DOT Pipeline Compliance News
July 2008 Edition

PHMSA Issues NOPR for Gas Distribution Integrity Management Programs (DIMP)
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PHMSA has issued a Notice of Proposed Rulemaking (NOPR) that will require operators of gas distribution pipelines to develop and implement integrity management programs. PHMSA is requesting comments be submitted by September 23, 2008. As proposed, a gas distribution pipeline operator will have 18 months to develop and implement a written integrity management program once the final rule is published. Within Part 192, the NOPR creates a new Subpart P – Gas Distribution Pipeline Integrity Management and deletes §192.383 Excess Flow Valve Customer Notification. Some highlights of the NOPR are listed below:

• Required elements within a DIMP
• Knowledge of gas distribution system – utilization of historical deign and operational data as available and implement processes for capturing this data going forward.
• Identification of threats – corrosion, natural forces, excavation damage, other outside force damage, material/weld failure, equipment malfunction, operations, and other as appropriate
• Evaluate and prioritize risk – allows for threat evaluation of regions within the distribution system that have common characteristics across multiple mains, service lines, etc. carrying similar risks and actions necessary to reduce risks within the same region.
• Identify and implement measures to address risks – implementation of leak management and enhanced damage prevention programs as well as evaluation of human error factors related to inappropriate operations.
• Measure performance, monitor results, and evaluate effectiveness – establish a baseline and measure performance improvements against this in terms of leak mitigation, excavation damage reduction, installation of excess flow valves (EFV), and others as appropriate.
• Periodic evaluation and improvement – establishes a maximum 5 year interval in which gas distribution operators must reevaluate its DIMP. The NOPR also requires operators to continually re-evaluate threats and risks and periodically evaluate human contributions to risk.
• Reporting results – lists four measurements to be included on the operator’s annual report (number of hazardous leaks eliminated/repaired and their cause, number of excavation damages, number of one-call tickets, and number of EFV’s installed).
• Requires gas distribution pipeline operators to report all material failures of plastic pipe within 90 days to PHMSA and appropriate state agency with jurisdiction.
• Provides circumstances when EFV’s are required for new or replaced service lines.
• Allows gas distribution operators to submit requests to PHMSA or the appropriate state agency for extending the frequency of inspections and tests required by Part 192 (e.g. leak survey, corrosion inspection, etc.) based upon engineering analysis and DIMP risk assessments.
• Allows operators of master meter or LPG systems to implement simplified DIMP based upon the simplicity of these types of systems.

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.

PHMSA Advisory Bulletin (ADB-08-05) – Advance Notice of Biofuel Transportation
[Docket No. PHMSA-RSPA-2004-19856]
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The Department of Transportation Pipeline and Hazardous Materials Safety Administration (DOT/PHMSA) issued Advisory Bulletin ADB-08-05 requesting voluntary advance notification of intent to transport biofuels and field testing. On August 10, 2007, PHMSA published a Federal Register document (72 FR 45002) on the applicability of the pipeline safety regulations to the transportation of ethanol and biofuels by pipeline. PHMSA noted the technical issues associated with transporting biofuels by pipeline including internal corrosion and stress corrosion cracking, and the performance of seals, gaskets and internal coatings. Please reference RCP's newsletter article in the September 2007 edition of DOT Pipeline Compliance News.

Operators intending to transport these new fuels are expected to conduct risk analysis, monitoring, and controls as needed to move biofuels safely, as well as conduct spill response planning for the new product. PHMSA seeks to work with pipeline operators that plan to transport these new fuels in existing regulated hazardous liquid pipelines or in new pipelines that might be constructed for the purpose of transporting ethanol or biofuels. PHMSA is requesting operators to provide advance notice of their intent to transport these fuels to facilitate cooperation in achieving safety.

PHMSA encourages field testing by pipeline operators to accelerate the development of knowledge about the safe and reliable transportation of ethanol and biofuels by pipeline. They are requesting that any operator intending to field test transportation of biofuels by pipeline provide advance notification to PHMSA so that PHMSA can work with the operator to address any safety concerns that arise.

Under 49 CFR 195, an operator is obligated to modify its operating procedures, integrity management programs, and emergency response plans, etc., prior to commencing commercial transportation of a new hazardous liquid. Operators must also update their spill response plans to account for the new product being transported. PHMSA requests that operators intending to commence regular commercial transportation of ethanol or other biofuels provide a 60-day advance notice to PHMSA.

Submit notifications in writing to: Information Resources Manager, OPS/PHMSA, 1200 New Jersey Avenue, SE, Washington, DC 20590, by fax to 202-366-7128, or by e-mail to informationresourcesmanager@phmsa.dot.gov. Include name, title, telephone number, and e-mail address of the person responsible for compliance with the integrity management requirements and a physical description of facilities involved including pipe design, manufacture, vintage, diameter, relevant operating history, and presence of any breakout tanks along with project timelines.

PHMSA will review all notifications received. Review may include site inspections by PHMSA or state pipeline safety agencies, particularly in states with certified hazardous liquid programs. If PHMSA finds that an operator's plans and operating procedures need additional attention or modification, they will provide feedback to the operator.

For a copy of ADB-08-05, contact Jessica Roger.

PHMSA Advisory Bulletin (ABD-08-06) Dynamic Riser Inspection, Maintenance, and Monitoring Records on Offshore Floating Facilities
[Docket ID PHMSA-2008-0162]
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PHMSA advises operators of hazardous liquid and natural gas pipelines with dynamic risers, such as steel catenary risers on offshore floating production facilities, to perform regular inspection and maintenance of these risers, monitor nearby environmental conditions, and maintain records of these activities. Failure of a dynamic riser could significantly impact safety, the environment, and delivery of an important source of natural gas and petroleum products used in the United States. PHMSA strongly urges operators to perform the above-listed actions and any other actions needed to ensure the safe and reliable operation of these systems.

A recent natural gas leak from a steel catenary export riser in the Gulf of Mexico created significant and unexpected risk, as well as major supply disruption. Though a root cause analysis of this incident is not yet complete, visual inspection by divers has determined that the source of the leak was a flexible joint on the riser. In 2004, another offshore riser flexible joint failure resulted in a small oil spill. Subsequent preemptive visual inspections performed on other steel catenary riser flexible joints in the Gulf of Mexico discovered damage to the elastomeric seal area near the rotating ball and drove the replacement of four flexible joints. The flexible joint riser failures described above have created potential safety risks on floating production facilities, and have impacted delivery of energy supplies from the Gulf of Mexico.

The national consensus standard for dynamic risers, American Petroleum Institute Recommended Practice 2RD, is currently under revision. The revised version will directly address concerns raised in this Advisory Bulletin by including guidance for integrity management of dynamic risers. PHMSA will consider adopting the revised standard into its regulations for both natural gas and hazardous liquid pipelines.

FOR FURTHER INFORMATION CONTACT: Elizabeth Komiskey at 202-366-3169, or by e-mail to Elizabeth.Komiskey@dot.gov.

Note: the Department of Interior / Minerals Management Service also issued a similar notice in their recent Safety Alert No. 264.

Cased Pipeline Integrity Assessments Workshop
[Docket ID PHMSA-2008-0161]
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PHMSA is holding a Workshop on Cased Pipeline Integrity Assessments on July 15-16, 2008 at the Sheraton Gateway Suites Chicago O'Hare, 6501 North Manheim Road, Rosemont, IL 60018. The workshop will assist pipeline operators, trade associations, and others in addressing concerns with successfully using External Corrosion Direct Assessment integrity evaluation methods and use of other technologies to assess casings in High Consequence Areas. The goal of the workshop is to develop a list of potential solutions that can address issues with cased crossing inspections through usage of new technology, understanding of and/or changes to the regulations, updating of standards, operating practices and/or research. PHMSA will then analyze the list of potential solutions with stakeholders for consideration on which solutions can best address the issues.

The first day of the workshop will include:

• A background of the regulatory integrity requirements,
• Technical updates by both operators and service providers,
• Overview of research of new technology, inspection issues and the current integrity inspection positions,
• Status of the stakeholders represented followed by panels presenting and discussing current NACE standards,
• Approaches and assessment methodologies being used for cased pipeline segments, and
• Research completed or underway.

• Breakout sessions on the above topics, followed by the group convening to talk about technical assessment successes,
• New technology,
• New integrity assessment approaches,
• Status update of assessments, and
• Long term issues.

TRRC Adopts Risk-Based Leak Survey Program
16 TAC Chapter 8 – Pipeline Safety Regulations
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The Texas Railroad Commission (TRRC) adopted new §8.206, “Risk-Based Leak Survey Program” effective September 1, 2008, for operators of gas distribution pipeline systems. The adopted rules require Texas gas distribution companies to establish a risk-based schedule of increased leak inspections; standardize leak grading and repair time frames; and repair or remove and replace certain compression couplings due to leaks or serviceability. No later than March 1, 2009, each operator shall have completed and submitted to TRRC either a prescriptive or a risk-based program for leak surveys for its pipeline systems that complies with the requirements of this section.

When establishing a risk-based schedule, pipeline operators are required to:

• create a risk model on which to base its leak survey program to identify those systems or segments within systems that pose the greatest hazard and thus will be inspected for leaks more frequently
• re-evaluate and update its leak survey inspection program to address any changes that may be identified through the monitoring of the pipeline system in accordance with the requirements imposed by 49 CFR 192.613 (relating to Continuing Surveillance)

• Grade 1 leaks are defined as an existing or probable hazard to persons or property and requires the operator to take immediate action to eliminate the hazard and make repairs.
• Grade 2 leaks are non-hazardous at the time of detection and can be scheduled for repair on a normal routine basis with periodic reinspection at least once every 30 days until the leak is repaired or cleared. Grade 2 leaks vary greatly in degree of potential hazard and may require a scheduled repair within the next 5 working days and others within 30 days. This new section outlines additional criteria that require repairs made within 6 months of detection of any leak.
• Grade 3 leaks are non-hazardous at the time of detection and can be reasonably expected to remain non-hazardous. Operators must repair a Grade 3 leak within 36 months of detection.
• There is a concise reference table for leak grading and leak repair deadlines in §8.207(g).

• For leaks identified on any underground compression coupling used to mechanically join steel pipe, operators must either replace the leaking compression coupling or repair it using a sleeve welded over the compression coupling.
• Operators are required to repair or replace any compression coupling used to mechanically join steel pipe that is exposed during operation and maintenance activities unless the operator can determine the coupling was installed after 1980.
• For leaks identified on any underground compression coupling used to mechanically join plastic pipe, operators must remove and/or replace the leaking compression coupling.
• For any other compression coupling used to join plastic pipe that is exposed during operation and maintenance activities (2-inches or less in diameter) operators must replace or remove coupling unless the operator can determine that the coupling is designated as an ASTM D2513 Category 1 type fitting. For plastic pipe greater than 2-inches in diameter, operators must replace or removed coupling unless the operator can determine that the coupling is designated as an ASTM D2513 Category 1 or Category 3 type fitting.

Has the Gas Gathering definition affected your pipelines?

RCP can conduct a detailed analysis of your gas pipelines to determine end points of production and gathering based upon the recently finalized definition of gas gathering pipelines. The analysis will also determine whether your gathering pipelines are regulated and whether they are classified as Type A or B regulated gas gathering. For more information, click here to contact Jessica Roger.

Colorado Proposed Modifications to Pipeline Safety Regulations
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The Colorado Public Utilities Commission (CPUC) published a Notice of Proposed Rulemaking regarding amendments to the rules relating to the gas pipeline safety program, 4 Code of Colorado Regulations (CCR) 723-4, and also amends the existing state pipeline safety rules by adopting federal amendments up to October 1, 2007. The purpose of the proposed rules is to bring the Gas Pipeline Safety Rules up to date and in compliance with amended safety rules promulgated by the U.S. Department of Transportation, 49 U.S.C. § 60105 et seq.

The CPUC will conduct a hearing on these proposed rules before an Administrative Law Judge at 9 a.m. on August 18, 2008 at the CPUC Hearing Room 1560 Broadway, Suite 250 Denver, Colorado. Interested persons may submit written comments on the rules, including data, views, or arguments and present these orally at the hearing unless the Commission deems oral presentations unnecessary. Suggestions for changes that will make the subject rules more efficient, rational, or meaningful are also encouraged.

Submit written comments both in paper and electronic format no later than August 1, 2008. Reply comments should be submitted by August 11, 2008.

RCP Participation at the International Pipeline Conference 2008
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RCP will be presenting three papers at the International Pipeline Conference in Calgary. Presenting authors from RCP include: Bill Byrd, P.E.; Larry Decker, P.E., and Ken Palmer, PhD. Starting with this month’s newsletter, we are providing an abstract of each paper — hopefully you will join us in Calgary for the full presentations.

Abstract: Transfers of Ownership: The Devil is in the Details
Ken Palmer, Lead Author and Bill Byrd, Co-Author
During the lifespan of a pipeline, it will most likely undergo several generations of acquisition, divestiture and other company transitions. This poster session begins with an overview of what is involved in a company name change, and includes a detailed presentation of the steps required for name change completion. Topics covered in this progression include: inventorying, agencies to contact, company personnel to be interviewed, forms to complete, required fees, required signatures and report preparation. Methodology is presented in a strategically designed format that allows one to complete this process in a timely and efficient manner. Information in this presentation will make one realize that a name change goes far beyond the relettering of company signs.

International Pipeline Conference 2008
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Pipeline industry professionals from around the world will gather for the 7th International Pipeline Conference (IPC) on September 29 – October 3, 2008 in Calgary, Alberta, Canada at the TELUS Convention Centre and Hyatt Regency Hotel. Organized by volunteers representing international E&P, transmission, and distribution corporations, energy and pipeline associations and governments, the IPC has become internationally renowned as the world’s premier pipeline conference. Visit the IPC website for more information.

RCP Hideout at the IPC Conference

If you are planning to attend the International Pipeline Conference in Calgary (September 29 – October 3) ask Donna for directions to the RCP Hideout. Wii’ll be hosting a two-day competition with the Nintendo Wiis®. Drop by for food, drinks, and some friendly competition. Practice your electronic tennis, bowling, and baseball skills. Win a Wii®! Your family will love you for it!

TEEX Pipeline Training Facility / Emergency Responders
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The Texas Engineering Extension Service (TEEX) is world renowned for its hands-on customized training — providing training and technical assistance to more than 204,000 workers last year. This year, TEEX is building a pipeline prop at their facility which will benefit the industry in training emergency responders. It will be fully functional for training on both gas and liquid pipelines. Phase I is complete which includes 6 stand alone props and 2,300 ft. of underground pipeline. Phase II features a Chemical Complex which will tie into the pipeline prop. Once completed, this complex will enable TEEX to continue to remain the flagship for training in the pipeline emergency response field.

For more information regarding TEEX and how you can make a monetary or equipment donation to the "Chemical Complex Program" please contact: Kevin McMaughan at (979) 458-0171, or by email: james.mcmaughan@teexmail.tamu.edu.

Save the Dates!

Online Version of Pipeline Emergencies Training
Thanks to the CATS Connection newsletter for the following notice:
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The National Association of State Fire Marshals (NASFM) has created an on-line version of Pipeline Emergencies to provide first responders with a general awareness of pipeline safety. Pipeline operations and commodity properties are highlighted in this summary of the full Pipeline Emergencies training program. In order to quantify the reach of Pipeline Emergencies 101, first responders are required to register on the web site before starting the training. NASFM and PHMSA encourage pipeline operators to include the link to Pipeline Emergencies 101 in pipeline safety awareness messages to first responders.

2008 International Pipeline Security Forum
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The International Pipeline Security Forum (IPSF) will be held in Salt Lake City, UT at the Hilton Salt Lake City Center Hotel on October 29 & 30, 2008. The Forum is sponsored by the Transportation Security Administration (TSA) in collaboration with Natural Resources Canada. Registration and attendance at the forum is limited to pipeline, energy and security representatives and officials from private industry and government. This event is not open to the general public and media. IPSF Registration is free and hotel reservations can be made directly with the Hilton Salt Lake City Center Hotel no later than Sunday, September 28, 2008 for the discounted room rate.

Forum registration procedures and hotel reservation information can be found at the TSA Website.

The Forum agenda is currently being developed. Click here for the Draft Agenda.

Need A Security Plan or Audit?

We have the expertise to develop a security plan and perform risk assessments for pipeline and terminal facilities to meet recent DOT Hazmat Transportation & Pipeline regulations. We can also assist you in USCG security plans for dock facilities and vessels. Please contact Jessica Roger for more information.