DOT Pipeline Compliance News

August 2016 Issue

In This Issue

Pipeline Pressure Testing Workshop: August 16-17, 2016

RCP is now offering a 2-day Pipeline Pressure Testing Workshop at its facilities in downtown Houston. The workshop will begin by outlining the objectives for performing a pressure test and how those relate to DOT requirements. The workshop will then build upon these foundations to answer many specific pressure testing questions including:

  • What are the different types of tests commonly conducted and how do you design each one?
  • What is the theory and physical science behind a pressure test?
  • How do you plan for a pressure test from start to finish:
    • Cleaning the line
    • Environmental hazards and permitting
    • Landowner and operations safety
    • Customer/stakeholder impact
    • Logistical details and scheduling
    • Pipeline modifications and anticipating failures
  • What is the required instrumentation and how does it need to be configured?
  • What data is absolutely necessary to validate a pressure test?
  • How do you determine and prove a successful pressure test?
  • What does a good test report look like (that will also satisfy PHMSA)?

Each attendee will receive the presentation as well as applicable handouts in a hardcopy notebook. Attendees will also have the opportunity to work through several exercises specifically covering 1) calculating the SMYS, MAOP and test pressures for various pipeline segments at various elevations 2) calculating the volume of water required for a hydrotest, fill times and velocities, and determining how the volume of test water changes with pressure and 3) designing a complete test plan for a hypothetical pipeline, i.e., dividing the line into test sections and determining the test parameters for each section.

To register for our workshop, click here.

PHMSA Projected Rulemaking Dates

Since we last reported on PHMSA’s projected rulemaking dates (January 2016 edition of the DOT Pipeline Compliance News), there have been several changes to the projected publications dates for regulations that will affect gas and liquid pipelines. A quick reference table for the pipeline safety regulations that are affected is provided below with a short description of each rulemaking after the table. Click here for the full report.

NPRM: Notice of Proposed Rulemaking
RRR: Retrospective Regulatory Review

Excess Flow Valves
[Docket No. PHMSA-2011-0009]
This rulemaking would require excess flow valves (EFVs) be installed in all new and renewed gas service lines, for structures other than single family dwellings, when the operating conditions are compatible with readily available valves. These changes would be in response to NTSB and PHMSA investigations of current EFV installation practices. The intended effect of the rule is to increase the level of safety for structures other than single family dwellings currently subject to Federal pipeline safety regulation.

Safety of On-Shore Liquid Hazardous Pipelines
[Docket No. PHMSA-2010-0229]
This rulemaking would address effective procedures that hazardous liquid operators can use to improve the protection of High Consequence Areas (HCA) and other vulnerable areas along their hazardous liquid onshore pipelines. PHMSA is considering whether changes are needed to the regulations covering hazardous liquid onshore pipelines, whether other areas should be included as HCAs for integrity management (IM) protections, what the repair timeframes should be for areas outside the HCAs that are assessed as part of the IM program, whether leak detection standards are necessary, valve spacing requirements are needed on new construction or existing pipelines, and PHMSA should extend regulation to certain pipelines currently exempt from regulation. The agency would also address the public safety and environmental aspects any new requirements as well as the cost implications and regulatory burden.

Amendments to Parts 192 and 195 to require Valve installation and Minimum Rupture Detection Standards
[Docket No. (not assigned yet) / RIN 2137-AF06]
This rule would propose installation of automatic shutoff valves, remote controlled valves, or equivalent technology and establish performance based meaningful metrics for rupture detection for gas and liquid transmission pipelines. The overall intent is that rupture detection metrics will be integrated with ASV and RCV placement with the objective of improving overall incident response. Rupture response metrics would focus on mitigating large, unsafe, uncontrolled release events that have a greater potential consequence. The areas proposed to be covered include High Consequence Areas (HCA) for hazardous liquids and HCA, Class 3 and 4 for natural gas (including could affect areas).

Gas Transmission (RRR)
[Docket No. PHMSA-2011-0023]
In this rulemaking, PHMSA will be revisiting the requirements in the Pipeline Safety Regulations addressing integrity management principles for Gas Transmission pipelines. In particular, PHMSA will address: repair criteria for both HCA and non-HCA areas, assessment methods, validating & integrating pipeline data, risk assessments, knowledge gained through the IM program, corrosion control, change management, gathering lines, and safety features on launchers and receivers.

Operator Qualification, Cost Recovery and Other Pipeline Safety Proposed Changes
[Docket No. PHMSA 2013-0163]
This rulemaking would address various issues that are included in the most recent Pipeline Safety Act, including: Operator Qualification for new construction, incident reporting criteria, cost recovery processes, transportation of non-supercritical carbon dioxide, and renewal process for special permits.

Underground Gas Storage Workshops

The Department of Energy, supported by several national laboratories, sponsored a “Workshop on Well Integrity for Natural Gas Storage in Depleted Reservoirs and Aquifers” on July 12-13, 2016, followed by a 1-day meeting workshop hosted by PHMSA on “Underground Natural Gas Storage.” All 3 days of meetings were attended by PHMSA Administrator, Marie Therese Dominguez, and DOE Under Secretary for Science and Energy, Franklin Orr, which is a clear indication of the importance both DOE and PHMSA place on this topic. The DOE workshop included much discussion of storage well design and safety features such as tubing, packing, and subsurface safety valves. PHMSA intends to publish a rulemaking on this topic by the end of this year.

Information concerning the DOE meeting is available here. The PHMSA meeting information, including a recording of the workshop and the speaker presentations, is available on the PHMSA meetings website.

Oil and gas production well permitting and regulation are done at the state level, and several states are also actively involved in the issue of underground gas storage. The state efforts are being coordinated through the States First Initiative. State regulations may evolve in parallel with PHMSA regulations on this topic.

RCP Underground Storage Services & Gas Storage Facility Procedures

Does your company have underground storage assets? Do you know what is included in the new PHMSA advisory bulletin and RPs 1170 & 1171?

RCP has extensive expertise in the underground storage recommended practices for both reservoirs and salt caverns which we would like to put to work for your company. We have developed integrity management programs and operating procedures for many storage facilities across the US. We can provide a wide variety of related services such as:

  • Assess current operations against new RP 1170/1171
  • Develop underground storage programs
  • Complete risk assessments
  • Develop risk mitigation plans

We are well-positioned to support your organization’s response to the recent PHMSA advisory bulletin as well as the California Emergency rule on underground gas storage. For more information, please contact Jessica Foley.

California Public Workshops on Draft Regulations for Gas Storage


The State of California is holding two public workshops on August 9 and 11 to provide information and answer questions from the public on the Discussion Draft, “Requirements for California Underground Gas Storage Projects.” The public workshops are scheduled for the following dates and locations:

August 9, 2016 from 1:00 – 5:00 p.m.
Natural Resources Building, Auditorium
1416 Ninth Street
Sacramento, CA 95814

August 11, 2016 from 1:00 – 5:00 p.m.
Hilton Woodland Hills, Trillium Room
6360 Canoga Ave.
Woodland Hills, CA 91367

For further information please visit the State of California, Department of Conservation Division of Oil, Gas and Geothermal Resources home page or click here for a link to the public notice.

Late Summer Conference Schedule

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

LGA 2016 Pipeline Safety Conference
August 8-12, 2016
Astor Crowne Plaza Hotel – New Orleans, LA

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 see you at this new venue in New Orleans. Laissez les bons temps rouler! (Let the good times roll!)

Western Regional Gas Conference
August 23-24, 2016
Tempe Mission Palms Hotel – Tempe, AZ

2016 RRC Pipeline Safety Conference
August 24-26, 2016
Embassy Suites Riverwalk Hotel – San Antonio, TX

RCP’s Web-Based Compliance Management Systems

RCP’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 repairs of third party damages)

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

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.

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

Best regards, 

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