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DOT Pipeline Compliance News
June 2015 Edition

PHMSA Proposed Gas Rule for Plastic Pipe
[Docket No. PHMSA-2014-0098]
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On May 21, 2015, PHMSA published a notice of proposed rulemaking to amend 49 CFR 192 to address regulatory requirements concerning plastic pipe used in gas service. The proposed changes correct errors, address inconsistencies and respond to petitions for rulemaking. Several subject areas in the regulations are affected including: additional definitions, changes in the documents incorporated by reference; requiring Type “B” gathering pipelines with plastic pipe to meet all requirements for plastic pipe in the regulations; materials used in plastic pipelines; design and construction of plastic pipelines; design factors; plastic pipe repair; service lines; external corrosion protection for metal alloy fittings in plastic pipelines; and pressure testing plastic pipelines. In addition, the proposed changes add regulations concerning the following: tracking and traceability provisions; procedures for storing and handling plastic pipe and components; installation of plastic pipelines by trenchless excavation; repairing leaks in distribution systems; equipment maintenance; and calibration for joining plastic pipe by heat fusion.

PHMSA is requesting comments to the proposed regulations. Submit comments via the E-Gov Website by July 31, 2015 and reference Docket No. PHMSA-2014-0098.

For a copy of PHMSA's Plastic Pipe proposed rulemaking, contact Jessica Foley.

Office of Inspector General Audit of PHMSA
Project ID: 15S3007S000
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The Department of Transportation’s Office of Inspector General (OIG) will be conducting an audit of PHMSA’s progress addressing significant safety issues on the basis of concerns about the length of time PHMSA has taken to implement a number of mandates.

OIG’s objectives are to assess PHMSA’s:

  • Progress in addressing congressional mandates and recommendations issued by the National Transportation Safety Board, Government Accountability Office, and OIG since 2005;
  • Process for implementing mandates and recommendations, including any impediments to Agency action; and,
  • Efforts to coordinate and address operating administrations' safety concerns.
The audit was scheduled to begin in May 2015. Click here to view a copy of the Audit Announcement.

Obama Nominates Marie Therese Dominguez to Lead PHMSA
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President Obama nominated Marie Therese Dominguez to lead the Pipeline and Hazardous Materials Safety Administration (PHMSA). PHMSA has been without a permanent head since October when former administrator Cynthia Quarterman stepped down. If confirmed, Dominguez would replace Timothy P. Butters, who has been acting PHMSA administrator.

Dominguez has over 15 years of government experience and is currently the principal deputy assistant secretary at the Army Corps of Engineers. She previously worked for the US Postal Service, the Federal Aviation Administration, the Clinton White House and the National transportation safety Board. Dominguez is a graduate of Smith College and Villanova Law School.

Pressure Test Webex
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RCP is a leading industry expert on pressure testing and will be hosting two Webex presentations on TestOp™, our new comprehensive pressure testing tool. TestOp™ is a proprietary web-based application that provides operators with a platform to plan, design, certify and document their pressure tests. For use on gas and liquid lines, with tests using water, nitrogen, natural gas or air, TestOp™ takes the confusion out of pressure testing by providing real-time determination of whether the test segment is experiencing pipe yielding or air entrapment during the ramp up to spike pressure while also modeling the pressure/temperature relationship of the test to determine if a leak is occurring. TestOp™ also calculates the MAOP established by the test, the reassessment interval based on federal code requirements, the test factor required based on pipe inputs, and more.

Mark your calendar and plan to attend one of these sessions:

  • June 22 (Monday) at 2 p.m. CST
  • July 16 (Thursday) at 2 p.m. CST
Click here to get Log-in information.

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Final Rule on Waters of the USA
[EPA-HQ-OW-2011-0880; FRL-9927-20-OW]
RIN 2040- AF30

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On May 27, 2015, the U.S. EPA and Army Corps of Engineers (COE) issued a Final Rule re-defining and expanding the definition of jurisdictional “waters of the U.S.” under the federal Clean Water Act. This definition affects the need for permits under the COE’s Section 402 (NPDES) and Section 404 (wetland) programs, the need for EPA’s SPCC plans for non-transportation related facilities under 40 CFR 112, the need for OPA-90 spill response plans for pipelines under 49 CFR 194, and may affect the reporting requirements for releases or other incidents to the federal government and states.

The new rule extends the “significant nexus” standard in the 2001 SWANNC v. Army Corps decision, and establishes the following categories of waters that arguably demonstrate a significant nexus:

  • traditional navigable waters;
  • interstate waters;
  • territorial seas;
  • impoundments of jurisdictional waters;
  • tributaries;
  • adjacent waters (including any isolated water that is within 100' of the ordinary high water mark of some other jurisdictional water, or located in the 100 year flood plain (in whole or part) of any jurisdictional water, and within 1500' of the ordinary high water mark of that water), and
  • other areas, including five specific types of waters: Prairie potholes, Carolina and Delmarva bays, pocosins, western vernal pools in California, and Texas coastal prairie wetlands.
The definition of “waters of the US” has been the subject of much interpretation, reinterpretation, and litigation, for decades… and this latest rulemaking is likely to continue that trend. Stay tuned.

Summer Conference Schedule
July & August 2015
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Have you registered and confirmed your reservations for these upcoming conferences? RCP will be attending. We hope to see you there!

LGA Pipeline Safety Conference
July 20 – 24, 2015
Royal Sonesta / New Orleans, LA

SGA Operating Conference & Exhibits
July 20 –22, 2015
OMNI Hotels & Resorts / Nashville, TN

Power-Gen Natural Gas New this year!
August 18 – 20, 2015
Greater Columbus Convention Center /Columbus, OH
An annual conference and exhibition targeting gas-fired generation related to the development of natural gas reserves in the Marcellus and Utica shales of the Appalachian Basin.

Western Regional Gas Conference
August 25 & 26, 2015
Tempe Mission Palms / Tempe, AZ

Save the Dates!
RCP 2015 Workshop Schedule

Join us at our corporate office and dedicated training facility in downtown Houston. We are now offering Pressure Test Workshops in addition to our DOT gas & liquid pipeline seminars. Visit our Training Website for updates and registration information.

Pressure Test Workshop:
August 4 & 5 (Tuesday & Wednesday)

DOT Combined Gas & Liquid Workshop:
August 11, 12, 13 (Tuesday, Wednesday, Thursday)

DOT Hazardous Liquid Pipeline Workshop
October 6, 7, 8 (Tuesday, Wednesday, Thursday)

We would welcome the opportunity to discuss our services with you.

Best Regards,

W. R. (Bill) Byrd, PE
RCP Inc.



About RCP
RCP is a registered professional engineering corporation staffed by more than 50 energy pipeline experts with extensive experience in energy pipeline risk management and regulatory compliance issues. Since 1995, RCP has assisted companies and organizations of all types and sizes, including every pipeline operator in the Forbes 500 down to small municipal operators, with the challenges of energy pipeline and terminal regulatory compliance and integrity management at the federal level, in every state, and in several foreign countries. Our personnel have experience as operators, engineers, and managers, and participate at the highest levels of the gas and liquid energy pipeline industry by serving on technical research committees and developing industry standards. RCP also offers pipeline integrity and corrosion control consulting services by providing operational support and program implementation management services, including selection, contracting, and management of subcontractors in the field to implement the required program activities for corrosion control, in-line inspection, direct assessment, and more. RCP has the perfect team to support your pipeline integrity and compliance requirements - from initial consulting, to program development, to implementation and final analysis of a broad range of pipeline regulatory compliance and integrity management issues.

For more information, please contact Jessica Foley at 713-655-8080 or visit www.rcp.com.

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