DOT Pipeline Compliance News

December 2018 Issue

In This Issue

PHMSA Plastic Pipe Final Rule

[Docket No. PHMSA-2014-0098: Amdt. No. 192-124]

PHMSA is amending the Federal Pipeline Safety Regulations that govern the use of plastic piping systems in the transportation of natural and other gas. These amendments are necessary to enhance pipeline safety, adopt innovative technologies and best practices, and respond to petitions from stakeholders. The changes include increasing the design factor of polyethylene pipe; increasing the maximum pressure and diameter for Polyamide-11 pipe and components; allowing the use of Polyamide-12 pipe and components; new standards for risers; more stringent standards for plastic fittings and joints; stronger mechanical fitting requirements; the incorporation by reference of certain new or updated consensus standards for pipe, fittings, and other components; the qualification of procedures and personnel for joining plastic pipe; the installation of plastic pipe; and a number of general provisions.

The Final Rule will only apply to new, repaired, and replaced pipelines. Regulatory updates include an increased design factor for polyethylene pipe; updated standards governing the use, maximum pressure limits, and diameters for pipelines made of polyamide 11 and 12 thermoplastics; new and expanded standards for the installation of plastic pipe to help mitigate contact with other underground utilities and structures; and several other installation and operational related provisions for plastic pipe and plastic pipe components.

As a result of the Final Rule’s updated design factor, the cost of materials to produce new pipe is estimated to be reduced by 10 percent, resulting in an annual material cost savings of approximately $32 million for transmission, gathering, and distribution operators.

This final rule is effective 60 days after the date of publication in the Federal Register. For a copy of the Plastic Pipe Final Rule, contact Jessica Foley.

PHMSA Pipeline Safety: Guidance on the Extension of the 7-year Integrity Management Reassessment Interval by 6 Months

[Docket No. PHMSA-2018-0073]

On November 15, 2018, PHMSA published a document titled “Pipeline Safety: Guidance on the Extension of the 7-year Integrity Management Reassessment Interval by 6 Months.” PHMSA is requesting comments on the FAQs developed for the aforementioned subject.

Under the amended section 5 of the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011, an operator may request an extension of 6 months beyond the required 7-year reassessment interval of high-consequence areas (HCA). The guidance consists of one revised and two new FAQs on the eligibility for this type of extension. The main points of the FAQs are summarized below.

  • In order to request an extension of no more than 6 months, an operator must notify PHMSA 180 days prior to the end of the 7-year assessment date (49 CFR 192.949).
  • The operator must include documentation (49 CFR 192.943) which:
    • Explains why the deadline could not be met and how it will not compromise safety
    • Identifies any additional actions to ensure public safety during the extension period.
  • Section 192.939(a)(1) specifies two options for establishing reassessment intervals: (i) considering identified threats, assessment results, data integration, and risk analysis, or (ii) using Table 3 of ASME/ANSI B31.8S. Operators choosing option (i) may establish intervals longer than those in Table 3 but must not exceed the maximum intervals listed in the table in 192.939.
  • For operators conducting assessments by pressure testing:
    • Higher pressure tests are required to justify reassessment intervals which extend beyond the 7 years (192.937(c)(2), 192.937(a), and 192.939(a) and (b)).
    • If using test pressures meeting Subpart J requirements, the operator may establish a 7-year reassessment interval regardless of the result from Table 3, unless their analysis under 192.939(a)(i) indicates a need for a shorter interval.
    • If using test pressures and reassessment intervals from Table 3, the operator may establish a reassessment interval up to the maximums listed in the table in 192.939, unless their analysis under 192.939 indicates a need for a short interval. In order to establish intervals longer than 7 years, the operator must conduct a confirmatory direct assessment within the 7-year period. This assessment may be substituted with a low-stress reassessment per 192.941 for pipe segments operating under 30% specified maximum yield strength (SMYS).

Comments can be submitted on the e-gov website on or before December 17, 2018. Reference Docket No. PHMSA-2018-0073 when submitting comments. For a copy of the Notice from the Federal Register, contact Jessica Foley.

NTSB Emergency Recommendation in response to the Merrimack Valley Incident

[Docket No. PHMSA-2018-0073]

On September 13, 2018, a series of explosions and fires occurred after high-pressure natural gas was released into a low-pressure gas distribution system in the northeast region of the Merrimack Valley, Massachusetts. The distribution system was owned and operated by Columbia Gas of Massachusetts, a subsidiary of NiSource. The National Transportation Safety Board (NTSB) has issued five urgent safety recommendations as investigation of this incident continues:

To the Commonwealth of Massachusetts:

Eliminate the professional engineer licensure exemption for public utility work and require a professional engineer’s seal on public utility engineering drawings. (P-18-005)

To NiSource:

  1. Revise the engineering plan and constructability review process across all of your subsidiaries to ensure that all applicable departments review construction documents for accuracy, completeness, and correctness, and that the documents or plans be sealed by a professional engineer prior to commencing work. (P-18-006) (Urgent)
  2. Review and ensure that all records and documentation of your natural gas systems are traceable, reliable, and complete. (P-18-007) (Urgent)
  3. Apply management of change process to all changes to adequately identify system threats that could result in a common mode failure. (P-18-008) (Urgent)
  4. Develop and implement control procedures during modifications to gas mains to mitigate the risks identified during management of change operations. Gas main pressures should be continually monitored during these modifications and assets should be placed at critical locations to immediately shut down the system if abnormal operations are detected. (P-18-009) (Urgent)

The preliminary report and related recommendations can be found on the NTSB Investigations webpage.

Senate Committee Hearing on Pipeline Safety in the Merrimack Valley: Incident Prevention and Response

[Docket No. PHMSA-2018-0073]

The US Senate on Commerce, Science and Transportation held a hearing on November 26th to hear testimony regarding the over-pressurization incident that occurred in Merrimack Valley Massachusetts on September 13, 2018. Representatives from the federal, state and local government, emergency responders, NiSource and affected public provided testimony, including what actions are being taken to understand the causes of the incident and what steps are being taken to prevent a similar incident from occurring in the future.

To read and/or download copies of testimonies, click here.

AGA: Leading Practices to Reduce the Possibility of a Natural Gas Over-Pressurization Event

The American Gas Association (AGA) has published a 43-page document intended to provide guidance to natural gas utilities on leading practices that may supplement current practices to reduce the possibility of an over-pressurization event, especially in a utilization pressure system. The document contains practices above and beyond minimum federal regulations, recognizing that not all practices will be applicable given the size, configuration, pressures, and other features of a particular system. The document addresses the following as related to preventing over-pressurization of gas distribution systems:

  • Design of Distribution Systems and Regulator Stations
  • Operating Procedures and Practices
  • Human Factors
  • Managing the Risk of an Over-pressurization Event

AGA has posted this document on their website.

Introduction to the Unified Agenda of Federal Regulatory and Deregulatory Actions – Fall 2018

The Unified Agenda has appeared in the Federal Register twice each year since 1983 and has been available online since 1995. The complete Fall 2018 Unified Agenda contains the Regulatory Plans of 28 Federal agencies and 66 Federal agency regulatory agendas providing information about regulations that the Government is considering or reviewing.

The Fall Edition of the Unified Agenda include the agency regulatory plans required by Executive Order 12866, “Regulatory Planning and Review,” which identify regulatory priorities and provide additional detail about the most important significant regulatory actions that agencies expect to take in the coming year. All federal regulatory agencies have chosen to publish their regulatory agendas as part of this publication.

The complete Unified Agenda and Regulatory Plan can be found online. The online Unified Agenda offers flexible search tools and access to the historic Unified Agenda database to 1995. A reduced print version can be found in the Federal Register. Information regarding obtaining printed copies can also be found on the website.

Meeting of the Voluntary Information-Sharing System Working Group

JANUARY 8-10, 2019

The Voluntary Information-sharing System (VIS) Working Group is meeting to discuss proposed recommendations to establish a voluntary information-sharing system. The public meeting will be held on December 18th from 9:00 a.m. to 5:00 p.m. ET and December 19th from 8:30 a.m. to 5:00 p.m. ET. Members of the public who wish to attend in person should register no later than December 11. The meeting will be held at the U.S. Department of Transportation, 1200 New Jersey Ave. SE, Washington, DC 20590. The meeting agenda and additional information can be found on the VIS Working Group registration webpage.   

DOT Pipeline Compliance Workshop

JANUARY 8-10, 2019

Join us January 8-10, 2019 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.

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.

RCP Workshops – Which one should I attend?

Introduction to DOT Pipeline Regulations
The DOT pipeline workshop covers federal regulatory requirements and their applicability to both hazardous liquid and natural gas gathering, transmission, and distribution pipeline operators.

It is appropriate for people who are new to pipeline regulations, need a refresher course or better understanding of current and pending DOT rule makings as well as how they are applied to their job or their group, including operational, supervisory, and managerial personnel.

Fundamentals of Energy Transmission Pipelines (FETP)
The Fundamentals of Energy Transmission workshop provides participants an overview of how transmission pipelines operate and walks them through the practical things that a typical pipeline company does on a regular basis to operate and maintain the pipeline system as a whole.

It is appropriate for both technical and non-technical personnel who are new to the transmission pipeline industry, as well as those who need a broader understanding of the pipeline operations and management such as new hires, managers and executives from outside the pipeline industry, including attorneys, and business development professionals.

The table below gives some examples of the differences between these courses:

Introduction to DOT PL RegulationsFundamentals of Energy Transmission Pipelines
What are the regulatory requirements for energy transmission pipelines?Why do we have energy transmission pipelines?

How do they make money?

What do the operations and engineering people do in our company, and why?
What are the inspection requirements for a mainline valve?What are the different types of valves? When is each type used?
How are breakout tanks defined?What are the different types of tanks? When is each type used?
What is the definition of line pipe?How is pipe made? What are the important differences?
What are the requirements for integrity management?Why are we doing integrity management?
What are the procedure requirements for pumps and compressors?What are the various types of pumps and compressors, and how do they differ?

Free Training on Pipeline Safety for Non-Pipeline Personnel

May 8-10, 2019; Houston, TX

The Pipeline Safety Trust (PST) received a grant in 2017 and again in 2018 to send 20-30 people from local and tribal government, and non-profit organizations to an in-depth training on pipeline safety. Their goal with this training is to provide attendees with the information they need to better understand pipelines and pipeline regulations. With this information, participants will be better able to understand the daily operations and potential risks from pipelines, and hopefully develop programs and engage in regulatory processes that address these risks more effectively. This training focuses on the safety of existing (or soon to be existing) pipelines, and will not get into other important related issues such as the impacts of oil and gas production methods, the impacts from the use of the fuels pipelines transport, or the regulatory system for the siting of new pipelines.

The training will be held May 8-10, 2019 and take place in downtown Houston, Texas. Over the course of this three-day training, attendees will learn how pipelines are constructed, operated, maintained, inspected and regulated, as well as a review of the different types of pipelines and the major failure causes and what is done to try to prevent those failures. The PST seeks to fund people who will continue to be involved in pipeline safety issues in years to come. This training will be provided by RCP at our headquarters in downtown Houston. All travel costs for the selected attendees will be paid by the Pipeline Safety Trust.

Application for the 2019 training is now open. To apply go fill out the short nine question application here. If you know of other people who might be interested in this training please forward them this notice.

For any questions send an email to or call at (360) 543-5686.

Editor’s Note: Those of you who work in the for-profit world should plan to attend RCP’s regular 3-day DOT training course on the following week, May 14-16. Please forward this notice to those people in the non-profit world who have a legitimate need and desire to understand pipelines and pipeline safety.

Season’s Greetings from RCP!
RCP would like to thank our valued clients for a wonderful year. We appreciate the opportunities you have given us to serve as your Professional Engineers, Regulatory Experts, and Trusted Partners. We look forward to working with you on even more projects in the years ahead. Best wishes for the holiday season and the New Year, from your friends at RCP.

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


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