for Liquid Operators May 21 2015 Webinar Purpose To reduce the amount of time NPMS staff spend processing operator submissions by Providing an overview of resources for operators Explaining common issues and mistakes we see in submissions ID: 670244
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Slide1
NPMS Operator Conference
for Liquid Operators
May 21, 2015Slide2
Webinar Purpose
To reduce the amount of time NPMS staff spend processing operator submissions by
Providing an overview of resources for operators
Explaining common issues and mistakes we see in submissions
Responding to your questions about the submission processSlide3
NPMS staff?Slide4
NPMS staff
Amy Nelson
GIS Manager, PHMSA
Katie Field
NPMS Manager, Michael Baker International
Bellinda Monge
GIS Specialist, Michael Baker International
Leigha Gooding
GIS Specialist, PHMSA
Not speaking: Melissa
Scherr
and Kelly FitzpatrickSlide5
Agenda
Resources for pipeline operators
Common problems with submissions
Tips for a problem-free submission
Questions from operators (all lines will be muted until the Q&A period)Slide6
Part 1:
Resources for Pipeline OperatorsSlide7
NPMS Website
www.npms.phmsa.dot.govSlide8
Operator Standards and
Submission GuideSlide9
Operator Standards
Formal requirements regarding what must be submitted.
Submission Guide
Description of the workflow the submission goes through when received by NPMS staff
Detailed instructions and examples on how to install and use the Builder tool for both metadata and attributes.
Example of how coordinate spatial data is linked to attributes in the Builder tool.
Designed for the operator to reference the sections which apply to his environment/situation.
Detailed descriptions and examples regarding the proper use of status codes (STATUS_CD) and revision codes (REVIS_CD). Slide10
Data Reviewer and
Submission Reviewer
Submission Reviewer will be shut down on July 1, 2015Slide11
Submission Reviewer
Allows the operator to review his/her processed submission before it’s uploaded to the NPMS web applications.
Will be shut down this year due to low usage. Will be replaced by an email notifying you when your data has been uploaded to NPMS web applications.
Data Reviewer
Requires a PIMMA login
Allows an operator to view his/her previously submitted NPMS data
Allows operator to notify NPMS staff of no changes to data, in order to fulfill submission requirementSlide12
Impact of Final
Rule 2137-0596
Starting October 1, 2015 operators must submit gas transmission pipelines and LNG plants to the NPMS by March 15. Operators must submit hazardous liquid pipelines to the NPMS by June 15. Submitted data must reflect assets as of December 31 of the previous year.
We greatly appreciate it when you submit early!
The requirement to submit to the NPMS has changed from the Pipeline Safety Improvement Act of 2002 to PHMSA Pipeline Safety Regulations Sections 191.29 and 195.61Slide13
OPIDs
with both gas transmission and
hazardous
liquid pipelinesOperators with both gas transmission and hazardous liquid pipelines preferably should submit updated data for both types by March 15.
If
you are unable
to submit hazardous liquid portion by March 15:
Only the gas transmission portion should be submitted by March 15. Cover letter should clearly indicate that the submission only represents the gas transmission portion and will be submitting the hazardous liquid portion by the June 15 deadline. Submission must contain all components.
Only the hazardous liquid portion should be submitted by June 15. Cover letter should clearly indicate that this portion of the submission contains only the hazardous liquid pipelines. Submission must contain all components.
When gas portion is received, NPMS staff will conduct a cursory review and notify operator of the status.
When the hazardous liquid portion is received, NPMS staff will merge the two submission pieces together and conduct a thorough review, notify the operator of the status and proceed with the processing of the complete submission.Slide14
Professional Conduct
We appreciate most operators’ efforts to make a complete, timely, and accurate NPMS submission
In the rare cases that an operator acts unprofessionally (does not return phone calls/emails, misrepresents their data, or is not professional and courteous in their dealings with NPMS staff), the GIS Manager is notified.
She maintains a list of these operators and will work with our regional offices to discuss this conduct with your company’s management during your next inspectionSlide15
Part 2:
Common problems NPMS staff see with operators’ submissionsSlide16
Common issues with map projection
Be sure to define a projection
in
a shapefile and include the .prj file in the data submission
U
se
the right
(accurate) projection
on a
shapefile
; don’t copy
an existing .
prj
file and rename
it
Our preferred projection/datum is Geographic
Latitude Longitude
NAD83
NPMS staff calculates mileage based on North America Albers Equal Area NAD83Slide17
Missing
Components
Metadata is not automatically submitted via the Builder
toolOutdated cover letter
Not required to use NPMS’s cover letter template document but required to include responses to all of the questions identified as being included in the template (listed in
Section 2.3 of the
Operator Standards
).
Missing/Invalid Attributes
Invalid attribute values or combinations of values
Use
EPL/EPG solely
for abandoned
pipelines and should reflect type of commodity previously transported
Idle/retired pipelines should reflect the COMMODITY previously
transported
Commodity details (CMDTY_DTL*) must relate to the appropriate commodity. CMDTY_DTL* values should not be repeated in each
column
Populate LOW_STRESS only
for in service HL pipelinesSlide18
Disconnect
between OPER_LINK values in the geospatial data and attribute data
If
you work with shapefiles, please add the attributes directly
to
the shapefile rather than
using
the Pipeline Attribute section of the Builder tool
Pipeline Attribute section of the Builder tool is intended for operators without a GIS system (e.g. CAD data or coordinate (
lat
/long) data)Slide19
Purpose of the OPER_LINK AttributesSlide20
Incorrect use of Status Codes
(STATUS_CD; In Service, Idle, Abandoned, Retired)
Use appropriate code based on PHMSA definition
Invalid
attribute values or combinations of
values (for more information, see page 53 of the Submission Guide)
Use
EPL/EPG solely
for abandoned
pipelines
Idle/retired pipelines should reflect the COMMODITY previously
transportedSlide21
Common issues with abandoned pipelines
Abandoned pipes are divorced from your OPID and do not appear on your PHMSA Annual Reports.
Pipelines
which are removed from the ground are not abandoned
“Abandonment by sale” is not
abandoned in the NPMS
Pipelines
which you may return
to service are not
abandoned, they are retired or idle
Abandoned pipelines
which cross a CNW or fall offshore must be included in your NPMS submission and accompanied by a certificate of
abandonment
Template for the certificate of abandonment is available on the NPMS
website (and on Page 56 of the Operator Standards)
All information in the certificate is required
.
“Abandoned” is not a valid description of the method of
abandonment
Certificate must be signed manually (and scanned) or with a digital signatureSlide22
Common issues with abandoned
pipelines
Abandoned
pipelines which fall onshore and do not cross a CNW may be voluntarily submitted to the NPMS.If you abandon one of these pipelines and choose not to submit it to the NPMS, please indicate that on your cover letter. Otherwise, we will run into problems during our review and will be contacting you.
Abandoned pipelines must be submitted one time only
At best
you will
receive an email seeking
clarification; at worst, duplicate
pipelines are created in the
NPMS
If
you determine
that pipelines previously reported as abandoned are not in fact abandoned,
that pipeline
must be included in the submission and a detailed explanation must be included in the cover letter. Slide23
When you
sell or reclassify
pipelines…
Please indicate this information, along with any other detailed information, on your cover letter (transmittal) to help analysts process your submission more quickly and accuratelyYour submission cannot be completely processed until we can account for these lines
Please respond promptly when an analyst asks for more informationSlide24
Incorrect use of Revision Codes (REVIS_CD)
Use
the REVIS_CD field to indicate what change has occurred since your last submission for a
pipe segment“
C”
(new construction) should
only be used to indicate new pipelines which add mileage
Repairs to an existing pipeline are not considered to be new construction
“J” (new to PHMSA’s jurisdiction) should be used to indicate pipelines added due to change in classification (e.g., gas gathering became gas transmission).
“A” (addition) is only used when pipelines are newly included in the submission because the pipeline was acquired from another operator or the pipeline was previously left out in error.
If
operator’s system is unable to accurately track the type of
revision:
Operator is required to correctly code where REVIS_CD should be A, C or J
Operator may default to B
(both spatial and attribute changes), if
unsure of specific changes. Do not default to
N (no changes).Slide25
Pipes added to your submission
When you buy, build, re-route, or upgrade pressure on pipes, please let us know on the cover letter
Use
the REVIS_CD field to also indicate this change
Transfer
between OPIDs within same parent company is still considered to be an acquisition and divesture and REVIS_CD needs to reflect “A” for the
buyerSlide26
Outdated notifications to PHMSA regarding
new
construction
NPMS staff references PHMSA notifications
when the operator’s submission is
received
Notifications which are not
current/updated (
e.g., estimated construction completion date) result in NPMS
staff seeking
clarification from the
operator
Incomplete or
missing notifications
to PHMSA
regarding
sales
Notification
of sale may not contain enough detailed information to specifically identify which pipelines in the NPMS national layer were sold/acquired.Slide27
NPMS
submissions are compared to
PHMSA
Annual Report data to reveal discrepancies
The pipelines must be represented in the same way in both
reporting requirements
OPID must match
Do not submit offshore or onshore gas gathering to NPMS
In service, idle, and retired pipelines should be included in the Annual
Report
Please ensure your mileage by state matches (within 5%) between the Annual Report and the NPMS submission
Please ensure your
inter/intrastate mileage matches (within 5%) between
the Annual Report and the NPMS
submissionSlide28
“No Changes”
No need to submit the data, cover letter etc. if there are no
changes
The following types of changes do not require you to resubmit
Changes to the REVIS_CD (e.g., from S to N)
Changes
to contact information (primary, technical or public
) may be submitted at anytime throughout the year; email npms@dot.gov for primary or technical contact changes or use
online public contact info form
for public contact changes
Changes
to the operator
name
;
NPMS staff are automatically notified throughout the yearSlide29
NPMS staff can make changes
to your data in limited cases
Edits
which NPMS staff may make on your behalf:Attribute changes that do not require
changing the pipe segmentation
; impacted segments must be easily identifiable.
Removal of entire data segments
Abandonment of entire data segments
Additions to existing data
Transfer of all pipelines from one OPID to another
OPID
Removal of an entire OPID (e.g. no longer transmission, abandoned, sold)
If you feel that this describes your situation, contact NPMS staff for details and
approvalSlide30
Change Detection
NPMS staff perform change detection on incoming submissions to match the pipelines against an operator’s previous submission, or to identify lines the operator has bought or sold
Change detection is used to track the history of a pipeline as it changes operatorship
Many of the most time-consuming tasks in processing your submission are related to change detection
It is important for you to identify
:
what you have acquired/sold, new construction, new to jurisdiction, re-routes, and re-
GPSed
lines so that we can process your submissionSlide31
Pink
=
This Year’s Submission
Green
=
NPMS National Layer
(i.e., previous submission)Slide32
Pink
=
This Year’s Submission
Green = NPMS National Layer (i.e., previous submission)Slide33
Pink
=
This Year’s Submission
Green
=
NPMS National Layer
(i.e., previous submission)Slide34
Pink
=
This Year’s Submission
Green
=
NPMS National Layer
(i.e., previous submission)Slide35
Pink
=
This Year’s Submission
Green
=
NPMS National Layer
(i.e., previous submission)Slide36
Good practices for NPMS submissions
Submit
all required components
All components should meet
NPMS submission standards
Refer to the
Operator Submission Guide
for tips and tricks while preparing a submission
Keep in mind that NPMS staff compare your previous submission to your incoming submission and need explanations for all spatial changes, and that NPMS staff compare your NPMS submission mileage (by state and inter/intrastate) to your Annual Report submission
Respond promptly to questions from NPMS staff to ensure your submission is processed quickly and accurately; delayed responses from you may result in your OPID being put on the noncompliant listSlide37
NPMS Information Collection
If you haven’t read it already, please review
OMB Control No. 2137-0596
(https://
www.federalregister.gov/articles/2014/07/30/2014-17865/pipeline-safety-request-for-revision-of-a-previously-approved-information-collection-national)
There are important changes proposed to the NPMS data which will affect all operators
Operators will be given sufficient time after the Information Collection is final to collect this data if needed, and to prepare their submissionsSlide38
Part 3:
Your QuestionsSlide39
Contact Us
Amy.Nelson@dot.gov
NPMS@dot.gov
Slides will be posted to the Pipeline Operator page in the “Make an NPMS submission” section on www.npms.phmsa.dot.gov after the meeting concludes