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DOT Pipeline Compliance News
October 2016 Edition

PHMSA Interim Final Rule on Enhanced Emergency Order Procedures
[Docket No. PHMSA-2016-0091]
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This new enforcement tool will allow the Administrator to issue an emergency order either prohibiting an unsafe condition or practice or imposing an affirmative requirement when an unsafe condition, practice or other activity in the transportation of natural gas or hazardous liquids poses a threat to life or significant harm to property or the environment.

The emergency order authority conferred by the PIPES Act is intended to serve as a flexible enforcement tool that can be used to address time-sensitive, safety conditions affecting multiple owners/operators, facilities, or systems that pose a threat to life or significant harm to property or the environment. Unlike a Corrective Action Order issued to a single operator, an emergency order would affect multiple or all operators and/or pipeline systems that share a common characteristic or condition.

A variety of circumstances could warrant such an action, including: (1) where a natural disaster affects many pipelines in a specific geographic region; (2) where a serious flaw has been discovered in pipe, equipment manufacturing, or supplier materials; and (3) where an accident reveals a specific industry practice that is unsafe and needs immediate or temporary correction.

The IFR is expected to be published in the Federal Register within a few days. It will be effective once published and there will be a 60 day comment period. If you would like a copy of the IFR, contact Jessica Foley, and a copy will be sent to you once it has been published in the Federal Register.

PHMSA Final Rule Expands Requirement for EFVs
[Docket No. PHMSA-2011-0009; Amdt. No 192-121]
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PHMSA issued a preview version of their Final Rule that will expand the requirements for excess flow valves (EFVs) on new and replaced gas distribution pipelines. The Final Rule entitled “Expanding the Use of Excess Flow Valves in Gas Distribution Systems to Applications Other than Single-Family Residences" is expected to be published in the Federal Register within a few days.

The Final Rule expands safety requirements for Excess Flow Valves (EFVs) to multi-residential and commercial applications. The final rule requires the installation of EFVs in new or replaced service lines for multi-family residences, including apartment buildings and other multi-residential dwellings and small commercial buildings.

Excess Flow Valves automatically halt the flow of gas caused by damage to service lines that supply gas to buildings and significantly reduce the risk of fires or pipeline explosion. Excess flow valves are already required in new and replaced service lines that supply gas to single-family residences.

The rule also requires gas distribution companies to install curb valves, manually-operated shutoff valves located near the service main, or EFVs for all new or replaced service lines with meter capacities exceeding 1,000 standard cubic feet per hour to protect against uncontrolled gas releases from larger commercial and industrial users.

Lastly, this final rule requires operators to notify customers of their right to request installation of an EFV on service lines that are not being newly installed or replaced. PHMSA has left the question of who bears the cost of installing EFVs on service lines not being newly installed or replaced to the operator’s rate-setter.

This final rule is effective six months after publication in the Federal Register. If you would like a copy of the Final Rule, contact Jessica Foley, and a copy will be sent to you once it has been published in the Federal Register.

PHMSA Publishes Pipeline Civil Penalty Structure Online
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The U.S. Department of Transportation's Pipeline and Hazardous Materials Safety Administration (DOT/PHMSA) announced it has made a pipeline civil penalty framework available on its website. A respondent in an enforcement case may request a proposed civil penalty calculation related to that case. PHMSA also announced that it will, as appropriate, issue higher penalties, which serve as a strong deterrence, driving down incident risk. More information on DOT's efforts to improve pipeline and hazardous materials safety and awareness, including details about PHMSA's pipeline civil penalty framework, can be found on PHMSA's website.

Arizona Damage Prevention Regulation Update
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Arizona has updated section 40-360.24. Notice of Damage to Underground Facility, to require immediate notification to 911 for any damage that results in a release. The existing requirements regarding notifications and repairs concerning "any damage to or dislocation of any underground facility..." are unchanged.

Underground Natural Gas Storage Services

RCP has extensive expertise in the underground storage operations and integrity for depleted reservoirs which we would like to put to work for your company. RCP has developed a comprehensive solution that allows underground natural gas storage operators to:

  • Assess current operations against new RP 1171
  • Develop written standards and procedures for underground natural gas storage
  • Complete risk assessments
  • Develop integrity assessment risk mitigation plans
  • Track progress of all remedial actions from beginning to end
We are well-positioned to support your organization’s response to the recent PHMSA advisory bulletin as well as the California Emergency rule on underground gas storage. For more information, including a demonstration of the advanced tools we have developed, please contact Jessica Foley.

Ohio Notification Changes for Intra-State Gas Pipelines
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The State of Ohio has modified its regulations in Number 4901:1-16 - Gas Pipeline Safety, to change the reporting phone number to 1-844-OHCALL1 (1-844-642-2551), and to require telephonic reports within thirty minutes of discovery unless notification within that time is impracticable under the circumstances. They also updated the version of the federal pipeline safety regulations incorporated by reference to August 1, 2016.

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.

  • October 26, 2016 (Wednesday) at 2 p.m. CDT
  • November 30, 2016 (Wednesday) at 2 p.m. CDT
Click here to register.

Pipeline Safety Trust Conference
October 20-21 – New Orleans
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Join us in New Orleans at the Hotel Monteleone on October 20-21, 2016, for the annual conference hosted by the Pipeline Safety Trust. This conference provides a unique forum to gather pipeline operators, regulators, local governments and concerned citizens for two days to talk all things pipeline safety. A stroll to the Café Du Monde for beignets will certainly occur at some time in the evening, and much powdered sugar may fly. Meanwhile, people who frequently stake out diametrically opposed positions on various pipeline topics will find plenty of opportunities to talk with each other and share their perspectives. It’s all good. We hope to see you there. Online registration, the agenda and hotel information can be found on the Pipeline Safety Trust website.

RCP's Web-Based Compliance Management System

RCP's compliance management system, TaskOp, is an invaluable tool for managing all aspects of regulatory workflow. Some examples of how our clients are using TaskOp include:

  • Inspection & Maintenance Activity Scheduling
    • Cathodic Protection Inspection and Data Management
    • Asset Integrity Assessment & Remediation
    • Leak Life Cycle Management
    • Asset Repair / Replacement
  • Asset Integrity Risk Analysis
  • Operator Qualification Administration and Workflow Integration
  • Environmental, Health and Safety Compliance
  • Management of Change
  • Audit Action Item Tracking
Industry Applications
  • Pipeline facilities
  • Gas processing facilities
  • Petrochemical and refining facilities
  • Underground gas and hazardous liquid storage
  • Oil and refined product storage terminals
  • Onshore and offshore oil & gas production
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 (ex. leak surveys, CP surveys, etc.)
  • Create work orders for unscheduled / unplanned activities (i.e. repairs of third party damages)
To request a demonstration or to request more information, please contact Jessica Foley.

Pipeline Leak Detection-Program Management Webinar
Save the Date – November 3rd
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API, along with the support of the API RP 1175 Pipeline Leak Detection-Program Management, Implementation Team, is hosting a Webinar for pipeline operators on November 3rd from 10 – 11:30 AM (CST). For registration details and other information, send your name, company name and contact information to: PipelineLDP@API.org.

PHMSA Pipeline Safety Research and Development Forum
November 16-17, 2016 – Cleveland, OH
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The forum is a 2-day event held periodically to generate a National research agenda that fosters solutions for the various challenges associated with pipeline safety and with protecting the environment. The forum allows public, government and industry pipeline stakeholders to develop a consensus on the technical gaps and challenges for future research. It also reduces duplication of programs, factors ongoing research efforts, leverages resources and broadens synergies. The national research agenda coming out of these events is aligned with the needs of the pipeline safety mission, makes use of the best available knowledge and expertise, and considers stakeholder perspectives. Specifically the forum:

  • Identifies key pipeline technical challenges facing industry and government;
  • Disseminates information on current research efforts; and
  • Identifies new research that can help to meet known challenges.
Registration information, hotel links, and an agenda can be found on the PHMSA Meeting website.

Save the Dates!
RCP Workshop Schedule for 2017

DOT Gas & Liquid Pipeline Workshop: March 21-23 (Tuesday, Wednesday & Thursday)

Pressure Test Workshop: April 12-13 (Wednesday & Thursday)

Fundamentals of Pipeline Operations Workshop: May 24-25 (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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