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Other Regulatory Initiatives

Other Regulatory Initiatives. Or Isn’t I V P Enough ?. David Johnson. Houston, Texas. With my favorite h oliday approaching . . . I thought – How can I depict what it’s like being a pipeline operator these days ? ? ?. Aha !. Where they come from. Advanced Notice of Proposed Rulemaking

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Other Regulatory Initiatives

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  1. Other Regulatory Initiatives Or Isn’t I V P Enough ?

  2. David Johnson Houston, Texas

  3. With my favorite holiday approaching . . . I thought – How can I depict what it’s like being a pipeline operator these days ? ? ?

  4. Aha !

  5. Where they come from • Advanced Notice of Proposed Rulemaking • Notice of Proposed Rulemaking • Final Rule • Information Collection • Advisory Bulletin • Workshop / Public Meeting • Regulatory Agenda • Any or all can be driven by: • Congressional mandates • NTSB / GAO / OIG / other recommendations • PHMSA self-initiated • Third-party petitions / inquiries

  6. Current - ADB • 2012-02 – Post-accident drug and alcohol testing • 2012-05 – Cast iron pipe – monitor, review, replace • 2012-06 – TVC records for Cl. 3, 4 & HCA MAOP • 2012-07 – Distribution report all mech fitting failures • 2012-08 – Inspection after all railway accidents • 2012-09 – Communication during emergencies (911) • 2012-10 – Meaningful IM metrics • 2012-11 – 5-day notice of MAOP exceedances • 2013-01 – 1-hour telephonic notification time limit • 2013-02 – Flooding can damage pipelines • 2013-04 – Recall of certain leak repair clamps

  7. Current – Final Rule • Administrative Procedures: Updates & Corrections • 78FR58897 – 9.25.2013 • Enforcement and due process

  8. Near Term – Info Collection • Annual report • Much more data, including MAOP verification status • Incident report • More details, plus follow-ups • Class location • IMP/PIR, Class Location, neither, both? • Mapping – NPMS • Much higher accuracy, much more data

  9. Mid-Term - NPRM • Miscellaneous Changes – 2.3.2012 • Const. inspections, Pipe transportation, NPMS, Welder qualification, Odorization • EFVs – 2.3.2012 • Damage Prevention – 4.2.2012 • Administrative Procedures – 8.13.2012 • Periodic Standards Updates – 8.16.2013

  10. Planning - Workshop • Leak Detection & Valves – March 2012 • Reports issued to Congress • R&D Forum – June 2012 • R&D plan and BAAs • Pipeline Data – January 2013 • State One-Call Exemption Forum – March 2013 • Enforcement, “model one-call” • Public Awareness Workshop – June 2013 • Protesters! • Integrity Verification Process – August 2013

  11. Planning - ANPRM

  12. Planning – Operator Inquiry • Farm Taps • DIMP Plan Required

  13. Master List – Reg Agenda

  14. Rhyme & Reason Some of these are on more than one list, so What’s the typical process? • Idea / Mandate / Perceived Need • ANPRM / Workshop-Public Meeting • Report • NPRM • Comments & analysis • Final Rule

  15. Web Locations • Advisory Bulletins http://phmsa.dot.gov/pipeline/regs/advisory-bulletin • Rulemakings http://phmsa.dot.gov/pipeline/regs • Notices http://phmsa.dot.gov/pipeline/regs/notices • Final Rules http://phmsa.dot.gov/pipeline/regs/rulemaking/final • Regulatory Agenda http://www.reginfo.gov/public/do/eAgendaMain

  16. Advice ? • Pay attention to previously listed web pages, plus • Federal Register - http://www.gpo.gov • Participate • Through your trade associations • Make comments on things that matter to you • http://www.regulations.gov/

  17. Just hang in there, you’ll get it figured out -

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