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DOT Pipeline Compliance News
July 2015 Edition

PHMSA NPRM: OQ, Cost Recovery, Accident and Incident Notification, and Other Pipeline Safety Proposed Changes
[Docket No. PHMSA-2013-0163]
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The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) has published a Notice of Proposed Rulemaking (NPRM) proposing amendments to the pipeline safety regulations to address Sections 9 and 13 of the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 (2011 Act), and to update and clarify certain regulatory requirements.

Among other provisions, PHMSA is proposing to add a specific time frame for telephonic or electronic notifications of accidents and incidents and add provisions for cost recovery for design reviews of certain new projects, for the renewal of expiring special permits, and for submitters of information to request PHMSA keep the information confidential. They are also proposing changes to the operator qualification (OQ) requirements and drug and alcohol testing requirements and incorporating consensus standards by reference for in-line inspection (ILI) and Stress Corrosion Cracking Direct Assessment (SCCDA) in Part 195. This NPRM covers the following areas:

  • OQ enhancement, including new construction, regulated gathering
  • Control room management updates
  • Design reviews by PHMSA for large projects or new technology
  • Excluding farm taps from DIMP and adding over pressure protection requirements for farm taps
  • Notifications to PHMSA for flow reversal or conversion of service
  • Part 195 incorporated by reference updates
  • Part 195 IMP updates, including SCCDA assessment
  • Special permit renewal process
  • Drug & alcohol testing criteria following incidents
  • Reporting of drug & alcohol test results
  • Adding references to API 1104, Appendix B for in-service welding
Comments on this proposed rulemaking are due by September 8, 2015. For a copy of the NPRM, please contact Jessica Foley.

PHMSA Advisory Bulletin ADB-2015-02: Potential for Damage to Pipeline Facilities Caused by Hurricanes
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Hurricanes can adversely affect the operation of a pipeline and require corrective action under §192.613 and 195.401. Hurricanes also increase the risk of underwater pipelines in the Gulf of Mexico and its inlets becoming exposed or constituting a hazard to navigation under §192.612 and 195.413. The Gulf of Mexico is now in hurricane season, and PHMSA recently published ADB-2015-02 to remind all owners and operators of gas and hazardous liquid pipelines that pipeline safety problems can occur from 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. After a disruption, operators 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.
PHMSA would appreciate receiving information about any damage to pipeline facilities caused by hurricanes. The Federal pipeline safety regulations require that operators report certain incidents and accidents to PHMSA by specific methods. Damage not reported by these methods may be reported to David Lehman, Director for Emergency Support and Security, 202-366-4439 or by email at PHMSA.OPA90@dot.gov.

Pressure Test WebEx
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Join us on July 16 (Thursday) at 2 p.m. CST for a WebEx presentation on TestOp™, our new comprehensive pressure testing tool. TestOp™ is a proprietary web-based application that provides operators with a platform to plan, design, certify and document their pressure tests. For use on gas and liquid lines, with tests using water, nitrogen, natural gas or air, TestOp™ takes the confusion out of pressure testing by providing real-time determination of whether the test segment is experiencing pipe yielding or air entrapment during the ramp up to spike pressure while also modeling the pressure/temperature relationship of the test to determine if a leak is occurring. TestOp™ also calculates the MAOP established by the test, the reassessment interval based on federal code requirements, the test factor required based on pipe inputs, and more.

Click here to get Login information.

Gas Distribution Annual Report Form
PHMSA F7100.1-1 (rev 5-2015)
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PHMSA posted an updated Gas Distribution Annual Report Form F7100.1-1 for the submission of calendar year 2015 data in 2016. Updates to the form include:

  • addition of "Reconditioned Cast Iron" as a material specification for reporting pipeline mileage;
  • operators can differentiate between historic cast iron mileage and mileage that has been modified;
  • Part D – Excavation Damage: operators will be able to identify the root causes of excavation damage.

Pipeline Pressure Testing Workshop: August 4-5, 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.

Revised PHMSA OpID Assignment Request and Operator Registry Notification
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Revised OpID Assignment Request and Operator Registry Notification forms and instructions are available on the PHMSA website and for online entry in the PHMSA Portal. The changes took place June 1st, 2015.

Basic changes to the OpID assignment request include requiring cell phone numbers and e-mail addresses for operator contacts. Gas Distribution includes more categories such as Landfill Gas, Synthetic Gas, and Hydrogen Gas. Definitions of these new categories are included in the instructions. In Gas Distribution, two new categories for the type of operator, investor owned or cooperatively owned, have been added while categories LPG and LNG have been removed. Supplemental data for assets now include whether pipeline or facilities are inter or intrastate and the number of miles of pipe per state is also required.

Procedure Manual for Operations, Maintenance, and Emergencies is now included for ALL facilities while Integrity Management Programs are now required for Gas Distribution, Gas Transmission, and Hazardous Liquid Pipeline Facilities. For operators who are not sure if safety programs will be separate and independent of other OpIDs at the time of OpID application, a Registry Type C Notification is required within 60 days after approval of the OPID.

Basic changes to the Operator Registry Notification form mirror the changes to the OpID assignment request. Clarifying language has been added on when a Type C Notification is required. When facilities remain with an OpID, but the operator begins using a new, shared safety program for that system, a Type C notification is required within 60 days of the change. Flow diagrams have been added to help operators decide which type of notification is necessary for buying or selling assets, changing the operating entity, or constructing/rehabilitating facilities.

Major changes include the ability for operators to deactivate an OpID number. Type D and E notifications, for acquisition and divestiture of 50 or more miles of pipeline has been merged into a single Type D notification. If you need to report both an acquisition and a divestiture (Type D) or change the operating entity that includes both an assumption and cessation (Type B), then two separate notifications must be submitted regardless of whether the date of the events is the same or not. If Gas Transmission and Hazardous Liquid are selected for a Type C notification, it must be completed twice – once for Gas Transmission and once for Hazardous Liquid. Construction or Rehabilitation of facilities Type F or J notifications are required 60 days prior to such an "event". On September 12, 2014, PHMSA published an Advisory Bulletin describing the activities that constitute the “event” of construction, which determines the due date for the notification.

PHMSA Pipeline Data & Stats Website and Incident Flagged File Change
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PHMSA has revamped the data and statistics portion of its website to a new and more modern look. Additionally, PHMSA updated its data specifications for Pipeline Incident Flagged Files as of June 30, 2015 to provide property damage totals in (1) 1984 dollars; (2) nominal dollars as of the incident; and (3) current year dollars as of the date of the data download. Property damage totals in 1984 dollars are included because one of the criteria for a "significant incident" is $50,000 in total costs, measured in 1984 dollars. Based on current 2015 inflation calculations, the significant incident total cost threshold is $99,458 in 2015.

DOT Pipeline Compliance Workshop – Gas & Liquid
August 11 - 13, 2015
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Join us August 11-13, 2015 in Houston at our corporate office and dedicated training facility for an informative, lively, and interactive workshop on DOT Pipeline Compliance topics . The workshop provides an overview of the DOT pipeline regulations in 49 CFR 191, 192, 194, 195, and 199. It also describes pipeline operations and engineering concepts. It is appropriate for people who are new to pipeline regulations, who could use a refresher, or anyone who needs to know the latest developments in these areas. This workshop will be a combined format, addressing both gas and liquid pipeline topics in parallel. This will eliminate some redundancy of materials, and will allow more time for in-depth discussions for each topic.

Topics to be addressed in the workshop include:

  • An overview of DOT/OPS pipeline compliance requirements
  • State and Federal agency roles for pipeline safety
  • PHMSA Jurisdiction
  • PHMSA Inspections and Enforcement Processes
  • Engineering Concepts and Stress – Strain Relationships; %SMYS
  • Design Requirements
  • Construction Requirements
  • Corrosion Control Concepts and Requirements
  • Operations and Maintenance Requirements
  • Emergency Response Requirements (including spill response planning requirements for liquid pipelines)
  • Damage Prevention Programs
  • Operator Qualification Programs
  • Drug and Alcohol Programs
  • Public Awareness Programs
  • Integrity Management (gas and liquid) Programs
  • Control Room Management Programs
We will also discuss the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 (pipeline reauthorization bill), recent Advisory Bulletins from PHMSA, and new, pending and proposed rulemakings.

Each attendee will receive the presentation as well as applicable handouts in a hardcopy notebook, and electronic copies of the applicable regulations and voluminous reference materials including rulemakings, letters of interpretation, and other guidance documents. The workshop will adjourn at 2 p.m. on the third day, for those who need to fly out Thursday evening.

To register for our workshop, click here.

PHMSA Report to Congress: Review of Existing Federal and State Regulations for Gas and Hazardous Liquid Gathering Lines
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On May 8, 2015, DOT Secretary Anthony Foxx sent a study on the Review of Existing Federal and State Regulations for Gas and Hazardous Liquid Gathering Lines to various chairpersons of committees in Congress. The cover letters state:

"PHMSA is considering the need to propose additional regulations to ensure the safety of natural gas and hazardous liquid gathering lines. Furthermore, and subject to a risk-based assessment of prioritization, PHMSA is reviewing the need to propose changes to existing exemptions from Federal regulation for gas and hazardous liquid gathering lines. As a part of the regulatory process, PHMSA will analyze the economic impact, technical practicability, and challenges of applying any proposed regulations to gathering lines that are not currently subject to Federal regulation when compared to public safety benefits."

The report and transmittals can be accessed by clicking here. In short, we should stay tuned for further developments.

Storage Tanks in West Virginia – Proposed Rule
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The State of West Virginia has proposed an extensive set of regulations for above ground storage tanks, including registration, corrosion control, and routine inspections, in WVR Volume XXXII, Issue 26, 06/26/2015. There will be a public hearing on Thursday, July 30, 2015, 6.00 p.m., at the WVDEP HQ; Coopers Rock Training Room; 601 57th Street, SE; Charleston, WV 25304.

Written comments must be submitted by Thursday, July 30, 2015, 6.00 p.m., to:

AST Rule Comments
Attn: Joe Sizemore
601 57th Street, SE
Charleston, WV 25304

For a copy of the proposed regulations, contact Jessica Foley at jfoley@rcp.com.

API Publishes API 1173 Recommended Practice for Pipeline Safety Management Systems
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On July 8, 2015, API published a new Recommended Practice (RP) concerning safety management systems for pipelines. API RP 1173 will provide pipeline operators a comprehensive way to make safe operations and continuous safety improvement a constant focus of their operations. Safety management systems provide a formal framework to monitor, measure and improve safety performance continuously over time, and have been used successfully in the aviation, chemical production, refining, and nuclear power industries. The U.S. National Transportation Safety Board recommended the pipeline industry build on the success of other industries and develop its own safety management system. Pipeline operators, Federal and State regulators, and members of the public worked together over 2 years to develop this RP. The recommended practice was formally adopted under the American Petroleum Institute standard setting practice accredited by the American National Standards Institute and meeting essential requirements for openness, balance, consensus and due process. The focus now shifts to implementation where the pipeline industry will encourage, educate and assist its member operators with their own implementation of the recommended practice.

API 1173 Recommended Practice for Pipeline Safety Management Systems can be purchased at API's Publications Store.

Jurisdictional Determination

Is there uncertainty as to whether a pipeline meets the applicability of 49 CFR 195 or 192? RCP can answer your questions regarding the jurisdictional status related to pipelines that may be regulated by the Department of Transportation Pipeline and Hazardous Materials Safety Administration (DOT/PHMSA). Click here to request more information on how RCP can help.

PHMSA Risk Modeling Methodologies Public Workshop
[Docket No. PHMSA–2015–0139]
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PHMSA will hold a public workshop on Wednesday, September 9, 2015, and Thursday, September 10, 2015, in the Washington DC area, to advance risk modeling methodologies of gas transmission and hazardous liquid pipelines and non-pipeline systems. This workshop will bring industry, Federal and state regulators, interested members of the public, and other stakeholders together to share knowledge and experience on risk modeling within the pipeline industry and other fields, ways to advance pipeline risk models, and practical ways that operators can adopt and/or adapt them to the analyses of their systems.

PHMSA is inviting abstracts on relevant engineering and technical modeling considerations related to advancing pipeline risk models, and risk modeling methodologies used in other non-pipeline applications. PHMSA recognizes that other industries may offer potential ideas and solutions to risk modeling that are applicable to pipelines and therefore encourages participation in the solicitation from outside of the pipeline industry and outside of industrial applications. Each author of an accepted abstract will be invited to make a short presentation at the workshop.

To be considered for presentation at the upcoming workshop, authors must submit abstracts to the docket PHMSA–2015–0139 and email Kenneth Lee at Kenneth.lee@dot.gov by July 15, 2015. PHMSA will notify authors by email by July 31, 2015, whether their abstracts were accepted for presentation. Each author of an accepted abstract will be invited to make a short presentation at the workshop. Members of the public may also submit written comments either before or after the workshop. Comments should reference Docket No. PHMSA–2015–0139.

P&GJ Pipeline Integrity Issue
Vol. No. 242 Number 6 June 2015
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Need a summer reading suggestion? The Pipeline & Gas Journal Pipeline, Integrity Issue should be landing in your mailbox any day. Or, you can check it out online. Make sure to turn to page 51 and read "Changes to PHMSA Rules Affect Wide Range of Inspections, Reports" by Bill Byrd (RCP President) and co-authored by Deborah Brunt (RCP Executive Consultant).

Summer / Fall Conference Schedule
July – September 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!

LGA Pipeline Safety Conference
July 20 – 24, 2015
Royal Sonesta / New Orleans, LA

SGA Operating Conference & Exhibits
July 20 –22, 2015
OMNI Hotels & Resorts / Nashville, TN

Power-Gen Natural Gas New this year!
August 18 – 20, 2015
Greater Columbus Convention Center /Columbus, OH
An annual conference and exhibition targeting gas-fired generation related to the development of natural gas reserves in the Marcellus and Utica shales of the Appalachian Basin.

Western Regional Gas Conference
August 25 & 26, 2015
Tempe Mission Palms / Tempe, AZ

Arkansas Gas Association 2015 Annual Conference
September 20 – 22, 2015
Hot Springs Convention Center, Arkansas

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 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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