DOT Pipeline Compliance News

April 2016 Issue

In This Issue

PHMSA Gas Transmission NPRM

[DOCKET NO. PHMSA-2011-0023 RIN 2137-AE72]

The Pipeline Hazardous Materials Safety Administration (PHMSA) intends to publish a Notice of Proposed Rulemaking (NRPM) to revise the Pipeline Safety Regulations applicable to the safety of onshore gas transmission and gathering pipelines. The proposals within this rule cover many different aspects of the safety of these pipelines, including:

  • New definitions, including Moderate Consequence Areas
  • New standards incorporated by reference
  • Expansion of regulated gas gathering
  • Additional corrosion control measures
  • Spike testing requirements
  • Material verification
  • MAOP verification
  • Removal of the “Grandfather Clause” (§192.619(c)) for MAOP determination
  • Additional integrity assessment and repair criteria
  • Data gathering and integration
  • Management of change
  • Inspection of pipelines following weather events
  • Records retention schedule

Once the NPRM is officially published in the Federal Register, RCP will send out a special edition newsletter that will be just on this rule. In the interim, contact Jessica Foley for a pre-publication version.

Louisiana State Regulation Changes Concerning Salt Dome Storage


Changes were made to Louisiana state regulations concerning Hydrocarbon Storage Wells in Salt Dome Cavities ( and Class III (Solution Mining) Injection Wells ( Salt dome storage development and activity has come under increasing scrutiny at the state and federal levels, and these changes reflect the additional interest in these operations.

Two of the changes that can potentially mean more work and expense for the owner / operator involve the new permitting regime, which has many more steps than in the past, and a change to a 15 year frequency for refilling caverns with water and running multiple integrity tests. Other changes are summarized below.

For Title 43, Part XVII.3.3 – Hydrocarbon Storage Wells in Salt Dome Cavities, changes to the regulations include:

  • §303.B. This modification involves Statewide Orders 29-M and 29-M (Revision 3) and requirements for compliance.
  • §303.G. Additional Requirements: these are now given in much greater detail, and reports must be submitted by licensed professional geoscientists and licensed professional engineers.
  • §309.B.1. The financial responsibility requirements are now expanded to explicitly include class II saltwater disposal wells and any associated equipment or pipelines whether located inside or outside of the permitted facility boundary.
  • §309.B.3. and 4. The information on Assistance to Residents has been removed for other parts of the regulation and consolidated and expanded in new subpart 3. The new subpart 4 contains a description of reimbursement to states and individuals.
  • §309.F.9. Under Notification Requirements, there is an addition that requires that hydrocarbon storage caverns that are not in an inactive status as of the date written notification of permanent conclusion of storage operations is submitted to the Office of Conservation will be immediately placed in an inactive status.
  • §309.K.1. This section, under Compliance Review, now gives a detailed list of acceptable submittals for satisfying cavern location and periphery of salt stock review.
  • §311.D.1.c. This is a new section under Public Hearing Requirements as part of the Permitting Process that pertains only to Iberia Parish, and concerns the requirement of a public hearing prior to the issuing of certain salt cavern permits.
  • §315.B.3.d. Regarding salt periphery under Cavern Design, this new section will allow caverns with less than 300 feet but more than 100 feet of salt separation to continue to operate with enhanced monitoring and any additional documentation that the commissioner feels necessary in the interest of safe operations.
  • §327. A Mechanical Integrity Test (MIT) must now be performed prior to well closure except in the event of mechanical failure in the cavern. Additionally, a separate pressure test on the casing, of at least 60 minutes, shall be performed when an MIT is run.
  • §329. Concerning cavern configuration and capacity, types and frequency of surveys are more detailed.
  • §331. Inactive caverns may not be returned to service without the submittal of a written request and work permit application to the Office of Conservation, and the approval of the commissioner.

Similar changes were made in Title 43, Part XVII.5.33 – Class III (Solution Mining) Injection Wells.

RCP Integrity Services: Salt Domes, Too!

RCP has the tools and expertise to develop comprehensive Integrity Management Plans and implementation for liquid and gas pipelines, and salt dome storage facilities. If you would like information on RCP’s Integrity Management Services, contact Jessica Foley.

PHMSA Oil Spill Response Planning and Preparedness Public Workshop April 12, 2016

[DOCKET NO. PHMSA-2016-0021]

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) will hold a public workshop to address oil spill response planning and preparedness. This workshop will include how to harmonize PHMSA’s regulations with the requirements of other agencies, and how operators of onshore oil pipelines can prepare for an oil spill. The public workshop will held on Tuesday, April 12, 2016, from 9:00 a.m. to 4:30 p.m. EST. Changes to start and finish times will be updated on the PHMSA Meeting Website.

The workshop will be held at the National Transportation Safety Board Conference Center located in L’Enfant Plaza at 490 L’Enfant Plaza East SW, Washington, DC. If you are unable to attend in person, webcasting will be provided by The Capitol Connections. The links will be provided as the event nears. You can test your system through It is recommended to do this prior to the date of the event.

Registration and additional information are available on the PHMSA website.

DOT Pipeline Compliance Workshop – Gas & Liquid

APRIL 12-14, 2016

Join us April 12-14, 2016 in Houston at our corporate office and dedicated training facility for an informative, lively, and interactive workshop on DOT Pipeline Compliance topics. The workshop provides an overview of the DOT pipeline regulations in 49 CFR 191, 192, 194, 195, and 199. It also describes pipeline operations and engineering concepts. It is appropriate for people who are new to pipeline regulations, who could use a refresher, or anyone who needs to know the latest developments in these areas. This workshop will be a combined format, addressing both gas and liquid pipeline topics in parallel. This will eliminate some redundancy of materials, and will allow more time for in-depth discussions for each topic.

Topics to be addressed in the workshop include:
  • An overview of DOT/OPS pipeline compliance requirements
  • State and Federal agency roles for pipeline safety
  • PHMSA Jurisdiction
  • PHMSA Inspections and Enforcement Processes
  • Engineering Concepts and Stress – Strain Relationships; %SMYS
  • Design Requirements
  • Construction Requirements
  • Corrosion Control Concepts and Requirements
  • Operations and Maintenance Requirements
  • Emergency Response Requirements (including spill response planning requirements for liquid pipelines)
  • Damage Prevention Programs
  • Operator Qualification Programs
  • Drug and Alcohol Programs
  • Public Awareness Programs
  • Integrity Management (gas and liquid) Programs
  • Control Room Management Programs

We will also discuss the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 (pipeline reauthorization bill), recent Advisory Bulletins from PHMSA, and new, pending and proposed rulemakings.

Each attendee will receive the presentation as well as applicable handouts in a hardcopy notebook, and electronic copies of the applicable regulations and voluminous reference materials including rulemakings, letters of interpretation, and other guidance documents. The workshop will adjourn at 2 p.m. on the third day, for those who need to fly out Thursday evening.

To register for our workshop, click here.

API Liquids Pipeline Safety Management System (PSMS) Workshop – Encore!

The API workshop on Pipeline Safety Management Systems on February 16th of this year was sold out with more than 100 people in attendance – so a second workshop similar to the first has been scheduled for April 26th. This workshop is designed to provide liquids pipeline companies with tools and knowledge to implement API Recommended Practice 1173 Pipeline Safety Management System. To encourage an open sharing of ideas and implementation challenges, the workshop is open to employees of liquid pipeline operating companies only.

The Workshop will be held at the Hyatt Regency Houston Galleria, 2626 Sage Road, Houston, TX 77056. Hotel room reservations deadline is April 11, 2016. The workshop registration, hotel information and a preliminary program can be found on the API Website.

API RP1173 Assessment Services

API recently published a new Recommended Practice (RP) concerning safety management systems for pipelines. API RP 1173 provides pipeline operators with a comprehensive way to make safe operations and continuous safety improvement a constant focus of their operations. The first step for most pipeline operators will be to assess their current safety management system maturity – from nothing in place to a sustainable, improving system. RCP can assist operators in the evaluation of the maturity levels of each element of the recommended practice, and establish an action plan for further development / maturity. Contact Jessica Foley for API RP 1173 Assistance.

Pressure Testing Webinar – Advantages of Using TestOp®

RCP will be hosting webinar presentations to discuss pipeline pressure testing practices and demonstrate the advantages of utilizing new technology for planning, designing, and capturing real-time data to validate and document whether it was a successful test. The same technology that RCP has used for the past six years to validate our customer’s pressure tests has been greatly enhanced and is now being made available as a web-hosted solution for operators to use themselves.

TestOp® takes the confusion out of pressure testing by providing real-time determination of whether the test segment is experiencing potential issues, such as yielding or air entrapment volume absorption, all while modeling the mass balance relationship of pressures, volumes and temperatures of the test. TestOp® will provide real-time indicators and corresponding data to confirm whether the test is successfully performing to plan or if there might be a small pin-hole leak that would otherwise go undetected before taking the line segment off test. TestOp® generates comprehensive and consistent reports, including a certification letter, pressure test plan versus actual test results, pressure/spike test log, test instrument and pump calibrations, pipe volume calculations sheet, stress/strain and pressure/volume plots as well as upload capability for pictures and other document scans associated with the test.

We encourage any liquid or gas pipeline operator who has upcoming projects that involve replacement, integrity verification, new construction, uprates, conversions and/or reversals to sign up for the 45 minute webinar. Some of the largest and most respected pipeline operators are now using TestOp® because they see the value it brings to their overall pipeline integrity assurance program and we are confident you will too once you have seen it in person.

Mark your calendar and plan to attend one of these sessions or request an individual demonstration for your company at a date convenient to you.

Maine Updates Underground Facility Damage Prevention Requirements

Last summer, Maine updated portions of its Underground Facility Damage Prevention Requirements (Maine State Regulations 65-407 Chapter 895) regarding Dig Safe System notifications and OKTODIG database. Effective March 14, 2016, additional updates to the regulation take effect. Excavations must now commence within 30 days of the notification to the Dig Safe System from the previous 60 days. Also, if the proposed excavation or blasting is not fully completed 60 calendar days after notification, the excavator shall re-notify the Dig Safe System. Additional information on the Maine Underground Damage Prevention Program can be found by visiting the Maine Public Utilities Commission.

National Safe Digging Month

April is National Safe Digging Month (NSDM) and the Common Ground Alliance (CGA) wants to hear about the creative ways that you will be spreading the word about the importance of calling 811 before digging. They’ve created several easy-to-use tools and templates to get you started:

However you’re spreading the 811 safety message this month, please be sure to email with information and photos as well as filling out this quick NSDM survey.

Pipeline Conference Schedule – Spring 2016

Have you registered and confirmed your reservations for the AGA Operations Conference? RCP will be attending. We hope to see you there!

AGA Operations Conference
April 19 – 22, 2016
Arizona Biltmore / Phoenix, AZ

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. The Operations Conference is AGA’s largest forum with regularly more than 500 operations management in attendance, including 80 speakers, and over 100 technical presentations.

Mark your calendar and plan to attend one of these sessions on Thursday, April 21st from RCP staff:

  • Track D2 / 8:00 a.m.: “Development of Industry Guidelines for the Engineering Critical Assessment Process Under Integrity Verification”
  • Track G3 / 3:35 p.m.: “Is an 8-hour pressure test long enough?”

RCP is also hosting a special reception in The Biltmore “Gold Room” on April 20 (Wednesday) from 6 – 9 p.m. There will be cocktails, hors d’oeuvres, live entertainment and more. Keep checking your inbox for an invitation!

PHMSA Public Workshop on LNG Regulations May 18-19, 2016

[DOCKET NO. PHMSA- 2016-0005]

PHMSA will hold a public workshop to solicit input and information on future regulatory changes to the Part 193 regulations governing liquefied natural gas (LNG) facilities. According to PHMSA, existing regulations may not adequately incorporate risk-based assessments, process safety practices, and technologies that have been developed since the 1970s when most LNG facilities were constructed.

The workshop will be held at the DOT headquarters, West Building Atrium, 1200 New Jersey Ave., SE in Washington, DC and will be webcast. To submit comments before or after the meeting via the E-Gov Websitereference Docket No. PHMSA- 2016-0005 and follow the instructions.

Online registration and additional information are available on the PHMSA Meeting Website.

PHMSA Incident and Annual Data Analysis

RCP has designed a Pipeline Database Query tool, PDQ™, which researches gas transmission, gas distribution, or hazardous liquid pipelines based on PHMSA accident or infrastructure data. Have you ever wondered: How does your company stack up against your peers in accident rates? How do you weigh the risk based on the materials and age of your pipeline against industry trends? PDQ™ can answer these questions and more. For more information, contact Jessica Foley.

Save the Dates!

RCP Workshop Schedule for 2017

  • DOT Gas & Liquid Pipeline Workshop: March 21-23 (Tuesday, Wednesday & Thursday)
  • Fundamentals of Pipeline Operations Workshop: May 24-25 (Wednesday & Thursday)
  • Pressure Test Workshop: June 20-21 (Tuesday & Wednesday)

Visit our training website for updates, registration, and hotel information.

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