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DOT Pipeline Compliance News
November 2006 Edition Recent Trends in DOT Pipeline Regulations |
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DOT Pipeline Compliance Workshop - December 8, 2006 Back to Top RCP will be hosting our very popular workshops on DOT Pipeline Compliance on December 8 in Park City, Utah. 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. Introduction to DOT/PHMSA Pipeline 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, including a seminar brochure, go to our website here. California: Hazardous Liquid Pipeline Excavation Bill Signed into Law Back to Top On Sept. 29, a bill was signed into law that establishes tougher safety procedures for excavation work that is conducted near high-risk pipelines carrying flammable fuels such as gasoline and natural gas. The legislation was inspired by the Nov. 9, 2004, pipeline excavation accident at a construction site in Walnut Creek, Calif., that killed five workers. Among the bill's requirements:
ASME B31Q-2006 Pipeline Personnel Qualification Standard Back to Top The consensus process for approval of the ASME B31Q has been completed and ASME published the pipeline operator qualification standard on September 15, 2006. In all, over 100 people worked diligently to retain as much of the existing framework of OQ as was feasible and to develop a technically based standard, recognizing the diverse needs of the industry and regulators. The ASME B31Q Project Team included representatives from federal and state regulatory agencies, contractors, industry associations, labor and three industry sectors – hazardous liquid, gas transmission, and local distribution companies. The project team met regularly over a period of twenty months to reach consensus on the content of the standard. Additional resources, including Subject Matter Experts, industry associations and service providers were utilized regularly. A copy of the new standard can be purchased for $185 by clicking here At this point, it is not clear what the Office of Pipeline Safety plans to do with this standard. OPS published a concept paper and held a public meeting on 12/15/05 that addressed Operator Qualification as it might relate to training, re-evaluation intervals, and new construction activities. Industry submitted their comments soon thereafter, but no formal action has been taken by OPS since. Alaska to Create Artic Pipeline Technology Team Back to Top Alaska Governor Frank H. Murkowski directed the Department of Environmental Conservation to assemble an Arctic Pipeline Technology Team and called for a corrosion conference to ensure the integrity of oil pipeline infrastructure and continued crude oil production. The Arctic Pipeline Technology Team will be created by a Memorandum of Understanding between the Department of Environmental Conservation, the Department of Natural Resources, the Alaska Oil and Gas Conservation Commission and the federal Office of Pipeline Safety. The team will work with industry and other government or non-governmental professionals with expertise in arctic pipeline engineering on leak detection, corrosion prevention, monitoring and inspection. The team will share technical resources and information related to pipeline integrity in arctic and sub-arctic climates. It will troubleshoot design, construction, operation and maintenance problems, validate engineering approaches, examine the regulatory regime and recommend changes to reflect latest technologies, and ensure the best available technology is being applied to Alaska's North Slope pipeline system. The governor also directed DEC to work with other agencies and industry to convene a conference in Alaska on pipeline integrity. The conference will convene the foremost experts in the world on pipeline integrity and management programs. The purpose of the conference is to gather information from across the globe on pipeline integrity technology including programs and equipment and to examine how proven or promising technologies could be applied to our pipelines. For more details, click here. Common Ground Alliance Meeting Back to Top The Common Ground Alliance is holding a free informational Summit regarding the national 811 awareness campaign. The meeting will be held on November 17 at the offices of Northern Natural Gas Company 1111 South 103rd Street Omaha, Nebraska 68124. Topics to be discussed include:
PHMSA Gas Gathering Workshops Back to Top PHMSA has published several more dates and locations for the gas gathering definition workshops. The first few workshops have been very informative and have provided an opportunity for “lively” exchanges among federal, state, and industry stakeholders. Workshop schedule and registration information can be found by clicking here.
The topics to be discussed include:
PHMSA Issues Revised Liquid IMP Protocols Back to Top The Pipeline and Hazardous Materials Safety Administration’s (PHMSA) Integrity Management Inspection Protocols for hazardous liquid pipeline operators have been revised to reflect experience obtained during the first round of Integrity Management inspections. The inspection forms were updated in December 2004, and will be used beginning with the second round of Integrity Management inspections for hazardous liquid operators. An additional minor update was implemented in October 2006 to incorporate the external corrosion direct assessment (ECDA) rule change and add integrity management-related Annual Report data reviews. These protocols are being used to inspect operators for compliance with all aspects of the Integrity Management Rule §195.452. To help illustrate updates and organizational changes to the protocols, a cross-reference table table between the updated protocols and the protocol set used for the first round of Integrity Management inspections is also available.
Gas IMP Revised FAQ-174: Considering GIS accuracy in locating HCAs Back to Top Question: The centerline of a pipeline may not be accurately determined via GIS or other method. The locations of structures (e.g., from aerial photography) may also involve inaccuracies. What provisions must be taken to address for inaccuracies in these measurements, in order to accurately determine the relative location of structures with respect to the pipeline? Answer: The rule does not explicitly address mapping/measurement inaccuracies. Instead, it specifies the use of distances that apply to pipelines, and distances from those pipelines, as they actually exist in the field. The research behind the C-FER equation used to estimate potential impact circles was based on actual measurements of the distances affected by pipeline accidents. PHMSA recognizes that mapping and measuring technologies involve some level of inaccuracy/tolerance. Operators must take these into account and consider the uncertainties in the distances they measure or infer when evaluating potential impact circles (PICs). Each operator's approach must be technically sound, must account for the uncertainties as they exist in the mapping/measurement methods used by the operator, and must be documented in its IM plan or related procedures. Operators may use a combination of techniques in order to account for these inaccuracies. For instance, aerial photography may be used as an initial screen. Field measurements (such as pipeline locators along with chainage measurements or survey quality range finders) may be used to verify if structures near the edge of the PIC (i.e., within the range of mapping/GIS inaccuracies) are actually inside or outside the PIC. PHMSA will inspect each operator's approach to assure that the operator's process is adequate to identify all covered segments. New Oil Spill Response Guidance From The MMS Back to Top A new Notice to Lessees (NTL) has been released by the MMS, superseding NTL 2002-G09. The new NTL 2006-G21, which is effective as of October 26, 2006, provides additional guidance on the review and update of Oil Spill Release Plans (OSRP), recognizes the National Incident Management System (NIMS), adds a new Section 22 to the OSRP regarding prevention measures for facilities in State waters, updates regulatory citations, and makes a few minor technical amendments. As with NTL 2002-G09, this NTL provides clarification, guidance and information concerning facilities, leases, and pipeline rights-of-way (ROW) located seaward of the coastline with regard to who is required to submit a regional OSRP and how to prepare and submit a regional OSRP in the MMS Gulf of Mexico OCS Region. While much of the guidance remains unchanged, there are significant differences with the addition of Section 22 regarding State waters, and with the requirement that the OSRP must be consistent with NIMS as well as the National Contingency Plan and appropriate Area Contingency Plans. This NTL also addresses regional OSRPs when referenced in an Exploration Plan or a Development Operations Coordination Document. When the state of Florida is an 'affected State', the MMS GOMR will not allow reference to a regional OSRP. In this instance, a site-specific OSRP must be submitted, or with MMS GOMR approval, an approved subregional OSRP may be referenced. For assistance with your OSRP preparation under these new guidelines, contact RCP. If you have a relevant regulatory meeting planned, please let us know, and we'll announce it in our upcoming DOT Pipeline Newsletters. Best Regards, W. R. (Bill) Byrd, PEwrbyrd@your-rcp.com www.your-rcp.com RCP - Your Regulatory Compliance Partner! http://www.your-rcp.com or call us at 1-888-RCP-X-YES to see how we may be of assistance to you! |