DOT Pipeline Compliance News
April 2009 Edition

Control Room Management Update
[Docket ID PHMSA-2007-27954]
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On September 12, 2008, the Department of Transportation Pipeline and Hazardous Materials Safety Administration (DOT/PHMSA) issued a Notice of Proposed Rulemaking (NOPR) to revise the Federal pipeline safety regulations to address human factors and other components of control room management. (See related article in the October edition of the DOT Compliance News.) Public comments to the proposed rulemaking and the Advisory Committee Meeting transcripts have been posted to the PHMSA Website.

If you plan on attending the API Pipeline Conference on April 21-22 in Ft. Worth, Texas, you will probably want to attend the breakout session on “Control Room Management – NPRM Status and Implications for Operators” on Tuesday, April 21. This presentation will focus on the impacts on pipeline company control centers and general operations that are likely to arise as a result of PHMSA’s Control Room Regulations. Particular focus will be placed on the potential impacts to the Control Room and general operations staffing levels, the potential incremental expense generated by compliance with the regulations, and new procedures and documentation that will be necessary as part of the compliance regimen.

Control Room Management

If you are interested in participating in a joint effort with several other companies in the development of a control room management plan, contact Jessica Roger.

ANOTHER SPCC Deadline Extension
[Docket EPA-HQ-OPA-2007-0584]
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Effective immediately, the Environmental Protection Agency (EPA) is delaying the effective date of the final rule that amends the Spill Prevention, Control, and Countermeasure (SPCC) regulations. The effective date of the final rule (FR Doc. E8-28159), published in the Federal Register on December 5, 2008 (73 FR 74236), that was delayed until April 4, 2009 (74 FR 5900), is further delayed to January 14, 2010. EPA additionally is requesting public comment on whether a further extension of the effective date may be warranted. Comments must be received on or before May 1, 2009. The Agency will provide a complete discussion of the comments received specific to the amendments, and its response to those comments, in a Federal Register notice describing any changes to the 2008 amendments.

Consistent with the January 21, 2009 OMB memorandum "Implementation of Memorandum Concerning Regulatory Review," the EPA Administrator has chosen the final rule that amends the Spill Prevention, Control, and Countermeasure (SPCC) regulations for additional assessment of policy and legal issues. EPA must carefully consider the issues raised in comments received to-date. Because EPA cannot adequately address the comments before an April 4, 2009 effective date, the Agency agrees to delay the effective date.

Finally, the Agency is also reviewing the dates by which owners or operators of facilities must prepare or amend their SPCC Plans, and implement those Plans. EPA intends to address these dates in a separate notice.

EPA Proposed Rule on Greenhouse Gas Emissions
[Docket No. EPA-HQ-OAR-2008-0508]
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The Environmental Protection Agency (EPA) has proposed a rule that requires mandatory reporting of greenhouse gas (GHG) emissions from large sources in the United States. EPA is developing this rule under the authority of the Clean Air Act.

EPA proposes that suppliers of fossil fuels or industrial greenhouse gases, manufacturers of vehicles and engines, and facilities that emit 25,000 metric tons or more per year of GHG emissions submit annual reports to EPA (that would be about equivalent to the CO2 emissions from a 5,000 horsepower engine for a year). The gases covered by the proposed rule are carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFC), perfluorocarbons (PFC), sulfur hexafluoride (SF6), and other fluorinated gases including nitrogen trifluoride (NF3) and hydrofluorinated ethers (HFE). The proposed rule will be open for public comment for 60 days after publication in the Federal Register.

Two public hearings will be held on April 6 & 7in Arlington, Virginia and April 16 in Sacramento, California. EPA encourages those who wish to attend or give public comments, to register on-line in advance of the hearing.

More information on the proposed rule can be found on the EPA website at: http://www.epa.gov/climatechange/emissions/ghgrulemaking.html.

Pending Audits?

Has the DOT notified you of a pending audit? RCP can provide confidential internal auditing to help ensure that your facilities are up to the agency's latest standards. Click here to find out more.

Kansas Proposed Regulations to Adopt 49 CFR 192 & 199
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The State of Kansas issued a notice of hearing on proposed administrative regulations to consider the adoption of K.A.R. 82-11-4 and 82-11-10.

82-11-4. Transportation of natural and other gas by pipeline; minimum safety standards. This regulation adopts by reference the federal rules and regulations found at 49 CFR Part 192, with the enumerated exceptions. The modifications to this regulation are minor and nonsubstantive in nature.

82-11-10. Drug and alcohol testing. This regulation adopts 49 CFR Part 199 concerning drug and alcohol testing, with the enumerated modifications and exceptions.

A public hearing will be conducted at 9 a.m. on Wednesday, May 13, in the third floor hearing room at 1500 S.W Arrowhead Road, Topeka, Kansas 66604. All interested parties may submit written comments prior to the hearing to Colleen R. Harrell, Litigation Counsel, State Corporation Commission, to the address above.

For a copy of the proposed regulations, contact Jessica Roger.

GulfSafe Website for Offshore Damage Prevention & Notification System
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On February 16, 2009, GulfSafe, LLC (GulfSafe), Dallas, TX, a wholly-owned subsidiary of Texas Excavation Safety System, Inc. (TESS), started a website operation for an offshore damage prevention and notification system. Their goal is to eliminate preventable damage to subsurface infrastructure in the Gulf of Mexico (GOM) and the Straits of Florida. TESS operates one of the largest One Call centers in the United States, processing over two million incoming notifications annually, and has over 20 years of notification system experience. Their damage prevention notification system is the only one that currently operates offshore in the GOM.

All states have some form of “One Call” system that can be used by excavators and the operators of buried facilities, in order to avoid excavation damage. These systems provide a centralized communications platform connecting excavators with the operators of buried facilities in the area of their planned excavation. While these systems have proven their worth in preventing excavation damage and incidents, until recently, no notification system was available to function in a similar manner for offshore excavation activities.

Unlike a traditional One-Call operation, GulfSafe’s notification process is completely web-based. All notifications are submitted through www.gulfsafe.com and all member or facility operator notifications are made online. Technical and User Support may be completed online or by phone at 1-888-910-GULF. Use of this service to request notifications of activity is free. Costs are paid by member companies that enjoy a cost-effective way to prevent damage to their structures. GulfSafe shares notification requests with all five One-Call Centers on the Gulf coast.

RCP Web-Based Tracking Systems

We’ve developed two (extremely handy) web-based applications that will organize your compliance information.

RCP’s Compliance Management System manages all of your permit requirements, inspections, procedures and data requirements. The Compliance Management System’s email reminders and document links provide you with the information that you need to stay in compliance with the hundreds of regulatory tasks.

RCP’s Leak Tracking System tracks all leaks through their life span and compiles the data into annual DOT reports or semi-annual TRRC reports. (The TRRC report can be quickly uploaded into the TRRC Electronic Document Interchange process.) RCP’s Leak Tracking System is customizable so that field personnel can load data from laptops or hand-held devices. It’s simple to use, easy to access and can be integrated so that the leak data can be automatically sent to your GIS system.

Because these are web-based applications, there are no IT issues to struggle through to get started. For more information on either of these systems, please contact Jessica Roger.

RCP in Industry Publications
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You know those pipeline and gas journals that pile up on the corner of your desk? Take a few moments to unearth the February and March issues to read these recent articles from the staff of RCP.

“Risk Assessment Model for Pipeline Facility Operations” by Larry Decker, p. 38, in the March 2009 issue of the Pipeline and Gas Journal. Recent efforts to develop a consistent understanding of the risk associated with operating a cross country pipeline system have focused primarily on the pipe itself. The typical risk analysis model frequently does not address the risks associated with operating non-pipe components such as valves, tanks, pump and compression units. This article outlines a detailed logical approach that can be utilized to evaluate the relative safety, environmental and cost risk associated with operating diverse types of equipment within a pipeline facility. The methodology enables an “apples to apples” comparison of diverse pipeline components and systems from a risk standpoint, and provides the detail (granulation) necessary to identify opportunities to reduce operational risk.

“Company Name Change Requires Diligent Execution” by Ken Palmer & Bill Byrd, p. 60, in the March 16, 2009 issue of the Oil and Gas Journal. A pipeline can undergo several generations of acquisition, divestiture and other company transitions during its history. This article describes a pipeline company name change process. Methodology was designed to be streamlined and turnkey. Unanticipated findings during the inventorying phase of the project included several “eye-openers” and lessons learned are presented in the conclusions. Information in this article will clearly demonstrate that a name change goes far beyond the lettering on Company signs.

And last but not least is a Q&A Executive Profile on Bill Byrd in the February 2009 issue of the Pipeline and Gas Journal. Here’s your opportunity to read about the man behind RCP and the DOT Compliance newsletter.

DOT Pipeline Compliance Workshop - June 2 & 3, 2009
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RCP will be hosting our very popular 2-day workshop on DOT Pipeline Compliance on June 2 & 3, 2009, in Houston, TX. Join us for an informative, lively, and interactive workshop on DOT Pipeline Compliance.

Day 1 (June 2): Gas Pipeline Regulations (49CFR192): Covering all the topics below but special emphasis will be placed on the changes in **GAS GATHERING** regulations.

Day 2 (June 3): Liquid Pipeline Regulations (49CFR195)

Each day of the workshop will address the following issues as they specifically relate to either Gas or Hazardous Liquid pipelines:

• PHMSA Overview
• PHMSA Jurisdictional Boundaries
• Production / Gathering / Transmission
• Onshore / Inlets to the Gulf of Mexico / Offshore
• Compliance Requirements:
• Design
• Construction
• Operation
• Maintenance
• Corrosion
• Testing
• Integrity Management
• Operator Qualification
• Emergency Response
• Reporting
• New/Proposed Regulations - including liquid rural low stress and new gas production pipeline rules in Texas and other states.

For additional information go to our website here.

Save the Dates!

PHMSA Workshop on New Pipeline Construction
[Docket ID PHMSA-2009-0060]
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Recent new pipeline construction inspections by PHMSA have identified issues regarding procedures and inspection of pipeline coating, welding, and general pipeline construction practices. Many of the issues required immediate response from operators to avoid impacting long term pipeline integrity before the pipeline was put into service. PHMSA is leading a workshop cosponsored by the National Association of Pipeline Safety Representatives (NAPSR), the Federal Energy Regulatory Commission (FERC), and the Canadian National Energy Board (NEB), on new pipeline construction in established rights-of-way to allow stakeholders of the pipeline safety community to learn about and discuss these construction issues and current practices used to resolve issues and ensure pipeline safety.

Due to time constraints, this workshop will focus solely on natural gas transmission and hazardous liquid pipelines being constructed on established rights-of-way and will not include discussion on property rights, permitting or siting issues. The workshop will include:

• Quality Control and Inspection,
• Welding,
• Coating,
• Materials, and
• Best practices for pipeline construction.

API Pipeline Conference and Safety, Environmental, and Distinguished Award Program
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The 60th Annual API Pipeline Conference will be held April 21-22 in Fort Worth, Texas, with registration April 20. The Conference will end this year at 3:30 PM on April 22. The Pipeline Safety, Environmental and Distinguished Awards will be presented at the luncheon on April 22. A letter describing the award program was sent to all pipeline operators the week of January 12, along with the applications. The deadline for submitting the Safety and Environmental Award applications is March 2. More information, including a link to online information, will be provided after the award letter is finalized.