DOT Pipeline Compliance News
March 2009 Edition

Texas Railroad Commission Issues More Revised Pipeline Regulations
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The Railroad Commission of Texas (TRRC) has approved adoption of amendments to pipeline safety regulations that will have significant impacts to gas production and gathering pipeline facilities in Texas. This is the second final rule published by the Texas Railroad Commission in the last month. The proposed amendments were published on October 10th (Proposed 16 TAC Chapter 8), comments were submitted (Comments), and the final rule was posted on February 10th (Final Rules). The final rules were published in the Texas Register on February 27th and became effective on March 2, 2009. A summary of the changes is provided below.

• Chapter 8.1 General Applicability has been amended to incorporate gas production pipelines downstream of the first point of measurement, treating these essentially the same manner as a gas gathering pipeline. In a previous final rulemaking, production pipelines were incorporated into the definition of Transportation of Gas, but the specific compliance requirements and deadlines where not discussed. With this new rulemaking, the Texas Railroad Commission clearly specifies which gas production pipelines are regulated and the dates in which these newly regulated pipelines must be in full compliance. The same criteria used for regulated gas gathering (i.e. Type A and Type B) will be applied to gas production pipelines. Therefore, any onshore gas production pipeline located in a Class 1 area will remain exempt from pipeline safety regulations. Gas Production pipelines located in Class 2, 3, or 4 areas will be regulated and must comply with the same requirements as Type A or Type B gas gathering pipelines. The dates for these newly regulated pipeline facilities to be compliant are as follows:
  
  • Date pipeline placed into service: any new, replaced, relocated, or otherwise changed
  • March 1, 2010: Establish Maximum Allowable Operating Pressure per 49 CFR 192.619
  • September 1, 2010: Establish and implement Damage Prevention program per 49 CFR 192.614
  • March 1, 2011: Install and maintain line markers per 49 CFR 192.707
  • March 1, 2011: Establish and implement Public Education and liaison per 49 CFR 192.616
  • March 1, 2012: Establish and maintain cathodic protection requirements per 49 CFR 192
  • March 1, 2011: for Type A lines, comply with all other provisions applicable to Type A gas gathering lines per 49 CFR 192.8(c)
• Chapter 8.101 Pipeline Integrity Assessment and Management Plans for Natural Gas and Hazardous Liquids Pipelines has been amended. The final rule eliminates gas gathering pipelines from the assessment schedule for inline inspection, pressure testing and subsequent remediation requirements. Gas transmission pipelines are still subject to this schedule found under 16 TAC Chapter 8.101(b)(2).

Leak Management Tracking System

RCP has developed a leak management system that tracks all leaks through their life span and will allow for the reports required by the TRRC to be easily generated and uploaded into the TRRC Electronic Document Interchange process. It is a web-based application that can be customized so that field personnel can interface through laptops or hand-held devices. Because it is web-based, there are no IT issues to struggle through to get started. Simple to use, easy to access, and can be customized with GIS integration tools, etc. For more information, contact Jessica Roger.

Texas Railroad Commission New Email Service
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The Texas Railroad Commission (TRRC) has placed on its website the opportunity for an individual to be informed via email of all proposed TRRC rule changes, proposals, rules adopted by the commission, etc. merely by going through a painless sign-up procedure. The rules will be attached to the emails and in PDF format.

Interested in Web-Based Compliance Management Systems?

RCP has the latest technology to help manage all of your permits, inspections, procedures, and data requirements and neatly organize them into one overall compliance assurance system. Because it is web-based, there are no IT issues to struggle through to get started. For more information, click here to contact Jessica Roger.

Stay of Enforcement for API 5L (43rd Edition) and API 1104 (19th Edition)
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On December 23, 2008, Jeff Wiese issued a Stay of Enforcement related to API 5L (43rd Edition) and API 1104 (19th Edition), as long as the more recent editions (44th and 20th, respectively) were used in their place. The PHMSA pipeline safety regulations are very specific about which edition of incorporated standards must be used, and sometimes obsolete editions are intentionally incorporated into the regulations. In this case, however, PHMSA intends to incorporate the more recent editions of these standards and has issued this stay of enforcement on the obsolete editions, pending an update to PHMSA’s rules that will officially incorporate the newer editions.

Editor’s note: Mea Culpa. I knew about this stay in December, but forgot to include it in our January newsletter. Better late than never…

Revisions to New Jersey Gas Pipeline Regulations
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The State of New Jersey has made extensive changes to their regulations governing intrastate gas transmission and gas distribution pipelines (New Jersey State Regulations Title 14, Chapter 7). The changes include restrictions on installation or relocation of high pressure gas transmission lines within 100 feet of an occupied building, additional welding, construction, and testing requirements, new valve location and mapping requirements, new emergency planning and drill requirements, and a requirement that all natural gas pipelines constructed in New Jersey after March 2, 2009, shall meet the design standards for a Class 4 pipeline location, as set forth in 49 CFR 192.5, 192.609 and 192.611.

MAOP Analysis Model

Are you familiar with our Maximum Allowable Operating Pressure (MAOP) Analysis Model? Changes to MAOP can have a direct impact to the bottom line. Many companies are finding that changes to the pipeline that have occurred over years significantly impact the calculated MAOP value. We can input the data including pressure test records, construction design records, and repair records to derive an accurate MAOP for your current system. The model also allows you to review the impact on MAOP of proposed changes to the pipeline before they happen. For more information, contact Jessica Roger.

Operator Qualification – Criminal Probe / Raid
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Several federal agents from the Department of Transportation's Office of Inspector General raided a Palo Alto Utilities Department building Friday, February 6, 2009, as part of a criminal investigation into the qualifications and certification of city pipeline workers. According to the search warrant, the agents were authorized to seize a list of employees certified to work on the pipelines, their work performance histories and contact information, and examinations they took to receive the certifications. They were to search for evidence of false statements. The agents took seven boxes of documents but made no arrests.

Editor’s note: This investigation was apparently triggered by a whistleblower complaint, and was not the result of a routine state or federal OQ audit.

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 for more information.

DOT Random Drug Testing Rate
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The US Department of Transportation (DOT) has announced that the random drug testing rate will remain at 25% for 2009. DOT re-evaluates the random drug testing rate each year, based on the rate of positive random drug test results in the prior year.

Workshop on Internal Corrosion in Hazardous Liquid Pipelines (March 26, 2009)
[Docket ID PHMSA-2009-0026]
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The Pipeline, Inspection, Protection, Enforcement, and Safety Act of 2006 (PIPES), Public Law 109-468, Section 22, requires the Pipeline and Hazardous Materials Safety Administration (PHMSA) to review the internal corrosion control regulations to determine if the regulations are currently adequate to ensure that the pipeline facilities subject to the regulations will not present a hazard to public safety or the environment. As a follow-up to this review and the report to Congress, PHMSA is sponsoring a Workshop on Internal Corrosion in Hazardous Liquid Pipelines to allow stakeholders of the pipeline safety community to learn about and discuss PHMSA regulations, industry standards and practices, current evaluation practices and methods to assure pipeline safety.

The workshop will be held at the OMNI Hotel at CNN Center, 100 CNN Center, Atlanta, GA 30303 on March 26, 2009. Name badge pick-up and on-site registration will be available starting at 7:30 a.m. with the agenda taking place from 8 a.m. until approximately 5 p.m. Members of the public may attend this free workshop. To help assure that adequate space is provided, all attendees are encouraged to register here for the workshop. Refer to the meeting Web site for updated agenda and times.

Please Note: The workshop will NOT be webcast. However, presentations will be available on the meeting Web site within 30 days following the workshop.

PHMSA publishes requirements for the mitigation of internal corrosion at 49 CFR Part 195 for hazardous liquids pipelines. Pipeline safety regulations at 49 CFR 195.579(a) require operators to determine if the hazardous liquids they are transporting could corrode the pipeline and, if so, take adequate steps to mitigate that corrosion potential. PHMSA and other presenters plan to discuss the process of analyzing a pipeline system to determine whether internal corrosion is a threat and how to manage the threat if it exists. PHMSA will consider the discussion at the workshop and comments submitted to the docket in determining whether changes to regulatory requirements are needed and what those changes should be. PHMSA emphasizes that, while the workshop will involve issues related to Part 195, some of the technical discussions on research and methods are of relevance to natural gas pipeline operators. For this reason, PHMSA also encourages natural gas pipeline operators to attend the meeting.

Although the base commodity may not be corrosive, all hazardous liquids regulated under Part 195 could be corrosive during some phase of the production and/or manufacturing process when contaminants could be introduced. Often, the only barrier separating untreated product or corrosive materials from a pipeline transporting processed/refined products is the processing plant or refinery. These plants occasionally undergo upset conditions where all or a portion of the untreated product may bypass the treatment process and enter the downstream piping. During those upset conditions, corrosive materials might be introduced into the pipeline and could create a corrosive condition. Pipeline operators who previously concluded that an internal corrosion control program was not needed may need to critically re-analyze operating conditions and internal corrosion risk factors and periodically monitor, or otherwise reconfirm, that the pipeline is free of corrosive materials. Operators should perform a periodic system analysis and document the results, confirming that they properly analyzed the pipeline for possible internal corrosion precursors. In addition, operators should also conduct periodic monitoring for changes that might increase this risk and identify possible sites of selective internal corrosion risks.

For further information contact: Joshua Johnson at (816) 329-3825, or by e-mail at joshua.johnson@dot.gov.

Editor’s Note: I’m a Georgia Tech grad, and the meeting is just a few blocks from campus. Join me the night before to get “2 naked dogs walking” at The Varsity. If you’ve been there, you’ll understand.

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.

API Public Awareness Workshop
March 24-25, 2009
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The American Petroleum Institute (API) is planning a Public Awareness Workshop, March 24-25, 2009 in Houston, Texas. The workshop is open to member company industry personnel only. Key personnel responsible for developing and implementing Public Awareness programs would benefit from attending. Among the learning objectives are: Assessing your current public awareness efforts; Trigger points for program enhancements; Program evaluation, Continuous improvement and Program implementation and progress tracking. More detailed information will be posted at www.api.org/meetings by the end of January. Please contact Madeleine Sellouk at 202-682-8332 or sellouk@api.org with questions.

Save the Dates!

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.