DOT Pipeline Compliance News

April 2018 Issue

In This Issue

GPAC Summary – Safety of Gas Transmission and Gathering NPRM

The Gas Pipeline Advisor Committee (GPAC) met for the 4th and 5th time in March to discuss the Notice of Proposed Rulemaking (NPRM) Safety of Gas Transmission and Gathering Pipelines. In addition to reviewing public and committee comments, PHMSA announced they will be splitting this NPRM into three separate final rulemakings.

The first final rule expected to be published will address the legislative mandates from the 2011 Pipeline Safety, Regulatory Certainty and Jobs Creation Act. The final rule will be called the Safety of Gas Transmission Pipelines: MAOP Reconfirmation, Expansion of Assessment Requirements, and Other Related Amendments and will address the following items:

  • 6-month grace period for 7 calendar-year reassessment intervals
  • Seismicity threats related to integrity management
  • MAOP exceedance reporting
  • Material verification, MAOP reconfirmation, & amendments related to §192.619
  • Non-HCA assessments and MCA definition
  • Related record provisions

The second final rule will be called the Safety of Gas Transmission Pipelines: Repair Criteria, Integrity Management Improvements, Cathodic Protection, Management of Change, and Other Related Amendments and will cover all remaining elements of the NPRM (except for gas gathering):

  • Repair criteria (HCA and non-HCA)
  • Inspections following extreme events
  • Safety features on ILI launchers and receivers
  • Management of change
  • Corrosion control
  • Integrity management clarifications
  • Strengthened assessment requirements

The third final rule will be called the Safety of Gas Gathering Pipelines and will address the following items for gas gathering:

  • Reporting requirements
  • Appropriate safety regulations for gas gathering lines in Class 1 locations
  • Definitions related to gas gathering

The GPAC has met five times since January 2017 to review public comments and make recommendations to PHMSA. The GPAC completed their review of the NPRM on March 28th, except for gas gathering. The next GPAC meeting, scheduled for September, will focus on gas gathering. A significant number of recommendations have been made to PHMSA to improve the NPRM. PHMSA has posted their slide presentations and GPAC voting slides at the following locations:

For more information, including a consolidated file with all of the GPAC voting slides, please contact Jessica Foley.

MAOP Reconfirmation, Expansion of Assessment Requirements Rule

RCP has been a market leader in providing MAOP Validation Services for over 20 years, including over 100,000 miles of gas and liquid pipeline analysis and support. RCP has a wealth of experienced engineers and support staff that are uniquely positioned to help our clients to understand and comply with the pending New Safety of Gas Transmission Pipelines: MAOP Reconfirmation, Expansion of Assessment Requirements Rule. For more information contact Jessica Foley.

April is National Safe Digging Month

The Common Ground Alliance (CGA) is a member-driven association of individuals, organizations and sponsors in every facet of the underground utility industry. CGA is committed to saving lives and preventing damage to underground infrastructure by promoting effective damage prevention practices. Damage prevention starts with one phone call, and since 2007 the phone number for that call has been 811. CGA has created several easy-to-use tools to help promote National Safe Digging Month (NSDM) and dialing 811. Visit the 811 Toolkit page on CGA’s website to download a suite of NSDM media materials, social media messages and infographics, advertising materials and more.

DOT Pipeline Compliance Workshop

JUNE 5 -7, 2018

Join RCP on June 5-7, 2018 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, 196, 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 PIPES Act of 2016; 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.

Colorado Flowline Rulemaking

[Docket No. 171200767]

The Colorado Oil and Gas Conservation Commission (COGCC) newly created Form 44 will be introduced to interested parties on April 17, 2018 at 9:45 AM following the April Industry Operation Meeting at the COGCC Denver Office. Meeting details and the Webcast instructions will be provided on the Operator Guidance page. For questions regarding Form 44, contact Ellice Whittington at

For a copy of COGCC’s PowerPoint overview of the rule with more detailed information about Form 44; or for a copy of the form release schedule, contact Jessica Foley.

Georgia Proposed Amendments to Petroleum Pipeline Permit Procedures

[GAC 391-3-23]

On March 8, 2018, the Georgia Department of Natural Resources (DNR) proposed amendments to the Georgia Rules for Petroleum Pipeline Eminent Domain Permit Procedures, Chapter 391-3-23. This notice, together with an exact copy of the proposed Rule amendments, a synopsis, and a statement of rationale of the rule revisions can be viewed by clicking here.

Written comments can be emailed to by close of business on April 13, 2018. Be sure to include the words “Proposed Petroleum Pipeline Permit Rule Amendments” somewhere in the subject line to help ensure that your comments will be forwarded to the correct staff.

The proposed Rule amendments will be considered for adoption by the Board of Natural Resources at its meeting on May 23, 2018 at 9:00 a.m. in the DNR Board Room located at 2 Martin Luther King Jr. Drive, SE, Suite 1252, East Tower, Atlanta, Georgia 30334. The meeting is open to the public.

Kentucky Pipeline Safety Measure

Kentucky legislators have been asked to bring Kentucky into federal compliance with certain aspects of the pipeline safety act. Currently, the “Call Before You Dig” 811 program is not mandatory in the State of Kentucky. Tom Fitzgerald with the Kentucky Resources Council said the measure broadens the state’s involvement when pipelines are severed during digging. The State Public Service Commission would get notice of any pipeline damage within 30 days of the incident. “They will be able to compile that information and hopefully will help in the development of a mandatory notice program,” said Fitzgerald.

In February, legislation addressing these issues passed the Senate Natural Resources and Energy Committee. Fitzgerald said the legislation currently being considered in the general assembly also gives the state the ability to enforce federal penalties.

Final Integrity Management Requirements Expected Soon

PHMSA’s Final Rule containing new integrity management improvement requirements may be here sooner than you expect. RCP’s broad, deep understanding of the operational integrity issues clients face combined with our In-depth understanding of the regulations, standards, and engineering requirements behind the rules, has earned RCP a worldwide reputation for providing high-quality, highly effective integrity management services. If you have questions about the pending Safety of Gas Transmission Pipelines: Repair Criteria, Integrity Management Improvements, Cathodic Protection, Management of Change, and Other Related Amendments rule or need help with your Integrity Management Program contact Jessica Foley.

TRRC Accepting Comments on New Proposed Pipeline Safety Fees

The Railroad Commission of Texas (TRRC) is accepting comments until May 7, 2018 on the new proposed pipeline fees to fund the TRRC’s pipeline safety program. The TRRC is establishing the fees at the direction of the Legislature in the Commission’s Sunset Bill, House Bill 1818 passed in 2017. The new proposed fees are divided into two groups: Group A and Group B pipelines.

  • Group A Pipelines are natural gas transmission and storage pipelines; hazardous liquids transmission and storage pipelines; and hazardous liquids gathering pipelines. Proposed fees for Group A pipes are a $20 per mile annual fee; and a $500 fee for a new permit or permit renewal.
  • Group B Pipelines are intrastate (pipelines that begin and end within Texas) production and gathering pipelines that leave a lease. Proposed fees for Group B pipes are a $10 per mile annual fee, and a $500 fee for a new permit or permit renewal.

More information on the proposed rule and fees can be found under Chapter 3: Oil & Gas Division; 3.70 here.

Utah Regulations R307-505

[DAR File No.: 42110]

Effective March 1, 2018, Utah Administrative Code added Rule 505 – Oil and Gas Industry: Registration Requirements to Title R307 – Environmental Quality: Air Quality. R307-505 establishes requirements for sources in the oil and gas industry to register with the Division of Air Quality. R307-505 applies to new and existing operations at a source with Standard Industrial Classification codes in the major group 13, which includes but is not limited to industries involved in oil and natural gas exploration, production, and transmission operations; well production facilities; natural gas compressor stations; natural gas processing plants and commercial oil and gas disposal wells, and evaporation ponds. This rule covers both existing and new operations:

  • New operations on or after January 1, 2018, shall register with the director 30 days prior to commencing operation.
  • An owner or operator that is in operation before January 1, 2018, shall register with the director by July 1, 2018.

More information can be found on the Utah Office of Administrative Rules website.

California OSFM Hazardous Liquid Pipeline Safety Seminar


The Office of the State Fire Marshall (OSFM), Pipeline Safety Division is holding their 2018 Pipeline Safety Seminar on Wednesday, April 18, in Long Beach, California. This 1-day seminar will be of interest to pipeline industry personnel as well as local and state agency personnel who wish to gain a better understanding of the regulations that pertain to the safe operation of pipelines that transport hazardous liquid throughout California. Registration information and agenda can be found by clicking here.

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.

2018 Industry Conference Schedule

July 22 – 25, 2018
Hilton Portland Downtown
Portland, OR

The American Public Gas Association (APGA) Annual Conference is the largest gathering of municipal natural gas professionals across the nation. From the educational sessions with key industry figures generating new ideas to networking opportunities with hundreds of colleagues from across the nation, the APGA Annual Conference is the event of the year for city- and community-owned natural gas utility professionals and industry experts.

July 30 – August 1, 2018
Tampa Marriott Waterside Hotel & Marina
Tampa, Florida

The SGA Operating Conference format is a focused round table discussion. Attendees learn smart practices and lessons learned from their peers with 22 concurrent facilitated sessions to choose from. Breakout sessions with presentations from subject matter experts open the conference following the keynote address. Make plans to visit the exhibit hall, which will include over 100 services and product service organizations showcasing the latest products and services available to the industry.

July 30 – August 3, 2018
Astor Crowne Plaza, New Orleans

RCP is once again a proud sponsor and exhibitor at this year’s conference, which has been referred to as the “Premier Pipeline Safety Conference.” We are excited to showcase our newest developments and all our services for Pressure Test support.

August 28 – 29, 2018
(Note: Updated conference dates!)
M Resort in Henderson, Nevada

The Western Regional Gas Conference provides a forum for the free exchange of information between natural gas companies and their state and federal regulators, and with associated industry organizations, consultants, manufacturers and vendors that serve the pipeline industry.

August 21 – 22, 2018
AT&T Conference Center in Austin, TX

This year the Railroad Commission of Texas (RRC) combines its two largest regulatory conferences, the Pipeline Safety Conference and the Oil & Gas Regulatory Conference, into one event. Registration is now open for the 2018 RRC Regulatory Conference: Environmental Protection, Pipeline Safety and Well Filings. Early bird registration ends July 23rd. For additional conference information and to register, visit the RRC’s website.

October 10, 2018
San Luis Hotel, Galveston

October 18-19, 2018
Hotel Monteleone, New Orleans

Each year since 2006, the Pipeline Safety Trust has hosted pipeline safety conferences. What makes them unique among pipeline conferences is the mix of attendees, who come with experience as the affected public, the pipeline industry, and government regulators. All these people come together to discuss barriers to safer pipelines.

October 30 – Nov 1, 2018
The Chattanooga Hotel
Chattanooga, TN

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


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