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DOT Pipeline Compliance News
July 2017 Edition

PHMSA's UGS Petition for Reconsideration
[Docket No. PHMSA-2016-0016]

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On December 19, 2016, PHMSA issued its Underground Natural Gas Storage (UGS) Interim Final Rule (IFR) regulations. The rules apply to all existing and newly constructed underground natural gas storage facilities including solution mined salt caverns, depleted reservoirs, and aquifer storage facilities. The IFR incorporates by reference two API RPs: (1) API RP 1170, “Design and Operation of Solution-mined Salt Caverns used for Natural Gas Storage,” issued in July 2015, and (2) API RP 1171, “Functional Integrity of Natural Gas Storage in Depleted Hydrocarbon Reservoirs and Aquifer Reservoirs,” issued in September 2015.

On January 18, 2017, the American Gas Association, API, American Public Gas Association, and the Interstate Natural Gas Association of America (collectively, the petitioners) submitted a petition seeking reconsideration of the IFR, insofar as it modified the non-mandatory nature of many of the recommendations in the RPs. The petitioners contended, among other things, that the implementation periods were impracticable and should reasonably be extended.

On June 20, 2017, PHMSA issued Notice related to the relief sought by the petitioners. First, PHMSA determined that it would be impracticable to respond to the petition for reconsideration within the 90 day timeframe consistent with their policy regarding any petition for reconsideration. PHMSA plans to leave the petition for reconsideration open and evaluate the petition, along with the comments it received during the development of a final rule. PHMSA plans on using the final rule to address the comments and the petition for reconsideration and revise the requirements detailed in the IFR accordingly. PHMSA expects to issue a final rule by January 2018.

Second, regarding the manner in which non-mandatory sections of the RPs were made mandatory in the IFR, the petitioners expressed concern that treating non-mandatory practices as mandatory could result in unnecessary burdens for operators. PHMSA received similar comments to those raised in the petition on this issue during the 60 day comment period immediately after the IFR was issued. PHMSA understands these concerns and is reviewing the treatment of non- mandatory provisions as mandatory and will respond to these points in a final rule which is expected to be issued in January 2018.

In the interim, PHMSA announced it will not issue any enforcement citations to operators for non- compliance with any non-mandatory provisions in the RPs until at least one year following publication of a final rule. Also, during this same period they will not issue enforcement citations to operators for non-compliance with the requirement to justify and document deviations from the non-mandatory provisions. PHMSA will, however, retain and enforce the other compliance deadlines in the IFR, including the requirement that operators of existing underground gas storage facilities develop, by January 18, 2018, policies and procedures to implement those sections of the RPs that are identified as mandatory in the actual RPs.

Finally, PHMSA noted that nothing in their latest Notice is intended to prevent or discourage any operator from carrying out any recommended practice that is non-mandatory in the RPs if the operator determines that the recommended practice needs to be followed to ensure the safe operation of its facilities.

For a copy of this UGS Petition for Reconsideration published in the Federal Register, contact Jessica Foley.

Underground Gas Storage Compliance

How does RCP deliver a comprehensive solution for natural gas storage operational integrity assurance?

Experienced Resources

  • Highly respected underground storage & risk management SME's (the past Chair of PRCI’s and AGA’s underground storage committees is on our staff)
  • Professional engineering support
  • Written program development / improvement from knowledgeable technical standards developers (Our lead technical writer was the editor for the API RP1170 development team.)
State-Of-The-Art Tools (TaskOp™)
  • Program gap assessment and corrective action tracking
  • Storage risk assessment
  • Integrity assessment and remediation process tracking
For more information regarding our capabilities or to request an online demonstration of our TaskOp™ underground gas storage solution, visit our website or contact Jessica Foley.

PHMSA Develops New Online Code of Federal Regulations Mobile Application
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PHMSA has developed a new online Code of Federal Regulations (oCFR) mobile application. The oCFR app was released to both Apple’s App Store and the Google Play Store for use on iOS and Android mobile devices, and is free. The oCFR app provides the ability to search, view and navigate PHMSA’s Hazardous Materials Regulations in 49 CFR parts 100-180, as well as the Pipeline Safety Regulations in 49 CFR parts 190-199. The mobile app allows users to navigate regulations at the paragraph level.

The oCFR mobile application is a simplified version of the web-based application which was released to the public in March of 2016 ( https://www.phmsa.dot.gov/hazmat/phmsa-online-cfr). The web-based application enables more detailed exploration of relevant letters of interpretation, enforcement actions, etc., than the app.

Editor’s cautionary note: The regulations contained in the web-based application (and presumably the mobile app) are only updated once a year. Thus, they may not reflect recent rulemaking activity.

Hint: Since this is a PHMSA-wide app, it includes all the hazmat regs which must be scrolled through (and through, and through) to get to the pipeline regs (which are dead last, numerically). Searching is quick and easy if you know the citation you want, or at least a key word from a section title. If you want to browse the gas pipeline regulations, for example, enter “192.” in the search window, which will take you to all the sections that start with 192 (and skip over all that hazmat stuff...).

PHMSA conducts 2nd GPAC meeting for Safety of Gas Transmission & Gathering Pipelines NPRM
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PHMSA conducted the 2nd Gas Piping Advisory Committee (GPAC) meeting to discuss certain elements of the gas transmission and gathering NPRM. All presentations and transcripts can be found here.

The GPAC voted on the following NPRM topics:

  1. Corrosion Control - 192.319; Subpart I; Appendix D; 192.935(f) & (g)
  2. Records – 192.13(e); 192.5(d); 192.67; 192.127; 192.205; 192.227(c); 192.624(f); and Appendix A
  3. Integrity Management Clarifications - 192.917 (a)–(c); 192.935(a)
  4. Reporting of MAOP Exceedances - 191.23; 191.25
The topic of Materials Documentation was covered but not voted on by the GPAC. Dates for a 3rd and possibly 4th GPAC meetings have not yet been set.

PHMSA VIS Meeting Notice
[Docket No. PHMSA-2016-0128]

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PHMSA held a public meeting of the Voluntary Information-Sharing System (VIS) Working Group on June 29th and 30th to continue the discussion on the need for, and the identification of, a voluntary information-sharing system. The meeting documents presented will be available on the meeting website and posted on the E-Gov webite under docket number PHMSA-2016-0128 within 30 days following the meeting.

The VIS Working Group is a recently created advisory committee. On December 15, 2016, the Secretary of Transportation (the Secretary) appointed 24 members to the committee. The VIS Working Group agenda included briefings on topics such as mandate requirements, existing integrity management regulations, data types and tools, ILI repair methods, geographic information system pipeline data and operator implementation, potential subcommittee needs, past integrity management lessons learned, examples of existing information-sharing systems, safety management systems, and the potential need for additional expertise with committee membership. As part of its work, the committee will ultimately provide recommendations to the Secretary addressing:

  1. The need for, and the identification of, a system to ensure that dig verification data are shared with in-line inspection operators to the extent consistent with the need to maintain proprietary and security-sensitive data in a confidential manner to improve pipeline safety and inspection technology;
  2. Ways to encourage the exchange of pipeline inspection information and the development of advanced pipeline inspection technologies and enhanced risk analysis;
  3. Opportunities to share data, including dig verification data between operators of pipeline facilities and in-line inspector vendors to expand knowledge of the advantages and disadvantages of the different types of in-line inspection technology and methodologies;
  4. Options to create a secure system that protects proprietary data while encouraging the exchange of pipeline inspection information and the development of advanced pipeline inspection technologies and enhanced risk analysis;
  5. Means and best practices for the protection of safety and security-sensitive information and proprietary information; and
  6. Regulatory, funding and legal barriers to sharing the information described in paragraphs (a) thru (d).
The Secretary will publish the VIS Working Group's recommendations on a publicly available DOT Web site. The VIS Working Group will fulfill its purpose once its recommendations are published online.

For information about the meeting, contact Cheryl Whetsel by phone at 202-366-4431 or by email at cheryl.whetsel@dot.gov.

Fundamentals of Pipeline Operations Workshop
September 13-14, 2017
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Join us September 13-14, 2017 in Houston at our corporate office and dedicated training facility for this new workshop on the fundamentals of pipeline operations. This 2-day course is designed to give a comprehensive overview of gas and liquid energy transmission pipelines and how they are operated and maintained.  It is appropriate for both technical and non-technical personnel who are new to the energy transmission pipeline industry, as well as those who need a broader understanding of pipeline operations and management in general.  The course walks through the practical things that a typical pipeline company’s operations organization does on a regular basis to operate and maintain the pipeline system as a whole.  Course topics include:

  • Components of a pipeline system (types of pipe, coatings, tanks, valves, pumps, compressors, pressure vessels, pig traps, meters, instrumentation, control systems / SCADA)
  • Operations activities (starting / stopping, batching, managing receipts and deliveries, measurement, monitoring, pressure control, leak detection)
  • Inspection and Maintenance (valves, ROWs, tanks, pumps, compressors, instrumentation, pigging, cathodic protection)
  • Repair (in-service repair techniques, welding, OOS repairs / replacements)
  • Integrity Management (ILI, Pressure Tests, Direct Assessment), including assessment processes, analysis, follow-ups
  • Emergency Response (planning, organization/ ICS, drills, response)
  • Public Awareness / Damage Prevention / One Calls
Each attendee will receive the presentation as well as applicable handouts in a hardcopy notebook.

The course involves many hands-on demonstrations and examples using RCP’s in-house Pipeline Flow Loop*.  To promote an optimal learning environment, class size will be limited.  To register for our workshop, click here .

*RCP's in-house Pipeline Flow Loop is an engineering marvel (!).  It is a working 2” diameter pipeline system incorporating many of the components of a transmission pipeline system including state-of-the-art SCADA control system and instrumentation for flow, pressure, temperature, and volume, as well as automated valves, pig traps, variable speed pump, and more.  It also incorporates clear pipe segments so that students can see a pig in operation, see phase separation as it occurs, and understand the importance of elevation change.  It occupies 2 walls outside our training room.  Students can monitor and control the pipeline from the training room (“control room”), and then step into the hall to see the pipeline in action. 

Advisory Committee Vacancies – Request for Nominations
[Docket No. PHMSA-2016-0033]

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PHMSA is requesting nominations for individuals to serve on the Gas Pipeline Advisory Committee (GPAC), also known as the Technical Pipeline Safety Standards Committee, and the Liquid Pipeline Advisory Committee (LPAC), also known as the Technical Hazardous Liquid Pipeline Safety Standards Committee. Each committee is composed of 15 members each appointed by the Secretary of Transportation (the Secretary). PHMSA is seeking nominations for personnel, preferably executive level leadership, from the Federal Government and from industry to fill one Federal Government vacancy and one industry vacancy on the GPAC and one Federal Government vacancy and two industry vacancies on the LPAC.

Each GPAC member must be experienced in the safety regulation of transporting gas and of gas pipeline facilities or technically qualified, by training, experience, or knowledge in at least one field of engineering applicable to transporting gas or operating a gas pipeline facility, to evaluate gas pipeline safety standards or risk management principles. Similarly, each LPAC member must be experienced in the safety regulation of transporting hazardous liquid and of hazardous liquid pipeline facilities or technically qualified by training, experience, or knowledge in at least one field of engineering applicable to transporting hazardous liquid or operating a hazardous liquid pipeline facility, to evaluate hazardous liquid pipeline safety standards or risk management principles. Regarding nominations of industry personnel, at least three of the individuals selected for each committee from the industry must be currently in the active operation of natural gas or hazardous liquid pipelines or pipeline facilities. At least one individual selected for each committee serving from the industry must have education, background, or experience in risk assessment and cost-benefit analysis. Nominees should represent a broad constituency whose views the candidate can represent. Additionally, the Secretary will consult with the national organizations representing the owners and operators of pipeline facilities before selecting individuals from the industry.

Each member serves a three-year term, unless the member becomes unable to serve, resigns, ceases to be qualified to serve, or is removed by the Secretary. Members may be reappointed.

All members serve at their own expense and receive no salary from the Federal Government, although travel reimbursement and per diem may be provided. The GPAC and LPAC generally meet in-person in the Washington, DC, Metropolitan area.

Any interested person may nominate one or more qualified individuals for membership on the advisory committee. Self-nominations are also accepted. Nominations must include a current, complete resume including current business address and/or home address, telephone number, email address, education, professional or business experience, present occupation, and membership on other advisory committees past or present) for each nominee. Each nominee must meet the training, education, or experience requirements listed above. Nominations must also specify the advisory committee for which the nominee is recommended (the GPAC or LPAC). Nominations must also acknowledge that the nominee is aware of the nomination unless the individual is self-nominated.

Nominations were due by July 5, 2017. All nomination material can be submitted to Cheryl Whetsel, Advisory Committee Program Manager, at Cheryl.whetsel@dot.gov, by fax at 202-366-4566, or mailed to the Pipeline and Hazardous Materials Safety Administration, 1200 New Jersey Ave. SE., PHP-30, E24-445, Washington, DC 20590.

Summer 2017 Pipeline Conference Schedule
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Have you registered and confirmed your reservations for these upcoming conferences? RCP will be attending the following conferences. We hope to see you there!

SGA Operating Conference & Exhibits
July 17-19, 2017
Hilton Downtown Atlanta

The Operating Conference format is focused round table discussion. Attendees learn smart practices and lessons learned from their peers with 22 concurrent facilitated sessions to choose from. Make plans to visit the exhibit hall showcasing the latest products and services available to the industry.

Western Regional Gas Conference (WRGC)
August 29-30, 2017
Hyatt Regency Mission Bay in San Diego, CA

Who should attend? Regulatory and Code Compliance personnel, Gas Engineers, Pipeline Construction Supervisors, Technical and Standards Engineers/writers, Customer Service Supervisors, Measurement and Control personnel, Damage Prevention personnel, Integrity Management managers, Gas Control supervisors, operations and engineering personnel.

RCP's Subject Matter Expert will be giving a presentation on Underground Storage: Developing a Comprehensive Underground Storage Integrity Management Plan, on Tuesday, August 29th, from 1:30 -2:15 pm. Click here for the preliminary conference agenda.

Pressure Testing Webinar - Advantages of using TestOp®
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RCP will be hosting webinar presentations to discuss pipeline pressure testing practices and demonstrate the advantages of utilizing new technology for planning, designing, and capturing real-time data to validate and document whether it was a successful test. The same technology that RCP has used for the past six years to validate our customer's pressure tests has been greatly enhanced and is now being made available as a web-hosted solution for operators to use themselves.

TestOp® takes the confusion out of pressure testing by providing real-time determination of whether the test segment is experiencing potential issues, such as yielding or air entrapment volume absorption, all while modeling the mass balance relationship of pressures, volumes and temperatures of the test. TestOp will provide real-time indicators and corresponding data to confirm whether the test is successfully performing to plan or if there might be a small pin-hole leak that would otherwise go undetected before taking the line segment off test. TestOp generates comprehensive and consistent reports, including a certification letter, pressure test plan versus actual test results, pressure/spike test log, test instrument and pump calibrations, pipe volume calculations sheet, stress/strain and pressure/volume plots as well as upload capability for pictures and other document scans associated with the test.

We encourage any liquid or gas pipeline operator who has upcoming projects that involve replacement, integrity verification, new construction, uprates, conversions and/or reversals to sign up for the 45 minute webinar. Some of the largest and most respected pipeline operators are now using TestOp because they see the value it brings to their overall pipeline integrity assurance program and we are confident you will too once you have seen it in person.

Mark your calendar and plan to attend one of these sessions or request an individual demonstration for your company at a date convenient to you.

  • July 26, 2017 (Wednesday) at 2 p.m. CDT
  • August 30, 2017 (Wednesday) at 2 p.m. CDT
Click here to register.

RCP Workshop Schedule for 2017

Fundamentals of Pipeline Operations Workshop: September 13-14 (Wednesday & Thursday)
DOT Gas & Liquid Pipeline Workshop: October 24-26 (Tuesday, Wednesday & Thursday)

Visit our training website for updates, registration, and hotel information.

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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