DOT Pipeline Compliance News

December 2014 Issue

In This Issue

Drug and Alcohol Testing Update

[Docket ID PHMSA-2014-0137]

PHMSA has determined that the minimum random drug testing rate for covered employees will remain at 25 percent during calendar year 2015. Operators are reminded that drug and alcohol testing information must be submitted for contractors performing or ready to perform covered functions. For calendar year 2014 reporting, PHMSA will not attempt to mail the “user name” and “password” for the Drug and Alcohol Management Information System (DAMIS) to operators, but will make the user name and password available in the PHMSA Portal. For questions contact Blaine Keener at 202-366-0970 or by email.

TRRC Adopts Pipeline Permit Rule Amendments

[Utilities Docket No. 10366]

On December 2, 2014, the Texas Railroad Commission (TRRC) adopted pipeline permit rule amendments in 16 TAC §3.70 to clarify how a pipeline operator may be classified by the TRRC as a common carrier. The rule amendments require pipeline operators to verify their claim to be a common carrier when applying for a T-4 Permit to operate a pipeline or when renewing, amending or cancelling an existing permit. The adopted rule amendments take effect on March 1, 2015, and include the following requirements:

  • permit applications must now include additional information including requested classification and purpose of the pipeline or pipeline system as a common carrier, a gas utility or private line operator;
  • permit applications must include a sworn statement from the pipeline applicant providing the operator’s factual basis supporting the classification and purpose being sought for the pipeline;
  • if applicable, the pipeline operator must submit documentation such as a contract or tariff for third-party transportation in the case of a common carrier, along with any other information requested by the Commission;
  • the pipeline T-4 permit, if granted, shall be revocable at any time after a hearing if the Commission finds that the pipeline is not being operated in accordance with state laws and Commission rules and regulations.
  • the applicant must acknowledge the eminent domain provisions in the Texas Landowner’s Bill of Rights.

For a copy of TRRC’s Pipeline Permit Rule Amendments, contact Jessica Foley.

API RP1173 Draft Pipeline Safety Management System

A final draft is ready for approval and public comment on the Pipeline Safety Management System Recommended Practice (RP), API 1173 (PSMS). This is the second ballot and will result in a new document (1st Edition). Comments are due by December 20, 2014 and will be accepted online at The ballot ID number is 3392. See our related article in the July 2014 edition of the DOT Pipeline Compliance News for detailed information about how to download and vote on the ballot.

Audit Assistance

Has the DOT or TRRC notified you of a pending audit? Are your O&M and IMP programs ready for their next PHMSA audit? RCP can review your plans based on Advisory Bulletins and Enforcement Guidelines to ensure compliance. RCP is well versed in PHMSA and TRRC audit preparation and will help you identify opportunities for improvement and track each item to closure using RCP’s audit tracking tool, TaskOp™. RCP can provide confidential internal auditing to help ensure that your facilities are up to the agency’s latest standards. For more information, contact Jessica Foley.

Pipeline Pressure Testing Workshop: January 13-14, 2015

RCP is now offering a 2-day Pipeline Pressure Testing Workshop at its facilities in downtown Houston. RCP has established itself as a leading industry expert on pipeline pressure testing with clients securing RCP’s services specifically to validate their pressure tests.

Our Pressure Testing Workshop will begin by outlining the objectives for performing a pressure test and how that relates 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 3 different worksheets 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 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, determining the test parameters for each section and specifying the pressure ratings of equipment needed.

To register for our workshop, click here.

PHMSA Pipeline Incident Statistics

Ever wonder how pipeline incidents and accidents have trended over time? Check out PHMSA’s new incident trend website at

PHMSA has collected pipeline incident reports since 1970. Although the report formats have changed in that time frame, the report data have been merged and scrubbed to generate 20 year trend graphs.

The trend data can be filtered by state and by system type (gas distribution, gas transmission, gas gathering, hazardous liquid or liquefied natural gas). Data are available for all incidents, for “serious incidents” or those which include a fatality or injury requiring hospitalization, and for “significant incidents” or those which had $50,000 or more in total costs, measured in 1984 dollars. Significant hazardous liquid incidents also include highly volatile liquid (HVL) releases of 5 barrels or more, non-HVL liquid releases of 50 barrels or more, or an unintentional fire or explosion.

You can also download a ZIP file of all reports submitted by operators or a ZIP file of “flagged incidents” which includes the data used to generate the trend data.

CGA DIRT Report for 2013 Vol. 10 Released September 2014

The Common Ground Alliance (CGA) has issued its Damage Information Reporting Tool (DIRT) Report for 2013, providing a summary and analysis of the pipeline damage, near miss, and downtime events that occurred in 2013. The DIRT Report identifies the importance of calling 811 as most critical to safety. Last year there was a 3.5% decrease in damage incidents and an overall 10% increase in locate requests. The report also observed that natural gas and telecommunications industries experienced the most damage-related service interruptions.

The DIRT Report is a summary of utility damage data submitted anonymously from facility operators, locators, one-call centers, and regulators. The report gives us the opportunity to not only understand the root causes of damages, but to measure the effectiveness of damage prevention efforts and campaigns. DIRT offers insight on equipment used, type of work being performed, one-call notification, the effects of one-call exemptions, and regional differences.

The complete DIRT Annual Report for 2013 is available for download at the CGA website.

Damage Prevention Plans

RCP can develop or update your Damage Prevention plan. For more information about how RCP can assist you with your Damage Prevention Plan, click here.

Colorful Comments

Thanks to our friend Vince Murchison for pointing out this site which has tracked the frequency with which swear words (specifically the F word and the S word) are used in public comments to agency rulemakings. It would surprise no one that the “winner” is the IRS. The last agency on the list, with the least swear words in comments, is PHMSA. Having been on plenty of pipeline sites, I would never have guessed that the pipeliners would swear less than the others. To view the online article from the Washington Post, click here.

Save the Dates! RCP 2015 Workshop Schedule

Join us at our corporate office and dedicated training facility in downtown Houston. We are now offering Pressure Test Workshops in addition to our DOT gas & liquid pipeline seminars. Visit our Training Website for updates and registration information.

Pressure Test Workshops:
January 13 & 14 (Tuesday & Wednesday)
August 4 & 5 (Tuesday & Wednesday)

DOT Combined Gas & Liquid Workshops:
March 10, 11, 12 (Tuesday, Wednesday, Thursday)
August 11, 12, 13 (Tuesday, Wednesday, Thursday)

DOT Gas Pipeline Workshop
June 2, 3, 4 (Tuesday, Wednesday, Thursday)

DOT Hazardous Liquid Pipeline Workshop
October 6, 7, 8 (Tuesday, Wednesday, Thursday)

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