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DOT Pipeline Compliance News
April 2015 Edition

PHMSA Final Rule: Misc. Changes to Pipeline Safety Regs
[Docket No. PHMSA-2010-0026; Amdt. Nos. 191-23; 192-120; 195-100]
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On March 11, 2015, PHMSA published a Final Rule amending the pipeline safety regulations in the following subject areas: post-construction inspections, leak surveys of Type B onshore gas gathering lines, qualifying plastic pipe joiners, regulation of ethanol, transportation of pipe, filing of offshore pipeline condition reports, and calculation of pressure reductions for hazardous liquid pipeline anomalies. The Final Rule also made several editorial changes in the regulations. The changes are effective October 1, 2015.

Post-construction inspections: PHMSA modified the gas and hazardous liquid regulations to require that post-construction inspections of gas transmission and hazardous liquids pipelines be performed by a person other than the one who performed the construction task. In response to comments on the proposed rule, PHMSA clarified that it did not intend to require third-party inspections or prohibit all persons from a company from inspecting the work of another company employee. Only the person who performed the construction task will be excluded from conducting the inspection.

Regulation of Transportation of Ethanol by Pipeline: The definition of "hazardous liquid" has been modified to include ethanol.

Offshore Pipeline Condition Report: Because inspections of shallow-water pipelines are based on risk, reports are no longer required 60 days after inspections. This reporting requirement (191.27 and 195.57) has been removed from the gas and hazardous liquid regulations.

Calculating Pressure Reductions for Hazardous Liquid Pipeline Integrity Anomalies: The requirements for pressure reduction calculations have been clarified. ASME/ANSI B31G and PRCI PR-3-805 (R-STRENG) can now be used to calculate the required pressure reduction as well as for determining if an anomaly is an "immediate repair condition." If no "suitable remaining strength calculation method" can be identified, then pressure must be reduced a minimum of 20% from the actual operating pressure of the past 2 months.

National Pipeline Mapping System (NPMS): PHMSA added sections 191.7(e), 191.29 and 195.58(e), and 195.61 to codify the statutory requirement for submission of information to the NPMS.

Welders vs Welding Operators: Welding operators are now specifically included in the requirements for welding procedures and qualifications. Additionally, Appendix A of API 1104 has been added as an option for evaluating welds.

Odorization of Gas Transmission Lateral Lines: PHMSA proposed to amend § 192.625(b)(3) to state that the length of a lateral line, for purposes of calculating whether at least 50 percent of the line is in a Class 1 or Class 2 location, be measured between the distribution center and the first upstream connection to the transmission line. This proposal was removed due to comments received and discussions at the Gas Pipeline Advisory Committee (GPAC) meetings. PHMSA will re-evaluate the proposal and may consider it in a future rulemaking action.

Leak Surveys for Type B Gas Gathering Lines: Annual leak surveys (not to exceed 15 months) will be required for Type B gathering lines. Any hazardous leaks found must be repaired.

Components Fabricated by Welding: All ASME pressure vessels to be used in gas meter stations, compressor stations and other locations subject to testing for Class 3 or Class 4 requirements must be designed and pressure tested to 1.5 times the MAOP. The ASME Boiler and Pressure Code Section VIII specifies that pressure tests must be done to 1.3 times the MAOP.

Qualifying Plastic Pipe Joiners: Plastic pipe joiners must be re-qualified each calendar year (not to exceed 15 months) or after any production joint is found unacceptable. Current regulations allow 3 joints or 3% of all joints made to be unacceptable.

Testing Components Other Than Pipe in Low-Pressure Gas Pipelines: The requirements for testing of components, now found in 192.505 for pipelines that operate at 30% of SMYS or more, will be applicable to all pipelines and mains.

Mill Tests for Pipe to Operate at Alternative MAOP: The allowance for combining loading stresses imposed by pipe mill hydrostatic testing equipment with the internal test pressure has been eliminated.

Alternative MAOP Notifications: For new pipelines to be operated using an alternative MAOP, notification to PHMSA will be required at least 60 days prior to the earliest start date of either pipe manufacturing or construction activities. For pipelines already in service, the 180 days notification requirement remains.

Transportation of Pipe: The exception for gas transmission pipe transported before November 12, 1970 has been eliminated. All pipe transported by rail must be transported in accordance with API 5L1, if the pipe will be operated at a hoop stress of 20% or more of SMYS and has a diameter-to-wall-thickness ratio of 70 to one or more.

For a copy of PHMSA's Final Rule of misc. changes to the pipeline regulations, please contact Jessica Foley.

Introducing TestOp™

The software that RCP utilizes on-site to validate our customer’s pressure tests is now available to license. The license allows operators to create, plan, simulate, execute and generate comprehensive reports of pressure tests using a web-based platform with optional offline data upload capabilities. Some key features of TestOp™ include:

  1. Useful for any pressure test conducted under
    1. 49 CFR 192 Subpart J Test Requirements
      1. Gas transmission
      2. Gas distribution
      3. Regulated gas gathering
    2. 49 CFR 195 Subpart E Pressure Testing
    3. ASME B31.3 Process Piping, Section 345 Testing
  2. All allowable test mediums
    1. Water
    2. Nitrogen
    3. Air
    4. Natural gas
  3. Applications
    1. New construction
    2. Repairs & replacements
    3. Uprates
    4. Conversion of service
    5. Integrity / MAOP verification
    6. Grandfathered pipe
    7. Spike / elevated pressure testing
    8. Pipeline integrity assessments, including ASME B31.8S, Table 3

Pressure Test Services

RCP is a leading industry expert on pressure testing. We design and validate pressure tests using a proprietary web-based program (TestOp™) that calculates the allowable pressure/temperature change for a particular test segment, confirming or denying the presence of pin-hole leaks while also detecting possible pipe yielding or air entrapment during a spike. RCP also offers Pressure Test Workshops that teach you how to plan for a pressure test from start to finish, and how to determine/prove if the test was successful.

To request a demonstration or obtain more information on RCP's pressure test services, contact Jessica Foley.

Advisory Bulletin ADB-2015-01: Potential for Damage to Pipeline Facilities Caused by Severe Flooding
[Docket No. PHMSA-2015-0105]
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PHMSA has released five Advisory Bulletins on the subject of potential for damage to pipeline facilities caused by flooding, river scour, and river channel migration, with the earliest issued July 29, 1993, (ADB-93-03), and the most recent on July 27, 2011, (ADB-11-04; 76 FR 44985). Each of these bulletins followed an event that involved severe flooding that affected pipelines in the areas of rising waters.

River bottom scour and channel migration may occur due to seasonal flooding, increased stream velocities, and man-made and natural river bank restrictions. River scour and channel migration may damage a pipeline as a result of additional stresses imposed on the pipe by undermining underlying support soils, exposing the pipeline to lateral water forces and impact from waterborne debris. Lateral water forces may cause excessive bending loads that lead to pipeline failures, and possible impact forces from debris in the river or harmonic vibrations from water rapidly passing over pipelines can also increase the potential for pipeline failures.

Additionally, the safety of valves, regulators, relief sets, pressure sensors, and other facilities normally above ground or above water can be jeopardized when covered by water. Not only can these facilities become inoperable when submerged, but they are also at a greater risk of damage by outside forces, floating debris, river currents, and craft operating on the water. Boaters involved in rescue operations, emergency support functions, sightseeing, and other activities are generally not aware of the seriousness of an incident that could result from their craft damaging a pipeline facility that is unseen beneath the surface of the water. Depending on the size of the craft and the pipeline facility struck, significant pipeline damage may result.

Although accidents at river crossings account for less than one percent of the total number of pipeline accidents, the consequences of a release in water can be much more severe because of the threats to drinking water supplies and the environment. Unlike hazardous liquid releases on land where it can be easier to respond to and contain spills, swift-moving river currents will carry hazardous liquids further downstream, potentially impacting much larger geographical areas and more communities. Product releases in rivers can create difficult, costly, and lengthy spill response and remediation scenarios and activities for operators, communities, and local, state, and Federal responders.

The latest advisory bulletin lists 14 steps that pipeline operators may need to take to address these issues. For a copy of the entire bulletin, contact Jessica Foley.

PHMSA Pipeline SMS Workshop April 22nd
Westin Galleria, Houston, TX
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PHMSA is conducting a one-day public workshop to discuss the recent Pipeline Safety Management Systems (PSMS) national consensus standard. The meeting will include participation from all major pipeline sectors, State and Federal regulators, and public safety advocates. PHMSA is hoping to draw some senior industry representation to the workshop.

This workshop will detail the development process of the SMS standard. The workshop will also emphasize the core elements of the standard including leadership and management commitment, risk management, emergency preparedness and response, competence awareness and training, management review and continuous commitment, and the critical role of safety culture.

The workshop will be held at the Westin Galleria, which is located at 5060 West Alabama Street. Hotel reservations may be made under the room block "PHMSA – Pipeline Safety Management System Workshop" by calling the hotel directly at (713) 960-8100.

Online registration and an agenda for the meeting is available on the PHMSA meeting webpage.

RCP Continues to Add More Firepower to its Staff
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Jerry Rau has joined RCP as an Executive Consultant. Jerry has 35+ years of experience in the industry with expertise in corrosion control and pipeline integrity management for both onshore and offshore assets. He is a specialist in many areas of corrosion control including: cathodic protection, chemical inhibitors, coatings and materials selection. Jerry has been involved with the development of integrity management industry standards and directed research activities for the pipeline industry. He has also developed and implemented threat assessment and risk management programs. We are looking forward to his valuable contributions to RCP and our clients.

Spring 2015 Conference Schedule
April – May 2015
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Have you registered and confirmed your reservations for these upcoming conferences? RCP will be attending. We hope to see you there!

Western Energy Institute Operations Conference
April 21 -24, 2015
Red Rock Resort / Las Vegas, NV

WEI's Operations Conference unites almost 400 electric and natural gas energy operations managers, supervisors and front line employees for 3 days of education and networking across ten different tracks. This conference is a must for any upper-level manager and many choose to bring their direct reports for team and skill-building.

API Pipeline Conference
April 28 & 29, 2015
Savannah International Trade & Convention Center, Savannah, GA

API's one and one-half day conference program features a keynote address by Alex Epstein, author of The Moral Case for Fossil Fuels, an Executive Roundtable focusing on which issues Pipeline Company Presidents and CEO's view as the most challenging issues facing our industry as well more than 50 technical sessions featuring topics such as Business, Natural Forces, Safety Culture, Human Resources and a host of other timely subjects.

AGA Conference & Biennial Exhibition
May 19 – 22, 2015
Gaylord / Grapevine, TX

The annual AGA Operations Conference is the natural gas industry's premier gathering of natural gas utility and transmission company operations management from across North America and the world for the sharing of technical knowledge, ideas and practices to promote the safe, reliable, and cost-effective delivery of natural gas to the end-user. Be sure to mark your calendar and plan to attend Bill Byrd's presentations on May 20:

  • "Thermal Stabilization During Hydrostatic Testing" [Transmission Pipeline Operations Track A7 (10:15 am - 11:00 am)]
  • "Monte Carlo Methods for Pipeline Site Risk Assessment" [Distribution Measurement/ Engineering Track B3 (3:50 pm - 4:35 pm)]

Midwest Energy Association Legal, Regulatory & Government Affairs Summit
Breckenridge, CO
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The Midwest Energy Association (MEA) is holding a summit designed specifically for legal and regulatory professionals working with energy delivery companies and will include candid, practical information from those in the know. The summit will be held from September 29 – October 1, 2015 at the DoubleTree by Hilton Hotel in Breckenridge, CO. Visit the MEA website for more information regarding registration, agenda, and hotel.

Save the Dates!
RCP 2015 Workshop Schedule

Join us at our corporate office and dedicated training facility in downtown Houston. We are now offering Pressure Test Workshops in addition to our DOT gas & liquid pipeline seminars. Visit our Training Website for updates and registration information.

DOT Gas Pipeline Workshop
June 2, 3, 4 (Tuesday, Wednesday, Thursday)

Pressure Test Workshop:
August 4 & 5 (Tuesday & Wednesday)

DOT Combined Gas & Liquid Workshop:
August 11, 12, 13 (Tuesday, Wednesday, Thursday)

DOT Hazardous Liquid Pipeline Workshop
October 6, 7, 8 (Tuesday, Wednesday, Thursday)

We would welcome the opportunity to discuss our services with you.

Best Regards,

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



About RCP
RCP is a registered professional engineering corporation staffed by more than 50 energy pipeline experts with extensive experience in energy pipeline risk management and regulatory compliance issues. Since 1995, RCP has assisted companies and organizations of all types and sizes, including every pipeline operator in the Forbes 500 down to small municipal operators, with the challenges of energy pipeline and terminal regulatory compliance and integrity management at the federal level, in every state, and in several foreign countries. Our personnel have experience as operators, engineers, and managers, and participate at the highest levels of the gas and liquid energy pipeline industry by serving on technical research committees and developing industry standards. RCP also offers pipeline integrity and corrosion control consulting services by providing operational support and program implementation management services, including selection, contracting, and management of subcontractors in the field to implement the required program activities for corrosion control, in-line inspection, direct assessment, and more. RCP has the perfect team to support your pipeline integrity and compliance requirements - from initial consulting, to program development, to implementation and final analysis of a broad range of pipeline regulatory compliance and integrity management issues.

For more information, please contact Jessica Foley at 713-655-8080 or visit www.rcp.com.

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