DOT Pipeline Compliance News

April 2010 Issue

In This Issue

PHMSA Advisory Bulletin ADB 10-03 Girth Weld Quality Issues

[Docket No. PHMSA-2010-0078]

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) issued Advisory Bulletin ADB 10-03 to notify owners and operators of recently constructed large diameter natural gas pipeline and hazardous liquid pipeline systems of the potential for girth weld failures due to welding quality issues. Misalignment during welding of large diameter line pipe may cause in-service leaks and ruptures at pressures well below 72 percent specified minimum yield strength (SMYS). PHMSA has reviewed several recent projects constructed in 2008 and 2009 with 20-inch or greater diameter, grade X70 and higher line pipe. Metallurgical testing results of failed girth welds in pipe wall thickness transitions have found pipe segments with line pipe weld misalignment, improper bevel and wall thickness transitions, and other improper welding practices that occurred during construction. A number of the failures were located in pipeline segments with concentrated external loading due to support and backfill issues. Owners and operators of recently constructed large diameter pipelines should evaluate these lines for potential girth weld failures due to misalignment and other issues by reviewing construction and operating records and conducting engineering reviews as necessary.

For a copy of ADB 10-03, contact Jessica Roger.

PHMSA Cased Crossing Guidelines

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) published “Guidelines for Integrity Assessment of Cased Pipe for Gas Transmission Pipelines in HCAs” as well as the FAQs for this document on March 1, 2010. PHMSA worked with a group of state regulators, representatives from industry, trade associations, and other stakeholders to develop guidelines for performing External Corrosion Direct Assessment (ECDA) of gas transmission pipe inside casings. These guidelines are intended to assist operators in complying with 49 CFR 192, Subpart O for cased pipe in HCAs.

Cased pipe presents significant challenges to conducting a successful integrity assessment using ECDA/CDA, especially with regard to step 1 (region identification and indirect inspection tool selection), step 2 (indirect assessment) and step 3 (direct examination) of the 4-step process. The 4th step in the ECDA process is post assessment.

For cased pipe, PHMSA considers the following data critical to the success of the ECDA process. This data is important for proper selection and use of indirect inspection tools, ECDA region identification, feasibility determination, use and interpretation of indirect inspection tool results, and selection of casings for direct examination.

  • Data needed for indirect tool selection,
  • Data needed for region identification,
  • Data on casing construction,
  • For filled casings, type of fill material,
  • Casing monitoring data (for example, if the casing is shorted, or wax fill is in poor condition),
  • Operating conditions (operating pressures above 60% SMYS and operating temperatures above 120° F should be considered higher risk),
  • Coating type and condition (note: these guidelines may not be used if the carrier pipe is bare, i.e., uncoated),
  • History of metallic shorts and/or electrolytic contact.

The guidelines in this document address considerations for tailoring the ECDA methodology to conditions specific to cased pipe. Indirect inspection tools have limited ability to detect corrosion activity and/or coating holidays reliably for pipe inside casings. The guidelines also address the additional considerations for the selection of indirect inspection tools when conducting ECDA on cased pipe.

For cased pipe, region identification can be particularly problematic. PHMSA has developed guidelines for assuring that all casings in a single region are sufficiently similar, as specified in NACE RP 0502-2002, §, while still maintaining enough flexibility to allow the grouping of casings (where warranted) into a single region.

Exhibit C of these guidelines provide supplementary guidance on special considerations, cautions, engineering considerations, and limitations that should be taken into account when using, interpreting, and analyzing the results of indirect inspection tools used to assess cased pipe. PHMSA has previously released guidelines for using, interpreting, and analyzing the results of GWUT used to assess cased pipe.

The other assessment activities (such as monitoring casing integrity) supplement the indirect inspection tool data with additional data which is indicative of the effectiveness of engineered systems (such as casings, end seals, and wax fill) in preventing corrosion and protecting carrier pipe integrity. PHMSA has identified guidelines for these other assessment activities in order to:

  • Compensate for the limited effectiveness of indirect inspection tools when conducting indirect inspections of cased pipe and,
  • Assist the analysis of indirect assessment results and allow the selection the highest risk casings for direct examination.

For a copy of the Guidelines or FAQs, contact Jessica Roger.

Integrity Management Services

RCP can assist pipeline operators with ongoing compliance management and engineering associated with your IMP. This includes direct assessment strategies, tool and vendor selection, ILI/ECDA report analysis, corrosion control programs, repair strategies, and IMP/risk model updates. For more information on how RCP can support your ongoing IMP needs, Click Here.

PHMSA Cased Pipe Workshop – April 28, 2010 Baltimore, MD

PHMSA is holding a workshop on the integrity assessment of cased pipe at the Sheraton Inner Harbor, 300 South Charles Street, Baltimore, MD on April 28, 2010. The workshop will be for pipeline operators, trade associations and the public to address ideas and concerns with using External Corrosion Direct Assessment integrity evaluation methods and use of other technologies to assess pipelines in casings located within high consequence areas (HCAs). This workshop will include:

  • Briefing on the Guidelines for Integrity Assessment of Cased Pipe.
  • Briefing on FAQs.
  • Comments from Stakeholders.
  • Question and Answer Forum.

PHMSA held a workshop to address technical challenges in conducting External Corrosion Direct Assessment (ECDA) on cased pipe in July 2008. Following the workshop, PHMSA worked with a group of state regulators, representatives from industry, trade associations, and other stakeholders to develop “Guidelines for Integrity Assessment of Cased Pipe in Gas Transmission Pipelines.” These guidelines are intended to assist pipeline operators in complying with 49 CFR 192, Subpart O for cased pipe in HCAs.

The workshop is free and will not be webcast. Hotel reservations under the “U.S. Department of Transportation” room block for the night of April 27, 2010, can be made by contacting the hotel directly at 1-800-325-3535. A daily base rate of $161.00 is available for the night of April 27, 2010. For this rate, room reservations must be made by April 13, 2010. Additional information is available on the meeting website.

DOT Pipeline Compliance Workshop June 8 & 9, 2010 / Houston, TX

RCP invites you to attend one of our remaining quarterly workshops on DOT Pipeline Compliance. These informative, interactive and lively workshops have been attended by hundreds of pipeline personnel with excellent feedback. They are designed to provide an overview of the DOT pipeline regulations, and are appropriate for people who are new to pipeline regulations, who could use a refresher, or anyone who needs to know the most current information in these areas. Click on one of the upcoming dates for more information:

Gas Distribution Construction Workshop – April 20, 2010

[Docket ID PHMSA-2010-0084]

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) is conducting a workshop on April 20, 2010, on new distribution pipeline construction. Natural gas distribution pipelines are subject to a unique subset of construction-related risks and issues, as compared to transmission and other pipelines. Poor construction quality has led to short and long term pipeline integrity issues and risk to public safety.

PHMSA developed this workshop in collaboration with NAPSR, state partners, and the American Gas Association to inform the public and review lessons learned from inspections, and to improve distribution pipeline construction practices. The workshop will allow stakeholders in the pipeline safety community to learn about and discuss construction issues and current practices in natural gas distribution pipeline construction management and quality control. This workshop will address common issues, focusing on the results of Federal and state regulators’ perspectives, and explore potential solutions. The workshop will include:

  • Federal and state observations related to inspection findings.
  • Distribution materials, Quality Assurance/Quality Control, related best practices.
  • Construction Issues, Joining, Horizontal Directional Drill/Boring, Excavation Damage.
  • Discussions of solutions.

The workshop will be held at the Hilton St. Louis at the Ballpark, St. Louis, MO. Hotel reservations under the “U.S. DOT Distribution Workshop” room block for the nights of April 19 & 20 ($110 room rate) can be made at 1-877-845-7354. Name badge pick up and on-site registration will be available starting at 7:30 a.m., with the workshop taking place from 8:30 a.m. until approximately 5 p.m. Members of the public may attend this free workshop. To help assure that adequate space is provided, all attendees are encouraged to register for the workshop. The workshop presentations will be available on the meeting Web site within 30 days following the workshop.

PHMSA Webinar on Incident Reporting for Distribution Operators

PHMSA has scheduled a webinar for distribution operators to review the functionality associated with its new web-based form to be used for reporting Gas Distribution Incidents to PHMSA. The webinar will be held on Tuesday, April 13 starting at 11:00 AM Eastern. Click here to register.

PHMSA Final Rule on HazMat Security Regulation Changes

[Docket No. PHMSA–06–25885 (HM–232F)]

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) issued a Final Rule on 49 CFR Part 172 Hazardous Materials: Risk-Based Adjustment of Transportation Security Plan Requirements. PHMSA, in consultation with the Transportation Security Administration (TSA), is modifying current security plan requirements applicable to the commercial transportation of hazardous materials by air, rail, vessel, and highway. The final rule narrows the list of materials subject to security plan requirements and also clarifies certain requirements related to training and documentation. Security Plans must include:

  • Site-specific risks and vulnerabilities
  • Identify, by job title, the senior management official responsible for the overall development and implementation of the plan
  • Security duties for each position or department that is responsible for the plan’s implementation
  • Employees must be aware of their individual security responsibilities and receive initial training every 3 years.

The TSA has broad responsibilities and authority for security in all mode of transportation, including the area of pipeline and hazardous materials transportation industries. Facilities must permit inspection of any security related document (facility security plans, security training records, etc.) by a TSA or other Dept. of Homeland Security official, at any time and in a reasonable manner, without advance notice.

The Final Rule requires that transportation security risk assessments be conducted, an assessment report written, and it must be included in the transportation security plan. The Transportation Security Plan must be reviewed annually and updated if circumstances change; and must be accessible at all times. The Plan may be stored electronically (CD or company internet).

This Final Rule is effective October 1, 2010. Voluntary compliance with all the amendments in this final rule is authorized as of April 8, 2010.

For a copy of the Final rule, contact Jessica Roger.

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.

State of Virginia Approves Rule Change to Underground Utility Damage Prevention Act

HB 1230, recently passed by the State of Virginia, addresses the parties responsible for marking sewer laterals on private property. Specifically, it establishes a set of requirements for the protection of sewer system laterals and private sewer laterals that are unique from the general requirements of the Underground Utility Damage Prevention Act. In addition, it further clarifies procedures to address the issue of recurring non-compliance by localities and other political subdivisions. The new provisions of this Act will become effective on January 1, 2011.

For a copy of HB 1230, contact Jessica Roger.

TRRC Proposed Rulemaking 16 TAC Chapter 5-Carbon Dioxide

The Railroad Commission of Texas (TRRC) proposes new Chapter 5, relating to Carbon Dioxide, to implement Senate Bill (SB) 1387, which was effective September 1, 2009. SB 1387 amended the Texas Water Code and the Texas Natural Resources Code to provide for the implementation of projects involving the capture, injection, sequestration, or geologic storage of carbon dioxide. The purpose of the proposed rules is to protect underground sources of drinking water while promoting the capture and storage of anthropogenic carbon dioxide.

For more information on this and other rulemakings, or to access the online comment form, please see the Proposed Rules table. The deadline to submit comments is 5:00 p.m., Monday, April 26, 2010, and may be submitted online at ; or by electronic mail to

For a copy of the proposed rule for Chapter 5 on Carbon Dioxide, contact Jessica Roger.

RCP’s Web-Based Compliance Management Systems

CP’s Compliance Management System (CMS) is an invaluable tool for managing all aspects of regulatory workflow. Some examples of how our clients are using the CMS include:

  • O&M Scheduling and Data Acquisition;
  • Cathodic Protection Inspection and Data Management;
  • One-Call Screening and Ticket Management;
  • Repair / Replacement Programs;
  • Operator Qualification Administration and Workflow Integration;
  • Leak Life Cycle Management;
  • Environmental, Health and Safety Compliance;
  • Audit Action Item Tracking; and
  • Customer Data Management.

DIMP Integration

For gas distribution operators looking for a powerful tool to implement DIMP, the RCP CMS integrates O&M data captured from field personnel along with inherent system attributes to provide real-time risk analysis, performance reporting, as well as track additional and accelerated actions taken to mitigate risks.

Key Features

  • GIS integrated workflow management
  • Custom tailored e-mail notifications and reporting
  • Runs on any web-enabled device, no software to download
  • Powerful reporting and custom query functionality
  • Multiple security and user privilege settings
  • Document storage and control (ex. procedures, maps, images, and completion documentation)
  • Automatic recurrence setting for routine tasks (example: leak surveys, CP surveys, etc.)
  • Create work orders for unscheduled / unplanned activities (ex. release reporting)

To request a demonstration or to request more information, please contact Jessica Roger.

PHMSA Pipeline Safety Program Management Changes

On March 12, the Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) announced the appointment of two new PHMSA Pipeline Safety Program Executives (both will be stationed in Washington DC):

  • Linda Daugherty, Director of the PHMSA Southern Region, is appointed as the Deputy Associate Administrator for Policy and Programs. She will have oversight of regulations, enforcement, training and qualifications, engineering, program development, state programs, program evaluation, and information and analysis.
  • Alan Mayberry, Director of Engineering & Emergency Support, is appointed as the Deputy for Field Operations. He will have oversight of the PHMSA Regions and Emergency Support and Security Operations.

Placement and Removal of Real Estate Signs Affected by Changes Proposed in State of Virginia’s HB553

The State of Virginia recently approved HB 553, which permits local government bodies to adopt ordinances to control and enforce signage regulation in public highway rights-of-way (ROW). At closer glance, this legislation provides authority to county employees (and others defined in the Bill) to remove and confiscate signs from the ROW. It also allows for provisions to the sign owner to reclaim the sign within a specified time frame. And finally, the legislation exempts placement of signs by hand or foot from the one call requirement.

For a copy of HB 553, contact Jessica Roger.

National Safe Digging Month

In order to address the issue of underground damage prevention, the Common Ground Alliance and its stakeholders have designated April 2010 as National Safe Digging Month. In support of this, the month of April will be dedicated to increasing awareness of safe digging practices across the country and to celebrate the three-year anniversary of 811, the national call-before-you-dig number.

Throughout the busy digging month of April, the CGA and its members are encouraging homeowners and contractors to call 811 before they dig to prevent injuries, property damage and inconvenient outages.

National Safe Digging Month can be easily promoted by:

Know What’s Below. Call Before You Dig!

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