DOT Pipeline Compliance News
August 2015 Edition

PHMSA – Expanding the Use of Excess Flow Valves in Gas Distribution Systems
[Docket No. PHMSA 2011-0009]
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On July 15, 2015 PHMSA published a Notice of Proposed Rulemaking (NPRM) concerning the use of excess flow valves (EFVs). The proposed rule will expand the requirement for installation of excess flow valves to include installation in new or replaced branched service lines servicing SFRs, multi-family residences, and small commercial entities consuming gas volumes not exceeding 1,000 Standard Cubic Feet per Hour (SCFH). The regulation also provides a means for customers to request installation of an EFV on service lines that are not being newly installed or replaced. PHMSA is proposing to delegate the decision on who is responsible for paying for these additional valves to the operator, customer and state administrators. The proposed rule would also require the installation of manual service shut-off valves in service lines where the meter capacity exceeds 1,000 SCFH.

These changes are being proposed by updating the introductory text to 49 CFR 192.381 and rewriting 192.383 for EFV Installation. The requirements concerning manual service line shut-off valve installation are located in a proposed new section 49 CFR 192.385.

The regulation defines a manual service shut-off valve as a curb valve or other manually operated valve located near the service main or a common source of supply that is accessible to first responders and operator personnel to manually shut off gas flow to the service line in the event of an emergency.

You may submit comments by September 14, 2015 via the regulations.gov website and identified by Docket number PHMSA-2011-0009.

For a copy of this NPRM contact Jessica Foley.

Pipeline Damage Prevention Programs
[Docket No. PHMSA-2009-0192; Amdt. No. 196-1; 198-7]
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On July 23, 2015, PHMSA published a final rule to allow for Federal administrative enforcement action in States with inadequate enforcement programs of excavation damage prevention requirements. The Federal requirements PHMSA will enforce in States with inadequate excavation damage prevention law enforcement programs, as well as the adjudication process for administrative enforcement proceedings against excavators where Federal authority is exercised, are contained in a new Part 196 of the pipeline safety rules in 49 CFR, which applies to excavators.

Because the new Part 196 will only apply in states that do not have an adequate damage prevention enforcement program, the rule also establishes the review criteria for State excavation damage prevention law enforcement programs, and an administrative process for making State adequacy determinations. These revisions are contained in Part 198 of 49 CFR, applicable to states.

Editor's note: Damage prevention legislation, regulation, and enforcement for excavators is currently conducted at the state level. PHMSA's damage prevention regulations historically have only applied to pipeline operators, not excavators. IMHO, PHMSA has no interest in taking over enforcement of damage prevention regulations within any state against excavators. This rule was required by Congress under the PIPES act, and is intended to encourage States to develop effective excavation damage prevention law enforcement programs to protect the public from the risk of pipeline ruptures caused by excavation damage.

This final rule is effective January 1, 2016.

For a copy of this Final Rule, contact Jessica Foley.

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, contact Jessica Foley.

Miscellaneous Corrections to the Final Rule of January 5, 2015
[Docket No. PHMSA-2011-0337; Amdt. Nos. 192-119; 193-25; 195-99]
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On August 6, PHMSA issued miscellaneous corrections to the final rule of January 5, 2015, concerning periodic updates of regulatory references to technical standards. The January document inadvertently removed paragraphs (b)(1) through (b)(4) in 49 CFR 192.153. The August 6 rule removes that amendment and makes several (very minor) editorial changes. The re-instated rule language is:

§ 192.153 Components fabricated by welding.
* * * * *
(b) * * *
(1) Regularly manufactured butt-welding fittings.
(2) Pipe that has been produced and tested under a specification listed in appendix B to this part.
(3) Partial assemblies such as split rings or collars.
(4) Prefabricated units that the manufacturer certifies have been tested to at least twice the maximum pressure to which they will be subjected under the anticipated operating conditions.

For a copy of the Miscellaneous Corrections, contact Jessica Foley.

Petitions for Reconsideration of March 11, 2015 Final Rule
[Docket No. PHMSA-2010-0026]
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On March 11, 2015, PHMSA published a final rule (80 FR 12762) addressing several subject matter areas including the performance of post-construction inspections, leak surveys of Type B onshore gas gathering lines, qualifying plastic pipe joiners, regulation of ethanol, transportation of pipe, filing of offshore pipeline condition reports, and calculation of pressure reductions for hazardous liquid pipeline anomalies.

PHMSA received three petitions for reconsideration on April 10, 2015, submitted by persons affected by the final rule: the American Gas Association (AGA), the American Public Gas Association, (APGA) and the Interstate Natural Gas Association of America (INGAA). APGA and AGA expressed concerns about the provisions of the Final Rule applicable to construction inspections. INGAA and AGA expressed concerns regarding provisions in the Final Rule applicable to components fabricated by welding. On August 6th, PHMSA announced that in accordance with 49 CFR 190.337(b), PHMSA anticipates acting on these three petitions by October 1, 2015.

FERC Issues Best Practices for Natural Gas Industry
July 2015
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The Federal Energy Regulatory Commission (FERC) Office of Energy Projects published its "Suggested Best Practices for Industry Outreach Programs to Stakeholders." The document highlights public outreach tools to effectively engage stakeholders during the process of siting, constructing, and operating interstate natural gas and LNG facilities. Topics discussed in the Best Practices include:

• Development of a stakeholder outreach program
• Initial outreach efforts
• Pre-filing process
• Updates after the application is filed
• Continued outreach following receipt of the certificate
• Ongoing public engagement

API RP1173 Assessment Services

API recently published a new Recommended Practice (RP) concerning safety management systems for pipelines. API RP 1173 provides pipeline operators with a comprehensive way to make safe operations and continuous safety improvement a constant focus of their operations. The first step for most pipeline operators will be to assess their current safety management system maturity – from nothing in place to a sustainable, improving system. RCP can assist operators in the evaluation of the maturity levels of each element of the recommended practice, and establish an action plan for further development / maturity. Contact Jessica Foley for API RP 1173 Assistance.

Pressure Test WebEx
September 15, 2015
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RCP is a leading industry expert on pressure testing and will be hosting a WebEx presentation on TestOp™, our new comprehensive pressure testing tool. TestOp™ is a proprietary web-based application that provides operators with a platform to plan, design, certify and document their pressure tests. For use on gas and liquid lines, with tests using water, nitrogen, natural gas or air, TestOp™ takes the confusion out of pressure testing by providing real-time determination of whether the test segment is experiencing pipe yielding or air entrapment during the ramp up to spike pressure while also modeling the pressure/temperature relationship of the test to determine if a leak is occurring. TestOp™ also calculates the MAOP established by the test, the reassessment interval based on federal code requirements, the test factor required based on pipe inputs, and more.

Mark your calendar and plan to attend on September 15 at 2 p.m. CST

Click here to get login information.

Hazardous Liquid Integrity Verification Process Meeting
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On August 27, 2015, from 9:00 AM EST to 4:50 PM EST, PHMSA will host a meeting about the proposed Hazardous Liquid Integrity Verification Process (HL IVP) at the Crystal City Marriott at Reagan National Airport, 1999 Jefferson Davis Highway Arlington VA 22202 [Phone 703-413-5500].

The Integrity Verification Process is to confirm the Maximum Operating Pressure (MOP) when pipeline records are not traceable, verifiable, or complete. PHMSA held a similar workshop in August 2013 on the Integrity Verification Process for gas transmission pipelines, to help address several mandates in the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 and National Transportation Safety Board recommendations. At this 1-day workshop, PHMSA will present a proposal for Integrity Verification Process for hazardous liquid pipelines, and have presentations of perspectives from pipeline operators, state regulatory partners, and the public.

Earlier draft material provided to stakeholders along with comments in response are available via the same public docket that will be used for this workshop (PHMSA-2014-0150) or the direct link: http://www.regulations.gov/#!docketDetail;D=PHMSA-2014-0150. To register or obtain additional information, visit the meeting website.

PHMSA Risk Modeling Methodologies Public Workshop
[Docket No. PHMSA–2015–0139]
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PHMSA will hold a public workshop on Wednesday, September 9, 2015, and Thursday, September 10, 2015, at the Crystal City Marriott at Reagan National Airport in the Washington DC area, to advance risk modeling methodologies of gas transmission and hazardous liquid pipelines and non-pipeline systems. This workshop will bring industry, Federal and state regulators, interested members of the public, and other stakeholders together to share knowledge and experience on risk modeling within the pipeline industry and other fields, ways to advance pipeline risk models, and practical ways that operators can adopt and/or adapt them to the analyses of their systems.

PHMSA recognizes that other industries may offer potential ideas and solutions to risk modeling that are applicable to pipelines and anticipates presentations from outside of the pipeline industry and outside of industrial applications. Use this link to register and for additional information: http://primis.phmsa.dot.gov/meetings/MtgHome.mtg?mtg=104&nocache=9447

Meeting of the Pipeline Safety Advisory Committees
[Docket No. PHMSA-2015-0173]
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The Gas Pipeline Advisory Committee (GPAC), also known as the Technical Pipeline Safety Standards Committee, and the Liquid Pipeline Advisory Committee (LPAC), also known as the Technical Hazardous Liquid Pipeline Safety Standards Committee, will meet in joint sessions on Tuesday, August 25, 2015, from 1:00 p.m. to 5:00 p.m. and on Wednesday, August 26, 2015, from 9:00 a.m. to 5:00 p.m., EST., at the Crystal City Marriott at Reagan National Airport, 1999 Jefferson Davis Highway, Arlington, VA 22202. The meetings will not be web cast; however, presentations will be available on the meeting Website and posted on the E-Gov Website: under docket number PHMSA-2015-0173 within 30 days following the meeting.

More information and a link to reserve a room is available on the meeting Website. You can also call the hotel directly at 1-703-413-5500 and ask for the "U.S. Department of Transportation Meeting" block. The agenda and any additional information will be published on the pipeline advisory committee meeting and registration page.

Late Summer / Fall Conference Schedule
August – November 2015
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Have you registered and confirmed your reservations for these upcoming conferences? RCP will be attending. We hope to see you there!

Power-Gen Natural Gas New this year!
August 18 – 20, 2015
Greater Columbus Convention Center /Columbus, OH
An annual conference and exhibition targeting gas-fired generation related to the development of natural gas reserves in the Marcellus and Utica shales of the Appalachian Basin.

Western Regional Gas Conference
August 25 & 26, 2015
Tempe Mission Palms / Tempe, AZ

Arkansas Gas Association 2015 Annual Conference
September 20 – 22, 2015
Hot Springs Convention Center, Arkansas

Pipeline Safety Trust
November 19 & 20, 2015
New Orleans, LA

Save the Dates!
RCP 2015 Workshop Schedule

Join us at our corporate office and dedicated training facility in downtown Houston. We are now offering Pressure Test Workshops in addition to our DOT gas & liquid pipeline seminars. Visit our Training Website for updates and registration information.

DOT Hazardous Liquid Pipeline Workshop
October 6, 7, 8 (Tuesday, Wednesday, Thursday)

PHMSA Incident and Annual Data Analysis

RCP can provide detailed and timely analysis of PHMSA historical incident and annual data for clients needing to compare their performance against the industry averages, respond to press inquiries, or analyze trends. Contact Jessica Foley for more information.