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DOT Pipeline Compliance News
January 2015 Edition

Pipeline Pressure Testing Workshop: January 13-14, 2015
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RCP is now offering a 2-day Pipeline Pressure Testing Workshop at its facilities in downtown Houston. The workshop will begin by outlining the objectives for performing a pressure test and how those relate to DOT requirements. The workshop will then build upon these foundations to answer many specific pressure testing questions including:

  • What are the different types of tests commonly conducted and how do you design each one?
  • What is the theory and physical science behind a pressure test?
  • How do you plan for a pressure test from start to finish:
    • Cleaning the line
    • Environmental hazards and permitting
    • Landowner and operations safety
    • Customer/stakeholder impact
    • Logistical details and scheduling
    • Pipeline modifications and anticipating failures
  • What is the required instrumentation and how does it need to be configured?
  • What data is absolutely necessary to validate a pressure test?
  • How do you determine and prove a successful pressure test?
  • What does a good test report look like (that will also satisfy PHMSA)?
Each attendee will receive the presentation as well as applicable handouts in a hardcopy notebook. Attendees will also have the opportunity to work through several exercises specifically covering 1) calculating the SMYS, MAOP and test pressures for various pipeline segments at various elevations 2) calculating the volume of water required for a hydrotest, fill times and velocities, and determining how the volume of test water changes with pressure and 3) designing a complete test plan for a hypothetical pipeline i.e. dividing the line into test sections and determining the test parameters for each section.

To register for our workshop, click here.

Periodic Updates of Regulatory References to Technical Standards and More!
[Docket No. PHMSA–2011–0337]
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The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) issued a Final Rule effective March 6, 2015, regarding standards incorporated by reference (IBR), as well as other miscellaneous rule amendments for both gas and liquid pipelines. The new rule incorporates about 20 updated standards and 2 new standards: API RP 5LT regarding truck transportation of pipe, and ASTM D2513-09a regarding PE plastic pipe (with the exception of re-worked plastic pipe). It also corrects typos and incorrect references, and standardizes wording and references in a number of areas. The new rule does not incorporate the latest edition of API RP 1162, dealing with public awareness programs – although it does leave the door open for incorporation once PHMSA and its state regulatory partners have had an opportunity to review the latest round of inspections under the previous RP, and have conducted a workshop to discuss best practices. But it does not stop there.

It also requires that liquid pipeline operators maintain their integrity management records for the useful life of the pipe. Perhaps the most important revision that could affect liquid pipeline operators is disallowance of Risk Based Inspection intervals for internal tank inspections under Section 6.4.3 of API Standard 653. Per the revised rule, operators who used 6.4.3 prior to March 6, 2015 to establish RBI intervals can no longer use that section, and must do an inspection by Jan 5, 2017, if:

  1. it has been longer than 20 years since the last inspection
  2. a calculation using 6.4.2 would have required re-inspection by now
  3. the inspection interval calculated under 6.4.3 was not based on actual corrosion rates and other relevant factors.
For all other tanks, operators must calculate and follow inspection intervals per 6.4.2. This effectively means a default internal inspection interval of 10 years regardless of risk, and a maximum inspection interval of 20 years if adequate data is available to support the longer interval.

For a copy of PHMSA's Final Rule, contact Jessica Foley.

BOEM Issues Final Rule Increasing Offshore Oil Spill Liability Limits
[Docket No. BOEM-2012-0076]
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The Bureau of Ocean Energy Management (BOEM) issued a Final Rule increasing the limit of liability for damages caused by responsible parties related to oil spills from offshore facilities, other than deepwater ports, under the Oil Spill Pollution Act of 1990. This rule adjusts the limit of liability to reflect the significant increase in the Consumer Price Index (CPI) that has taken place since 1990. It also establishes a methodology for BOEM to use to periodically adjust the OPA offshore facility limit of liability for inflation. The liability limit will increase from $75 million to $133.65 million.

This Final Rule is effective January 12, 2015. For a copy of BOEM's Final Rule, contact Jessica Foley.

FERC Final Rule Natural Gas Act Pipeline Maps
[Docket No. RM14-21-000; Order No. 801]
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The Federal Energy Regulatory Commission (FERC) issued a Final Rule, revising 18 CFR Part 154 regulations concerning interstate natural gas pipeline maps. As proposed in its Notice of Proposed Rulemaking (see related article in the "DOT Pipeline News" August 2014 edition), FERC is permanently eliminating the requirements that pipelines include system maps in their tariffs and must file to update those tariff maps by April 30 of any year following a major system change. As further proposed in the NOPR, FERC is retaining the requirement that pipelines maintain a system map on their internet Web sites, revising the regulations to require pipelines to update the online maps no later than the end of the next calendar quarter after a major system change.

Final Rule Effective Date: March 17, 2015.

For a copy of FERC's Final Rule, contact Jessica Foley.

PHMSA Projected Rulemaking Dates
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The Department of Transportation (DOT) publishes a Significant Rulemaking Report that reflects the revised dates for the Pipeline Hazardous Materials Safety Administration (PHMSA) rulemakings. There are indications that there will be major changes in 2015. A quick reference table for the pipeline safety regulations is provided below with a short description of each rulemaking after the table. The full report can be seen here: http://www.dot.gov/regulations/report-on-significant-rulemakings.

PHMSA Rulemaking Stage Projected Publication Date
Excess Flow Valves NPRM January 20, 2015
Safety of On-shore Liquid Hazardous Pipelines NPRM February 3, 2015
Enforcement of State Excavation Damage Laws Final Rule April 14, 2015
Misc. Pipeline Amendments Final Rule April 23, 2015
Operator Qualification (RRR) NPRM April 23, 2015
Rupture Detection and Valves Rule NPRM May 14, 2015
Gas Transmission (RRR) NPRM June 10, 2015

NPRM: Notice of Proposed Rulemaking
RRR: Retrospective Regulatory Review

Excess Flow Valves
[Docket No. PHMSA-2011-0009]
This rulemaking would require excess flow valves (EFVs) be installed in all new and renewed gas service lines, for structures other than single family dwellings, when the operating conditions are compatible with readily available valves. These changes would be in response to NTSB and PHMSA investigations of current EFV installation practices. The intended effect of the rule is to increase the level of safety for structures other than single family dwellings currently subject to Federal pipeline safety regulation.

Safety of On-Shore Liquid Hazardous Pipelines
[Docket No. PHMSA-2010-0229]
This rulemaking would address effective procedures that hazardous liquid operators can use to improve the protection of High Consequence Areas (HCA) and other vulnerable areas along their hazardous liquid onshore pipelines. PHMSA is considering whether changes are needed to the regulations covering hazardous liquid onshore pipelines, whether other areas should be included as HCAs for integrity management (IM) protections, what the repair timeframes should be for areas outside the HCAs that are assessed as part of the IM program, whether leak detection standards are necessary, valve spacing requirements are needed on new construction or existing pipelines, and PHMSA should extend regulation to certain pipelines currently exempt from regulation. The agency would also address the public safety and environmental aspects any new requirements as well as the cost implications and regulatory burden.

Pipeline Safety: Excavation Damage Laws
[Docket No. PHMSA-2009-0192]
The PIPES Act provides PHMSA with the authority to enforce excavation damage laws in those states that have inadequate enforcement. This rulemaking would consider standards for excavators and operators to follow when conducting excavation in a vicinity of a pipeline and the administrative procedures to be used for enforcement proceedings.

Miscellaneous Pipeline Amendments
[Docket No. PHMSA-2010-0026]
This rulemaking would make minor changes to various provisions in the pipeline safety regulations to help clarify them by making editorial corrections, correcting inconsistent regulatory language and responding to several petitions for rulemaking, such as providing for an updated standard. The primary intended effect of this rule is to enhance the accuracy and reduce misunderstandings of the regulations. The amendments contained in this rule are non-substantive changes.

Operator Qualification, Cost Recovery, Accident and Incident Notification, and Other Changes (RRR)
[Docket No. (not assigned yet) / RIN 2137-AE94]
This rulemaking would address miscellaneous issues that have been raised because of the reauthorization of the pipeline safety program in 2012 and petitions for rulemaking from many affected stakeholders. Some of the issues that this rulemaking would address include: renewal process for special permits, cost recovery for design reviews, and incident reporting.

Amendments to Parts 192 and 195 to require Valve installation and Minimum Rupture Detection Standards
[Docket No. (not assigned yet) / RIN 2137-AF06]
This rule would propose installation of automatic shutoff valves, remote controlled valves, or equivalent technology and establish performance based meaningful metrics for rupture detection for gas and liquid transmission pipelines. The overall intent is that rupture detection metrics will be integrated with ASV and RCV placement with the objective of improving overall incident response. Rupture response metrics would focus on mitigating large, unsafe, uncontrolled release events that have a greater potential consequence. The areas proposed to be covered include High Consequence Areas (HCA) for hazardous liquids and HCA, Class 3 and 4 for natural gas (including could affect areas).

Gas Transmission (RRR)
[Docket No. PHMSA-2011-0023]
In this rulemaking, PHMSA will be revisiting the requirements in the Pipeline Safety Regulations addressing integrity management principles for Gas Transmission pipelines. In particular, PHMSA will address: repair criteria for both HCA and non-HCA areas, assessment methods, validating & integrating pipeline data, risk assessments, knowledge gained through the IM program, corrosion control, management of change, gathering lines, and safety features on launchers and receivers.

RCP's Web-Based Compliance Management Systems

RCP's Compliance Management System (CMS) is an invaluable tool for managing all aspects of regulatory workflow. Some examples of how our clients are using the CMS include:

  • O&M Scheduling and Data Acquisition;
  • Cathodic Protection Inspection and Data Management;
  • One-Call Screening and Ticket Management;
  • Repair / Replacement Programs;
  • Operator Qualification Administration and Workflow Integration;
  • Leak Life Cycle Management;
  • Environmental, Health and Safety Compliance;
  • Audit Action Item Tracking; and
  • Customer Data Management.

DIMP Integration

For gas distribution operators looking for a powerful tool to implement DIMP, the RCP CMS integrates O&M data captured from field personnel along with inherent system attributes to provide real-time risk analysis, performance reporting, as well as track additional and accelerated actions taken to mitigate risks.

Key Features

  • GIS integrated workflow management
  • Custom tailored e-mail notifications and reporting
  • Runs on any web-enabled device, no software to download
  • Powerful reporting and custom query functionality
  • Multiple security and user privilege settings
  • Document storage and control (ex. procedures, maps, images, and completion documentation)
  • Automatic recurrence setting for routine tasks (example: leak surveys, CP surveys, etc.)
  • Create work orders for unscheduled / unplanned activities (ex repairs of third party damages)
To request a demonstration or to request more information, please contact Jessica Foley.

Kansas Gas Regulations Revisions
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On December 26, 2014 the Kansas Corporation Commission made the following changes to their regulations governing natural gas pipelines found in Agency 92 Article 11:

  • Added definitions for "Town border station"
  • Revised definition for "Yard line"
  • Updated Section 82-11-4 to adopt applicable federal regulations in effect as of October 1, 2013 from 2010 with the following exceptions / changes
    • Replaced “administrator” in the federal regulations with "commission"
    • Added information to exclude adoption of forwards, table of contents and indexes to 49 CFR 192.7(c) and also to exclude the adoption of Appendix X.1.4 "appeals to HSB actions" from the adoption of the Plastics Pipe Institute Inc.’s policies and procedures for developing hydrostatic design basis, hydrostatic design stresses, pressure design basis, strength design basis and minimum required strength ratings for thermoplastic piping materials or pipe dated May 2008.
    • Deleted existing language in 49 CFR 192.181(a) and replaced with the following "Each high-pressure distribution system shall have valves spaced to reduce the time to shut down a section of main in an emergency. Each operator shall specify in its operation and maintenance manual the criteria as to how valve locations are determined using, as a minimum, the considerations of operating pressure, the size of the mains, and the local physical conditions. The emergency manual shall include instructions on where operating personnel can find maps and other means of locating emergency valves during an emergency. Each area of residential development constructed after May 1, 1989, shall be provided with at least one valve to isolate it from other areas."
    • Added the word “existing” to the extra subsection of 49 CFR 192.317 added to the Kansas regulation.
  • Removed a sentence previously added to 49 CFR 192.703 requiring the replacement, repair or removal from service within 5 days of any class 1 leak after the conditions are no longer hazardous.
  • Cleaned-up section 82-11-11 Fees
  • Made various minor editorial changes

New Mexico State Damage Prevention Regulation Changes
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New Mexico changed its Pipeline Safety Excavation Damage Prevention Regulations on December 30, 2014. A positive response registry system must be developed, and utility members must now submit positive responses for requested locates. The changes also provide additional clarification of the locate process, wide area locates, bid conferences, and updated one-call request timelines. Failures to pre-mark excavations or report damage are now counted as abuses of the state statute. Updated damage reports must now be submitted within thirty calendar days of an occurrence.

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, contact Jessica Foley.

PAPA Pipeline Safety Video
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The Pipeline Association for Public Awareness, with Underground Focus magazine, has developed a new pipeline safety video for excavators. It can be viewed on the Association's Vimeo channel at this link: Pipelines. PAPA encourages operators to use it as appropriate, and plans to have DVD versions available soon. For further information contact jeff.farrells@pipelineawareness.info.

RCP's 20th Anniversary 1995 – 2015

RCP's 20th anniversary is coming up in February . If you are going to be in Houston in February, please let us know so we can extend a special invitation to one of our events. Be on the lookout for other special events throughout the year.

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.

Pressure Test Workshops:
January 13 & 14 (Tuesday & Wednesday)
August 4 & 5 (Tuesday & Wednesday)

DOT Combined Gas & Liquid Workshops:
March 10, 11, 12 (Tuesday, Wednesday, Thursday)
August 11, 12, 13 (Tuesday, Wednesday, Thursday)

DOT Gas Pipeline Workshop
June 2, 3, 4 (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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