DOT Pipeline Compliance News

April 2014 Issue

In This Issue

PHMSA Updates Gas Transmission IMP Enforcement Guidance

On February 12, 2014, the Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) updated its Gas Transmission Integrity Management Enforcement Guidance for Sections 192.901 through 192.951. The document is intended for internal use by the PHMSA pipeline safety enforcement staff – but is also available to the public and pipeline operators. This guidance document describes the practices used by PHMSA pipeline safety investigators and other enforcement personnel in undertaking their compliance, inspection, and enforcement activities. For each section of the rule, the guidance document gives:

  • The rule language and citations
  • Interpretation Summaries
  • Advisory Bulletin/Alert Notice Summaries
  • Other Reference Material & Source
  • Guidance Information
  • Examples of a Probable Violation or Inadequate Procedures
  • Examples of Evidence
  • Other Special Notations

The Gas Transmission guidance document can be download from the PHMSA website.

PHMSA Revisions to OPID Assignment Request & Operator Registry Notification

[Docket No. PHMSA-2014-0018]

The Pipeline and Hazardous Materials Safety Administration (PHMSA) invites comments on its intention to revise two forms, PHMSA F 1000.1-OPID Assignment Request and PHMSA F 1000.2-Operator Registry Notification, and its intention to request approval from the Office of Management and Budget (OMB) for revised information collection burdens. The information collected from OPID Assignment Request forms and Operator Registry Notification forms is an important tool for identifying new operators and changes to existing pipeline systems as set forth in 49 CFR 191.22 and 195.64.

PHMSA is proposing to revise the OPID Assignment Request Form (PHMSA F 1000.1) to:

  1. Align the gas distribution and gas transmission commodity choices with those found on the annual and incident reports.
  2. Modify the list for types of gas distribution operators to reflect the ownership structure of the operator.
  3. Collect the miles of pipe and facility descriptions for each state.
  4. Eliminate liquefied natural gas (LNG) plans and procedures as a separate safety program type.
  5. Collect business cell phone numbers for contacts in addition to office phone numbers.

PHMSA is proposing to revise the Operator Registry Notification Form (PHMSA F 1000.2) to:

  1. Remove and revise instructions regarding pipeline safety program information submissions at several locations in the form and instructions.
  2. Reduce the number of notification types and the text describing each type to enhance clarity.
  3. Require Type B notifications to indicate whether the operator is assuming or ceasing operatorship of pipeline facilities.
  4. Require separate notifications for an acquisition and a divestiture.
  5. Allow an operator submitting a divestiture to request the deactivation of their OPID.
  6. Align the gas distribution and gas transmission commodity choices with those found on the annual and incident reports.
  7. Collect data about miles of pipeline separate from facilities, such as breakout tanks, storage fields, and compressor stations, in Step 3.
  8. Require operators to provide data about pipeline facilities (Step 3) when they submit a change in entity operating (Type B) notification.
  9. Collect the miles of pipe and facility descriptions for each state.
  10. Add a “Guidance for Selecting the Appropriate Notification Type” section to the instructions.

Comments can be submitted via the E-Gov Website on or before May 30, 2014.

For a copy of the Federal Register notice, contact Jessica Roger.

TRRC Chapter 18, Underground Pipeline Damage Prevention

The Railroad Commission of Texas (TRRC) has posted the informal comments received by the TRRC concerning draft amendments to various rules in Chapter 18 to make some changes to clarify the intent of the rules, simplify some of the requirements, and streamline the process to the extent possible. You can find the comments by clicking here.

RCP Receives 3 Patents for MAOP Software

RCP has received 3 patents (#8,548,756; #8,548,757; and #8,548,758) for our industry-leading MaxOp* software. RCP is the unquestioned market leader providing MAOP Validation Services, including over 100,000 miles of gas and liquid pipeline analysis and support. Not only does RCP bring a wealth of experienced professional engineers and support staff, we have brought the most comprehensive and complete MAOP validation tool to the market, MaxOp*.

MaxOp* Features:

  • NEW Section Q & R, Gas Transmission Annual Report: output MAOP reports compliant with PHMSA requirements
  • Data agnostic: works with all common database and GIS data formats
  • Traceable: connects data to source document image files
  • Verifiable: identifies exact 192/195 code sections driving MAOP results

MAOP Validation Services:

  • Turnkey: document review & imaging, data extraction, gap analysis, MAOP reporting
  • Quality Assurance: review existing validation efforts, compare calculations using MaxOp*
  • Annual Report: Import data to MaxOp*, export Section Q & R report
  • Remediation: develop strategies to close gaps and/or re-establish MAOP

For more information about RCP’s MAOP validation services or the MaxOp* calculator tool, please contact Jessica Roger. * MaxOp is a registered trademark of RCP, Inc., in the United States.

Safety Management Systems Meeting

PHMSA hosted a workshop on the pending API Recommended Practice 1173 on Pipeline Safety Management System Requirements. The agenda and presentations from the workshop are available here. The draft document can be accessed here.

Public comments on the draft will be accepted until April 11, 2014. Comments must be submitted online at The ballot ID number is 3178 and no Login ID is required – leave the field blank. After clicking submit, the API legal disclaimer will open and must be accepted to proceed. After completing your contact information (this is required in case the development group needs to contact you about your comments) the actual page to enter comments appears.

Spring/Summer Conference Schedule

Have you registered and confirmed your reservations for these upcoming conferences? RCP and RCP Integrity Services will be attending. We hope to see you there!

AGA Operations Conference 2014
May 20 -23, 2014
Omni William Penn, Pittsburgh, PA

The annual AGA Operations Conference is the natural gas industry’s premier gathering of natural gas utility and transmission company operations management from across North America and the world for the sharing of technical knowledge, ideas and practices to promote the safe, reliable, and cost-effective delivery of natural gas to the end-user.

RCP’s Executive Consultant, Mr. Larry Decker will be giving a presentation on producing and documenting a quality pipeline pressure test report, “Utilization of an Advanced In-Situ Pressure Test Validation Mode.” This presentation describes the use and benefits of an advanced in-situ pressure test validation model that has been successfully utilized to identify small leaks during ramp up, spike and hold pressures. Example tests deemed “successful” using traditional recordkeeping methods that actually had small leaks will be demonstrated along with traceable, verifiable and complete report outputs.

Texas Gas Association (TGA) Operations & Management Conference
June 10 – 13, 2014
San Marcos, Texas

Louisiana Gas Association (LGA) 2014 Pipeline Safety Conference
July 21 – 25, 2014
New Orleans, LA

Western Regional Gas Conference (WRGC)
August 19 – 20, 2014
Tempe, AZ

RCP Pipeline Pressure Testing Workshop August 26 & 27

For the first time, RCP is offering a 2-day workshop on Pipeline Pressure Testing. RCP personnel have established themselves as industry experts, designing, implementing and validating pressure test programs for various operators. Recent PHMSA advisories and pending regulations will soon mandate pressure tests for operating gas and liquid pipelines that have not previously been subjected to pressured leak and strength tests. This course will provide an overview of how to efficiently plan, execute and document pipeline pressure tests that consistently satisfy code requirements as defined by CFR 49 Parts 192 and 195.

More information and class registration can be found on the RCP website.

ASME Training Week – Denver April 14 – 18

Check out the pipeline training programs offered by ASME in Denver the week of April 14-18, 2014. Subject Matter Experts from RCP will provide training on the first day regarding pipeline pressure testing. Other courses are offered on ASME B31.4 (liquid transmission) and ASME B31.8 (gas transmission), as well as Composite Repairs, Defect Assessment, Inline Inspection, Integrity Management, and Onshore Design and Construction. Additional information can be found on the ASME website.

PHMSA Class Location Methodology Public Workshop – April 16 Hilton Crystal City, Arlington, Virginia

The Pipeline and Hazardous Materials Safety Administration (PHMSA) is holding a public workshop along with the National Association of Pipeline Safety Representatives to present perspectives and seek comment on whether applying the gas pipeline integrity management requirements beyond high consequence areas would mitigate the need for class location requirements. This event is just one action in support of addressing Section 5(a)(2) of the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 (Pub. L. 112-90).

This public workshop will be held on Wednesday, April 16 from 9:00 a.m. to 4:00 p.m. More information about this event can be found on the PHMSA website.

Class Location Studies

The RCP Class Location Model is an advanced geospatial model with easy-to-use results, making it ideal for all sizes and lengths of natural gas pipelines. RCP is capable of providing an efficient, repeatable, and thoroughly documented class location study. The RCP Class Location Model works equally well with five or five thousand miles of pipe, and provides easy-to-interpret results in a variety of formats. For more information, contact Jessica Roger.

Send us your tired, your poor, your huddled masses of Pipeline Samples, yearning to breathe free.

Is your pipeline company merging? Divesting? Moving? Are old hands retiring, and clearing out their offices? No matter the reason, if you have interesting pipeline samples that need a new home, please let us know. We do training frequently, and would like to have physical pipe samples of corrosion, cracking, welding defects, seam defects, etc. Miniature models of smart pigs and other tools are also welcome. We promise to give them a good home – but call before shipping those 40’ pipe joints.

For more information, contact Jessica Roger. Or ship direct to: RCP Inc., 801 Louisiana Street, Suite 200, Houston, TX 77002.

Join RCP’s MS150 Team from Houston to Austin April 12 – 13

RCP hosts a small but enthusiastic team of riders in MS150 bike rides, including the upcoming BP MS150 on April 12-13 from Houston to Austin. Your humble newsletter editor is happy to suffer a bit for a good cause, but he has his limits. The RCP team rents a ranch outside LaGrange for the overnight stop on Saturday. Soft beds. Hot showers. Home cooked food. If you are interested. you can join our merry band here.

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