DOT Pipeline Compliance News

August 2010 Issue

In This Issue

Technical Pipeline Safety Advisory Committee Teleconference Meetings

[Docket No. PHMSA-2009-0203]

The Technical Pipeline Safety Standards Committee (TPSSC) and the Technical Hazardous Liquid Pipeline Safety Standards Committee (THLPSSC) will meet via teleconference on Thursday, August 19, 2010, from 1 p.m. to 4 p.m. EST. The purpose of the meeting is to keep the members updated on current safety concerns, proposed rules, and future proposals. The PHMSA staff will brief the committees on several regulatory and policy initiatives including:

  • Pipeline safety reauthorization.
  • PHMSA accomplishments (National Transportation Safety Board, General Accounting Office, Congressional mandates).
  • PHMSA priorities (new construction, damage prevention), and the status of PHMSA rulemaking initiatives.
  • Administrative matters of the committee (charter, how we can best conduct business).

These two statutorily-mandated committees advise PHMSA on proposed safety standards, risk assessments, and safety policies for natural gas pipelines and for hazardous liquid pipelines. Each committee consists of 15 members-with membership evenly divided among the Federal and State Government, the regulated industry, and the public. The committees advise PHMSA on technical feasibility, practicability, and cost-effectiveness of each proposed pipeline safety standard.

PHMSA will post any new information or changes on the PHMSA/Office of Pipeline Safety web page about 15 days before the meeting takes place. For further information contact: Cheryl Whetsel by phone at 202-366-4431 or by e-mail.

To participate in this meeting:

  • The public may attend the meeting at the U.S. Department of Transportation, 1200 New Jersey Avenue, SE., Washington, DC 20590, Room E27-302. Attendees should register in advance at
  • Or, you may join us at RCP’s office at 801 Louisiana, Ste. 200, Houston, TX to watch and listen via LiveMeeting. Click here to participate at RCP’s office.

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) issued ADB-10-06 on July 27, 2010 to gas and liquid pipeline operators regarding the use of PEDs by pipeline employees who are performing operations and maintenance activities. PHMSA reminds owners and operators of natural gas and hazardous liquid pipeline facilities that there may be increased risks associated with the use of PEDs by individuals performing activities that affect pipeline operation or integrity. Pipeline operations and maintenance tasks require a critical level of attention and skill, which may be compromised by visual, manual, and cognitive distractions caused by the use of PEDs. Such distractions may also hinder their prompt recognition and reaction to abnormal operating conditions and emergencies.

Owners and operators of natural gas and hazardous liquid pipeline facilities should integrate into their written procedures for operations and maintenance appropriate controls regarding the personal use of PEDs by individuals performing pipeline tasks that may affect the operation or integrity of a pipeline. PHMSA is not discouraging the use of PEDs as a part of normal business operations. Owners and operators should also provide guidance and training for all personnel about the risks associated with the use of PEDs while driving and while performing activities on behalf of the company if that use poses a risk to safety.

For a copy of ADB-10-6 on Personal Electronic Device (PED) Related Distractions, 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. 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.

PHMSA Updates DIMP FAQ’s August 2, 2010

PHMSA has posted Frequently Asked Questions for the recently finalized Distribution Integrity Management Program regulation. We have inserted a few noteworthy FAQ’s below. To view the entire list of FAQ’s, click here.

A.8 The regulation exempts the installation of EFVs on services which do not operate at a pressure of 10 psig or greater throughout the year. Can you give examples of types of documentation that would be acceptable in demonstrating this issue?
Two possible methods to demonstrate that services operate at a pressure less than 10 PSIG include; (1) distribution system design documents, validated with actual pressure readings, which show that the main and therefore the associated services are designed to operate below 10 PSIG, or (2) actual pressure recordings or readings on all feeds which are upstream of the service(s) which are less than 10 psig.

B.2.2 Will operators be compared against other operators or national leak or safety data?
PHMSA recognizes that operators need to develop a DIMP plan appropriate for the applicable threats, the operating characteristics of their specific distribution delivery system, and the customers that they serve. PHMSA and State partners intend to focus on each individual operator’s performance trends.

C.3.7 Are operators required to include “farm taps” in their distribution integrity management plan?
In the past, distribution, gathering, and transmission operators connected landowners directly to transmission and gathering pipelines often in exchange for the right to install the pipeline across a landowner’s property. This connection to the gas pipeline is commonly referred to as a “farm tap”. Although new farm taps are not installed nearly as frequently as they were in the past, “farm taps” are very common. The vast majority of “farm taps” meet the definition of a distribution line given that they do not meet the criteria to be classified as a gathering line or a transmission line.

The “farm tap” is pipeline upstream of the outlet of the customer meter or connection to the customer meter, whichever is further downstream, and is responsibility of the operator. The pipeline downstream of this point is the responsibility of the customer. Some States require the operator to maintain certain portions of customer owned pipeline. The pipeline maintained by the operator must be in compliance with 49 Part 192.

Operators of distribution, gathering, and transmission lines with “farm taps” must have a distribution integrity management program meeting the requirements of Subpart P for this distribution pipeline. The DIMP plan is not required to include the customer-owned pipeline (unless required otherwise by State law). The operator having responsibility for operations and maintenance activities for the facility is responsible for developing and implementing the DIMP plan.

C.4.c.2 From which date are operators required to collect data for their Plan?
Operators should use the information they already have and start keeping additional data to develop their plan (e.g., assess the threats) as soon as possible. They need to assemble and evaluate enough data to be able to evaluate the risk. Useful and usable historical data is needed to identify threats and trends.

C.4.g.5 Are multiple tickets for a single job counted as single excavation ticket?
Some state laws require excavators to call in additional requests for on-going jobs prior to the life of the first excavation request expiring. In reporting data these additional requests for excavation projects of extended duration may be counted since there is excavation work associated with those requests. However, operators do not need to change the criteria for counting excavation tickets for the purpose of reporting performance measures. If they currently count multiple tickets for a single job, they may continue that practice. The definition of “ticket” should remain consistent with State law and one-call center definition.

C.5.5 Must operators report to PHMSA mechanical fitting failures that occurred historically (i.e., before a final DIMP rule became effective)?
Currently the DIMP rule states that operators need to collect data about mechanical fitting failures that result in hazardous leaks starting January 1, 2010 but PHMSA published a Federal Register notice on June 28, 2010 to inform operators that the portion of the Annual Report relative to mechanical fitting failures will be delayed by one year and will take effect starting with the 2011 calendar year. PHMSA is developing a final rule to revise the dates in the regulation.

C.7.2 What will PHMSA (or States) require for proposals for alternate inspection intervals?
Proposals must be submitted to each applicable oversight agency (usually the State). Each State will implement this provision under the State’s procedures. State authorities and regulatory structures differ. Requirements for consideration of an alternative interval may differ among State regulatory authorities. The regulatory authority will be responsible for reviewing each proposal, determining safe intervals based on the information in the operator’s proposal, and approving or rejecting the proposal.

Proposed alternative inspection intervals must demonstrate an equal or improved overall level of safety including the effect of the reduced frequency of periodic inspections. A quantitative estimate of risk is not required. PHMSA is developing criteria for evaluating an operator’s alternative interval proposal in the states where PHMSA exercises enforcement authority over distribution pipelines.

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.

SPCC Extension Proposed for some Facilities

[Docket ID No. EPA-HQ-OPA-2009-0880]

The EPA has proposed to amend the dates in 40 CFR §112.3(a), (b) and (c) by which the owners/operators of facilities must prepare or amend their SPCC Plans, and implement those Plans, to November 10, 2011, which is one year from the current SPCC compliance date of November 10, 2010.

This proposed extension of the compliance date does not apply to drilling, production or workover facilities that are completely offshore or that have both onshore and offshore components (e.g., an oil production facility with offshore wellheads connected to an onshore tank battery by submerged flowlines).

This proposed extension of the compliance date also does not apply to onshore facilities required to have and submit Facility Response Plans (FRPs, also known as OPA-90 Plans). FRP facilities are those with storage capacities of 1 million gallons or more that meet certain criteria, or those with storage capacities at or above 42,000 gallons and that transfer oil to or from a vessel over water (40 CFR Part 112.20 and 112.21). It should also be noted the Agency has not changed any compliance dates with respect to the FRP regulations.

Comments on this proposed rule must be received by August 18, 2010. Please submit your comments on the proposed amendments at Follow the online instructions to comment on Docket ID No. EPA-HQ-OPA-2009-0880.

Maine Safety & Operation Standards for LPG Distribution Systems

Adopted Rule Number: 2010-219

The State of Maine, Public Utilities Commission adopts this rulemaking of a new Chapter 421, Safety and Operation Standards for Liquefied Petroleum Gas (LPG) Distribution Systems, that sets forth safety and operation standards specifically for jurisdictional liquid propane gas transmission and distribution systems. Additionally, the new Chapter 421 expands and clarifies the requirements for the operation, installation, and maintenance of liquid propane gas transmission and distribution systems.

EFFECTIVE DATE: June 9, 2010

For more information, contact: Paula J. Cyr, Public Utilities Commission, 18 State House Station, Augusta, ME 04333-0018. Telephone: (207) 287-3831. E-mail:

For a copy of Chapter 421, contact Jessica Roger.

Misc. Ohio Pipeline Safety Regulation Changes

The Ohio Public Utilities Commission has made several miscellaneous changes to their gas pipeline safety regulations, such as revising the definition of Master Meter System; updating the date of incorporated federal regulations; modifying their leak classification and repair requirements; and giving the commission the right to waive any requirement of their regulations with good cause.

Pending Audits?

Has the DOT notified you of a pending audit? RCP can provide confidential internal auditing to help ensure that your facilities are up to the agency’s latest standards.
Click Here.

Underground Pipeline Damage Prevention Workshop August 18, 2010 – Austin, Texas

The Texas Railroad Commission is planning a Regulatory Workshop on Title 16 – Texas Administrative Code, Chapter 18 – Underground Pipeline Damage Prevention rule provisions that relate to prevention of damage to pipeline facilities resulting from movement of earth, including safety standards and best practices. The public and industry are invited to attend and provide comments. At this time there is not a set agenda for this meeting. The format is an informal gathering where interested parties, stakeholders, regulated industry and the general public will have an opportunity to present suggestions on Chapter 18 rule revisions for consideration.

The workshop will be held in Austin, Texas on August 18, 2010, at 10:00 a.m. at the William B. Travis Bldg., 1701 N. Congress Ave, Room 1-111.

Please provide the number of persons attending along with individual names and whom you are representing, and if you and/or your company, association or group would like to give a presentation on suggested rule revisions during the workshop to the RRC and meeting attendees.

Please reply with response via email to or 512-463-9119.

DOT Pipeline Compliance Workshop – October 19 – 21, 2010

Join us October 19 – 21 in Houston at our new office and dedicated training facility for an informative, lively, and interactive workshop on DOT Pipeline Compliance and OPA Planning for DOT Pipelines. This workshop has been attended by hundreds of pipeline personnel, with excellent feedback. The workshop provides an overview of the DOT pipeline regulations, and is appropriate for people who are new to pipeline regulations, who could use a refresher, or anyone who needs to know the latest information in these areas.


Day 1 (October 19): Gas Pipeline Regulations (49CFR192)
The workshop will include an introduction to DOT/OPS pipeline compliance; State and Federal program variations; roles and responsibilities; design, construction, operations, maintenance, and emergency response requirements; how to monitor rulemaking activity and stay current with your compliance program; operator qualification, public awareness; with a specific emphasis on the gas integrity management regulations. Each attendee will receive general training materials which include the applicable DOT 49 CFR 192 regulations for gas pipelines (cd-rom), inspection checklists, and speaker’s PowerPoint presentation handouts.

Day 2 (October 20): Special Topics
Back by popular demand! RCP is conducting a special workshop day to discuss topics that many of our clients have expressed an interest in:

  • Control Room Management
  • PHMSA reporting requirements and enforcement activities
  • DIMP implementation strategies
  • Public Awareness effectiveness evaluation & updates to RP 1162
  • Crude oil gathering & low stress liquid lines regulatory developments
  • Oil spill response plan developments

Each attendee will receive general training materials and speaker’s PowerPoint presentation handouts.

Day 3 (October 21): Liquid Pipeline Regulations (49CFR195)
The workshop will include an introduction to DOT/OPS pipeline compliance; State and Federal program variations, roles and responsibilities; design, construction, operations, maintenance, and emergency response requirements; spill response planning requirements; how to monitor rulemaking activity and stay current with your compliance program; operator qualification and public awareness. Each attendee will receive general training materials which include the applicable DOT 49 CFR 195 regulations for hazardous liquid pipelines (cd-rom), inspection checklists, and speaker’s PowerPoint presentation handouts.

To register, or for additional information, click here.

WRGC Regional Gas Conference August 24 & 25, 2010 Tempe, AZ

Join us at the 2010 Western Regional Gas Conference at the Tempe Mission Palms Hotel & Conference Center in Tempe, Arizona. RCP representatives will be attending the conference and look forward to meeting you. Chris Foley (RCP Vice President) will be giving a presentation on “Effective Compliance Assessment Methods & Successful Agency Audit Strategies Forum” on Tuesday, August 24. Click here to check for updates on the conference agenda and registration. (WRGC is a non-profit and volunteer-organized event to provide a venue for discussion of natural gas distribution and transmission issues.)

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