of the
rule to update the effective date of the adoption of all amendments to Federal
pipeline safety regulations that have become effective since February 12, 2010.
This change was necessary to maintain compliance with the program and funding
requirements of PHMSA. The adoption will be published in the Texas Register on
August 3, with an effective date of August 6, 2012.
For a copy of the TRRC amendment, contact Jessica Roger.
API Damage Prevention Workshop September 12 -13, Houston, TX
Registration
is now open for API’s Damage Prevention Workshop that will be held at the
Doubletree Hotel, 15747 John F. Kennedy Boulevard in Houston. Click here for registration information and
preliminary agenda. The deadline for pre-registration is September 5.
Day One – September 12 1PM – 5PM
A team has been formed to collect industry damage prevention practices into a
virtual toolbox. The toolbox and the practices in it will be presented and
discussed. Who can contribute to the toolbox? What sorts of practices are in
it? How can the toolbox be accessed?
Day Two – September 13 8AM – 12:00 PM
There will be discussion of excavation damage incidents and near miss events
that resulted from existing exemptions from the use of one-call laws and what
the strategies that have and may be employed to reduce the occurrence of such
accidents. Would laws simply eliminating or severely limiting such exemptions
be desirable? What are the pros and cons? What additional burdens may be placed
on industry to screen and respond to additional one calls if existing exemptions
are eliminated? Are there certain exemptions that the pipeline industry wants
to retain? What industry practices have been particularly effective?
API has arranged a discounted room block at the Doubletree Hotel at George Bush
Intercontinental Airport for $159/night. Reservations can be made by calling
281-848-4001. Please be sure to mention the API meeting. The cut-off date for
making room reservations is August 29, 2012.
For more information, contact Madeleine Sellouk.
Meet me at the Conference
Western Region Gas Conference
Tempe, AZ / August 21 & 22
Stop by RCP’s Booth for a MaxOp* Demo; and, mark your agenda to attend:
Tuesday (Aug 21) Morning Session: “Best Practices for MAOP Validation” –
Presented by Chris Foley
International Pipeline Conference
Calgary, Canada / September 24 – 28
In September 2012, members of the pipeline industry from around the world will
gather in Calgary for the 9th International Pipeline Conference (IPC 2012).
Organized by volunteers representing international energy corporations, energy
and pipeline associations and governments, the IPC has become internationally
renowned as the world’s premier pipeline conference. This is a not for profit
conference and proceeds continue to support educational initiatives in the
pipeline industry.
We invite you to stop by RCP’s Booth #527 at the IPE Expo.
These articles are maintained and updated as new information becomes available.
Regulatory Watch: Key Dates & Deadlines
Track PHMSA rulemaking, regulatory stages, and important compliance deadlines in RCP's Regulatory Watch.
View Full Regulatory Watch →Conference News
Pipeline Pigging and Integrity Management Conference
The 39th International Pipeline Pigging & Integrity Management Conference (PPIM) will take place at the George R. Brown Convention Center in Houston. The event brings together pipeline operators, engineers, and industry professionals to explore advancements in pipeline inspection, integrity management, risk assessment, and emerging technologies.…
RCP Team Attending
Heather Roark
Jessica FoleyPSI Training Schedule

| Date | Training Course | Price | Registration |
|---|---|---|---|
| Nov 17 – Nov 19, 2026 | DOT Pipeline Compliance Workshop | $2,150 | SOLD OUT |
| Feb 16 – Feb 18, 2027 | Pipeline Safety Audit Training | $2,150 | Register → |
| Feb 23 – Feb 25, 2027 | Advanced Pipeline Risk Assessment Workshop | $2,150 | Register → |
| Mar 23 – Mar 25, 2027 | DOT Pipeline Compliance Workshop | $2,150 | Register → |
WEBINAR RECORDING!
Unpacking the Key Updates in API RP 1170 & 1171, 2nd Edition
Unpacking the Key Updates in API RP 1170 & 1171, 2nd Edition
RCP and the Pipeline Safety Institute offered a free webinar exploring the 2nd Editions of API RP 1170, Design and Operation of Solution-mined Salt Caverns Used for Natural Gas Storage and API RP 1171, Functional Integrity of Natural Gas Storage in Depleted Hydrocarbon Reservoirs and Aquifer Reservoirs. Thank you to everyone who attended and participated in this informative webinar. The session recording is posted to our YouTube channel. Please watch, like, and subscribe to our channel!
New Workshop Alert!
Prepare Your Team for Pipeline Safety Audits with Confidence!
Our 3-day Pipeline Safety Audit Workshop is tailored for professionals responsible for the safe operation of hazardous liquid and natural gas pipelines. Designed for groups of 10-15 participants, this interactive training…
On-Site Training Request
We have conducted on-site training for oil and gas companies for over 25 years and can provide customized workshops for companies with groups of five or more.
We would welcome the opportunity to discuss our services with you.
Sincerely,
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W. R. (Bill) Byrd, PE
President
RCP Inc.![]()


