On January 3, 2011, The National Transportation Safety Board (NTSB) issued recommendations to PHMSA, CPUC, and PG&E related to the San Bruno pipeline incident (see related article in this month’s newsletter). NTSB’s preliminary findings indicate that the pipeline operator did not have an accurate basis for the MAOP calculation.

PHMSA issued ADB-11-01 on January 4, 2011 entitled: Pipeline Safety: Establishing Maximum Allowable Operating Pressure or Maximum Operating Pressure Using Record Evidence, and Integrity Management Risk Identification, Assessment, Prevention, and Mitigation. The ADB states that operators “must assure that the records used are reliable” when calculating MOP / MAOP, and that “these records shall be traceable, verifiable, and complete”. It further states that “If such a document and records search, review, and verification cannot be satisfactorily completed, the operator cannot rely on this method for calculating MAOP or MOP.”

It further states: “Any operator of a hazardous liquid or gas transmission pipeline that is not fully cognizant of the location, pipe material and seam type, coating, cathodic protection history, repair history, previous pressure testing, or operational pressure history, and other assessment information, incident data, soil type and environment, operational history, or other key risk factors of a pipeline operating at or above 30% SMYS should 1) institute an aggressive program as soon as possible to obtain this information, 2) assess the risks, and 3) take the proper mitigative measures based upon the operator’s IM program risk findings. In addition, if these operators do not have verified information on key risk factors, an immediate and interim mitigation measure that should be strongly considered is a pressure reduction to 80 percent of the operating pressure for the previous month, hydro testing the pipeline or creating a remediation program to identify threat risks.”

This is a very significant advisory, and indicates a policy shift within PHMSA that could have profound implications for some pipeline operators. For example, operators that have relied upon “default” values for key risk factors in the integrity management program or when calculating their MOP / MAOP (in the absence of data about particular line segments) may now be required to determine the actual values for each factor; and, they may be expected to take interim pressure reductions until that data is obtained. This could require a significant data-gathering and analysis effort – especially for older pipeline systems.

The advisory states that “Future PHMSA inspections will place emphasis on the areas noted in this Advisory Bulletin.” The advisory also mentions that PHMSA and its state partners intend to sponsor a public workshop on these issues, but the date for this workshop has not yet been determined. We will inform you of the details once they are established.

For a copy of ADB-11-01, or for help in addressing these issues, contact Jessica Roger.

The National Transportation Safety Board (NTSB) has made several Urgent safety recommendations to PHMSA, the California Public Utilities Commission, and Pacific Gas & Electric (the pipeline operator) regarding the San Bruno, CA pipeline incident. The focus of these recommendations is to ensure that PG&E specifically, and pipeline operators in general, have adequate documentation of their pipeline systems, and that they have accurately calculated the maximum allowable operating pressure (MAOP) of those systems.

The NTSB’s recommendation to PHMSA was:

P-10-1 (Urgent): Through appropriate and expeditious means such as advisory bulletins and posting on your website, immediately inform the pipeline industry of the circumstances leading up to and the consequences of the September 9, 2010, pipeline rupture in San Bruno, California, and the National Transportation Safety Board’s urgent safety recommendations to Pacific Gas and Electric Company so that pipeline operators can proactively implement corrective measures as appropriate for their pipeline systems. (emphasis added)

The NTSB’s Urgent recommendations to PG&E were:

P-10-2 (Urgent): Aggressively and diligently search for all as-built drawings, alignment sheets, and specifications, and all design, construction, inspection, testing, maintenance, and other related records, including those records in locations controlled by personnel or firms other than Pacific Gas and Electric Company, relating to pipeline system components such as pipe segments, valves, fittings, and weld seams for Pacific Gas and Electric Company natural gas transmission lines in class 3 and class 4 locations and class 1 and class 2 high consequence areas that have not had a maximum allowable operating pressure established through prior hydrostatic testing. These records should be traceable, verifiable, and complete.

P-10-3 (Urgent): Use the traceable, verifiable, and complete records located by implementation of Safety Recommendation P-10-2 (Urgent) to determine the valid maximum allowable operating pressure, based on the weakest section of the pipeline or component to ensure safe operation, of Pacific Gas and Electric Company natural gas transmission lines in class 3 and class 4 locations and class 1 and class 2 high consequence areas that have not had a maximum allowable operating pressure established through prior hydrostatic testing.

Join us January 18 – 20 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 (January 18): 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 (cd-rom), inspection checklists, and speaker’s PowerPoint presentation handouts.

Day 2 (January 19): 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, and Revised Reporting Requirements.

Day 3 (January 20): 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 (cd-rom), inspection checklists, and speaker’s PowerPoint presentation handouts.

To register, or for additional information, click here.

Docket ID PHMSA-2010-0229

On October 18, 2010, (75 FR 63774) the Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) published an advanced notice of proposed rulemaking (ANPRM) seeking comments on the need for changes to the regulations covering hazardous liquid onshore pipelines. In particular, PHMSA is interested in knowing whether:

• it should extend regulation to certain pipelines currently exempt from regulation;
• other areas along a pipeline should be identified for extra protection or be included as additional high consequences areas (HCAs) for Integrity Management (IM) protection;
• to establish and/or adopt standards and procedures for minimum leak detection requirements for all pipelines;
• to require the installation of emergency flow restricting devices (EFRDs) in certain areas;
• revised valve spacing requirements are needed on new construction or existing pipelines;
• repair timeframes should be specified for pipeline segments in areas outside the HCAs that are assessed as part of IM; and
• whether to establish and/or adopt standards and procedures for improving the methods of preventing, detecting, assessing and remediating stress corrosion cracking in hazardous liquid pipeline systems.

On November 15, 2010, the American Petroleum Institute and the Association of Oil Pipe Lines requested PHMSA to extend the ANPRM comment period deadline a minimum of 60 days to give their members sufficient time to respond to this ANPRM. Likewise, on November 29, 2010, Texas Oil and Gas Association requested extension of the comment period a minimum of 60 days. PHMSA has concurred, in part, with these requests and has extended the comment period from January 18, 2011, to February 18, 2011. This extension will provide sufficient time for submission of comments concerning this ANPRM.

For further information contact Mike Israni at 202-366-4566 or by e-mail.

PHMSA officially released the Pipelines & Informed Planning Alliance (PIPA) report. A press release was posted to the PHMSA web site. The PIPA Report is available in its entirety on the Land Use Planning page within PHMSA’s Stakeholder Communications website; or, you can access these pages more directly by visiting pipelineinformedplanning.com.

PIPA was sponsored by the United States Department of Transportation; Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety (PHMSA). This report was the result of approximately 130 stakeholder participants who worked to develop land use practices for consideration of local governments, property developers and owners, transmission pipeline operators and real estate boards. The stakeholder participants were divided among three task teams which addressed issues based on a consensus approach:

• Protecting Communities – Issues relating to land use planning and development on lands adjacent to transmission pipeline ROW
• Protecting Transmission Pipelines – Issues relating to land use and development activities on the pipeline ROW
• Communication – Issues relating to communication of information among pipeline safety stakeholders

The Texas Damage Prevention Summit (a CGA regional event) will be held on January 31, 2011 at the Embassy Suites, San Marcos Conference Center, in San Marcos, Texas. On-line registration and event details can be found on the Texas811 website.

David Knoelke, who recently retired from BP Pipelines (North America) as their Sr. Regulatory Compliance Coordinator, has joined RCP as a Senior Advisor. Dave brings a wealth of pipeline industry knowledge and regulatory expertise, particularly in DOT program development and effective implementation of compliance management systems that have withstood tough scrutiny from PHMSA. We are looking forward to his valuable contributions to RCP and our clients.

January 12, 2011

PHMSA staff will conduct a FREE webinar to discuss the forms that have been approved by the Office of Management and Budget as part of the “One Rule” final regulation and the draft distribution annual report changed for DIMP. To ensure operators are aware and familiar with the revised form, PHMSA will hold this webinar in conjunction with the American Gas Association (AGA) to demo the IT system currently under development and to go through the new form to answer any questions operators may have regarding the new form, online system, and/or the DIMP requirement.

The Webinar will be held on Wednesday, January 12, 1:30 to 3:00 pm EST and will include changes to the incident reporting criteria, the national registry for pipelines and LNG facilities, mechanical coupling failure reporting.

Operators can register for the webinar by going to the following URL http://www.phmsa.dot.gov/pipeline/calendar and clicking on “Event Details” for the January 12, 2011 “New PHMSA Gas Distribution Annual Report and Mechanical Fitting Failure Reporting Webinar.”