DOT Pipeline Compliance News
April 2008 Edition

DOT Pipeline Compliance Workshop - May 28 & 29, 2008
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RCP will be hosting our very popular 2-day workshop on DOT Pipeline Compliance on May 28 & 29, 2008, in Houston, TX. Join us for an informative, lively, and interactive workshop on DOT Pipeline Compliance.

Day 1 (May 28): Gas Pipeline Regulations (49CFR192): Covering all the topics below but special emphasis will be placed on the changes in **GAS GATHERING** regulations.

Day 2 (May 29): 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.

RCP & ESRI Business Partner Program

RCP is pleased to announce our partnership with ESRI in providing consulting services to GIS users. ESRI designs and develops the world's leading geographic information system (GIS) technology. RCP's staff includes GIS and mapping experts that conduct high consequence area (HCA) identification, risk assessment, class location analysis, underwater inspections, NPMS/RRC submittals, spill modeling, as well as other spatial analysis projects. For more information, contact Jessica Roger.

Proposed Rule: Increasing MAOP for Gas Transmission Pipelines
Docket ID PHMSA-2005-23447
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The Department of Transportation / Pipeline Hazardous Materials Safety Administration (DOT/PHMSA) proposed to amend the pipeline safety regulations to prescribe safety requirements for the operation of certain gas transmission pipelines at pressures based on higher stress levels. The result would be an increase of maximum allowable operating pressure (MAOP) over that currently allowed in the regulations. This action would update regulatory standards to reflect improvements in pipeline materials, assessment tools, and maintenance practices, which together have significantly reduced the risk of failure in steel pipeline fabricated and installed over the last twenty-five years. The proposed rule would apply to both new and existing pipelines, and would allow use of an established industry standard for the calculation of MAOP, but limit application of the standard to pipelines posing a low safety risk based on location, materials, and construction.

PHMSA has previously granted special permits on a case-by-case basis to allow operation of particular pipeline segments at a higher MAOP than currently allowed under the design requirements. These special permits have been limited to operation in Class 1, 2, and 3 locations and conditioned on demonstrated rigor in the pipeline’s design and construction and the operator’s performance of additional safety measures. Building on the record developed in the special permit proceedings, PHMSA has proposed to codify the conditions and limitations of the special permits into standards of general applicability. Under the proposed rule, several types of segments will not qualify for the higher MAOP:

• Segments in densely populated Class 4 locations
• Segments of grandfathered pipeline already operating at a higher stress level but not constructed in accordance with modern standards.
• Bare pipe.
• Non-steel pipe
• Pipe with wrinkle bends or mechanical couplings in lieu of welding
• Pipe experiencing failures indicative of a systemic problem, such as seam flaws, during the initial hydrostatic testing.
• Pipe manufactured by certain processes, such as low frequency electric welding process.
• Segments which cannot accommodate internal inspection devices.
• Segments within compressor or meter stations or segments underlying certain crossings.
• Segments not monitored by supervisory data control and acquisition systems.

• Incorporating by reference ASTM Designation: A 578/A578M—96 (Reapproved 2001) "Standard Specification for Straight-Beam Ultrasonic Examination of Plain and Clad Steel Plates for Special Applications".
• Prescribing additional design standards in §192.112.
• Prescribing additional construction requirements, including rigorous quality control and inspections, in §192.328.
• Specifying additional operations, maintenance, testing, and notification requirements.

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.

PHMSA Advisory Bulletin for Gas Distribution Systems
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The Department of Transportation / Pipeline Hazardous Materials Safety Administration (DOT/PHMSA) issued Advisory Bulletin ADB-08-03, "Pipeline Safety: Dangers of Abnormal Snow and Ice Build-Up on Gas Distribution Systems." Recent events on natural gas distribution system facilities appear to be related to either the stress of snow and ice or malfunction of pressure control equipment due to ice blockage of pressure control equipment vents by ice. This advisory bulletin advises owners and operators of gas pipelines of the need to take steps to prevent damage to pipeline facilities from accumulated snow or ice.

PHMSA is advising operators of gas pipeline facilities, regardless of whether those facilities are regulated by PHMSA or state agencies, to consider the following steps to address the safety risks from accumulated snow and ice on pipeline facilities:

• Notify customers and other entities of the need for caution associated with excessive accumulation and removal of snow and ice. Notice should include the need to clear snow and ice from exhaust and combustion air vents for gas appliances to prevent accumulation of carbon monoxide in buildings or operational problems for the combustion equipment.
• Pay attention to snow and ice related situations that may cause operational problems for pressure control and other equipment.
• Monitor the accumulation of moisture in equipment and snow or ice blocking regulator or relief valve vents which could prevent regulators and relief valves from functioning properly.
• The piping on service regulator sets is susceptible to damage that could result in failure if caution is not exercised in cleaning snow from around the equipment. Where possible, use a broom, instead of a shovel to clear snow off regulators, meters, associated piping, propane tanks, tubing, gauges or other propane system appurtenances.
• Remind the public to contact the gas company or designated emergency response officials if there is an odor of gas present or if gas appliances are not functioning properly. Also remind the public that, if there is a gas or propane odor, occupants should leave the residence immediately and contact their gas company, propane operator or designated emergency response officials.

Misc. Changes to Administrative Procedures, Address Updates, and Technical Amendments
[Docket No. PHMSA-2007-0033]
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PHMSA has issued an interim final rule to conform their administrative procedures with the Pipeline Inspection, Protection, Enforcement, and Safety Act of 2006 (PIPES Act) by establishing the procedures PHMSA will follow in issuing safety orders and handling requests for special permits, including emergency special permits. The interim final rule also notifies operators about electronic docket information availability; makes minor amendments reflecting the recent relocation of DOT headquarters; updates several Web site addresses, telephone numbers, and routing symbols; and clarifies the time period for processing requests for written interpretations of the regulations. The interim final rule is effective April 28, 2008, and does not impose any new operating, maintenance, or other substantive requirements on pipeline owners or operators.

For a copy of the new rule, 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.

Distribution Integrity Management
Reprinted from the American Gas Association (AGA)
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The proposed rule for Distribution Integrity Management has left the Office of the Secretary of Transportation and is now with the Office of Management and Budget (OMB). The OMB review is the final approval step before the proposed rule can be issued. PHMSA told Congress in the House oversight hearing that it missed the mandated deadline for a final rule but would issue the proposed rule by June 2008. In an effort to expedite the rulemaking process, PHMSA may reduce the comment period from 90 to 60 days. AGA is working with PHMSA to produce a web-cast that will explain the elements of the rule and improve communication during the rulemaking process. AGA is also working with PHMSA to coordinate a public meeting during the rulemaking. There are still many steps in the rulemaking process, but PHMSA is attempting to expedite the process to issue a final rule by the end of 2008. Contact: Phil Bennett, pbennett@aga.org.

2008 API Pipeline Conference and Cybernetics Symposium
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Mark your calendars for the 2008 Pipeline Conference and Cybernetics Symposium at the Florida Hotel and Conference Center in Orlando, Florida on April 8 – 10, 2008. Conference registration can be made here, and hotel reservations can be made at The Florida Hotel Orlando. We hope to see you all there!

Proposed Colorado Oil and Gas Conservation Commission Rules
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The Colorado Oil and Gas Conservation Commission (COGCC) has proposed numerous revisions to their oil and gas regulations, several of which could affect pipeline operators in the state. These include:

• New definitions for Gas Gathering System; Gathering Line; and Oil and Gas Facility
• New gas facility reporting and registration requirements
• New financial assurance requirements
• A requirement to, where practicable: consolidate facilities and pipeline rights-of-way in order to minimize adverse impacts to wildlife resources
• A requirement that any operator of a COGCC-jurisdictional pipeline become a member of the Utility Notification Center of Colorado
• New pipeline construction requirements.

Has the new Gas Gathering definition affected your pipelines?

RCP can conduct a detailed analysis of your gas pipelines to determine end points of production and gathering based upon the recently finalized definition of gas gathering pipelines. The analysis will also determine whether your gathering pipelines are regulated and whether they are classified as Type A or B regulated gas gathering. For more information, click here.

TEEX Pipeline Training Facility / Emergency Responders
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The Texas Engineering Extension Service (TEEX) is world renowned for its hands-on customized training — providing training and technical assistance to more than 204,000 workers last year. This year, TEEX is building a pipeline prop at their facility which will benefit the industry in training emergency responders. It will be fully functional for training on both gas and liquid pipelines. Phase I is complete which includes 6 stand alone props and 2,300 ft. of underground pipeline. Phase II features a Chemical Complex which will tie into the pipeline prop. Once completed, this complex will enable TEEX to continue to remain the flagship for training in the pipeline emergency response field.

For more information regarding TEEX and how you can make a monetary or equipment donation to the "Chemical Complex Program" please contact: Kevin McMaughan at (979) 458-0171, or by email: james.mcmaughan@teexmail.tamu.edu.

MMS Incident and Oil Spill Reports
NTL No. 2008-G02
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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-G02 regarding new spill reporting instructions. Under 30 CFR 250.188, you must report various incidents to the MMS GOMR immediately through oral communication and provide written reports within 15 calendar days after the incident. This NTL provides information on using the eWell Permitting and Reporting System to report incidents, oil spills, and pipeline damage information, and specifies the information to be included in the various required oral and written reports.

Effective date for NTL 2008-G02 is March 31, 2008. For more information or a copy of NTL No. 2008-G02, contact Jessica Roger.

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. Please contact Jessica Roger for more information.

MMS Pollution Inspection Intervals for Unmanned Facilities
NTL No. 2008-G03
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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-G03. It clarifies current policy by specifying that some of the pollution inspections for unmanned facilities are to be accomplished by physically boarding the facility. According to 30 CFR 250.301(a), you must inspect production facilities daily or at intervals approved or prescribed by the District Manager to determine if pollution is occurring.

Effective date for NTL 2008-G03 is April 14, 2008 and supersedes NTL 2000-G11, dated May 12, 2000.

For more information or a copy of NTL No. 2008-G03, contact Jessica Roger.

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