DOT Pipeline Compliance News
January 2008 Edition

DOT Pipeline Compliance Workshop - January 29 & 30, 2008
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RCP will be hosting our very popular 2-day workshop on DOT Pipeline Compliance on January 29 & 30, 2008, in Houston, TX. Join us for an informative, lively, and interactive workshop on DOT Pipeline Compliance.

Day 1 (January 29): Gas Pipeline Regulations (49CFR192): Covering all the topics below but special emphasis will be placed on the changes in **GAS GATHERING** regulations.

Day 2 (January 30): 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!

DOT Gas Pipeline Compliance Workshop - March 27, 2008
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RCP will be hosting our very popular one-day workshop on DOT Pipeline Compliance for Gas Pipelines on March 27th in Denver, Colorado. Join us for an informative, lively, and interactive workshop on DOT Pipeline Compliance. 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, or who could use a refresher.

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

• 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

Your Instructor: As principal of RCP, Mr. Byrd enjoys a solid reputation for working with the public, corporate management, and regulatory agencies to resolve complex regulatory issues. He serves on various industry association committees, works as an expert witness and consulting expert, and is frequently called upon to comment on current or proposed rulemakings at public and private meetings and conferences.

For additional information go to our website here.

Integrity Management Revised Protocols Available
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The Pipeline and Hazardous Materials Safety Administration’s (PHMSA) Integrity Management Inspection Protocols for hazardous liquid pipeline operators have been revised to reflect rule changes made in July 2007. These protocols are being used to inspect operators for compliance with all aspects of the Integrity Management Rule §195.452.

The rule changes require that operators notify PHMSA when a pressure reduction is in place for more than 365 days (Protocols 4.01 and 4.02); increased the maximum re-assessment interval to 5 years, “not to exceed 68 months” (Protocol 7.02), and clarified the use of alternate methods of calculating pressure reduction when the ASME/ANSI B31.4 Section 451.7 is not applicable (e.g., defects other than corrosion) (Protocol 4.01 and 4.02). Additional minor changes were made to the protocols. Please reference RCP's newsletter article on the updated protocols in the August 2007 edition of DOT Pipeline Compliance News.

To help illustrate updates and organizational changes to the protocols, a cross-reference table between the updated protocols and the protocol set used for previous Integrity Management inspections is now available.

For a copy of the updated protocols or the Protocol Cross-Reference Table, contact Jessica Roger.

Integrity Management Services

RCP can assist pipeline operators with ongoing compliance management and engineering associated with your IMP. This includes direct assessment strategies, tool and vendor selection, ILI/ECDA report analysis, corrosion control programs, repair strategies, and IMP/risk model updates. For more information on how RCP can support your ongoing IMP needs, click here.

Texas Railroad Commission Proposed Safety Regulation Updates
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Effective December 18, 2007, the Texas Railroad Commission (TRRC) withdrew the proposed amendments and revisions to 16 TAC Chapter 8 – Pipeline Safety Regulations to address new risk management initiatives for the Commission's pipeline safety evaluation program and to remove outdated or duplicative rule requirements. The proposed amendments included new language to address onshore pipelines and gathering and production facilities. Please reference RCP's newsletter article on the proposed revisions in the November 2007 edition of DOT Pipeline Compliance News. These proposed revisions to Chapter 8 Pipeline Safety Regulations appeared in the October 26, 2007 issue of the Texas Register (32 TexReg 7575), and comments on the proposed revisions were due on November 26. Click here to view TRRC's filing to withdraw.

In addition, the TRRC has proposed new regulations for risk-based schedules for leak surveys (16 TAC 8.206), leak grading and repair using modified Gas Piping Technology Committee (GPTC) standards (16 TAC 8.207), and mandatory removal and replacement program for compression couplings on gas distribution pipelines (16 TAC 8.208). These new regulations are intended to be applied primarily towards gas distribution operations. Comments are due to the TRRC by February 5, 2008.

At a meeting on Tuesday, January 8th, the TRRC discussed comments regarding these new rules as well as the withdrawn regulations. Expect the withdrawn regulations to be proposed again with several changes sometime in February. A few items of interest from these discussions are as follows:

• Removal of gathering pipelines from the Texas Integrity Management regulations (16 TAC 8.101) is expected to remain as originally proposed when the new proposals are issued in February. In the mean time, operators who wish to request waivers from Texas Integrity Management regulation requirements may do so by submitting a written request to the TRRC.
• Timelines for compliance are expected to be included in the new proposed rulemakings in February.
• The TRRC intends to reissue regulations that apply to pipelines that may have been recently exempted by the new gas gathering definition. Consideration is being given to create a new classification of regulated lines such as “regulated production lines” or something similar to that affect. The intent would be to apply safety regulations to these pipelines located in populated areas that may or may not have been regulated prior to the new federal definition for gas gathering pipelines.
• The TRRC clarified that the proposed T4 permit requirements were not intended to be applied towards pipelines such as gas distribution that have been exempt from these requirements in the past.
• Discussions were held regarding the responsibility for odorization of gas pipelines that serve large industrial consumers who might also be using the gas for domestic purposes as well. The TRRC will accept further comments from operators on how best to verify that large volume consumers utilize odorized for domestic purposes.
• Discussions were held regarding proposed risk-based schedules for leak surveys (16 TAC 8.206), leak grading and repair using modified Gas Piping Technology Committee (GPTC) standards (16 TAC 8.207), and mandatory removal and replacement program for compression couplings on gas distribution pipelines (16 TAC 8.208). Comments received from operators indicate a desire to remain consistent with current national standards.

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Public Awareness Programs and Line Markers Workshop
[Docket ID PHMSA-RSPA-2003-15852]
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PHMSA will host a workshop on February 20-21, 2008 to provide stakeholders with an update on public awareness programs for pipeline operators and to discuss the location of line markers.

On the first day, PHMSA will share the findings from its review of written public awareness programs. Between August 8, 2006, and October 15, 2007, pipeline operators submitted 1,568 public awareness programs to PHMSA for a centralized review. PHMSA will present summary statistics from the centralized review of the programs. The workshop will also include discussion of potential revisions to the first edition of the American Petroleum Institute (API) Recommended Practice (RP) 1162. The API typically publishes new editions of recommended practices every five years. The workshop will include discussion about potential revisions to API RP 1162 for the second edition. Pipeline operators will also share some lessons learned from their implementation of public awareness programs based on RP 1162.

On the second day, PHMSA will lead a discussion on the location of line markers. The workshop will include discussion about the appropriate interval between markers and conditions which make it impractical to use markers.

The workshop will be held at the Hotel Derek, 2525 West Loop South, Houston, TX 77027. Hotel reservations under the Department of Transportation room block can be made at (713) 297-4323. The meeting room will be posted at the hotel on the day of the workshop. Members of the public may attend this free workshop. To register for a workshop, select Public Awareness and Pipeline Marker Workshop from http://primis.phmsa.dot.gov/meetings/. Hotel reservations must be made by contacting the hotel directly. The part of the workshop on public awareness programs will be web cast and available for viewing for two months after the workshop. The web cast will be accessible at http://primis.phmsa.dot.gov/comm/PublicAwarenessWorkshops.htm. For further information contact: Blaine Keener at (202) 366-0970, or by e-mail at blaine.keener@dot.gov.

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Need to make sure your Public Awareness Program meets API RP 1162 standards?

RCP can conduct a gap analysis of your current program that includes a self assessment of your Public Awareness Programs. This final product will help you to meet API RP 1162 standards. We can provide turnkey implementation, mail-outs, evaluations, and tracking of your program. For more information, contact Jessica Roger

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Random Drug Testing Rate – Unchanged again!
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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 2008.

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Pipeline Advisory Committee Meetings and Workshop
Docket ID PHMSA-RSPA-1998-4470 (advisory committee)
Docket ID PHMSA-RSPA-2000-7666 (7-year reassessment workshop)
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PHMSA's Technical Pipeline Safety Standards Committee (TPSSC) and Technical Hazardous Liquid Pipeline Safety Standards Committee (THLPSSC) will meet in a joint session on Thursday, January 17, from 1 p.m. to 5 p.m. EST to discuss PHMSA's regulatory agenda and strategic plan. In conjunction with the advisory committee meetings, PHMSA will hold a half day public workshop on Friday, January 18, from 8 a.m. to 12 p.m. EST to gather comments on the use of the special permit process to allow gas transmission pipeline operators to vary from the 7-year reassessment interval in integrity management programs. Specifically, special permits would allow operators to tailor their reassessment intervals, based on pipe specific threats. PHMSA will ask for feedback on criteria developed for use in special permits.

The meetings will be at the Hotel Palomar Arlington, 1121 North 19th Street, Arlington, VA 22209. Members of the public may attend and may make a statement during the advisory committee meetings or during the public workshop. If you plan to make a statement please notify the relevant contact by January 9. Please note the meetings' presiding officer may deny a nonscheduled request to make a statement and may also limit the time of any speaker.

FOR FURTHER INFORMATION CONTACT:


• Technical Advisory Committee Meetings: Cheryl Whetsel (202) 366-4431, cheryl.whetsel@dot.gov;
• Public Workshop on Special Permit Consideration and Criteria Discussion for 7-Year Reassessments: Zach Barrett (405) 954-5559, zach.barrett@dot.gov.
PHMSA will post more detailed agendas and any additional information or changes on its Web page (http://phmsa.dot.gov) approximately 15 days before the meeting date.

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www.rcp.com

Now we're easier to find on the Internet.
Visit us at our new web domain: www.rcp.com.

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2008 API Pipeline Conference and Cybernetics Symposium
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Mark your calendars for the 2008 Pipeline Conference and Cybernetics Symposium at the Florida Hotel and Conference Center in Orlando, Florida on April 8 – 10, 2008. Conference registration can be made here, and hotel reservations can be made at The Florida Hotel Orlando. We hope to see you all there!

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

Best Regards,

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