DOT Pipeline Compliance News
March 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.

PHMSA Appointments
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Alan Mayberry has been named the new Director of the Office of Engineering and Emergency Support. Alan has over 26 years of experience in the industry and has worked as a member of senior staff of OPS for two years.

Steve Fischer is replacing Jeff Weiss as the Director of Program Development. Steve has been with Program Development for the past ten years, and is currently PHMSA’s lead for a joint industry-government project team researching new technologies for ROW surveillance.

PHMSA Advisory Bulletin – Identifying Issues with Mechanical Couplings that Could Lead to Failure
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The Department of Transportation Pipeline and Hazardous Materials Safety Administration (DOT / PHMSA) issued an update to information provided in Advisory Bulletin ADB–86–02 advising owners and operators of gas pipelines to consider the potential failure modes for mechanical couplings used for joining and pressure sealing two pipes together. Failures can occur when there is inadequate restraint for the potential stresses on the two pipes, when the couplings are incorrectly installed or supported, or when the coupling components such as elastomers degrade over time. In addition, inadequate leak surveys which fail to identify leaks requiring immediate repair can lead to more serious incidents. PHMSA advises operators of gas distribution pipelines using mechanical couplings to do the following to ensure compliance with 49 CFR 192:

• Review procedures for using mechanical couplings, including the coupling design and installation and ensure that they meet manufacturer's recommendations;
• Review leak survey procedures to ensure that leak surveys are properly conducted, taking into account other contributing factors (i.e., weather conditions, calibration); and,
• Review personnel qualifications to ensure they address leak surveys sufficiently.

• Use Category 1 fittings only if mechanical couplings are used on pipe sizes 1/2' CTS (Copper Tube Size) to 2' IPS (Iron Pipe Size). Per ASTM D2513-99 titled "Standard Specification for Thermoplastic Gas Pressure Pipe, Tubing and Fittings," Category 1 is a mechanical joint design that provides a seal plus a resistance to a force on the pipe end equal to or greater than that which will cause a permanent deformation of the pipe. At this time there is insufficient data to indicate there are issues involving fittings for larger diameter pipe. PHMSA will revisit if such issues do arise with larger diameter pipe.
• Improve recordkeeping on specific couplings that exist, i.e., their type, installation date, maintenance schedule, and any failures encountered, to help identify a trend of problems that may occur with a specific coupling or type of installation.
• Consider whether to adopt a full replacement program if there are too many unknowns related to couplings in service.
• Work with Federal and State pipeline safety representatives, manufacturers, and industry partners to determine how best to resolve potential issues in their respective state or region.

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.

OCS Pipeline Proposed Rule - Reopening Public Comment Period
Docket ID MMS-2007-OMM-0059; RIN 1010-AD11
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The Minerals Management Service (MMS) in the Department of Interior is reopening the comment period for proposed rule AD-11, pipelines and pipeline rights-of-way published on October 3, 2007 (72 FR 56442). That proposed rule requested comments on the revisions to Outer Continental Shelf pipeline and pipeline rights-of-way regulations. Industry has requested more time to review the proposal and submit comments. Commenters have specifically pointed to the comprehensive nature of the rule and the potential for jurisdictional conflicts between MMS and the Department of Transportation regulations as the reason for requesting additional time. The MMS has agreed to reopen the comment period to March 17, 2008. The MMS may not fully consider comments received after this date.

The MMS also held a public meeting to discuss the proposed rule in the MMS Gulf of Mexico Regional Office on February 22, 2008. MMS officials provided an overview of the proposed regulations and then turned the meeting over for comments. Members of the API Offshore Operating Committee and INGAA provided comments relating to the proposal. Several concerns addressed proposed reporting requirements, integrity management technologies and challenges, potential overlaps between PHMSA and MMS regulations, and cost basis for implementation of the proposed regulations. For a copy of the proposed regulations, please contact Jessica Roger.

Excavation Damage Prevention Resolution Passed by NARUC
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A resolution addressing excavation damage prevention was adopted by state utility regulators according to the American Gas Association (AGA).

The resolution was adopted by the National Association of Regulatory Utility Commissioners (NARUC). The resolution calls for the incorporation of nine elements into state pipeline safety regulations and/or laws. Thru the Excavation Damage Prevention Initiative, stakeholders produced “Guide to the 9 Elements.” This would provide guidance to stakeholders, state legislatures, and state commissions working to incorporate the nine elements into their states existing damage prevention programs. This guide will serve as the baseline for improving current programs.

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.

TRRC Study on Compression Type Couplings
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The Texas Railroad Commission (TRRC), Safety Division, initiated a study into the use of compression couplings in natural gas distribution systems as a result of three incidents involving mechanical type compression couplings. In addition to the recent incidents in Texas, there is history within other states of significant incidents related to coupling failures.

While the leading cause of incidents in Texas is third party damage (77%), these recent incidents involving compression couplings has raised the level of concern. Each of the incidents involved different type couplings and different operational characteristics, yet they all involved compression type couplings that were installed more than twenty years ago. Of specific concern is the continued safe operation of natural gas distribution systems that contain compression type couplings. While there have been improvements in materials and manufacturing methods over the years, the basic design concept has not changed. The applicable sections that cover the installation of mechanical type couplings are found in 49 CFR Part 192, with specific sections §§192.161 (e), 192.281, 192.283, 192.285, and 192.287.

In researching the use of compression couplings across the U.S., two prevailing types of failures of compression couplings were identified: pullout of pipe from a compression coupling, and leakage through the sealing surface between the coupling and the pipe. It also may be important to consider other contributing factors can lead to incidents. With the requirement for distribution integrity management (DIMP) expected within this calendar year, it is important to review the operating history of distribution pipelines. PHMSA is looking at how DIMP can help to identify leading and lagging indicators, and what actions PHMSA and the States can take to help assure DIMP effectiveness. No previous or present PHMSA Research and Development is directly addressing the coupling issue. The Safety Division staff has been in contact with the NTSB during the course of the study. PHMSA and NTSB have also met to discuss this issue.

On October 9, 2007, TRRC adopted the first directive as a result of this study. The directive required all operators that find compression couplings leaking to replace the coupling or repair the coupling by welding over a protective sleeve. TRRC is working on a rule proposal to require all pipeline operators to report all repaired leaks on their pipeline system. The report will include information on the type of leak, the cause of the leak, and the leak repair method.

In November 2007, TRRC approved a rulemaking to address two of three recommendations, and adopted the third as a directive:

• The first recommendation is for each operator to create a risk based model for scheduling and conducting leak surveys of their pipeline system based on established risk factors. The leak survey model suggested as part of this rule will go in hand with the DIMP rules being developed by the federal Office of Pipeline Safety.
• The second recommendation was a leak grading and repair proposal. This second proposal provides a consistent application of what a “graded” leak is in Texas.
• The third recommendation involves the replacement of certain compression couplings.

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.

TRRC Pipeline Eminent Domain and Condemnation
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Several questions and answers were posted on the Texas Railroad Commission website to provide general information about pipeline companies in Texas and their powers of eminent domain. To view a complete list of questions and answers, go to: http://www.rrc.state.tx.us/eminentdomain.html.

Q: Does the RRC have to approve the route of a proposed pipeline?
A: Generally, no. The Commission does not have the authority to decide the route a pipeline takes. The exception to this is when the pipeline contains “sour gas” (hydrogen sulfide) because of its toxicity at certain levels.

Q: How close can a pipeline come to my house or other permanent structure?
A: There are no minimum setback requirements concerning natural gas pipelines and structures. However, a hazardous liquids pipeline must be buried an extra 12 inches in addition the 36 inches/3 feet depth that pipelines must be buried at when installed, if the hazardous pipeline is within 50 feet of a permanent structure. Examples of hazardous liquid pipelines are any pipelines other than natural gas pipelines.

Q: Do all pipeline operators have the power of eminent domain?
A: Generally speaking, common carrier pipelines in Texas have a statutory right of eminent domain. Common carrier pipelines are operators that transport oil, oil products, gas, carbon dioxide, salt brine, sand, clay, liquefied minerals or other mineral solutions.

For example, a pipeline transporting hazardous liquids would be a common carrier, and would have the right of eminent domain. A ‘common carrier’ pipeline transporting natural gas would be a ‘public utility’ (more commonly referred to as a ‘gas utility’), and also would have the power of eminent domain. The Railroad Commission does not have the authority to regulate any pipelines with respect to the exercise of their eminent domain powers.

Q: How can I tell if the company that wants to cross my land has the power of eminent domain?
A: The Railroad Commission can inform you as to the status of a pipeline as either a gas utility or a common carrier, both of which have a statutory right of eminent domain. For information on natural gas pipelines, call the Railroad Commission’s Utility Audit Section at (512) 463-7022. For information on other pipelines, call the License & Permit Section at (512) 463-7167.

Q: If my property has been condemned for a pipeline easement, does the RRC want to be notified?
A: Yes. If your land has been condemned for a pipeline easement, the Commission would like to be informed, since there is no requirement for the operators to notify the Commission. This will help ensure that the operator is properly classified as either a gas utility or a common carrier, depending upon the commodity being transported. Please notify the Utility Audit Section at (512) 463-7022.

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!

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