NPMS Operator Webinar Winter 2016 Webinar Purpose To reduce the amount of time NPMS staff spend processing operator submissions and to assist operators preparing 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 process NPMS staff? 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 Nathaniel Thompson 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) Part 1: Resources for Pipeline Operators NPMS Website Operator Standards and Submission Guide 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). Submission Reviewer RETIRED Allowed an operator to review their processed submission before it became part of the National Layer Underutilized and did not improve data quality or minimize submission errors Primary and technical contacts will receivenotification when submission is visible on PIMMA If you notice any errors on PIMMA please contact Data Reviewer Requires a PIMMA login. Apply for PIMMA login at https://www.npms.phmsa.dot.gov/ApplyForOperatorPIMMAAccess.aspx https://www.npms.phmsa.dot.gov/ApplyForOperatorPIMMAAccess.aspx 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 requirement. Impact of Final Rule As of 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 and OPIDs with both gas transmission and hazardous liquid pipelines Operators 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. 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/ s, misrepresents their data, or is not professional and courteous in their dealings with NPMS staff), the GIS Manager is notified. The GIS Manager maintains a list of these operators and will work with our regional offices to discuss this conduct with your companys management during your next inspection If your submission is very late or you are not responding to our requests to correct errors, we will open an enforcement case. Part 2: Common problems NPMS staff see with operators submissions Common issues with map projection Be sure to define a projection in a shapefile and include the.prj file in the data submission Use the right (accurate) projection on a shapefile; dont 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 NAD83 Missing Components Metadata is not automatically submitted via the Builder tool Outdated cover letter Not required to use NPMSs 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 pipelines 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) Purpose of the OPER_LINK Attributes 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 transported 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 signature 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 anseeking 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. 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 accurately Your submission cannot be completely processed until we can account for these lines Please respond promptly when an analyst asks for more information 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 PHMSAs 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 operators 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). 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 buyer National Registry Notifications to PHMSA Submit on PHMSA Operator Portal (just like Annual Reports) Required for: New Construction Acquisitions/Purchases Divestitures/Sales Any Change in Ownership (use when Acquisition/Divestiture minimums not met) Benefits from accurate and detailed National Registry Notifications to PHMSA Minimize NPMS submission processing delays Minimize calls from NPMS staff asking for additional information 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 submission 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;for primary or technical contact changes or use online public contact info form for public contact changes online public contact info form Changes to the operator name; NPMS staff are automatically notified throughout the year 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 approval Change Detection NPMS staff perform change detection on incoming submissions to match the pipelines against an operators 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 submission Pink = This Years Submission Green = NPMS National Layer (i.e., previous submission) Pink = This Years Submission Green = NPMS National Layer (i.e., previous submission) Pink = This Years Submission Green = NPMS National Layer (i.e., previous submission) Pink = This Years Submission Green = NPMS National Layer (i.e., previous submission) Pink = This Years Submission Green = NPMS National Layer (i.e., previous submission) Good practices for NPMS submissions Submit all required componentsall required components All components should meet NPMS submission standardsNPMS submission standards Refer to the Operator Submission Guide for tips and tricks while preparing a submissionOperator Submission Guide 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 list NPMS Information Collection If you havent read it already, please review the FR notice on the NPMS Information Collection (https://www.federalregister.gov/articles/2015/08/27/ /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 submissions PHMSA expects the Information Collection to be reviewed by OMB in 2016 Part 3: Your Questions Contact UsSlides will be posted to the Pipeline Operator page in the Make an NPMS submission section onafter the meeting concludes