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DOT PIPELINE COMPLIANCE NEWS

MARCH 2022 ISSUE

IN THIS ISSUE

 1. PHMSA’s Webinar on Natural Gas Emission Reduction & Leak-Prone Pipe
 2. Final Rulemaking submitted to OMB
 3. Did you know?
 4. NAPSR Updates State Compendium
 5. The Enforcement Corner
 6. 2022 Conference News
 7. DOT Pipeline Compliance Workshops (In Person)
 8. Client Feedback
 9. Pipeline Safety Institute

--------------------------------------------------------------------------------


PHMSA’S WEBINAR ON NATURAL GAS EMISSION REDUCTION & LEAK-PRONE PIPE


[DOCKET NO. PHMSA-2021-0123]

PHMSA held a public meeting February 17th on their plans for 2022 and the
questions they have developed to assess operator plans for reducing or
mitigating methane emissions. PHMSA reviewed the requirements of Section 114 and
plans for PHMSA and state inspection of the requirements. A recording of the
session is posted on PHMSA’s meeting website. Following opening remarks, the
webinar addressed the following topics:

 1. Key elements of Section 114;
 2. Significant sources of natural gas (primarily methane) emissions from
    pipelines;
 3. Discussion of which types of pipeline facilities must comply with each
    portion of Section 114;
 4. PHMSA and state inspections, including reviews of a pipeline operator’s
    programs and procedures to reduce methane emissions;
 5. Inspection topics related to methane reduction and leak-prone pipes;
 6. General review of how operators’ programs and procedures will be inspected;
    and,
 7. The timelines for actions required by Section 114.

--------------------------------------------------------------------------------


FINAL RULEMAKING SUBMITTED TO OMB

The final rule “Pipeline Safety: Safety of Gas Transmission Pipelines, Repair
Criteria, Integrity Management Improvements, Cathodic Protection, Management of
Change, and Other Related Amendments” (otherwise known as RIN2) has been
transmitted to the federal Office of Management and Budget for review.  This
review can take up to 90 days to complete, but it does not always require that
much time.  The DOT’s significant rulemaking website lists May 11, 2022 when
they expect to publish the final rule in the federal register.

--------------------------------------------------------------------------------


DID YOU KNOW?

Thanks to the trusted domestic natural gas delivery system and continuous
technological innovations in natural gas furnaces and boilers, natural gas is an
incredibly efficient way for Americans to heat their homes and businesses. For
more information, click here.





--------------------------------------------------------------------------------


NAPSR UPDATES STATE COMPENDIUM

The National Association of Pipeline Safety Representatives (NAPSR) has released
their Compendium 2022. The Compendium highlights areas where actions have been
taken at the state level that go beyond federal pipeline safety regulatory
requirements. Click here to see the Compendium 2022.

--------------------------------------------------------------------------------


THE ENFORCEMENT CORNER

The Enforcement Corner summarizes recent PHMSA enforcement actions, indicating
where PHMSA is putting its enforcement efforts and the fines they are proposing
for various types of violations.

In January 2022, PHMSA issued 6 WLs, 9 NOAs, and 7 NOPVs accompanied by $900,200
in proposed fines. Significant proposed fines were attributed to the following
code sections:

 * $70,500 – 49 CFR 192.481(b) – Atmospheric Corrosion Control: Monitoring
 * $99,000 – 49 CFR 192.605(a) – Procedure Manuals
 * $31,700 – 49 CFR 192.745(a) – Valve Maintenance: Transmission Lines
 * $22,400 – 49 CFR 195.446(c)(2) – Control Room Management: Verifications
 * $32,800 – 49 CFR 195.446(g)(1)(vi) – Control Room Management: SCADA Systems
 * $75,600 – 49 CFR 195.412(a) – ROW Inspections of Crossings & Navigable Waters
 * $81,500 – 49 CFR 195.420(b) – Valve Maintenance
 * $38,000 – 49 CFR 192.619(a)(1)(ii) – MAOP
 * $28,300 – 49 CFR 192.705(c) – Transmission Lines: Patrolling
 * $45,200 – 49 CFR 192.706 – Transmission Lines: Leakage Surveys
 * $138,100 – 49 CFR 192.706(a) – Transmission Lines: Leakage Surveys
 * $195,700 – 49 CFR 192.947(d) – Recordkeeping: P&M Measure Process
 * $41,400 – 49 CFR 192.605(b)(2) – Procedure Manuals

Please note:

 1. Pipeline operators may disagree in whole or in part with each proposed
    violation cited by PHMSA. 
 2. Proposed Civil Penalties (PCP) may be reduced or eliminated before an
    enforcement action becomes final.
 3. A Corrective Action Order (CAO) usually addresses urgent situations arising
    out of an accident, spill, or other significant, immediate, or imminent
    safety or environmental concern.
 4. A Notice of Amendment (NOA) is frequently a result of a difference of
    opinion regarding written procedure requirements.
 5. A Notice of Proposed Safety Order (NOPSO) addresses pipeline integrity risks
    that may not constitute a hazardous facility requiring immediate corrective
    action (see Corrective Action Order described above),but do need to be
    addressed over time.
 6. A Notice of Probable Violation (NOPV) is not proof that a violation actually
    occurred.
 7. A Proposed Compliance Order (PCO) frequently documents actions the pipeline
    operator already planned to do.
 8. Warning Letter (WL) is an official notice by PHMSA that an operator needs to
    make improvements but that no further enforcement is proposed for those
    findings at this time.

RCP maintains a detailed database of all PHMSA enforcement actions dating back
to 2007 and is routinely asked for data analysis of various enforcement actions.
For more information on how RCP can assist with enforcement action data analysis
services, contact Jessica Foley.

Need to respond to a PHMSA enforcement action?
Need to know if your enforcement action is an outlier, or par for the course? 
RCP maintains a detailed database of all PHMSA enforcement actions and their
resolution which enables us to compare and contrast individual enforcement
actions to nationwide actions and trends.  We can help put things into context
to ensure an effective reply for each citation.  For more information on how RCP
can assist with enforcement action data analysis services, contact Jessica
Foley.

--------------------------------------------------------------------------------


2022 CONFERENCE NEWS

AGA Operations Conference
May 2-6, 2022 | Hilton New Orleans Riverside

The annual AGA Operations Conference will be an in-person event in New Orleans.
The 2022 Conference is a Non-Exhibit year. The Operations Conference is AGA’s
largest forum with more than 900 operations management regularly in attendance,
including over 100 speakers; and 120 technical presentations that run the gamut
of topics such as gas measurement, operations advocacy, safety, environment,
storage, engineering, construction and maintenance, gas control, supplemental
gas, corrosion control, and piping materials. AGA’s Spring Committee Meetings
(May 2-3) will meet in conjunction with the Operations Conference, May 3-6.


API Pipeline, Control Room and Cybernetics Conference
May 3-5, 2022 | Savannah Convention Center and Westin Hotel

2022 API Pipeline, Control Room and Cybernetics Conference will be an in-person
event in Savannah, Georgia. Check the API website for more information and
registration details.


SGA Natural Gas Connect
June 12-15 | St. Louis, Missouri

Save the dates for SGA’s 2022 Natural Gas Connect! Who should attend: Natural
gas industry employees involved in operations, safety & health, marketing, sales
and communications. More information will be posted on SGA’s conference webpage.


APGA Annual Operations Conference
July 17-20 | Minneapolis, MN

The APGA Annual Conference will take place at the Minneapolis Marriott City
Center in Minneapolis. Registration is now open and the room block is also open
for attendees to book their hotel rooms.


LGA Pipeline Safety Conference
July 18-21 | Hilton Riverside New Orleans

The Louisiana Gas Association (LGA) Pipeline Safety Conference continues to
cover 49 CFR Parts 191, 192, 195 & 199, and this year they are expanding their
agenda to include Part 193 and underground natural gas storage.  Also new this
year, LGA announced that they will be concurrently hosting the Louisiana Oil &
Gas Regulatory Conference (previously known as the SONRIS Conference). At this
conference, stakeholders will learn the ins & outs of LDNR’s SONRIS program and
other important updates from the Office of Conservation. The conference will be
held July 19-21, 2022 in conjunction with the Pipeline Safety Conference. Be on
the lookout for an agenda soon.

--------------------------------------------------------------------------------


DOT PIPELINE COMPLIANCE WORKSHOPS (IN PERSON)

The wait is over! We are excited to welcome all you really cool people back to
our dedicated training facility at our corporate headquarters in Houston, Texas
for an in-person gas & liquid 3-day workshop on May 10-12, 2022. We will be
following all CDC guidelines.

Topics to be addressed in the workshop include:

 * An overview of DOT/OPS pipeline compliance requirements
 * State and Federal agency roles for pipeline safety
 * PHMSA Jurisdiction
 * PHMSA Inspections and Enforcement Processes
 * Engineering Concepts and Stress/Strain Relationships; %SMYS
 * Design Requirements
 * Construction Requirements
 * Corrosion Control Concepts and Requirements
 * Operations and Maintenance Requirements
 * Emergency Response Requirements (including spill response planning
   requirements for liquid pipelines)
 * Damage Prevention Programs
 * Operator Qualification Programs
 * Drug and Alcohol Programs
 * Public Awareness Programs
 * Integrity Management (gas and liquid) Programs
 * Control Room Management Programs

We will also discuss the PIPES Act of 2021; recent Advisory Bulletins from
PHMSA; and new, pending and proposed rulemakings.

Each attendee will receive an electronic copy of the presentation as well as
applicable handouts, and applicable regulations and voluminous reference
materials including rulemakings, letters of interpretation, and other guidance
documents.

To register for either workshop, click here.

--------------------------------------------------------------------------------


CLIENT FEEDBACK

RCP has a tradition of creating and sustaining trusted partnerships with the
companies we serve. This has translated into long-term relationships that are
based not only on the quality and scope of the work we provide, but also on the
manner in which we provide it. We routinely hear from our clients with positive
feedback like this quote below:

“I just wanted to take a moment and give credit where credit is due. Your staff
has done an exceptional job in providing training and support for us the past
few years, and most recently today and this evening. [RCP] helped our Southern
Arizona Division with reviewing and assisting with a Hydrotest that went on
until late [your] time. I’m very impressed with your service and system. Greatly
appreciated!”  – Southwest Gas

--------------------------------------------------------------------------------


PIPELINE SAFETY INSTITUTE

Welcome to the Pipeline Safety Institute – your one-stop destination for
pipeline compliance training. Whether you are new to the industry, an
experienced oil & gas professional that needs a refresher, or you want to take a
deep dive into the latest regulation changes, you have come to the right place.

Training topics cover pipeline operations and engineering concepts, with future
course offerings for Integrity Management programs, including ILI, material
testing, fitting and component selection, and qualifying welders. Our curriculum
continues to grow to meet the changes and challenges in the energy industry.

The Pipeline Safety Institute has a team of experienced instructors and subject
matter experts from all disciplines. With over 25 years of training experience,
we are committed to providing the best pipeline safety training in the industry.
Click Here to see PSI’s available courses.

We would welcome the opportunity to discuss our services with you.

Sincerely,


W. R. (Bill) Byrd, PE
President
RCP Inc.







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RCP Inc.
801 Louisiana Street, Suite 200
Houston, TX 77002

(713) 655-8080

info@rcp.com


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 * Home
 * Who We Are
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   * Careers
 * What We Do
   * Compliance Programs
     * Operations & Maintenance
     * Control Room Management
     * Facility Response Plans and Integrated Contingency Plans
     * Operator Qualifications
     * Integrity Management Plans
     * Public Awareness
     * Damage Prevention Program
     * Underwater Inspection Procedures
     * PSM/Risk Management Plan
     * Spill Prevention Countermeasures & Control
   * Consulting Services
     * Jurisdictional Determination
     * Acquisition Due Diligence
     * Expert Witness
     * Pipeline Safety Management System
     * Audits
     * Agency Response Support
     * Training
   * Engineering Services
     * MAOP Reconfirmation
     * Pressure Test Services
     * Leak Detection Capabilities Evaluation
     * Emergency Flow Restriction Device Analysis
     * Relief Valve Capacity Evaluation
     * Uprate Studies
     * Conversion of Service Plans
     * Defect Analysis and Repair Plan
     * Root Cause Failure Analysis
     * Engineering Specifications
   * Integrity Management
     * Risk Management
     * ILI Program Management
     * ILI Data Analysis
     * IM Auditing & Compliance Verification
     * IMP Program Development & Maintenance
     * Program Development & Maintenance
     * HCA Analysis
     * Air Dispersion Modeling
     * Class Location
     * Spill Modeling
     * GIS and Mapping Services
     * Threat Analysis
     * Underground Gas Storage
     * Ongoing Integrity Management Support Services
 * Newsletter
   * Current Newsletter
   * Search Newsletter
   * Subscribe
 * Tools
   * Pressure Test Certification
   * MAOP Reconfirmation
   * Pipeline Incident Data
   * Asset Management Tracking System
 * TaskOp
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   * Pressure Test Validation
   * All Features
   * Request Free Trial
   * Preferred Contractors
   * Pressure Test Training Course
   * Free Webinars
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   * TestOp – FAQ
 * Methane
   * MethOp
   * Request Demo
 * Training
   * Mega-Rule #1: Gas Transmission Regulation Deep Dive Workshop
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   * Fundamentals of Transmission Pipeline Operations Workshop
   * On-Site Customized Training
   * Calendar of Events
 * Contact Us