On August 25th, PHMSA published in the Federal Register an ANPRM titled “Pipeline Safety: Safety of Gas Transmission Pipelines.” In this ANPRM PHMSA is considering whether changes are needed to the regulations governing the safety of gas transmission pipelines. In particular, PHMSA is considering whether integrity management (IM) requirements should be changed, including increasing prescriptiveness in some areas, and whether other issues related to system integrity should be addressed by strengthening or expanding non-IM requirements. Among the specific issues PHMSA is considering concerning IM requirements is whether:

• the definition of a high consequence area (HCA) should be revised to bring additional pipeline under IM requirements;
• additional requirements are needed to improve operator consideration and implementation of preventive and mitigative measures to protect HCAs against incident consequences;
• to revise IM repair criteria for pipeline segments; whether more prescriptive requirements are needed governing collection, integration, and validation of data concerning the pipeline; whether requirements related to pipeline risk analyses should be strengthened;
• additional or revised requirements are needed concerning operator application of lessons learned through implementing its IM program; and
• whether additional restrictions should be placed on the use of specific pipeline assessment methods.

With respect to non-IM requirements, PHMSA is considering whether:

• revised requirements are needed on new construction or existing pipelines concerning mainline valves, including spacing and whether remotely operated (e.g., operated from a control room via SCADA system) or automatically-operated (i.e., no human action is required) valves should be installed;
• requirements for corrosion control of steel pipelines should be strengthened;
• new regulations are needed to govern safety of underground gas storage facilities;
• requirements are needed to govern operator management of changes to its pipeline and operating practices; and
• whether pipeline operators should be required to implement formal quality management systems for new construction and installations as well as for post-construction operation and maintenance.
• exemptions applicable to facilities installed prior to the regulation and whether new regulations are needed to govern safety of rural gas gathering lines. These exemptions relate to allowable maximum operating pressure for pipelines that were in service before the initial gas pipeline safety regulations were published. These pipelines are commonly known as “grandfathered” pipelines.

The comment period for this ANPRM ends on December 2, 2011. For a copy of the ANPRM, please contact Jessica Roger.

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) recently published advisory bulletin ADB-11-05 to advise owners and operators of gas and hazardous liquid pipelines of the potential for damage to pipeline facility caused by the passage of hurricanes. Pipeline operators are urged to take the following actions to ensure pipeline safety:

1. Identify persons who normally engage in shallow-water commercial fishing, shrimping, and other marine vessel operations and caution them that underwater offshore pipelines may be exposed or constitute a hazard to navigation. Marine vessels operating in water depths comparable to a vessel’s draft or when operating bottom dragging equipment can be damaged and their crews endangered by an encounter with an underwater pipeline.
2. Identify and caution marine vessel operators in offshore shipping lanes and other offshore areas that deploying fishing nets or anchors and conducting dredging operations may damage underwater pipelines, their vessels, and endanger their crews.
3. If operators should need to bring offshore and inland transmission facilities back online, check for structural damage to piping, valves, emergency shutdown systems, risers and supporting systems. Aerial inspections of pipeline routes should be conducted to check for leaks in the transmission systems. In areas where floating and jack-up rigs have moved and their path could have been over the pipelines, review possible routes and check for sub-sea pipeline damage where required.
4. Operators should take action to minimize and mitigate damages caused by flooding to gas distribution systems including the prevention of overpressure of low pressure and high pressure distribution systems.

For a copy of ADB-11-05, contact Jessica Roger.

PHMSA has issued newly released inspection forms:

• PHMSA Form 1 Standard Inspection Report of a Gas Transmission Pipeline, Revised 8/4/11
• PHMSA Form 2 Standard Inspection Report of Gas Distribution Operator, Revised 5/6/11
• PHMSA Form 3 (Standard Inspection Report of a Liquid Pipeline Carrier), Revised July 15, 2011
• PHMSA Form 21 Public Awareness Program Effectiveness Inspection Form (192.616, 195.440), Rev. 0 July 21, 2011

Contact Jessica Roger for more information.

On August 23, 2011, the Railroad Commission of Texas (TRRC) adopted some amendments to §3.80, relating to Commission Oil and Gas Forms, Applications, and Filing Requirements. The amendments revise three existing forms, add five new forms, and delete five other forms. The adoption will be published in the September 9, 2011, issue of the Texas Register with an effective date of September 12, 2011.

Also at the August 23 open meeting, the TRRC proposed amendments to two other rules. The proposed amendments to §3.78, relating to Fees and Financial Security Requirements, implement portions of Senate Bill 1 and Senate Bill 2 (First Called Session, 2011) and add surcharges to fund the Oil and Gas Regulation and Cleanup Fund.

The TRRC also proposed amendments to §8.201, relating to Pipeline Safety Program Fees, to implement provisions of Senate Bill 1 and Senate Bill 2; the amendments increase the service line fee from 70 cents to 75 cents.

The comment period for the proposed amendments to §3.78 and §8.201 end at noon on Tuesday, October 11, 2011.

For more information on this and other rulemakings, or to access the online comment form for any proposed rulemakings, please see the Proposed Rules Table.

The Pipeline Research Council International (PRCI) has just released a new report on, “Pipeline Defect Assessment – A Review & Comparison of Commonly Used Methods.” This document is intended to provide the user with basic tools for defect assessment when the information available includes knowledge of the applied static stress levels in the pipe, the material properties (strength and toughness), and the dimensions of the defect.

The report is available for $285. Click here to order (Catalog Number: L52314).

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

• Pipeline Design, Construction, and Assessment (October 31 – November 2)
• Integrity Management (November 3)
• In-Line Inspection (November 4)

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.

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.

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.

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.

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.