DOT Pipeline Compliance News

February 2013 Issue

In This Issue

PHMSA Extends Deadline for Filing Gas Transmission & Gathering 2012 Annual Reports

[Docket ID PHMSA-2012-0319]

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) issued an updated report form and extended the deadline for filing the 2012 gas transmission and gathering annual reports from March 15, 2013 to June 15, 2013. Online submission via the PHMSA Portal is required unless an alternative reporting method is granted by PHMSA. The deadline has been extended because PHMSA made significant changes to the report form. PHMSA anticipates enabling the online submittal of gas transmission and gathering annual reports no later than March 1, 2013, and will notify pipeline operators who submitted calendar year 2011gas transmission and gathering annual reports when the online reporting system is available. The deadline extension does not apply to annual reports for hazardous liquid pipelines.

In addition, certain operators with Operator Identification Numbers (OPID) established prior to January 1, 2011, are required to validate their OPID data before June 30, 2012. PHMSA has determined that a number of operators have not completed their OPID data validations. Therefore, PHMSA is reminding operators to validate their OPID data. PHMSA has also noticed that annual reports submitted by gas transmission and LNG operators contain data that conflicts with other required reports submitted to PHMSA. Operators should review their annual report data to ensure it is accurate and submit supplemental reports to correct errors.

If electronic reporting imposes an undue burden and hardship, an operator may submit a written request for an alternative reporting method to the Information Resources Manager, Office of Pipeline Safety, Pipeline and Hazardous Materials Safety Administration, PHP-20, 1200 New Jersey Avenue, SE Washington DC 20590. The request must describe the undue burden and hardship. PHMSA will review the request and may authorize, in writing, an alternative reporting method. An authorization will state the period for which it is valid, which may be indefinite. An operator must contact PHMSA at 202-366-8075, or by email or make arrangements for submitting a report that is due after a request for alternative reporting is submitted but before an authorization or denial is received. Operators should request and receive authorization from PHMSA prior to the use of alternative reporting methods. Click here for information regarding online Submission Registration Requirements.

For a copy of the updated Annual Report form and/or instructions for filing, contact Jessica Roger.

MAOP Validation Services

RCP has developed a turnkey process by which pipeline operating companies will have a traceable, verifiable and complete MAOP dataset. It starts with our MAOP document review services where RCP conducts detailed reviews of relevant MAOP documents, extracts the necessary data onto our MaxOp* cover sheets and posts the data into the database for future dynamic segmentation and calculation. For each document, a MaxOp* cover sheet is attached and re-filed, awaiting digitization by the market leading document management services company, Iron Mountain. Once these documents are scanned and posted, MaxOp* will retain a permanent link from the data set to the document image. Finally, once the document review is complete, MaxOp* will dynamically segment any spatially related data and run the MAOP calculations. The resulting values and data sets can then be exported to our customer’s in-house pipeline data set (ex. Excel, PODS, APDM, other). At the completion of this effort, the basis for an MAOP management of change has been established and our customers can be confident that their MAOP values are capable of being traced back to source documentation, the calculated values have been validated with the most comprehensive calculator tool on the market, and the MAOP values have been completely evaluated and any potential deficiencies identified.

For more information about RCP’s MAOP services or the MaxOp* calculator, please contact Jessica Roger.

* MaxOp is a US Trademark and property of RCP Inc

PHMSA ADB 2013-01 Accident and Incident Notification Time Limit

[Docket No. PHMSA-2013-0015]

PHMSA issued Advisory Bulletin ADB-2013-01 to advise owners and operators of gas and hazardous liquids pipeline systems and LNG facilities that they should contact the NRC within one hour of discovery of a pipeline incident and should also file additional telephonic reports if there are significant changes in the number of fatalities or injuries, product release estimates or the extent of damages.

Owners and operators of gas and hazardous liquid pipelines and LNG facilities are reminded that the pipeline safety regulations already require operators to make a telephonic report of an incident to the NRC in Washington, DC at the earliest practicable opportunity (usually one-to-two hours after discovering the incident). However, under Section 9(b)(1) of the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011, PHMSA is required to issue regulations requiring owners and operators to notify the NRC within one hour of discovery of a pipeline accident or incident. The 2011 Act requires PHMSA to establish a time limit for telephonic or electronic notification of an accident or incident to require such notification at the earliest practicable moment following confirmed discovery of an accident or incident that is not later than one hour following the time of such confirmed discovery. PHMSA will issue a proposed rule at a later date, but encourages owners and operators of the gas and hazardous liquids pipeline systems and LNG facilities, as a practice, to report such accidents and incidents within one hour of confirmed discovery. The information required to be reported includes the name of the operator, the name and telephone number of the person making the report, the location of the incident, the number of fatalities and injuries, and all other significant facts that are relevant to the cause of the incident or extent of the damages.

For a copy of ADB-2013-01 contact Jessica Roger.

DOT Pipeline Compliance Workshop – March 5 – 7, 2013

Join us March 5-7, 2013 in Houston at our new 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, 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 (unlike our previous workshops), 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 recently enacted Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 (pipeline reauthorization bill), recent Advisory Bulletins from PHMSA, and new, pending and proposed rulemakings.

Each attendee will receive speaker’s PowerPoint presentation handouts in hard copy, 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.

PHMSA Posts Record Enforcement Numbers in 2012

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) is holding operators accountable for compliance with safety rules. In its push to ensure the nation’s pipeline companies continue to enhance the safety of their systems by investing in necessary improvements, PHMSA issued 116 enforcement orders to pipeline operators in 2012, its second highest year, for problems with integrity management programs, qualified personnel, corrosion control, and a number of other possible regulatory violations identified during routine inspections and failure investigations. As a result of its enforcement efforts, PHMSA issued a record $8,748,200 in proposed fines in 2012, including its highest ever civil penalty case in response to a crude oil pipeline failure in Marshall, Michigan. PHMSA’s number of enforcement orders issued in 2012 is just four shy of the agency’s single year record in 2011 of 120.

The Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011, was signed into law last year by President Obama. The Act doubled the maximum civil penalty amount PHMSA can issue to pipeline operators for violating pipeline safety regulations from $100,000 to $200,000 for each violation, and from $1,000,000 to $2,000,000 for a related series of violations. The Act also authorizes PHMSA to increase its federal pipeline inspector workforce.

For more information on the U.S. DOT’s efforts to improve pipeline safety and awareness, visit:

TRRC Excavation Damage Prevention Regulations – Proposed Changes

16 TAC Chapter 18

The Texas Railroad Commission (TRRC) has prepared Draft amendments to 16 TAC Chapter 18, relating to Underground Pipeline Damage Prevention: The proposed changes address many different aspects of the excavation damage prevention process, including ticket life, communication requirements, locating requirements (including qualification of locators, and marking deadlines), and damage reporting.

The public is encouraged to submit informal comments on these changes. The deadline for Informal Comments is 12:00 p.m. (noon), Tuesday, February 5, 2013. For more information or to submit written informal comments, please contact David Ferguson, Pipeline Safety Division, at or by telephone at (512) 463-9119.

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.

PHMSA State One-Call Exemptions Forum March 14 – West Palm Beach, FL

PHMSA will convene a forum for damage prevention stakeholders to discuss exemptions from state one-call programs. The forum will occur in West Palm Beach, Florida, immediately following the Common Ground Alliance 811 Excavation Safety Conference and Expo. PHMSA intends to webcast the meeting. To register or view the agenda, click here for more information.

PHMSA Online Inventory of High-risk Pipeline Infrastructure

PHMSA has created a website that provides data and information on cast and wrought iron gas distribution pipelines. The website includes an annually-updated online inventory that lists this “high-risk” pipeline infrastructure mileage by state. Click here for more information.

RCP Integrity Services

RCP Integrity Services, Inc. (RCP IS) was formed January 1, 2013 to provide a full range of field services related to planning and implementation of pipeline integrity activities including direct assessment, In Line Inspection analysis, internal corrosion control, and external corrosion control including High Voltage AC influence on buried pipelines analysis, Close-Interval-Surveys, Voltage Gradient surveys, and AC Current Attenuation surveys. RCP IS supports RCP Inc.’s pipeline integrity and corrosion control services including Operational Reliability Assessments, and Integrity Management Programs.

RCP Integrity Services, along with RCP Inc., comprise the perfect team to support all of your pipeline integrity requirements.” For more information, please contact John T. Schmidt

Meet me at the Conference

Have you registered and confirmed your reservations for these upcoming conferences? RCP will have representatives and Exhibits at NACE, API and AGA. We hope to see you there!

NACE Corrosion 2013 Conference & Expo
March 17 – 21 (Orlando, FL)
Booth #930

AGA Transmission Pipeline Workshop
March 19-20 (Chicago, IL)
API Pipeline Conference April 16 & 17
April 16 – 17 (San Diego, CA)

AGA Ops Conference & Biennial Exhibition
May 21 – 23 (Orlando, FL)

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