August, 2009, marks the 10 year anniversary of the DOT Pipeline Compliance Newsletter. I remember worrying 10 years ago that there might not be enough changes in pipeline regulatory issues on a sufficient frequency to justify a monthly newsletter. And now, 10 years later, we have never run out of newsworthy topics each month. The newsletter goes directly to more than 5,000 people, and is forwarded to many more people than that. Whenever I Google a pipeline safety topic, I frequently find our newsletter on that topic as the first “hit.” Thanks to all the people whose ongoing efforts make the newsletter a success! And, thank you to our readers and clients.

Here’s to another 10 years – even better than the last 10 years!

-Bill Byrd

Editor’s note: WARNING! This is a lengthy article, for which I apologize. However, the standards that are incorporated into the pipeline safety regulations are very important, and extensive. This article just gives the highlights of what is changing. Even the highlights are exhausting! As usual, if you have questions about how any of these standards apply to your operations, we’d be glad to help.

PHMSA proposes to incorporate all or parts of the latest editions of the following voluntary consensus technical standards referenced in the pipeline safety regulations:

• API RP 5L1 & API RP 5LW “Transportation of Line Pipe on Barges and Marine Vessels”
• API 620 (2008) “Design and Construction of Large, Welded, Low-Pressure Storage Tanks”
• ANSI/API Spec 5L/ISO 3183 Specification for Line Pipe (44th edition, 2007), Includes Errata and Addendum (2009)
• API Spec 5LW API Recommended Practice 5LW, “Recommended Practice for `Transportation of Line Pipe on Barges and Marine Vessels’ ” (2nd edition, 1996)
• API Spec 6D/ISO 14313 “Pipeline Valves” (23rd edition and errata 1, 2 and 3, (2009)
• ANSI/API 12F, Specification for Shop Welded Tanks for Storage of Production Liquids (11th edition errata, February 2007)
• ANSI/API 510, “Pressure Vessel Inspection Code: Maintenance Inspection, Rating, Repair, and Alteration,” (9th edition, June 2006)
• API 620, “Design and Construction of Large, Welded, Low-Pressure Storage Tanks” (11th edition, February 2008, Addendum 1, 2009)
• API 650, “Welded Steel Tanks for Oil Storage,” (11th edition, June 2007, Addendum 1, 2008)
• ANSI/API Recommended Practice 651, “Cathodic Protection of Aboveground Petroleum Storage Tanks” (3rd edition, January 2007)
• ANSI/API Recommended Practice 652, “Lining of Aboveground Petroleum Storage Tank Bottoms,” (3rd edition, October 2005)
• API 653, “Tank Inspection, Repair, Alteration, and Reconstruction,” (3rd edition, includes Addendum 1 (2003), Addendum 2 (2005), Addendum 3 (2008), and Errata (2008), April 2008)
• API 1104, “Welding of Pipelines and Related Facilities,” (20th edition, Errata/Addendum, (2007) and Errata 2 (2008))
• API 1130, “Computational Pipeline Monitoring for Liquid Pipelines” (1st edition, September 2007)
• API 2000, “Venting Atmospheric and Low-Pressure Storage Tanks” (5th edition, errata, November 1999)
• API Recommended Practice 2003, “Protection against Ignitions Arising Out of Static, Lightning, and Stray Currents,” (7th edition, January 2008)
• API 2026, “Safe Access/Egress Involving Floating Roofs of Storage Tanks in Petroleum Service,” (2nd edition, reaffirm, June 2006)
• API Recommended Practice 2350 “Overfill Protection for Storage Tanks in Petroleum Facilities,” (3rd edition, January 2005)
• ASCE/SEI 7-05, “Minimum Design Loads for Buildings and Other Structures” (2005 edition)
• ASTM A53/A53M-07 (2007), “Standard Specification for Pipe, Steel, Black and Hot-Dipped, Zinc-Coated, Welded and Seamless”
• ASTM A106/106M-08 (2008), “Standard Specification for Seamless Carbon Steel Pipe for High-Temperature Service”
• ASTM A372/A372M-03 (2008), “Standard Specification for Carbon and Alloy Steel Forgings for Thin-Walled Pressure Vessels”
• ASTM A381-96 (Reapproved 2005), “Standard Specification for Metal-Arc-Welded Steel Pipe for Use with High-Pressure Transmission Systems”
• ASTM A671-06 (2006), “Standard Specification for Electric-Fusion-Welded Steel Pipe for Atmospheric and Lower Temperatures”
• ASTM A672-08 (2008), “Standard Specification for Electric-Fusion-Welded Steel Pipe for High-Pressure Service at Moderate Temperatures”
• ASTM A691-98 (2007), “Standard Specification for Carbon and Alloy Steel Pipe, Electric-Fusion-Welded for High-Pressure Service at High Temperatures”
• ANSI/ASME B16.1-2005, Gray Iron Pipe Flanges and Flanged Fittings: Classes 25, 125, and 250 (August 2006)
• ANSI/ASME B16.9-2007, “Factory-Made Wrought Steel Butt Welding Fittings” (December 2007)
• ANSI/ASME B31.4-2006 “Pipeline Transportation Systems for Liquid Hydrocarbons and Other Liquids” (October 2006)
• ANSI/ASME B31.8-2007 “Gas Transmission and Distribution Piping Systems” (November 2007)
• ASME Boiler and Pressure Vessel Code, Section I: Rules for Construction of Power Boilers 2007 (July 2007)
• ASME Boiler and Pressure Vessel Code, Section VIII, Division 1: Rules for Construction of Pressure Vessels 2007 (July 2007)
• ASME Boiler and Pressure Vessel Code, Section VIII, Division 2: Alternative Rules 2007 (July 2007)
• ASME Boiler and Pressure Vessel Code, Section IX: Welding and Brazing Qualifications 2007 (July 2007)
• GTI-04/0032 LNGFIRE3: A Thermal Radiation Model for LNG Fires (2004)
• MSS SP-44-2006, “Steel Pipe Line Flanges” (January 2006)
• NACE SP0169-2007, “Control of External Corrosion on Underground or Submerged Metallic Piping Systems”
• NACE SP0502-2008 Standard Practice-Pipeline External Corrosion Direct Assessment Methodology (Reaffirmed)
• NFPA 30 (2008), “Flammable and Combustible Liquids Code”
• NFPA 59A (2006), “Standard for the Production, Storage, and Handling of Liquefied Natural Gas (LNG)”
• NFPA 70 (2008) “National Electrical Code”
• PPI TR-3/2008 (2008), “Policies and Procedures for Developing Hydrostatic Design Basis (HDB), Pressure Design Basis (PDB), Strength Design Basis (SDB), and Minimum Required Strength (MRS) Ratings for Thermoplastic Piping Materials or Pipe”

PHMSA is proposing to eliminate the use of the previous editions of API Specification 5L “Specification for Line Pipe” and API 1104 “Welding of Pipelines and Related Facilities” and to adopt only the latest (2007) edition of those standards. The April 14, 2009 Direct Final Rule on that subject allowed either the 2007 or the earlier editions of those standards to be used.

PHMSA is proposing to incorporate only specific sections of NFPA 59A, Standard for the Production, Storage, and Handling of Liquefied Natural Gas (LNG) (2006 edition). Except for the specified sections in the 2006 edition, PHMSA proposes to continue to reference NFPA 59A (2001).

Standards not proposed to be incorporated by reference at this time are:

• ASTM D638; Standard Test Method for Tensile Properties of Plastics (2008 edition)
• ASTM D2513; Standard Specification for Thermoplastic Gas Pressure Pipe, Tubing and Fittings (2007 edition)
• ASTM D2517; Standard Specification for Reinforced Epoxy Resin Gas Pressure Pipe and Fittings (2006)
• ASTM F1055; Standard Specification for Electrofusion-Type Polyethylene Fittings for Outside Diameter Controller Polyethylene Pipe and Tubing (2006)
• NFPA 58; Liquefied Petroleum Gas Code (LP-Gas Code) (2008 edition)
• NFPA 59; Utility LP-Gas Plant Code (2008 edition)

PHMSA also proposes to revise the pipeline safety regulations to make non-substantive edits, update contact information, and provide clarification as specified in the following summary:

PHMSA is proposing to revise paragraph (c) in § 192.11 to require that Part 192 prevails if there is a conflict between Part 192 and NFPA 58 or 59.

PHMSA proposes to revise section 192.711 to clarify that the repair times for pipelines covered by § 192.711 pertained only to nonintegrity management repairs.

PHMSA is proposing to revise paragraphs (d) and (e) of Section 192.145 to use the same language as ANSI/ASME B31.8, paragraph 831.11(c) in referring to shell components. Proposed revisions to paragraph (d) will clarify the elements of a “shell component.” The proposed revisions will clarify the intent of § 192.145(d) and (e) regarding the design requirements for pressure containing parts of valves used in compressor stations. OPS has several interpretations, PI-75-057 and PI-71-014, stating that the plug or ball is not a pressure containing part. It is OPS’s intent to permit the use of cast iron plugs or balls in combination with steel shell components. In paragraph (e), PHMSA is proposing to clarify that cast iron, malleable iron, or ductile iron may be used in the valve ball or plug. These materials may not be used in the pressure holding shell components (body, bonnet, cover, or end flange).

PHMSA proposes to move the definitions “active corrosion”, “electrical survey” and “pipeline environment” from § 192.465(e) to § 192.3. This proposed revision will provide a broader applicability of these terms to Part 192 because these terms are also found in Part 192, Subparts I and O.

PHMSA proposes to clarify requirements for MAOP uprating in § 192.557(c) by including the location factor requirements in § 192.619(a)(2).

PHMSA is proposing to revise Section 193.2101 to incorporate by reference sections from the 2006 edition of NFPA59A pertaining to the seismic design of stationary LNG storage tanks. Other sections from the 2001 edition of NFPA 59A would continue to be incorporated by reference as designated in 193.2013. NFPA 59A (2006) incorporates by reference the 1990 edition of API 620 but PHMSA proposes to incorporate by reference the most recent version, API 620 (2008), for seismic design.

PHMSA is proposing to clarify the language in § 193.2321(a) and to use the broader terminology for non-destructive testing. PHMSA also proposes to revise 193.2321(b) to add new requirements in accordance with NFPA 59A’s 2006 edition for the ultrasonic examination of LNG tank welds for storage tanks with an internal design pressure at or below 15 psig.

PHMSA is proposing to revise Section 195.307 paragraph (c) to reflect revised section numbering regarding pneumatic testing from 5.3 to 5.2 of API Standard 650.

PHMSA is proposing to revise Section 195.401 to clarify that the requirement to repair a condition within a reasonable time period (unless an immediate hazard) only applies to conditions on pipelines not covered by § 195.452.

PHMSA is proposing to revise Section 195.432 paragraph (b) to eliminate the reference to section 4 in API Standard 653. All sections in API Standard 653 relating to inspection of in-service atmospheric and low-pressure steel aboveground breakout tanks are incorporated by reference.

PHMSA is proposing to revise Section 195.452 paragraph (h)(4)(i) to reflect new section numbering as specified in the updated ANSI/ASME B31.4. The referenced section would be changed from “451.7” to “451.6.2.2 (b)”.

Submit comments on the subject of this proposed rule on or before September 21, 2009 to http://www.regulations.gov and reference Docket No. PHMSA-2008-0301.

Standard Operating Procedure Updates

RCP has developed standard operating procedures for hundreds of pipeline operators ranging from gas transmission, hazardous liquids, gas distribution, reservoir and salt dome gas storage facilities, oil terminals, regulated onshore gathering and offshore oil & gas facilities. Our procedure development process goes well beyond the typical cookie-cutter generic templates that you can buy off the shelf. We have a strong track record with successful PHMSA and state inspection performance – failure is not an option. Our procedure development process integrates with the daily operating processes that your personnel and contractors currently follow. When complete, you will have a comprehensive set of procedures that are easy to manage and comply with federal and state regulatory requirements. For more information, contact Jessica Roger.

The Technical Pipeline Safety Standards Committee (TPSSC) and the Technical Hazardous Liquid Pipeline Safety Standards Committee (THLPSSC) will meet on Thursday, August 6, 2009, from 1 pm to 5 pm EST. The TPSSC and the THLPSSC will take part in the meeting by telephone conference call. The committee will not be voting on any proposals at this meeting. PHMSA will discuss its pipeline safety regulatory program, and the following proposed rules or topics of interest:

• One-Rule and Changes to Incident and Accident Forms.
• Periodic Updates of Regulatory References to Technical Standards.
• Low Stress II-Survey Results.
• Installing Excess Flow Valves (EFV) – (Application for Apartments and Commercial Properties)
• Community Technical Assistance Grant Program.
• Pipelines and Informed Planning Alliance (PIPA).

The public may attend the meeting at the U.S. Department of Transportation, 1200 New Jersey Avenue, SE, Washington, DC 20590, Room E27-302. They may also join the online meeting using Microsoft
Office Live Meeting and by calling (800) 779-9618 Participant code: 36715

Members of the public may attend and make a statement during the advisory committee meetings. For a better chance to speak at the meetings, please contact Cheryl Whetsel by phone at (202) 366-4431 or by e-mail at cheryl.whetsel@dot.gov by July 27, 2009.

Join us at the 2009 Western Regional Gas Conference (WRGC) at the Tempe Mission Palms Hotel & Conference Center in Tempe, Arizona. The Arizona Utility Group organizes this natural gas industry conference to educate, train and provide a forum for the exchange of information for and between natural gas companies and their associated industry memberships, consultants, manufacturers and vendors.

RCP representatives will be attending the conference and look forward to meeting you. Conference speakers include presentations by RCP staff on:

• Maximum Allowable Operating Pressure (MAOP) Using Effective Tools for Determining MAOP by Chris Foley; and,
• Use of GPS Technology for Damage Prevention by Bill Byrd.

The preliminary agenda and registration information for the conference can be found on the WRGC website.

RCP will be hosting our very popular 2-day workshop on DOT Pipeline Compliance on October 6 & 7, 2009, in Houston, TX. Join us for an informative, lively, and interactive workshop on DOT Pipeline Compliance.

Day 1 (October 6): Gas Pipeline Regulations (49CFR192): Covering all the topics below but special emphasis will be placed on the changes in **GAS GATHERING** regulations.

Day 2 (October 7): 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
• Compliance Requirements:
• 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.