DOT Pipeline Compliance News
April 2017 Edition

Underground Gas Storage User Fees
[Docket No. PHMSA-2016-0092]
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PHMSA issued a notice to Underground Gas Storage operators on how it plans to assess annual user fees.  PHMSA will use working-gas capacity as the basis for the user-fee rate structure. PHMSA will use the working-gas capacity values from the most recent Form EIA-191 Monthly Underground Natural Gas Storage Report. PHMSA will sum the working-gas capacity for all fields operated by the holder of a PHMSA-issued operator identification number.  The operator working-gas capacity values will be divided into 10 tiers. The lowest values will be in tier 1 and the highest values in tier 10. The minimum and maximum working-gas capacities for each tier will be selected to place an equal number of operators in each tier. Each tier will have a user-fee assessment to be paid by each operator in the tier.  The tiers and assessment per tier to collect $8,000,000 would be:

Tier	Assessment per Operator	Working-Gas Capacity (Mcf) Range
1	$11,799	Less than 930,000.
2	23,599	More than 930,000 and less than 3,000,000.
3	29,499	More than 3,000,000 and less than 5,800,000.
4	35,398	More than 5,800,000 and less than 11,000,000.
5	47,198	11,000,000 or more and less than 13,700,000.
6	58,997	More than 13,700,000 and less than 21,000,000.
7	70,796	More than 21,000,000 and less than 32,100,000.
8	76,696	More than 32,100,000 and less than 48,000,000.
9	88,496	More than 47,000,000 and less than 91,500,000.
10	147,493	More than 91,500,000.

PHMSA placed a spreadsheet in the docket showing the EIA company names in each tier, as well as the methodology used to determine the assessment per tier and tier ranges.

For more information or to get a copy of this notice, contact Jessica Foley.

Underground Gas Storage Compliance

How does RCP deliver a comprehensive solution for natural gas storage operational integrity assurance?

Experienced Resources

• Highly respected underground storage & risk management SME's (ex. Rick Gentges)
• Professional engineering support
• Knowledgeable technical standards developers

• Program gap assessment and corrective action tracking (TaskOp)
• Written program development / improvement
• Storage risk assessment (TaskOp)
• Integrity assessment and remediation process tracking (TaskOp)

Comments Filed: Proposed Safety of Gas Transmission and Gathering Pipelines
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Three industry associations have filed joint comments to PHMSA regarding the proposed rulemaking for the Safety of Gas Transmission and Gathering Pipelines. AGA, API and INGAA filed comments, including proposed redlines for the topics that were covered at the first Gas Pipeline Advisory Committee meeting. These topics include:

• Transmission Integrity Management reassessment intervals
• Continuing surveillance after weather events
• Management of change
• Corrosion preventative and mitigative measures
• Integrity management clarifications

Construction of Pipelines Using Domestic Steel
[Docket No. 170309252-7252-01]
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The Department of Commerce (DOC) is seeking information on the construction and maintenance of American pipelines. This information will help the Department develop a plan for the domestic sourcing of materials for the construction, retrofitting, repair, and expansion of pipelines inside the U.S. as directed by the January 24, 2017 Presidential Memorandum regarding "Construction of American Pipelines" (Presidential Memorandum). The Secretary of Commerce, in consultation with relevant agencies, is required to deliver this plan to the President by July 23, 2017. In response to this directive, the DOC is conducting industry outreach to better understand:

• Current pipeline construction technology and requirements;
• Potential advances in pipeline technology;
• Domestic and foreign supply chain for pipeline materials; and,
• All other information respondents consider pertinent to the development of the domestic sourcing plan.

PHMSA Deactivation of Threats Advisory Bulletin (ADB-2017-01)
Docket No. PHMSA-2016-0131
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PHMSA has issued an advisory bulletin ADB-2017-01 to inform owners and operators of gas transmission pipelines that PHMSA has issued guidance on threat identification and the minimum criteria for deactivation of threats as well as guidance regarding documenting rationale of analyses, justifications, determinations, and decisions related to threat identification.

According to ASME B31.8S–2004, Section 2.2, an operator must consider nine individual threat categories as part of an IM program. As stated by ASME B31.8S–2004, Section 5.10, an IM program should provide criteria for eliminating a threat from consideration during a risk assessment; however, 49 CFR part 192—Subpart O does not include provisions for the permanent elimination of threats. An operator, therefore, must continually consider all threats in the evaluation of their IM program through periodic reviews and assessments, as required by section 192.937.

Some operators inappropriately label threats as inactive after they are eliminated from consideration during prior reviews and assessments, ignoring the continuous supply of new information provided during routine O&M activities. Others have opted to eliminate threats from consideration based on a lack of data, including missing, incomplete, or unsubstantiated data. Using insufficient data to eliminate a threat is not technically justified and is contrary to the guidance in ASME B31.8S–2004, Appendices A1–A9.

PHMSA acknowledges that the threats identified in ASME B31.8S–2004 may be considered active or inactive, but are never permanently eliminated. ASME B31.8S–2004, Appendix A, identifies the information an operator must collect and analyze for threats, which must demonstrate an individual threat is not acting on the pipe before an operator can properly declare the threat inactive for each assessment period. A threat must be considered active if any data required by Appendix A is missing, as lack of data indicating the existence of a threat is not an acceptable justification for considering the threat inactive.

Documents to support the determination of an inactive threat status must be maintained, as per the requirements of § 192.947(d). An operator does not need to assess a threat for the current assessment cycle if that threat is properly deemed inactive. When conditions warrant a review or new information becomes available during the required § 192.937 evaluation, operators are required to examine each applicable threat to determine it is active or inactive.

The advisory bulletin gives detailed guidance for each of the nine threat categories to help operators determine the active or inactive status. The advisory states that 4 of the 9 threats may be considered inactive if the facts warrant:  internal corrosion; manufacturing; construction; and equipment threats. The remaining 5 threats (i.e., external corrosion; stress corrosion cracking; third party damage; incorrect operations; and weather related and outside forces), must always be considered active.

For a copy of ADB-2017-01 Deactivation of Threats, contact Jessica Foley .

PHMSA Advisory Bulletin: Guidance on Training and Qualifications for the Integrity Management Program (ADB-2017-02)
[Docket No. PHMSA-2016-0067]
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PHMSA issued a new Advisory Bulletin (ADB-2017-02) for operators of natural gas transmission pipelines, outlining their expectations for qualifications of personnel who perform or supervise integrity management activities. PHMSA inspectors will use this Advisory Bulletin to clarify the intent of existing regulatory language when evaluating operator IM program personnel training and qualification effectiveness. Specifically, PHMSA advises that operators have the necessary qualifications and training for those personnel that:

• Have a role in executing the integrity management program,
• Have supervisory authority over integrity management activities, and
• Carry out integrity assessments and evaluate assessment results.
• Implement preventative and mitigative activities.

• Performing the integrity assessment;
• Evaluating the results of the integrity assessment;
• Integrating any other available information or data gathered in accordance with §192.917(b) that is applicable to the covered segment being assessed; and
• Deciding on actions to be taken based on these assessments.

Fundamentals of Pipeline Operations Workshop
May 17-18, 2017
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Join us May 17-18, 2017 in Houston at our corporate office and dedicated training facility for this new workshop on the fundamentals of pipeline operations. This 2-day course is designed to give a comprehensive overview of gas and liquid energy transmission pipelines and how they are operated and maintained.  It is appropriate for both technical and non-technical personnel who are new to the energy transmission pipeline industry, as well as those who need a broader understanding of pipeline operations and management in general.  The course walks through the practical things that a typical pipeline company’s operations organization does on a regular basis to operate and maintain the pipeline system as a whole.  Course topics include:

• Components of a pipeline system (types of pipe, coatings, tanks, valves, pumps, compressors, pressure vessels, pig traps, meters, instrumentation, control systems / SCADA)
• Operations activities (starting / stopping, batching, managing receipts and deliveries, measurement, monitoring, pressure control, leak detection)
• Inspection and Maintenance (valves, ROWs, tanks, pumps, compressors, instrumentation, pigging, cathodic protection)
• Repair (in-service repair techniques, welding, OOS repairs / replacements)
• Integrity Management (ILI, Pressure Tests, Direct Assessment), including assessment processes, analysis, follow-ups
• Emergency Response (planning, organization/ ICS, drills, response)
• Public Awareness / Damage Prevention / One Calls

April is National Safe Digging Month
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The Common Ground Alliance (CGA) is a member-driven association of individuals, organizations and sponsors in every facet of the underground utility industry. CGA is committed to saving lives and preventing damage to underground infrastructure by promoting effective damage prevention practices. Damage prevention starts with one phone call, and since 2007 the phone number for that call has been 811. CGA has created several easy-to-use tools to help promote National Safe Digging Month (NSDM) and dialing 811. Visit the 811 Toolkit page on CGA's website to download a suite of NSDM media materials, social media messages and infographics, advertising materials and more.

2017 Pipeline Conference Schedule
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Have you registered and confirmed your reservations for these upcoming conferences? RCP will be attending the following conferences. We hope to see you there!

AGA Pipeline Safety Management Systems Workshop
April 12 – 13
Omni Jacksonville, Florida

This workshop will feature presentations and case studies from pipeline operators, regulators, and service providers. Presentations will focus on information about pipeline safety management systems and their implementation. Regulators, pipeline operators, and service providers are all invited to participate in this forum. RCP's President, Bill Byrd, will be speaking on:

• Implementation Solutions: Bill will review tools and methods available to track progress for Pipeline Safety Management Systems deployment and effectiveness.

• "Underground Natural Gas Storage Risk Assessment Process - An Implementation Tool for API RP 1171" presented by Rick Gentges.
• "Assessment of MAOP Validation and the NPRM" presented by Michael Berg.

Pressure Testing Webinar - Advantages of using TestOp®
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RCP will be hosting webinar presentations to discuss pipeline pressure testing practices and demonstrate the advantages of utilizing new technology for planning, designing, and capturing real-time data to validate and document whether it was a successful test. The same technology that RCP has used for the past six years to validate our customer's pressure tests has been greatly enhanced and is now being made available as a web-hosted solution for operators to use themselves.

TestOp® takes the confusion out of pressure testing by providing real-time determination of whether the test segment is experiencing potential issues, such as yielding or air entrapment volume absorption, all while modeling the mass balance relationship of pressures, volumes and temperatures of the test. TestOp will provide real-time indicators and corresponding data to confirm whether the test is successfully performing to plan or if there might be a small pin-hole leak that would otherwise go undetected before taking the line segment off test. TestOp generates comprehensive and consistent reports, including a certification letter, pressure test plan versus actual test results, pressure/spike test log, test instrument and pump calibrations, pipe volume calculations sheet, stress/strain and pressure/volume plots as well as upload capability for pictures and other document scans associated with the test.

We encourage any liquid or gas pipeline operator who has upcoming projects that involve replacement, integrity verification, new construction, uprates, conversions and/or reversals to sign-up for the 45 minute webinar. Some of the largest and most respected pipeline operators are now using TestOp because they see the value it brings to their overall pipeline integrity assurance program and we are confident you will too once you have seen it in person.

Mark your calendar and plan to attend one of these sessions or request an individual demonstration for your company at a date convenient to you.

• April 19, 2017 (Wednesday) at 2 p.m. CDT
• May 24, 2017 (Wednesday) at 2 p.m. CDT

RCP Workshop Schedule for 2017