DOT Pipeline Compliance News
February 2010 Edition

DOT Pipeline Compliance Workshop – Gas, Liquids, DIMP & Control Room Management
March 2, 3, and 4, 2010 / Houston, TX
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Join us March 2-4, 2010 in Houston at the Crowne Plaza Downtown for an informative, lively, and interactive workshop on DOT Pipeline Compliance and OPA Planning for DOT Pipelines. This workshop has been attended by hundreds of pipeline personnel, with excellent feedback. The workshop provides an overview of the DOT pipeline regulations, and is appropriate for people who are new to pipeline regulations, who could use a refresher, or anyone who needs to know the latest information in these areas.

PROGRAM SCHEDULE:

Day 1 (March 2): Liquid Pipeline Regulations (49CFR195)
Each attendee will receive general training materials which include the applicable DOT 49 CFR 195 regulations for hazardous liquid pipelines (cd-rom), inspection checklists, and speaker's PowerPoint presentation handouts. The workshop will include an introduction to DOT/OPS pipeline compliance; State and Federal program variations, roles and responsibilities; design, construction, operations, maintenance, and emergency response requirements; spill response planning requirements; how to monitor rulemaking activity and stay current with your compliance program; operator qualification and public awareness.

Day 2 (March 3): Gas Pipeline Regulations (49CFR192)

Each attendee will receive general training materials which include the applicable DOT 49 CFR 192 regulations for gas pipelines (cd-rom), inspection checklists, and speaker's PowerPoint presentation handouts. The workshop will include an introduction to DOT/OPS pipeline compliance; State and Federal program variations, roles and responsibilities; design, construction, operations, maintenance, and emergency response requirements; how to monitor rulemaking activity and stay current with your compliance program; operator qualification, public awareness; and a specific emphasis on the gas integrity management regulations.

Day 3 (March 4): DIMP and Control Room Management

Morning Session: Control Room Management
On December 3, 2009, PHMSA published their final rule on control room management for gas and liquid pipeline operators to amend their existing written O&M procedures, operator qualification (OQ) programs, and emergency plans to assure controllers and control room management practices and procedures used maintain pipeline safety and integrity. The Final Rule adds provisions to 49 CFR parts 192, 193, and 195. This workshop session will discuss the regulations that address fatigue management and other components of control room management, i.e. alarm management, controller qualifications, controller human factors, and management of change.

Afternoon Session: DIMP
On December 4, 2009, PHMSA published the final rule for Distribution Integrity Management Programs (DIMP) which is applicable to gas distribution operators and became effective on February 2, 2010. The DIMP regulations are listed in Part 192 as a new Subpart P Gas Distribution Pipeline Integrity Management. The compliance deadline for developing a written distribution IM plan and implementing the plan is August 2, 2011 (18 months from the effective date). This workshop session will discuss the key elements of the DIMP regulation, including key strategies that gas distribution operators should consider when developing and implementing DIMP.

To register, or for additional information, go to our website.

Advisory Bulletin ADB-10-01 Liquid Pipeline Leak Detection
[Docket No. PHMSA-2009-0421]
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The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) issued Advisory Bulletin ADB-10-01 to the owners or operators of hazardous liquid pipelines concerning leak detection on hazardous liquid pipelines. In order to ensure the safe and environmentally sound operation of their hazardous liquid pipelines, the operating plans and procedures required by the pipeline safety regulations should include the performance of an engineering analysis to determine if a computer-based leak detection system is necessary to improve leak detection performance and line balance processes.

If the analysis determines that a computerized leak detection system is unnecessary, it is PHMSA's expectation that the operator should perform a line balance calculation and review process at no greater than one-hour intervals whenever product is flowing through the line, and monitor for pressure changes, meter movement and tank level changes even when the line is not flowing. As part of the recordkeeping requirements under current regulations, operators must retain documentation from any related engineering analyses for the computerized leak detection and line balance considerations to demonstrate the thoroughness of review during an inspection.

In addition, operators need to ensure open and regular communication between all active source and delivery points along the pipeline, either through verbal communication or through the use of SCADA or other similar technology.

For more information or a copy of ADB-10-01, contact Jessica Roger.

Advisory Bulletin (ADB-2010-01): Revised Incident/Accident Report Forms
[Docket No. PHMSA-2008-0211]
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The Pipeline and Hazardous Materials Safety Administration (PHMSA) issued Advisory Bulletin ADB-2010-01 advising owners and operators of gas pipeline facilities and hazardous liquid pipeline facilities that the incident/accident report forms for their pipeline systems were recently revised and should be used for all incidents/accidents occurring on or after January 1, 2010. The forms for Gas Distribution Systems, Gas Transmission and Gathering Systems, and Hazardous Liquid Systems include:

• PHMSA Form F 7100.1, Incident Report-Gas Distribution Pipelines
• PHMSA Form F 7100.2, Incident Report-Gas Transmission and Gathering Systems
• PHMSA Form F 7000-1-Accident Report for Hazardous Liquid Pipeline Systems

RCP’s Web-Based Compliance Management Systems

RCP’s Compliance Management System (CMS) is an invaluable tool for managing all aspects of regulatory workflow. Some examples of how our clients are using the CMS include:

• O&M Scheduling and Data Acquisition;
• Cathodic Protection Inspection and Data Management;
• One-Call Screening and Ticket Management;
• Repair / Replacement Programs;
• Operator Qualification Administration and Workflow Integration;
• Leak Life Cycle Management;
• Environmental, Health and Safety Compliance;
• Audit Action Item Tracking; and
• Customer Data Management.

DIMP Integration

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 (example: leak surveys, CP surveys, etc.)
• Create work orders for unscheduled / unplanned activities (ex. release reporting)

Advisory Bulletin ADB-09-04 - Reporting Drug and Alcohol Test Results for Contractors & Multiple Operator Identification Numbers
[Docket No. PHMSA-2009-0408]
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The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) issued Advisory Bulletin ADB-09-04. Beginning with MIS reports due by March 15, 2010, OPS will begin collecting annual drug and alcohol testing data for contractor employees. In January 2010, OPS will notify each operator who is required to submit a report before March 15, 2010 by mail. The notification will include detailed instructions for including all OpID and each contractor BTIN in both online and paper MIS reports.OPS will post the same detailed instructions on the Drug & Alcohol Program Web site.

Under Part 199, operators who had 50 or more operator and contractor employees performing §199.3 "covered functions" during calendar year 2009, must submit a MIS report. OPS may also request in writing, MIS reports from operators with fewer than 50 operator and contractor employees performing covered functions. The total number of covered employees is not limited to employees who physically worked in a maintenance, operations, or emergency response role during the previous calendar year. The definition of "performs a covered function" in Part 199.3 includes actually performing, ready to perform, or immediately available to perform a covered function.

Operators need to be cognizant of this definition when calculating the number of covered employees for both the operator and contractors. Employees who "perform a covered function" as defined in §199.3, are required to be included in the random drug testing pool. While the total number of covered employees determines if an operator must submit a MIS report, operator and contractor employee testing data must be submitted in separate MIS reports. To ensure that contractor employees are only counted once in the entire set of calendar year 2009 MIS reports, data for each contractor with a unique BTIN will be submitted in a separate MIS report.

Operators are encouraged to submit MIS reports online. If an operator submits a paper MIS report, the operator will not receive a confirmation receipt for the MIS report. If an operator submits an online MIS report and includes an e-mail address, a confirmation receipt will be sent.

For further information contact: Stanley T. Kastanas, Program Manager, Substance Abuse Prevention Program at 202-550-0629 or by e-mail at Stanley.Kastanas@dot.gov.

Control Room Management/Human Factors Rule Correction
[Docket No. PHMSA-2007-27954; Amdt. Nos. 192-112 and 195-93]
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The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) is correcting the human factors / control room management final rule that appeared in the Federal Register (74 FR 63310) on December 3, 2009. (See related article in the DOT Pipeline Compliance News, December 2009 Special Edition.) That final rule contained errors regarding certain dates, both in the preamble and the amendments. The corrections are given below.

• On page 63311 of the preamble to the December 3 rule, in the first column in the DATES section, the compliance date is corrected to read "Compliance Date: An operator must develop control room management procedures by August 1, 2011, and implement the procedures by February 1, 2013."
• In §192.631 paragraph (a)(2), in the second sentence, remove the phrase "implement the procedures no later than February 1, 2012" and add the phrase "implement the procedures no later than February 1, 2013" in its place.
• In §195.446 paragraph (a), in the last sentence, remove the phrase "implement the procedures no later than February 1, 2012", and add the phrase "implement the procedures no later than February 1, 2013" in its place.

Procedures for Transportation Workplace Drug and Alcohol Testing Programs
[Docket OST-2010-0026]
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The Department of Transportation (DOT) is proposing to amend certain provisions of its drug testing procedures dealing with laboratory testing of urine specimens. Some of the proposed changes will also affect the roles and standards applying to collectors and Medical Review Officers (MROs). The proposed changes are intended to create consistency with new requirements established by the U.S. Department of Health and Human Services (HHS) Mandatory Guidelines. On November 25, 2008, HHS issued a Notice of Revisions to the Mandatory Guidelines for Federal Workplace Drug Testing Programs (Revisions to Mandatory Guidelines) [73 FR 71858, Nov 28, 2008]. The HHS revised some of their requirements for collecting and testing urine specimens, initiated requirements for the certification of Instrumented Initial Test Facilities (IITFs), and expanded upon the roles of and standards for collectors and MROs. The DOT is proposing various changes to 49 CFR Part 40 in an effort to create consistency with this latest set of requirements established by HHS. This NPRM seeks to harmonize DOT requirements for laboratories, collectors, MROs, and employers with the new requirements contained in the revised HHS Mandatory Guidelines.

Comments to the notice of proposed rulemaking should be submitted by April 5, 2010. Go to http://www.regulations.gov and follow the online instructions for submitting comments. You must include the agency name and docket number DOT-OST for the rulemaking at the beginning of your comments.

SPCC.pro is now live!

RCP has designed a website that will answer all your questions about SPCC. Visit us at: www.spcc.pro.

FINAL Amendments to the SPCC Rule
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The delays are over and the Environmental Protection Agency (EPA) Administrator signed a notice amending certain requirements of the Spill Prevention, Control, and Countermeasure (SPCC) rule in order to address additional areas of regulatory reform that have been raised by the regulated community. The November 2009 amendments modify the December 2008 rule by removing certain provisions that were generally favorable to the industry. The final rule

• does NOT exclude farms and oil production facilities from the loading/unloading rack requirements;
• does NOT exempt produced water containers at an oil production facility; and
• does NOT provide alternative qualified facilities eligibility criteria for an oil production facility.

SPCC UPDATE

Are you ready? Does your SPCC Plan include the latest amendments as published on November 13, 2009? If not, RCP can develop or modify your SPCC Plan. Contact us today for more information.

Leak Detection Conference
February 23, 2010
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Join us at the Siemens Pipeline Leak Detection & Instrumentation Technology Conference at the Houston Sheraton Brookhollow on February 23, where our president, Bill Byrd, will be making a presentation on leak detection requirements. The conference will address pipeline surveillance issues relevant to terminal and pipeline operators, and will offer informative presentations, interactive question-and-answer sessions, and product presentations. Additional information can be found at the Siemens website.