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DOT Pipeline Compliance News
January 2017 Edition

Underground Natural Gas Storage Interim Final Rule
[Docket No. PHMSA-2016-0016; Amdt. Nos. 191-24; 192-122]
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On December 19, 2016, PHMSA issued its Underground Natural Gas Storage (UGS) Interim Final Rule (IFR) regulations for all underground natural gas storage facilities constructed on or before July 18, 2017, including solution mined salt caverns, depleted reservoirs, and aquifer storage facilities, to address safety issues related to downhole facilities including wells, well casing and tubing, and reservoirs. The IFR adopts and incorporates by reference the requirements and recommendations contained in API RP 1170 and 1171. To ensure enforceability of discretionary recommendations, PHMSA is making all recommendations in both RPs mandatory out of concern that failure to do so would weaken key safety provisions. The IFR provides a mechanism for operators to deviate from the recommendations in API 1170 and 1171, however deviations must be technically supported by a Subject Matter Expert (SME) to demonstrate that there will be no adverse impact on operations, maintenance, emergency preparedness and response, integrity and overall safety. The SME recommendation must then be approved and dated by a senior executive officer with responsibility over the storage assets.

All storage operators must develop a risk assessment plan for their storage facilities and have it in place no later than January 18, 2018 (the implementation date for the IFR). This risk assessment plan will guide the Operator in development of the remainder of their program, as follows:

Operators of salt cavern storage facilities must develop procedures for operation, maintenance, integrity demonstration and verification, monitoring, threat assessment and analysis, remediation, site security, emergency response and preparedness, and record keeping consistent with the recommendations contained in Sections 9, 10, and 11 in API RP 1170. Operators of depleted reservoirs and aquifer storage facilities must develop these same procedures consistent with the recommendations contained in Sections 8-11 in API RP 1171. The procedures must also include an implementation plan and prioritized implementation schedule based on site-specific risk assessment and threats. Preventative and mitigative measures must also be scheduled consistent with the risk associated with each asset (such as an individual storage well).

There are also new reporting requirements for storage operators, all of which will require significant time and resources. These include an annual report, incident reports, safety-related condition reports, and National Registry information.

PHMSA expects that baseline assessments will start within one year, but not to exceed two years, and that operators will complete those assessments within 3-8 years depending on facility size and complexity. PHMSA's initial inspections of facilities will focus on whether procedures are in place and whether the technical justification for the implementation plan and schedules are consistent with the operator's risk assessment results.

The effective date of these new regulations is January 18, 2017. Comments concerning the IFR must be received by PHMSA no later than February 17, 2017. You may submit comments identified by the docket number PHMSA-2016-0016 on the Federal eRulemaking Portal. For a copy of this Interim Final Rule, 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 (ex. Rick Gentges)
  • Professional engineering support
  • Knowledgeable technical standards developers
State-Of-The-Art Tools
  • Program gap assessment and corrective action tracking (TaskOp)
  • Written program development / improvement
  • Storage risk assessment (TaskOp)
  • Integrity assessment and remediation process tracking (TaskOp)
For more information regarding our capabilities or to request an online demonstration of our TaskOp™ underground gas storage solution, contact Jessica Foley.


Underground Gas Storage FAQs
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PHMSA's FAQs to clarify, explain and promote better understanding of issues concerning integrity assessment of Underground Natural Gas Storage can be found on PHMSA's Pipeline Technical Resources webpage.


New Associate Administrator for OPS
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Alan Mayberry has been selected as the new Associate Administrator for the Office of Pipeline Safety (OPS), replacing Jeff Wiese, who retired earlier in 2016.

Alan is a Civil Engineering graduate of the University of Tennessee, Knoxville, and is a registered professional engineer. He has over 34 years of experience in the energy industry, equally divided between pipeline operations and design engineering. In 2006, Alan first joined PHMSA's Office of Pipeline Safety in a senior engineering role in the Engineering and Emergency Support Division. Alan was appointed Director of the group in 2008. In that role, Alan was responsible for supporting programs and the regional offices on nationwide pipeline issues to ensure uniform policies. Additionally, Alan led the agency's response to major pipeline incidents. In 2010, Alan was appointed as Deputy Associate Administrator for Field Operations, overseeing US pipeline safety oversight through PHMSA's five regional offices. He was most recently the Deputy Associate Administrator for Policy and Programs at OPS, leading PHMSA's development of comprehensive oversight programs including regulatory development, engineering and research, state grants, federal enforcement and the Training and Qualifications Division.


PHMSA Claims Enforcement Jurisdiction in 5 States Over 3rd Party Excavators
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Per PHMSA's rule for evaluating state damage prevention and excavation enforcement programs (July 13th, 2015), PHMSA has evaluated eight damage prevention programs and deemed five states (Alaska, Colorado, Mississippi, Montana and West Virginia) inadequate to the standards of the new rule. Thus, PHMSA can enforce excavation enforcement programs in those states. For more information on the rule, evaluation schedules, and determinations of adequacy visit http://phmsa.dot.gov/pipeline/safety-awareness-and-outreach/excavator-enforcement.


PHMSA Pipeline Safety Information Collection Activities
[Docket No. PHMSA-2015-0205]
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On May 13, 2016, PHMSA published a notice in the Federal Register to invite comments on proposed revisions to these three forms:

  1. PHMSA F 7100.1 Incident Report-Gas Distribution System;
  2. PHMSA F 7100.2 Incident Report-Natural and Other Gas Transmission and Gathering Pipeline Systems; and
  3. PHMSA F 7100.3 Incident Report-Liquefied Natural Gas (LNG) Facilities, and the instructions associated with the Forms.
PHMSA also invited comments on PHMSA F 7000- 1 Accident Report-Hazardous Liquid Pipeline Systems and its associated instruction. On December 27, 2016, PHMSA published its response to the specific comments received and announced that the revised information collection will be submitted to OMB for approval. Comments regarding the burden estimate, including suggestions for reducing the burden, can be sent to OMB via email to OIRA-submission@omb.eop.gov on or before January 26, 2017. For a copy of PHMSA's Information Collection Notice, contact Jessica Foley.


High Consequence Area Identification Methods Advisory Bulletin (ADB-2016-07)
[Docket No. PHMSA-2016-0065]
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In response to NTSB Recommendation P-15-06, PHMSA has issued advisory bulletin ADB-2016-07 to inform owners and operators of gas transmission pipelines that PHMSA has developed guidance on the identification and periodic verification of HCAs, including the application of a buffer zone to the PIR, and information regarding the accuracy of class locations. PHMSA recommends operators frequently and consistently review their data, including class location data, for potential inaccuracies or limitations, and add a buffer zone to the calculated PIR to help ensure proper HCA identification. The purpose and usage of buildings, open structures, and outside areas can shift over time, changing the number of "identified sites" in a PIR, and therefore, whether an area is an HCA. PHMSA believes that if operators review class location and PIR data on an annual basis as a part of their IM programs, the accuracy of HCA determinations will be greatly improved.

A review of early PHMSA inspections has shown that many operators (28%) did not have procedures to adequately describe how to identify HCAs, using Method 1 or Method 2. To effectively use Method 2, operators should have a detailed and documented process in place to monitor the conditions surrounding their pipelines, including the existence of "identified sites."

A list of PHMSA-provided frequently asked questions on HCA identification can be found on the gas IM site at: https://primis.phmsa.dot.gov/gasimp/index.htm. Gas IM Frequently Asked Question Number 174 reminds operators that they should consider the uncertainties in the distances they measure or infer when evaluating PICs and consider geographic information system accuracy in locating HCAs: "... Operators may use a combination of techniques in order to account for these inaccuracies. For instance, aerial photography may be used as an initial screen. Field measurements (such as pipeline locators along with chainage measurements or survey quality range finders) may be used to verify if structures near the edge of the PIC (i.e., within the range of mapping/geographic information system inaccuracies) are actually inside or outside the PIC. PHMSA will inspect each operator's approach to assure that the operator's process is adequate to identify all covered segments."

Therefore, PHMSA is reminding operators of the existing guidance for making those determinations and is providing additional recommendations on how to improve the accuracy of HCA identification. Specifically:

  • PHMSA expects that most large operators will use a geographic information system or similar mapping software for segment identification. Operators should be able to demonstrate the usability of their system and show a graphical overlay of HCAs with their pipeline system.
  • An operator not using geographic information system or similar mapping software should describe or demonstrate how it performed its HCA segment identifications.
  • For both geographic information system-based and non-geographic information system based HCA identification processes, the operator should address how it will deal with tolerances (or buffers) on top of the calculated PIR regarding the accuracy of measured distances to structures and the location of the pipeline centerline.
For a copy of ADB-2016-07 HCA Identification Methods, contact Jessica Foley.


GIS Services

RCP is an Esri Business Partner which enables RCP to provide a better service to our clients with access to all of Esri's related products and technical support. RCP also has direct access to the latest NOAA Navigational Charts, USGS National Hydrology data, USDA Soil data, Bureau of Energy Management offshore data, Google and Bing map imagery, plus more!

RCP has developed a suite of GIS tools for pipeline operators including: Gas Pipeline HCA Determination; Class Location Analysis, Overland Flow Spill Analysis (HCA/USA impact analysis); Gulf of Mexico and its Inlets Determination.

For more information, contact Jessica Foley.


PHMSA Advisory ADB-2016-06 Safeguarding and Securing Pipelines from Unauthorized Access
[Docket No. PHMSA-2016-0137]
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The Pipeline and Hazardous Materials Safety Administration (PHMSA) issued an Advisory Bulletin in coordination with the Department of Homeland Security's Transportation Security Administration to remind all pipeline owners and operators of the importance of safeguarding and securing their pipeline facilities and monitoring their Supervisory Control and Data Acquisition (SCADA) systems for abnormal operations and/or indications of unauthorized access or interference with safe pipeline operations. Additionally, this Advisory Bulletin reminds the public of the dangers associated with tampering with pipeline facilities.

This Advisory Bulletin follows recent incidents in the United States that highlight threats to oil and gas infrastructure. On October 11, 2016, several unauthorized persons accessed and interfered with pipeline operations in four states, creating the potential for serious infrastructure damage and significant economic and environmental harm, as well as endangering public safety. While the incidents did not result in any damage or injuries, the potential impacts emphasize the need for increased awareness and vigilance.

For a copy of ADB-2016-06, 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. 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
Liquid Hazardous Pipelines Final Rule December 30, 2016 (...not!)
Rupture Detection and Valves Rule NPRM May 3, 2017 (Comment Period Ends: July 3, 2017)
Gas Transmission (RRR) Final Rule December 11, 2017


Hazardous Liquid Pipelines
[Docket No. PHMSA-2010-0229]
PHMSA published a Notice of Proposed Rulemaking (NPRM) in the Federal Register on October 13, 2015 to improve protection of the public, property, and the environment by closing regulatory gaps where appropriate, and ensuring that operators are increasing the detection and remediation of unsafe conditions, and mitigating the adverse effects of hazardous liquid pipeline failures.

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 Automatic Safety Valve (ASV) and Remote Control Valve (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
[Docket No. PHMSA-2011-0023]
PHMSA is amending the pipeline safety regulations to address integrity management principles for Gas Transmission pipelines. In particular, PHMSA is addressing repair criteria for both HCA and non-HCA areas, assessment methods, validating and integrating pipeline data, risk assessments, knowledge gained through the IM program, corrosion control, change management, gathering lines, and safety features on launchers and receivers.


Random Drug Testing Rate, etc.
[Docket ID PHMSA-2016-0147]
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PHMSA has determined that the minimum random drug testing rate for covered employees will remain at 25 percent during calendar year 2017 (editor's note: just like always...!). Operators are reminded that drug and alcohol testing information must be submitted for contractors performing or ready to perform covered functions. For calendar year 2016 reporting, PHMSA will not attempt to mail the "user name" and "password" for the Drug and Alcohol Management Information System (DAMIS) to operators, but will make the user name and password available in the PHMSA Portal.

For further information, contact: Blaine Keener, Director of Safety Data Systems and Analysis, by telephone at 202-366-0970 or by email at blaine.keener@dot.gov.


Misc. Pipeline Regulation Updates in Florida
[Docket No. 160121-GU]
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The Florida Public Service Commission has published miscellaneous revisions to its pipeline safety regulations, including:

  • Rule 25-6.0436, F.A.C., was updated to clarify the types of information to be in included quarterly work order lists and to require the information be sent directly to Commission staff via e-mail.
  • Rule 25-12.005, F.A.C. was amended to adopt the latest version of the federal standards that pertain to reporting requirements, safety standards, and drug and alcohol employee reporting standards and requirements for certain employees of gas pipeline operators and emergency response persons.
  • Rule 25-12.008, F.A.C., was amended to adopt the latest federal standards and to clarify the visual inspection, testing and active corrosion procedures.
  • Rule 25-12.022, F.A.C., was amended to clarify the valves used to close off system sections in an emergency and provide clarification on the procedure for valve identification.
  • Rule 25-12.027, F.A.C., was amended to correct a scrivener's error in the current rule, to clarify the appropriate American Petroleum Institute standards for welder qualification, and to adopt the latest version of the federal standards.
  • Rule 25-12.040, F.A.C., was amended to provide clarification on leak detection surveys, inspections and monitoring.
  • Rule 25-12.085, F.A.C., was amended to incorporate the most recent versions of the appropriate federal forms and to delete a redundant section of the rule.


New York Regulation Updates
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On December 30, 2016 the New York Department of Public Service updated their gas, hazardous liquid, liquefied natural gas and drug and alcohol testing regulations to better align with the requirements of the applicable federal regulations. As part of this update, Title 16 Chapter III Part 255 Section 559 concerning conversion of pipelines to jurisdiction under these regulations was renumbered as Section 14. Lastly, these changes repealed Section 61 concerning Copper Pipe, Section 237 Preheating and Section 239 Stress Relieving.


North Dakota Approved Safety Rules for Underground Crude Oil & Produced Water Gathering Lines
[Order No. 27865]
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The North Dakota Industrial Commission's proposed safety rules for underground crude oil and produced water gathering lines were approved on December 5, 2016. These rules apply for certain underground gathering pipelines capable of transferring crude oil or produced water from oil and gas production facilities.

The new rules establish bonding and notification requirements and a wide range of safety requirements addressing design, construction, inspection, GIS data, operations, leak detection, spill response, corrosion control, pipeline integrity, repairs, and abandonment. The new rule also establishes requirements for berms around facilities.

The rule became effective January 1, 2017. For a copy of these new rules from the North Dakota Administrative Code: Chapter 43-02-03 (Oil & Gas), contact Jessica Foley.


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.

  • January 18, 2017 (Wednesday) at 2 p.m. CDT
  • February 22, 2017 (Wednesday) at 2 p.m. CDT
Click here to register.


2017 Pipeline Conference News
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The New Year is all about change and there are two industry conferences that have changed venues for 2017: PPIM and WRGC (note: the API PL conference always changes its location each year, so that doesn’t count). Check out the details below. RCP will be attending the following conferences. We hope to see you there!

Pipeline Pigging and Integrity Management (PPIM) Conference
February 27 - March 2, 2017
George R. Brown Convention Center - Hall A3 / Houston, TX
RCP Booth #329

The industry's only forum devoted exclusively to pigging for maintenance and inspection, as well as pipeline integrity evaluation and repair, this event will draw engineering management and field operating personnel from both transmission and distribution companies concerned with improved operations and integrity management. Click here for a copy of the Registration Brochure.

API Pipeline Conference and Control Room Forum
April 25 - 27, 2017
Hyatt Regency Hill Country, San Antonio, TX

API's Pipeline Conference is the premier event of its kind in the U.S. Ś Held every year in April the conference provides attendees with an opportunity to hear about the latest in pipeline-related developments. Once again, RCP is a proud sponsor of this event and we look forward to seeing you there.

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

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.


Save the Dates!
RCP Workshop Schedule for 2017

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

Pressure Test Workshop: April 11-12 (Tuesday & Wednesday)

Fundamentals of Pipeline Operations Workshop: May 24-25 (Wednesday & Thursday)

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


HAWC Annual Race Against Violence
February 25, 2017 - Houston
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RCP is a proud sponsor of the Houston Area Women's Center (HAWC), a local non-profit organization committed to helping individuals affected by domestic and sexual violence move their lives forward. They offer a variety of services including shelter, counseling and advocacy. They also seek to end domestic and sexual violence through community awareness and education. Please join RCP as we support HAWC by participating in the 29th Annual Race Against Violence on the morning of Saturday, February 25th. Click on the link here to join our team and help us bring about positive change in our community!

Editor's note: I know the HAWC because of the efforts of one of our employees (who is awesome!). This isn't just some feel-good organization. HAWC does real work to help real victims of domestic violence. There are more than 100 murders (not counting "violence") each year in Texas among domestic partners, with most (but not all) of the victims being women. So let's try to fix that.

Editor's second note: I don't "run" (my body isn't built for running...), but I can (and do) provide moral and financial support for this worthy cause. I hope you can provide support, too. See you at the run!


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

Best Regards,

W. R. (Bill) Byrd, PE
President
RCP Inc.
888-727-9937
wrbyrd@rcp.com
www.rcp.com

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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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If you have a relevant regulatory meeting planned, please let us know, and we'll announce it in our upcoming DOT Pipeline Newsletters.

More About RCP
For additional information on RCP, please visit: rcp.com or Contact Jessica Foley at 1-888-727-9937 for more info.

Careers at RCP
RCP is actively seeking top pipeline professionals for the following positions:

If you know of someone who might be interested, they can submit their resume to our HR department.

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