DOT Pipeline Compliance News

December 2011 Issue

In This Issue

TRRC Stakeholder Regulatory Workshops December 6 – Austin, TX

The Texas Railroad Commission (TRRC) Safety Division has planned a series of Stakeholder Regulatory Workshops on Chapter 18, Pipeline Safety and Underground Pipeline Damage Prevention. The Pipeline Operators Workshop (both gas & liquids) will be held on Tuesday, December 6, 2011, Room 1-104. All of the workshops will be in the William B. Travis Building, 1701 N. Congress, Austin, Texas.

For more information contact or the website.

PHMSA Pipeline Safety – NPRM Misc. Changes

Docket No. PHMSA-2010-0026

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) issued a Notice of Proposed Rulemaking (NPRM) for parts of 49 CFR 191, 192, 195 and 198. PHMSA is proposing to make miscellaneous changes to the pipeline safety regulations to correct errors, address inconsistencies, and respond to rulemaking petitions. Some highlights include:

  1. Prohibits anyone who was involved in construction activities of a liquid or gas transmission line or gas distribution main from inspecting their own work. This includes contractors or pipeline operator personnel.
  2. Adds leak survey inspections to Type B gas gathering pipelines, similar frequency to those required of gas transmission.
  3. Adjusts the requalification interval for plastic pipe joining personnel.
  4. Adds more stringent mill testing requirements for pipe intended to be operated at the higher alternative design factors.
  5. Adds transportation of pure ethanol to the hazardous liquid regulations. The transportation of pure biodiesel is not included however.
  6. Limits the state pipeline safety agency funding for indirect expenses.
  7. Eliminates a grandfather clause exemption for transportation of pipe that has been sitting in stock yards prior to 1970.
  8. Changes a standard incorporated by reference for threading of copper pipe.
  9. Eliminate obsolete requirements for filing offshore pipeline condition reports.
  10. Adds alternative methods for calculating pressure reductions on liquid pipelines for non-corrosion related immediate repairs conditions
  11. Expands the pre-installation pressure testing allowances for replacing single components on low stress gas pipelines, similar to the requirements for lines operating at greater than 30% SMYS.
  12. Codifies the annual NPMS submission requirements (this is currently only listed as a requirement through an Advisory Bulletin).
  13. Adds qualification requirements for “welding operators” by incorporating by reference existing language from API 1105 and ASME B&PV Code. This is different than the existing requirements incorporated by reference for qualification of welders.
  14. Clarification to pressure test requirements of pressure vessels to ensure they are tested to at least 1.5 times MAOP.
  15. Clarifies the definition of a gas lateral line between transmission and the distribution center for purposes of determining odorization requirements.
  16. Misc. editorial corrections to reflect changes made to standards that have been incorporated by reference.

Persons interested in submitting written comments on this ANPRM must do so by February 3, 2012, to docket number PHMSA–2010–0026 and may be submitted to the E-Gov Web Site.

For a copy of this Notice of Proposed Rulemaking, contact Jessica Roger.

MAOP Analysis Services

RCP has developed the most comprehensive MAOP analysis model on the market. Using this model, RCP has successfully conducted MAOP analysis for dozens of complex onshore/offshore gathering, transmission, and distribution pipeline systems. The analysis can be performed as a service with the results delivered on a system-by system basis as well as detailed individual record MAOP reports that indicate the regulatory code citation or letter of interpretation that is driving the calculated MAOP value. The MAOP model can also be purchased and configured to run by your personnel using your in-house data sets. For more information, visit or contact Jessica Roger.

ANPRM Safety of Gas Transmission Pipelines (Extension of Comments)

Docket No. PHMSA-2011-0023

On August 25, 2011, (76 FR 53086) PHMSA published in the Federal Register an Advance Notice of Proposed Rulemaking (ANPRM) titled: “Safety of Gas Transmission Pipelines” seeking comments on the need for changes to the regulations covering gas transmission pipelines.

(See related story in the September 2011 edition of the DOT Pipeline Compliance News.) In particular, PHMSA is interested in knowing whether IM requirements should be changed, more prescriptive language added in some areas, and non-IM requirements strengthened or expanded.

PHMSA has received requests to extend the comment period in order to have more time to evaluate the ANPRM. PHMSA is extending the comment period from December 2, 2011, to January 20, 2012.

Submit Comments on the E-Gov Website and reference Docket No. PHMSA-2011-0023.

EFRD Evaluation

RCP can assist pipeline operators (both gas and liquids) with performing an emergency flow restricting device (EFRD) evaluation based on the criteria, e.g. type of leak detection installed, product transported, quantity released, local topography, etc., identified in the Integrity Management rules. §192.179 requires that intermediate valves be installed along a cross country pipeline at the time of construction at specified intervals based on class location. Likewise, §195.260 identifies for liquids pipelines locations where valves must be installed at the time of construction but it is much less specific than for gas lines. For more information on an EFRD Study for your pipeline assets, contact Jessica Roger.

ANPRM: Expanding the Use of Excess Flow Valves in Gas Distribution Systems to Applications Other Than Single-Family Residences

Docket No. PHMSA-2011-0009

The National Transportation Safety Board (NTSB) has made a safety recommendation to PHMSA that excess flow valves be installed in all new and renewed gas service lines, regardless of a customer’s classification, when the operating conditions are compatible with readily available valves. In response to that recommendation, PHMSA is seeking public comment on several issues relating to the expanded use of excess flow valves (EFVs) in gas distribution systems. PHMSA is also interested in seeking comment from gas distribution system operators on their experiences using EFVs, particularly from a cost-benefit perspective. PHMSA seeks public comment regarding the technical challenges, and the potential costs and the potential benefits of any expanded requirement to use EFVs in applications other than service lines serving single family residences. PHMSA additionally seeks comment as to whether to establish and/or adopt technical standards or guidance for the performance, specification, manufacturing, testing, installation, identification, and operation of EFVs.

Specifically, PHMSA is asking for comment on the following issues:

  • Technical Challenges – Operators have identified technical challenges to installing EFVs on services other than single family residences. These challenges include:
    • the effect of changing gas usage patterns
    • snap loads
    • business-critical gas supply applications
    • system configuration
    • pressure ratings; and
    • size of commercially available EFVs.
  • Economic Analysis Considerations (Potential Costs and Benefits).
  • Technical Standards and Guidance for EFVs.
    PHMSA has identified several potential areas in which enhanced or expanded technical standards and guidance for the performance, operation, installation, identification, and testing of EFVs could be valuable regardless of whether PHMSA decides to expand the classes of services requiring an EFV. The current DOT regulation applicable to excess flow valve standards is 49 CFR 192.381 which requires excess flow valves to be manufactured and tested by the manufacturer according to an industry specification or to the manufacturer’s written specification but does not prescribe a specification. While not incorporated by reference into the pipeline safety regulations, there are three technical standards that address the specification, manufacturing, and testing of EFVs. These standards may not be applicable to all sizes and pressure ratings of EFVs that would be needed if they were mandated for use in applications other than single family residences and would likely need to be expanded to cover other sizes and pressure ratings.

    A number of factors affect the performance and reliability of EFVs such as: installation location, configuration, selection, sizing, identification, installation method, and operation. ASTM International (ASTM) F2138 “Standard Specification for Excess Flow Valves for Natural Gas Service” addresses some of these factors at a high level, but not in depth. These standards may need to be expanded to better address the selection, installation, and performance testing of EFVs for a variety of design considerations and service line configurations. Operating conditions and system configurations under which EFVs are not compatible or potentially not advisable may need to be identified and integrated into the guidelines. If these standards and guidance are enhanced or developed, PHMSA may consider if they are adequate to be incorporated by reference into the Pipeline Safety Regulations.
  • Factors affecting the performance and reliability of EFVs such as installation location, configuration, selection, sizing, or installation method.

    PHMSA has identified several situations where the installation of an EFV may not be technically practicable. In these situations, the installation of a readily-accessible curb valve and box might serve a similar safety function to an EFV. Although not instantaneous, a curb valve could facilitate the manual shut-off of natural gas service in an emergency and provide an alternative solution to an EFV.

    PHMSA has identified several issues related to the costs and benefits associated with mandatory EFV or curb valve installation that should be considered when performing the economic analysis. Since the subset of incidents whose consequences potentially could have been mitigated if an EFV was installed versus those that potentially could have been mitigated by a curb valve is different, the magnitude of the expected benefits will also be different.

Persons interested in submitting written comments on this ANPRM must do so by February 18, 2012, to docket number PHMSA-2011-0009. For further information contact: Mike Israni, by telephone at (202) 366-4571, or by mail at DOT, PHMSA, 1200 New Jersey Avenue SE., PHP-1, Washington, DC 20590-0001.

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.

PHMSA National Registry

Docket #PHMSA-2008-0291

On December 13, 2010, in accordance with the Paperwork Reduction Act of 1995, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published a notice in the Federal Register of its intent to create a national registry of pipeline and liquefied natural gas (LNG) operators. PHMSA received one comment in response to that notice. PHMSA published this notice to respond to the comment, to provide the public with an additional 30 days to comment on the proposed revisions to the operator registry forms, including the form instructions, and to announce that the revised Information Collections will be submitted to the Office of Management and Budget for approval.

Submit comments by December 12, 2011 (include Docket # PHMSA-2008-0291) via the Federal eRulemaking Portal: Follow the online instructions for submitting comments. For further information, contact: Angela Dow by telephone at (202) 366-1246 or by email.

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

Pennsylvania PUC Seeks Comments on Oversight of Natural Gas Distribution Systems

Docket No. M-2011-2271982

On November 10, the Pennsylvania Public Utility Commission (PUC) issued for comment proposed procedures that will enhance the safety of the state’s natural gas distribution systems. These new procedures would require gas utilities to file plans outlining how much aging underground pipelines leak and when the utilities intend to replace them, and to require leak surveys during winter months. Comments are to be filed by December 2, 2011. The proposed pipeline replacement and performance plans apply to companies having annual intrastate operating revenues over $40 million.

The proposal calls for the utilities to file Pipeline Replacement and Performance Plans with the PUC for review. The proposal says the plans are to include replacement timeframes and performance metrics that include damage prevention, corrosion control and distribution system leaks. Under the proposal, plans would be submitted in spring/summer 2012 with final approval to follow in late 2012/early 2013.

The PUC action also requires the utilities to provide distribution integrity management program plans, which are required by the federal government, with the PUC by November 30, 2011.

As part of its proposed regulations, the PUC also plans to mandate “frost surveys” (leak surveys) that utilities perform during cold weather months. The regulation would require frost surveys from November 1 to April 30 each year. Previously, the PUC asked, but hadn’t mandated, frost surveys. The leak surveys are to be conducted weekly or monthly, depending on the location and size of the line. The utilities are required to report to the PUC all leaks on a biweekly basis and provide a schedule for repairing all reported leaks.

The PUC’s action is in response to the changing scope of federal gas safety regulations, the continuing pipeline development resulting from Marcellus Shale and recent tragic incidents.

For a copy of the proposed rulemaking, contact Jessica Roger

Pipeline Operations Manager

RCP has been approached by one of our customers about posting a critical need position on our newsletter. This is a great opportunity for someone looking to play a key role in a relatively young but growth-oriented company. Those with an interest should submit your resume to with Operations Manager listed in the subject line.

This position will coordinate and manage all operational activities associated with both hazardous liquid and natural gas pipelines. This includes oversight of field operations and maintenance personnel and contractors, as well as coordination with upstream production operations and regulatory compliance personnel. Strong desire for someone with extensive offshore experience.

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