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DOT Pipeline Compliance News
May 2006 Edition
Recent Trends in DOT Pipeline Regulations
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RCP is a professional engineering and regulatory consulting firm that works
throughout the United States.
RCP's Regulatory Newsletters reach thousands of industry professionals around the
nation. You can subscribe to the DOT Pipeline Compliance newsletter on
our website or you can e-mail your request to:
wrb@your-rcp.com
For additional information on RCP, visit our website: www.your-rcp.com or contact Jessica
Roger at 1-888-727-9937.
RCP is actively seeking top pipeline professionals for the following positions:
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Pipeline Integrity Project Manager
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Sr. Regulatory Consultant/DOT Pipeline Compliance
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Technical Writer
If you know of someone who might be interested, they can submit their resume to our HR department. hr@your-rcp.com
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In This Issue:
Public Awareness Workshop: ** Attention **
| All pre-workshop surveys for attendees are due by Monday, May 8th. |
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We have added additional speakers to the roster. |
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Andrew Cober - Market Strategies
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Tom Calabro - TFCC
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Jack Garret - Dig Tess *New
John Funderburk - Paragidm
Hal Bentley - Celeritas *New
Susan Waller - RCP
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This public awareness workshop is packed with good information and we look forward to seeing all of you there! |
How to Measure Your Program's
Effectiveness
PHMSA has this to say about API RP 1162: "Of significance is the requirement that
operators must review their [public awareness] programs for effectiveness and enhance
the programs as necessary."
How will you measure the effectiveness of your public awareness program?
Ask any three operators how to evaluate the public's "understanding" of pipeline issues,
and you'll receive at least three different answers. Measuring understanding and
developing benchmarks are challenges operators face in meeting the requirement to
determine the effectiveness of their public awareness programs. Yet in order to comply
with API RP 1162, every operator must implement some type of methodology to benchmark
the program and begin measuring understanding.
Now you have the chance to cut through the confusion and the buzzwords at an
important one-day seminar that brings together experts in the field of measurement
effectiveness.
- Is your message understood?
- Does your message motivate stakeholders to respond in alignment with the
information?
Because your company MUST answer these questions and more to be in compliance with the
federal requirements, RCP will bring together experts in the field of measurement
effectiveness for a seminar on May 9 aimed at de-mystifying the process of meeting the
evaluation requirement of API RP 1162.
What: Public Awareness Workshop — How to Measure Your Program's
Effectiveness
When: May 9, 2006
Where: Houston, Texas
Link: Registration
Why Attend:
This unique experience focuses on the current topics in the field of measuring
effectiveness. Come to Houston and receive:
- Results-Oriented Solutions
- Practical Benchmarking Tools
- New Insights into Best Measurement Practices
- Return on Investment
- Industry-Relevant Methodologies
Who Should Attend:
Operators of transmission, gathering and local distribution companies, public awareness
communicators, engineers, safety personnel, public relations staff, and anyone involved
in public awareness compliance activities.
What You Will Learn:
- Learn multiple approaches to measuring effectiveness.
- Analyze the validity of measurement techniques.
- Separate fact from fiction.
- Unlock the secrets of measuring the "unmeasurable."
Who Are the Speakers?
Market Strategies, Inc. (MSI) specializes in providing research and consulting
services that address RP 1162. Andrew Cober will discuss:
- The science of measuring effectiveness
- How to address the research needs surrounding RP 1162
- Different research methodologies
Andrew brings hands-on experience in designing operator’s surveys that provide a
benchmark for measurable results over time.
Paradigm is a leader in Community Awareness direct mail programs and in
identifying the stakeholders along an operator’s right-of-way. Paradigm’s John
Funderburk will:
- provide an overview of identifying stakeholder audiences
- explain resources for contacting those stakeholders
- list the challenges in reaching stakeholder audiences
- offer geo-coding techniques that allow operators to communicate with targeted
audiences
Twenty First Century Communications (TFCC) specializes in conducting telephonic
surveys that can assist operators in surveying stakeholders for the effectiveness of
their public awareness material. Tom Calabro, Senior Vice President of Twenty First
Century’s International Services will provide an overview of TFCC’s capabilities and
solutions that can help operators determine their program’s effectiveness. TFCC also
performs outbound telephone notifications that increase the effectiveness of direct mail
programs.
Regulatory Compliance Partners (RCP) provides operators assistance as they plan
and execute their public awareness programs ensuring that operators comply with RP 1162.
Susan Waller, one of the original contributors to RP 1162, will provide a brief overview
of RP 1162 and the implications of “continual program improvement.” She will also share
operators’ leading practices and methods to continually improve public awareness
programs.
Register Now!
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, call or Click here.
Gas Gathering Workshop
Back to Top
On March 15, 2006, the Pipeline and Hazardous Materials Safety Administration (PHMSA)
published its final rule on the definition of gas gathering lines. This rule completely
changes the previous
regulations for gas gathering. Pipelines that were previously considered to be regulated
gas gathering may now be exempt. Likewise, other pipelines that were previously
considered to be exempt gas gathering will now be regulated.
The new definition depends largely on API RP 80 to define the lines that are “gas
gathering,” with a few modifications. For those lines that are regulated, there will be
two levels of compliance requirements. Confused? You are not alone. Join us in Houston
as we delve into the details of the new regulations.
What: Gas Gathering Jurisdiction Workshop
When: May 10, 2006
Where: Houston, Texas
Link:
Registration
Why Attend
We’ll cover the following topics:
- How does RP 80 distinguish Production from Gathering?
- How does RP 80 distinguish Gathering from Transmission?
- What are the criteria for determining regulated onshore gathering lines?
- What are the compliance requirements and deadlines for regulated onshore gathering
lines?
- How should operators proceed under these new regulations?
The presentation will include specific examples and case studies, and will include time
for questions and answers.
Speaker
Bill Byrd of RCP, Inc., is a nationally recognized pipeline safety expert and
experienced workshop leader. He has conducted dozens of pipeline jurisdictional
determinations that consider the intricacies of federal and state pipeline safety
regulations in complex operating environments.
Register Now!
Utility Accommodation for Rail Facilities in Texas State ROWs
Back to Top
The State of Texas recently published new regulations governing the accommodation,
location, method of installation, adjustments, removal, relocation, and maintenance of
utility facilities within state railroad right of way. These new regulations were
developed in the interest of safety, protection, utilization, and future development of
state railroad right of way with due consideration given to public service afforded by
adequate and economical utility installations. These regulations are required because
of the Texas DOT’s newly enhanced statutory authority to own and operate rail
facilities. They include maintenance requirements for existing crossings. The new
regulations can be found in:
TEXAS STATE REGULATIONS
TITLE 43 - TRANSPORTATION
PART 01 - DEPARTMENT OF TRANSPORTATION
21 - RIGHT OF WAY
Subchapter 21O - Utility Accommodation for Rail Facilities
Contact Jessica
Roger for additional information.
Will your SPCC Plan pass an EPA inspection based on the new
SPCC Inspectors’ Guidance document?
RCP can conduct a gap analysis of your current SPCC Plan and provide updates and
recommendations based on the new SPCC Guidance for Regional Inspectors that was
published Dec. 2, 2005. The new guidance document includes more detail than is in many
of the plans in use today.
RCP can review and update your plan so that you will be prepared for an Inspection. For
more information, call or click here.
Texas Damage Prevention
Back to Top
On March 28, the Texas Railroad Commission held its first information-gathering meeting
to prepare for developing new damage prevention regulations for pipelines in Texas. The
informal meeting was used to explain the recent legislation in Texas that provides for
new TRRC regulations and to gather suggestions from the audience about potential
regulatory issues that should be addressed. An official docket has not yet been
established for this issue, but will be by the time a proposed rulemaking is developed.
For now, suggestions and comments can be sent directly to Mary McDaniel, Pipeline Safety
Director at the TRRC, for her consideration in developing a proposed rule. The next
meeting will be at the William B. Travis Bldg. - Room 1-100 in Austin, Texas, on May
23.
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.
Technical Advisory Committee Meetings - Workshops
Back to Top
Dockets: PHMSA-98-4470 / PHMSA-2004-18938 / PHMSA-2004-18584
PHMSA will hold public meetings of the Technical Pipeline Safety Standards Committee
(TPSSC) and Technical Hazardous Liquid Pipeline Safety Standards Committee (THLPSSC),
and 2 public workshops, on June 26-28, 2006. PHMSA will hold a half day public workshop
on Hazardous Liquid Low Stress Pipelines to solicit comments on a risk-based approach to
protecting unusually sensitive areas from risks associated with low stress lines. PHMSA
also will conduct an all-day public workshop to discuss the effectiveness of pipeline
control room operations and to obtain comments on ways to enhance the effectiveness of
pipeline control room operations and on findings from the Controller Certification
Project (CCERT). Lastly, the Committees will discuss regulatory issues and vote on two
rulemaking proposals: integrity management program changes and clarifications, and
design and construction standards to reduce internal corrosion in gas transmission
pipelines.
The dates and times are as follows:
- Monday, June 26 from 1:00 p.m. to 5:00 p.m. - THLPSSC and Public Workshop on
Hazardous Liquid Low Stress Pipelines
- Tuesday, June 27 from 8:00 a.m. to 5:00 p.m. – THLPSSC/TPSSC Public Workshop on
Effectiveness of Pipeline Control Room Operations
- Wednesday, June 28 from 8:00 a.m. to 9:00 a.m. – THLPSSC Meeting to vote on the NPRM
to address integrity management modifications
- Wednesday, June 28 from 9:30 a.m. to 4:30 p.m. – Joint meetings of the THLPSSC and
TPSSC
- Wednesday, June 28 from 5:00 p.m. to 6 p.m. - TPSSC meeting to vote on the NPRM to
address internal corrosion in gas transmission pipelines
The meetings will be at the Hilton Alexandria Old Town, 1767 King Street, Alexandria,
Virginia, 22314. Telephone: 1-703-837-0440, Fax 1-703-837-0454. Attendees staying
at the hotel must make reservations by Friday, May 26. The phone number for reservations
at the hotel is 1-800-HILTONS (445-8667). The hotel will give priority to the Committee
members and State Pipeline Safety Representatives for rooms blocked under “DOT Technical
Advisory Committee Meetings.”
O & M Manual Up-To-Date?
RCP has the tools and expertise to develop comprehensive procedures that you need to
protect your people, facilities, and environment. Click here to request more information.
OPS issues revised FAQ’s for Public Awareness Programs
Back to Top
On April 10th, the OPS posted revised FAQ’s for Public Awareness Programs on their
website. Some of the topics addressed in the FAQ’s include:
- When must programs be complete?
- What constitutes a complete program?
- When must an operator complete the initial distribution of RP 1162-compliant
communications to stakeholders.
- Are operators required to sample stakeholder audience awareness levels before June
20, 2006?
- When must an operator complete the first evaluation of program effectiveness?
- Must a public awareness program include supplemental elements (enhancements)?
- What is a significant percentage of non-English speaking populations and how can
that percentage be determined?
- How will PHMSA provide detailed instructions for operators to submit written
programs?
For a copy of the FAQ’s or to obtain more information about RCP’s public awareness
services, please contact
Jessica Roger at RCP.
Need to Update your Response Plan (FRP, ICP or
OSRP)?
We have the expertise to update your Facility Response Plan, Integrated Contingency
Plan, or Oil Spill Response Plan to include new guidance and lessons learned from recent
incidents and natural disasters.
Click here to request more information.
PHMSA Response to NTSB on SCADA Issues
Back to Top
On April 26th, PHMSA submitted their response to the National Transportation Safety Board (NTSB) regarding recommendations resulting from their study entitled “Supervisory Control and Data Acquisition Systems (SCADA) in Liquid Pipelines”. The NTSB recommended the following:
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P-05-1: Require operators of hazardous liquid pipelines to follow the American Petroleum Institute's Recommended Practice 1165 [API RP 11651 for the use of graphics on the SCADA screens.
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P-05-2: Require pipeline companies to have a policy for the review / audit of alarms.
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P-05-3: Require controller training to include simulator or non-computerized simulations for controller recognition of abnormal operating conditions, in particular, leak events.
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P-05-4: Change the liquid accident reporting form (PHMSA F 7000-1) and require operators to provide data related to controller fatigue.
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P-05-5: Require operators to install computer-based leak detection systems on all lines unless engineering analysis determined that such a system is not necessary.
The first four recommendations are being addressed through communications of the CCERT Study and public workshops as mentioned in the article above (Technical Advisory Committee Meetings - Workshops)
“This week PHMSA intends to announce in the Federal Register a public workshop in June to discuss opportunities to enhance the safety of pipeline control and findings from the CCERT Project. The workshop is a forum to discuss the adequacy of current regulations, some new concepts for improvement of control room management and operations, and for industry to provide feedback on any enhancements PHMSA offers for discussion on the topic. PHMSA would like to hear from the public and industry its experiences related to pipeline management processes, human fatigue issues, controller qualification training and other programs to assure the effective control of pipelines.”
PHMSA has addressed the Computer-Based Leak Detection recommendation (P-05-5) as follows:
“The integrity management rule for hazardous liquid pipelines requires operators to have a means to detect leaks on its pipeline system. To the extent an operator uses a computer-based leak detection system, the operator's system must comply with API Recommended Practice 1 130. Forty-six percent of PHMSA7s first round of inspections of integrity management programs revealed inadequate use of prevention and mitigation measures, including leak detection, in the program elements. As a result, our second round of inspections will include a more detailed examination of leak detection than the first round. In addition, we will include discussion of mandated use of computer-based leak detection at the public meeting on the CCERT Project this coming summer. This discussion will enable us to provide a more informed response to this recommendation at a later date."
Need to Update your Response Plan (FRP, ICP or
OSRP)?
We have the expertise to update your Facility Response Plan, Integrated Contingency
Plan, or Oil Spill Response Plan to include new guidance and lessons learned from recent
incidents and natural disasters.
Click here to request more information.
RCP Services Spotlight — Gas Gathering Jurisdictional Determination
Back to Top
On March 15, 2006, PHMSA published its final rule on the definition of gas gathering
lines. This rule depends largely on API RP 80 to define the lines that are “gas
gathering” with a few modifications. Of these lines, some are classified as “regulated
onshore gathering” of either Type A or Type B.
Type A regulated onshore gathering lines are required to comply with the transmission
pipeline regulations, except for the requirements for making a line smart-piggable and
for Pipeline Integrity Management. In addition, Type A lines in class 2 areas can meet
their Operator Qualification obligations simply by describing their qualification
process.
Type B lines are required to meet certain requirements for corrosion control, damage
prevention, public education, line marking, and establishing the MAOP of the line. Any
new, replaced, relocated, or otherwise changed lines will need to comply with current
design, installation, construction, initial inspection and initial testing
requirements.
The final rule takes effect April 14, 2006. Compliance dates for both Type A and B lines
vary by topic and range from 10/15/2007 to 4/15/2009.
RCP is in the process of helping gas production, gathering and transmission pipeline
operators update their jurisdictional determinations for these lines.
If you are interested in how RCP can help you evaluate the jurisdictional classification
of your pipelines, give Jessica Roger a call at (713) 655-8080.
Need to Update Your Current Operator Qualification
Program?
We have the expertise to update your current operator qualification program to satisfy
the upcoming regulation change and inspection protocols. Click here to request more information.
If you have a relevant regulatory meeting planned, let us know, and we'll announce it in our upcoming DOT Pipeline Newsletters.
Yours,
W. R. (Bill) Byrd, PE
President
RCP Inc.
888-727-9937
wrbyrd@your-rcp.com
www.your-rcp.com
RCP - Your Regulatory Compliance Partner!
Visit Regulatory Compliance Partners on the Web at
http://www.your-rcp.com
or call us at 1-888-RCP-X-YES to see what we can do for you.
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