DOT Pipeline Compliance News
October 2008 Edition

DOT Pipeline Compliance Workshop - November 4 & 5, 2008
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RCP will be hosting our very popular 2-day workshop on DOT Pipeline Compliance on November 4 & 5, 2008, in Houston, TX. Join us for an informative, lively, and interactive workshop on DOT Pipeline Compliance.

Day 1 (November 4): Gas Pipeline Regulations (49CFR192): Covering all the topics below but special emphasis will be placed on the changes in **GAS GATHERING** regulations.

Day 2 (November 5): 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.

PHMSA Notice of Proposed Rulemaking on Control Room Management
[Docket ID PHMSA-2007-27954]
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The Department of Transportation Pipeline and Hazardous Materials Safety Administration (DOT/PHMSA) issued a Notice of Proposed Rulemaking (NOPR) to revise the Federal pipeline safety regulations to address human factors and other components of control room management. The proposed rules would require operators of hazardous liquid pipelines, gas pipelines, and liquefied natural gas facilities to amend their existing written O&M procedures, operator qualification (OQ) programs, and emergency plans to assure controllers and control room management practices and procedures used maintain pipeline safety and integrity. This proposed rule would add provisions to 49 CFR parts 192, 193, and 195. As part of the Prevention through People (PTP) program, this proposed rule addresses requirements applicable to controllers, key players among the people who can affect pipeline safety. The rule focuses on the enhancement areas identified by PHMSA in its earlier public meetings, including alarm management, controller qualifications, controller human factors, and management of change.

Written comments are due by November 12, 2008 and may be submitted to the E-Gov Web site at www.regulations.gov. Reference Docket No. PHMSA-2007-27954. PHMSA will consider late comments filed so far as practical.

For a copy of the proposed rule on Control Room Management, contact Jessica Roger.

AGA Control Management Workshop
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AGA will hold a Control Room Management Workshop on Thursday, October 30th at the Embassy Suites Dulles North, VA. This workshop will serve as a forum for government and industry to explain their views of the intent of the proposed regulation. For more information (including a draft agenda) and online registration can be found on the AGA Website.

PHMSA Proposed Security Plan Requirements
Docket No. PHMSA-06-25885 (HM-232F)
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The Pipeline and Hazardous Materials Safety Administration (PHMSA) is proposing to modify its current security plan requirements (49 CFR 172) governing the commercial transportation of hazmat by air, rail, vessel, and highway. To determine the types of materials that should be subject to security planning requirements, PHMSA evaluated specific transportation scenarios in which a terrorist could deliberately use hazardous materials to cause large-scale casualties and property damage. The proposed rule would narrow the list of materials subject to security plan requirements.

Comments to the proposed rule changes to the Security Plan Requirements are due by November 10, 2008 to www.regulations.gov — use docket number PHMSA-06-25885 on all correspondence.

For a copy of the proposed changes to the Security Plan Requirements (including a table summarizing the list of hazardous materials for which Transportation Security Plans will be required), contact Jessica Roger.

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.

MMS Reporting for Damage Caused by Hurricanes Gustav and Ike
NTL No. 2008-G18 / Effective date: September 25, 2008
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The U.S. Dept. of the Interior, Minerals Management Service (MMS) issued a notice to lessees and operators in the Gulf of Mexico OCS region, NTL No. 2008-G18 (which supersedes NTL No. 2008-G16, effective 9-11-08) to elaborate on the inspections you need to conduct and the plans and reports you need to prepare because of known and potential damage to OCS facilities caused by Hurricanes Gustav and Ike. You may access a map of the affected area on the MMS Internet website. The MMS GOMR has determined that you must perform the following surveys on all fixed OCS platforms located in the affected areas of both hurricanes:

• Level I survey before you man a platform located in the affected area.
• Level II & III underwater surveys may be necessary (see full text for details)
• Level IV survey if a Level III survey detects significant structural damage

• A list of all your OCS platforms in the affected area;
• For each listed platform, an initial inspection plan
• A timetable that shows how you will complete all inspections by March 31, 2009

Gas Distribution Integrity Management Programs (DIMP) Comment Period Extended
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The Pipeline Hazardous Materials Safety Administration (PHMSA) is extending the period for public comment to give interested persons an additional 30 days to comment on a proposed rule to amend the Federal Pipeline Safety Regulations to require operators of gas distribution pipelines to develop and implement integrity management programs. Please reference RCP's newsletter article on the proposed rule in the July 2008 edition of DOT Pipeline Compliance News. PHMSA is extending the period for written comments on the proposed rule until October 23, 2008, and will consider late filed comments so far as practicable. Comments should reference Docket No. PHMSA-RSPA-2004-19854 and may be submitted to the E-Gov Web Site: http://www.regulations.gov.

For a copy of the DIMP proposed rulemaking, or for information on how RCP can support the development activities of a DIMP, please 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.

Workshop on Anomaly Assessment and Repair
Docket ID PHMSA-2008-0255
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PHMSA is sponsoring a Workshop on Assessment and Repair of Anomalies in Pipelines to allow stakeholders of the pipeline safety community to learn about and discuss recent research results, current evaluation practices, and methods to assure pipeline safety. The discussion of current evaluation practices and methods to assure pipeline safety should include: A review of safety factors used to evaluate anomalies when assessing in-line tool and excavation results, review of how outside forces and overpressure may affect anomaly stresses, how ILI tool accuracy is applied to anomaly evaluation, and how anomaly growth rates in assessments are considered. This will include a discussion of recent research indicating that existing methods of predicting the remaining strength of corroded pipe could provide non-conservative results (i.e., the pipe will fail at a pressure lower than that predicted) in some circumstances. Non-conservative results could be obtained even when the dimensions of pipeline anomalies are known with precision.

The workshop will be held at the Gaylord National Resort and Convention Center, 201 Waterfront Street, National Harbor, MD 20745 on October 22, 2008. 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. 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. Hotel reservations under the "United States Department of Transportation #2" room block for the night of October 21, 2008, can be made at 1-301-965-2000. A daily rate of $233 is available. The meeting room will be posted at the hotel on the day of the workshop.

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.

2008 International Pipeline Conference
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The International Pipeline Conference (IPC) was held September 30 – October 3, in Calgary, AB, Canada. RCP presented the following technical papers / poster session:

• Best Practices in Damage Prevention for Parallel Construction Projects – Bill Byrd, P.E.
• Pipeline Integrity Management – Estimating and Prioritizing the Risk Resulting from Pipeline Facility Operations – Larry Decker, P.E.
• What tools are available to help maintain a code compliant MAOP for a highly complex and changing gas pipeline system? – Larry Decker, P.E.
• Transfers of Ownership: The Devil is in the Details – Ken Palmer, PhD

Damage Prevention Plans

RCP can develop or update your Damage Prevention plan. For more information about how RCP can assist you with your Damage Prevention Plan, click here.

Michigan Proposed Rule Revision to Gas Safety Standards
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The Michigan Public Service Commission is considering the revision of rules governing gas safety standards, located at R 460.20101 to R 460.20606. These proposed rule revisions will incorporate existing federal gas safety standards into the Michigan gas safety standards. The Commission will hold a public hearing October 28, 2008, at 9 a.m. in Lansing, Michigan, to solicit comments on the proposed rules. The rules are proposed to take effect immediately upon filing with the Secretary of State.

Written and electronic comments may be filed with the Commission and must be received no later than 5:00 p.m. on November 18, 2008, to mpscedockets@michigan.gov.

For a copy of the proposed ruling, contact Jessica Roger.

New Jersey Proposed Rule Changes for Natural Gas Pipelines
40 NJR 4915(a)
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The New Jersey Board of Public Utilities (Board) is proposing rule changes regarding various aspects of natural gas pipelines (N.J.A.C. 14:7), which address the construction, operation, and maintenance of natural gas transmission and distribution pipelines. These rules explain where pipelines may be constructed, and set requirements for ensuring that the pipelines remain safe both during and after installation. The rules also set specifications that pipeline operators must follow when installing, inspecting, operating and maintaining natural gas pipelines. Some of the changes that should be noted are:

• Amendments are proposed to clarify that the rules apply to both transmission and distribution lines and that the pipeline operator is the person responsible for compliance.
• Require that all pipelines constructed in New Jersey in the future meet standards for a Class 4 pipeline location.
• A reference to the Federal code is added, including the requirements for an integrity management program in 49 CFR 192, Subpart O.
• Proposed new section provides much more specific and measurable requirements for the number and spacing of valves on distribution lines, and includes factors the operator must consider in determining the appropriate number and spacing of valves. The proposed new section also requires pipeline operators to file an evaluation report with Board staff regarding the number and spacing of valves.
• Proposed new section N.J.A.C. 14:7-1.11 governs the installation of pipe and its requirements are more stringent than corresponding Federal regulations at 49 CFR 192.325. It requires all gas pipelines to be installed with at least 12 inches separation from any other subsurface structure or facility, whereas the corresponding Federal regulations require 12 inches separation only for the installation of transmission pipelines. It also specifies size and type of wire required for tracer wire on plastic pipe installations. These specifications are more stringent than the corresponding Federal regulations at 49 CFR 192.321, which do not govern the size and type of wire.
• Proposed new section requires damage prevention efforts consistent with the requirements of Federal regulations at 49 CFR 192.614; requires an operator to take additional measures when the operator becomes aware of potential high risk excavations, such as performing on-site inspection, coordinating with the excavator, continuing surveillance, and checking/verifying clear access to gas valves that may be operated in an emergency. Also, an operator must provide training for operator personnel in preparation for potential high risk excavations around underground gas facilities.

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. This includes regulatory tasking, data management, and exception reporting. Because it is web-based, there are no IT issues to struggle through to get started. An institutional memory is created of the compliance history and ongoing compliance requirements, despite operator or personnel turnover. For more information, click here to contact Jessica Roger.

Pipeline Informed Planning Alliance (PIPA) Update
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The PIPA initiative involves a broad stakeholder group working together to develop more detailed guidance for property development in the vicinity of transmission pipelines. (See related article in the DOT Compliance News February 2008 edition.) A draft report is expected by the end of October, which will be distributed to participating PIPA organizations for review/comments that will be due by December. Stakeholder comments will be incorporated during January 2009, with the goal of posting the final PIPA product on the PHMSA Communications website by February 1, 2009.

SPCC Rule Update
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The US Environmental Protection Agency (EPA) sent the Oil Spill Prevention, Control, and Countermeasure “loose Ends” final rule to the Office of Management and Budget (OMB) at the end of August 2008 for 60-day review. EPA had committed to getting the final rule published by July 2008. EPA is now aiming to get OMB approval and to issue the final rule by October 31, 2008.

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.