July 2010 Issue
In This Issue
- Notice of Proposed Rulemaking – Low Stress Rural Pipelines
- MMS NTL No. 2010-G04 Hurricane Reporting 2010
- Pending Audits?
- RCP Houston Has Moved!
- Railroad Commission of Texas – Proposed updates to Pipeline Regulations
- Railroad Commission of Texas – Proposed updates to Chapter 3 – Oil and Gas Division
- Need to Update your Response Plan (FRP, ICP or OSRP)?
- Signed Changes to Louisiana Underground Utilities and Facilities Damage Prevention Law
- SGA Operations Conference July 19-21, 2010 Houston, Texas
- LGA Annual Conference July 26-30, 2010 New Orleans
- Are you ready for a Public Awareness Plan Audit?
- WRGC Regional Gas Conference August 24 & 25, 2010 Tempe, AZ
Notice of Proposed Rulemaking – Low Stress Rural Pipelines
[Docket PHMSA-2008-0186] RIN 2137-AE36
PHMSA is proposing to amend its pipeline safety regulations to apply safety regulations to rural low-stress hazardous liquid pipelines that are not covered by safety regulations in 49 CFR Part 195. The Pipeline Inspection, Protection, Enforcement, and Safety Act of 2006 (PIPES Act), requires PHMSA to “issue regulations subjecting low-stress hazardous liquid pipelines to the same standards and regulations as other hazardous liquid pipelines.” PHMSA decided to implement the PIPES Act mandate in phases.
- Phase one, published as a final rule on June 3, 2008 (73 FR 31634) applied full Part 195 regulation to the higher-risk, larger-diameter rural low-stress pipelines (i.e., those low-stress pipelines with a diameter of 8 5/8-inches or greater located in or within one-half mile of an unusually sensitive area, or USA).
- Phase two, the subject of this proposed rulemaking, would regulate all rural low-stress pipelines not included in the phase one rule. Thus, the pipelines addressed by this proposed rule are those rural low-stress pipelines of any diameter located more than one-half mile from a USA and those less than 8 5/8 inches in diameter located within one-half mile of a USA.
This phased approach results in the following distinct groups of rural low-stress pipelines:
- Rural low-stress pipelines that cross navigable waterways. These are already subject to the safety requirements of Part 195. These pipelines are not affected by this rulemaking.
- Rural low-stress pipelines 8 5/8 inches or greater in diameter that are located in or within one-half mile of a USA. The requirements of Part 195 were made applicable to these rural pipelines in the phase one rule.
- Rural pipelines less than 8 5/8 inches in diameter that are located within one-half mile of a USA.
- Rural low-stress pipelines of any diameter that are located more than one-half mile from a USA.
To implement the compliance dates and requirements for these
different groups, we are proposing to define several “categories” of
rural low-stress pipelines. These are as follows:
Category 1: Those rural low-stress pipelines that were covered under the phase
one rule;
Category 2: Rural low-stress pipelines of smaller diameter (less than 8 5/8
inches diameter) located in or within one-half mile of a USA; and
Category 3: All other rural low-stress pipelines that were not included in
phase one.
This Notice of Proposed Rulemaking (NPRM) would retain the compliance deadlines
established in phase one for Category 1 pipelines. It would subject Category 2
pipelines to the same Part 195 requirements as those made applicable to
Category 1 pipelines in phase one but with different compliance deadlines.
PHMSA also proposes to apply all requirements of Part 195 to Category 3
pipelines except for the integrity management requirements of § 195.452.
Anyone interested in filing written comments on this NPRM must do so by August
23, 2010. PHMSA will consider late comments filed so far as practical. For
technical contents of the NPRM contact Mike Israni by phone at 202-366-4571 or
by e-mail at Mike.Israni@dot.gov.
MMS NTL No. 2010-G04 Hurricane Reporting 2010
The
Minerals Management Service (MMS) has issued NTL No. 2010-G04, Hurricane and
Tropical Storm Effects Reports, which provides guidance on using either e-mail
or the eWell Permitting and Reporting system to report hurricane and tropical
storm effects information, specifies the information included in the various
hurricane and tropical storm reports, updates contact information , and makes
minor administrative amendments.
Effective date June 1, 2010, expiration date November 30, 2010. This Notice to
Pipeline Right-of-way Holders (NTL) supersedes expired NTL no. 2009-G12.
For a copy of NTL No. 2010-G04, contact Jessica Roger.
Pending Audits?
Has the DOT notified you of a pending audit? RCP can provide confidential internal auditing to help ensure that your facilities are up to the agency’s latest standards.
Click Here.
RCP Houston Has Moved!
RCP
recently moved to our newly constructed offices located on the 2nd floor of 801
Louisiana in downtown Houston. The move to the 12,000 square foot office space
was good timing as we have grown considerably over the last few years. The
space will allow RCP to continue its upward growth and provide even more
efficient services to our clients. Our new location features a spacious and
well equipped training facility and break room capable of hosting up to 50
participants for workshops and industry meetings. This combined with its
convenient location in the heart of the theatre district, makes 801 Louisiana a
perfect new place for RCP to call home. Feel free to stop by anytime for a
visit.
Note that there have been no changes to our phone numbers or email addresses.
Railroad Commission of Texas – Proposed updates to Pipeline Regulations
The
Texas Railroad Commission (TRRC) proposes amendments to their pipeline safety
regulations in chapter 8 of Title 16. Economic Regulation, sections §§8.1, 8.5,
8.101, 8.130, 8.201, 8.235, 8.310, and 8.315, relating to General Applicability
and Standards; Definitions; Pipeline Integrity Assessment and Management Plans
for Natural Gas and Hazardous Liquids Pipelines; Enforcement; Pipeline Safety
Program Fees; Natural Gas Pipelines Public Education and Liaison; Hazardous
Liquids and Carbon Dioxide Pipelines Public Education and Liaison; and
Hazardous Liquids and Carbon Dioxide Pipelines or Pipeline Facilities Located
Within 1,000 Feet of a Public School Building or Facility. The purpose of the
amendments is to update federal provisions and citations, to correct the name
of the Safety Division to Pipeline Safety Division, and to conform the rules to
the statutory changes regarding community liaison activities enacted by House
Bill 4300, 81st Legislative Session (Regular Session, 2009).
TRRC proposes the amendments in §8.1(b) to update the minimum safety standards
and to adopt by reference the United States Department of Transportation’s
(USDOT) pipeline safety standards found in 49 CFR parts 191, 192, 193, 195, and
199. The current rule adopts the federal pipeline safety standards as of August
25, 2008; the proposed amendment will show this date as February 12, 2010. The
amendments proposed in §8.235 and §8.310 conform these rules to the revised
wording enacted in Texas Utilities Code, §121.2015(c) and (d), and in Texas
Natural Resources Code, §117.012(i) and (j) by House Bill 4300 regarding the
process by which the operators of natural gas, hazardous liquids, and carbon
dioxide pipelines conduct community liaison activities with fire, police, and
other appropriate public emergency response officials. The liaison activities
must be conducted in person, except as provided by statute. The revised
statutory language permits pipeline operators to dispense with having to make
multiple efforts to conduct face-to-face meetings; if a pipeline operator is
unable to arrange a meeting in person, the operator may conduct liaison
activities either by telephone conference call or by delivering liaison
information by certified mail, return receipt requested. The proposed amendments
in §8.235 and §8.310 mirror the statutory wording. The remaining proposed
amendments merely correct the name of the Pipeline Safety Division.
Comments on the proposal may be submitted to Rules Coordinator, Office of
General Counsel, Railroad Commission of Texas, PO Box 12967, Austin, Texas
78711-2967; online; or by electronic
mail.
TRRC will accept comments until noon (12:00 p.m.) on Monday, July 26, 2010,
which is 31 days after publication in the Texas Register; comments should refer
to GUD No. 9989. For further information, call Ms. Mary McDaniel, P.E.,
Director, Pipeline Safety Division at (512) 463-7166. The status of TRRC
rulemakings in progress is available at www.rrc.state.tx.us/rules/proposed.php.
For a copy of the proposed updates to TRRC’s Chapter 8 Pipeline Regulations,
contact Jessica Roger.
Railroad Commission of Texas – Proposed updates to Chapter 3 – Oil and Gas Division
The
Texas Railroad Commission (TRRC) proposes the repeal of §3.15 relating to
Surface Casing to be Left in Place, as part of a concurrent rulemaking
proceeding to implement House Bill 2259, 81st Legislative Session (Regular
Session, 2009), which becomes effective September 1, 2010. HB 2259 amended the
Texas Natural Resources code to establish requirements for disconnecting
electrical service, purging fluids from tanks, lines, and vessels, and removing
surface equipment from inactive land wells. HB 2259 also amended the Texas
Natural Resources Code to establish requirements for all operators to annually
address their inventory of inactive wells to obtain approval of their yearly
organization report.
In a separate, concurrent rulemaking, TRRC is proposing new §3.15, to be
entitled Surface Equipment Removal Requirements and Inactive Wells, as well as
some amendments to §3.1, 3.14, 3.21, and 3.78, relating to Organization Report;
Retention of Records; Notice Requirements; Plugging; Fire Prevention and
Swabbing; and Fees and Financial Security Requirements, to address HB 2259.
Comments on the proposal may be submitted to Rules Coordinator, Office of
General Counsel, Railroad Commission of Texas, PO Box 12967, Austin, Texas
78711-2967; online; or by electronic
mail.
TRRC will accept comments until noon (12:00 p.m.) on Monday, July 26, 2010,
which is 31 days after publication in the Texas Register; comments should refer
to O&G Docket No. 20-0265910. For further information, call Mark Helmueller
at (512) 463-6802. The status of TRRC rulemakings in progress is available at www.rrc.state.tx.us/rules/proposed.php. For a
copy of the proposed updates to Chapter 3 – Oil and Gas Division, 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.
Signed Changes to Louisiana Underground Utilities and Facilities Damage Prevention Law
House Bill 396 Act No. 249 was signed by Governor Jindell on June 17, 2010. These changes become effective on September 1, 2010. The following is a summary of the changes:
- The definition of “excavation or excavate” was extended to exclude normal probing.
- A definition for “Forestry excavation” was added to mean an excavator who is a logger, prescribed burner, site preparation operator, or tree planter for commercial forestry operations.
- Allows for electronic notice of intent to excavate or demolish be given instead of telephonic notice. A record of this notice is required to also be retained by the regional notification center for 3 years from the date of notification.
- No longer excludes cable television from becoming a member of, participating in and sharing the cost of a regional notification center.
- The regional notification center must have the capability to receive emergency locate requests 24 hours a day and to disseminate the information as soon as it is received to the appropriate operators and all affected regional notification centers in the state.
- Requires all member operators to furnish the regional notification center with current emergency contact or notification information including 24 hour telephone numbers.
- Markings performed at the request of a forestry excavator are deemed good as long as the markings are visible or up to 30 calendar days from the time the markings were made, whichever is shorter.
SGA Operations Conference July 19-21, 2010 Houston, Texas
Meet us at the 2010 SGA Operating Conference & Exhibit at the Hyatt Regency in Houston, Texas. RCP representatives will be attending the conference and look forward to meeting you. If you have not seen a demo of our one-call and leak tracking system, please stop by RCP’s exhibit at Booth 205 in the Exhibit Hall. Click here for conference registration information, the preliminary agenda, and an-online interactive search tool of exhibits to plan your day at the conference.
LGA Annual Conference July 26-30, 2010 New Orleans
RCP is proud to be a sponsor of the annual Louisiana Gas Association (LGA) 191/192 & 195 Pipeline Safety Conference & Tradeshow. The conference will be held at the Royal Sonesta Hotel in New Orleans, Louisiana. RCP representatives will also be attending the conference and look forward to meeting you. Make plans to stop by RCP’s exhibit. Click here for registration information and the preliminary agenda.
Are you ready for a Public Awareness Plan Audit?
A
recent NTSB accident investigation determined that an operator’s oversight and
evaluation of the effectiveness of the public education program, and the
performance of the public awareness contractor, were inadequate. The NTSB
recommended that PHMSA exercise their right to review the operators’ evaluation
process to determine the effectiveness of the public awareness plans developed.
Will your plan stand up to a PHMSA audit?
Also, if you wrote your Public Awareness Plan 5 years ago, you may be due for a
review. RCP can assist you by reviewing your plan and conducting an
effectiveness evaluation. Contact Jessica
Roger for more information.
WRGC Regional Gas Conference August 24 & 25, 2010 Tempe, AZ
Join us at the 2010 Western Regional Gas Conference at the Tempe Mission Palms Hotel & Conference Center in Tempe, Arizona. RCP representatives will be attending the conference and look forward to meeting you. Chris Foley (RCP Vice President) will be giving a presentation on “Conducting Effective Internal Pipeline Safety Audits” on Tuesday, August 24. Click here to check for updates on the conference agenda and registration. (WRGC is a non-profit and volunteer-organized event to provide a venue for discussion of natural gas distribution and transmission issues.)
W. R. (Bill) Byrd, PE
President
RCP Inc.