DOT Pipeline Compliance News
September 2008 Edition

RCP Hideout at the IPC Conference
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If you are planning to attend the International Pipeline Conference in Calgary (September 29 – October 3) ask Donna for directions to the RCP Hideout. With all the awesome information at the conference, you may need a Wii little break. Check out the RCP Hideout, practice your Wii skills, and enter the big tournament on Wednesday, October 1st. 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!

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.

DIMP Webcast
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The Pipeline & Hazardous Materials Safety Administration (PHMSA) published a proposed rule that would establish integrity management requirements for gas distribution pipeline systems (DIMP). The DIMP Webcast provides background information concerning the proposed rule. The video presentation is a bit dry, but informative. Each video segment is approximately 30 minutes or less. You can view the entire program, or only those segments of interest to you. Or, you can download a zip file of the presentation slides. The DIMP Webcast is appropriate for all audiences – from the general public to the experienced operators. Topics of interest include: the 7 key elements of the DIMP regulation, HCAs, GPTC Guidance, and Excess Flow Valves.

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.

DIMP FAQ’s Posted
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The Distribution Integrity Management Program (DIMP) Frequently Asked Questions have been posted on the PHMSA website recently. [Last Revised July 28, 2008] Click here to view the answers provided to the FAQs listed below.

General
FAQ-1. Why is PHMSA proposing integrity management requirements for distribution pipeline systems?
FAQ-3. Why aren’t distribution pipeline operators required to physically inspect their pipelines as are operators of other types of pipelines?
FAQ-11. Must an operator follow the Gas Piping Technology Committee (GPTC) DIMP guidelines?
FAQ-22. Why has PHMSA selected the performance measures that it has for periodic reporting?

Proposed Rule Scope
FAQ-2. Why aren’t the proposed distribution integrity management requirements focused on high consequence areas?
FAQ-4. Why are master meter and LPG system operators proposed to be subject to different requirements?
FAQ-12. The proposed rule requires that an operator know its system. Must an operator excavate simply to gather information about parts of its system where it may not now have complete knowledge?

Mitigating Risks
FAQ-5. Why not simply require distribution operators to replace old, risky pipe?
FAQ-14. Must an operator implement new actions to reduce risk from its pipeline?
FAQ-18. If an operator already has a leak management program, do they have to implement a new program in response to this proposed rule?

Excess Flow Valves
FAQ-6. Why are Excess Flow Valves included in integrity management requirements?
FAQ-8. Will an operator have to retrofit excess flow valves into existing service lines?
FAQ-9. Will excess flow valves provide protection for gas line breaks inside a residence?
FAQ-10. Will an operator still have to notify customers of the availability of excess flow valves after the final rule becomes effective?

Threat / Risk Analysis
FAQ-13. Must an operator use a computer-based risk analysis model?
FAQ-17. How will small operators, with limited staff, be able to implement the requirements for risk analysis and selection of risk control measures?

Reducing Intervals for Periodic Requirements
FAQ-15. May an operator reduce activities now being undertaken to comply with regulations if it finds that other actions would have a greater effect on reducing risk?
FAQ-16. How can operators use their DIMP programs to justify reductions in other periodic requirements?

Plastic Pipe
FAQ-20. Why is PHMSA proposing to require that plastic pipe failures be reported to PHMSA?
FAQ-21. Why is PHMSA seeking comments on marking of plastic pipe?

Performance through People (PTP)
FAQ-23. What is PTP, as referred to in the preamble to the proposed rule?
FAQ-24. What is PTP’s relationship with DIMP?

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.

GPTC Guidance for DIMP
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The Gas Piping Technology Committee (GPTC) developed the Distribution Integrity Management Program (DIMP) guidance in anticipation of the Notice of Proposed Rulemaking issued by PHMSA. GPTC has provided guidance for compliance with federal pipeline safety regulations since 1970. The GPTC Guide for Gas Transmission and Distribution Piping Systems was developed by a task group to: follow the 7 key elements of DIMP, address the needs of all operators (including small systems), and provide examples on how to implement the rule.

The DIMP guidance document is open for public review and comment. Comments on the draft guidance must be submitted to the GPTC by the close of business on September 8, 20008.

For a copy of the GPTC draft guidance for DIMP (including comment form), contact Jessica Roger.

AGA / DIMP Slide Presentation Posted on the Web
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The American Gas Association (AGA), Gas Distribution Integrity Management Workshop was held on August 13, 2008 in Chicago. The agenda and slide presentation from the workshop have been posted on the PHMSA website. Topics include: Development of a DIMP Plan, Plastic Pipe Data Collection, PTP, and Alternative Inspection Intervals.

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.

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 Participation at the International Pipeline Conference 2008
[Part 3 in a 3 Part Series]
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RCP will be presenting 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. This month’s featured abstract is by Bill Byrd. We hope you will join us in Calgary for the full presentations.

Best Practices in Damage Prevention for Parallel Construction Projects
New pipelines are increasingly being encouraged (or forced) to share common or adjacent rights of way with existing utilities. Installation parallel to existing underground facilities for long distances greatly complicates construction and damage prevention, and creates a multitude of opportunities for damage to occur. According to the Pipeline and Gas Journal, as of 2008, 144,096 miles of new oil and gas pipelines are under construction or planned. Of these, North American companies are planning, designing and building 46,072 miles of pipelines. Much of this new mileage will be located inside or adjacent to existing utility corridors. For example, more than 59% of the 639 mile long Rockies Express East pipeline will follow existing rights-of-way. Lengthy parallel excavations pose an almost unlimited number of opportunities for excavation-related incidents to occur. This large amount of construction adjacent to hundreds of miles of existing underground utilities poses a very real risk of excavation damage that must be addressed. This paper describes current regulatory and industry association efforts to address these issues, and gives a case study of a real accident that was caused during parallel construction of a water main adjacent to an HVL pipeline.

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.

PHMSA Notice & Request for Comments on Incident Report Forms
[Docket No. PHMSA-2008-0211]
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The Pipeline and Hazardous Materials Safety Administration (PHMSA) invites comments on its intention to revise forms: PHMSA F7100.2 – Incident Report for Gas Transmission and Gathering Systems; PHMSA F 7100.1 – Incident Report for Gas Distribution Systems; and PHMSA F7000-1 – Accident Report for Hazardous Liquid Pipeline Systems.

Submit comments by November 3, 2008 to the E-Gov Web site: http://www.regulations.gov. Comments should reference Docket No. PHMSA-2008-0211. Questions can be directed to Roger Little with the DOT at (202) 366-4569. Or, for a copy of the Notice requesting comments on these incident report forms, contact Jessica Roger.

PHMSA Recruiting for a Compliance Officer
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PHMSA is currently recruiting for a Compliance Officer, with a pipeline engineering background, reporting to the Director, Office of Enforcement. This person will help transform PHMSA’s enforcement program and will be responsible for safe, reliable and environmentally sound operations of Federal and State pipeline safety compliance programs. The position guides the risk-based application of pipeline safety regulations, industry engineering standards and compliance practices by natural gas and hazardous liquid pipeline operators. The successful candidate will work with regional directors to assure remedial action to reduce the occurrence of threats to pipeline integrity. This position provides technical expertise in analyzing issues underlying policy and regulatory development, accident investigation and follow on compliance actions. For additional information about this opportunity, click here.

Those having questions about the position are welcome to call Rod Dyck, the Director, Office of Enforcement, at 202-366-3844.