DOT Pipeline Compliance News

February 2017 Issue

In This Issue

On-Shore Hazardous Liquid Pipelines – Final Rule?

[Docket No. PHMSA-2010-0229; Amdt. No. 195-102]

On January 12, 2017, PHMSA posted the text of a pending final rule concerning hazardous liquid pipelines. The corresponding NPRM was published on 10/13/2015. This pending final rule has not yet actually been published in the Federal Register, and will no doubt undergo further review and possibly revision under the new administration. The posted version is summarized below, for your information only (as it isn’t actually a rule at this point in time). PHMSA plans to:

  1. Extend reporting requirements to certain hazardous liquid gravity and rural gathering lines;
  2. Require inspection of pipelines in areas affected by extreme weather, natural disasters, and other similar events;
  3. Require integrity assessments at least once every 10 years of onshore, piggable, transmission hazardous liquid pipeline segments located outside of high consequence areas (HCAs);
  4. Incorporate additional conservatism into the existing repair criteria and establish an adjusted repair schedule to provide greater flexibility;
  5. Extend the required the use of leak detection systems beyond HCAs to all regulated, non-gathering hazardous liquid pipelines;
  6. Require all pipelines in or affecting HCAs be capable of accommodating in-line inspection tools within 20 years, unless the basic construction of a pipeline cannot be modified to permit that accommodation;
  7. Clarify other regulations; and–Incorporate Sections 14 and 25 of the PIPES Act of 2016.
  8. Incorporate Sections 14 and 25 of the PIPES Act of 2016.

DOT Pipeline Compliance Workshop – Gas & Liquid

March 21 – 23, 2017

Join us March 21-23, 2017 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, 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.

Operator Qualification, Cost Recovery, Accident and Incident Notification, Etc.

[Docket No. PHMSA-2013-0163]

PHMSA is amending the pipeline safety regulations to address requirements of the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 (2011 Act), and to update and clarify certain regulatory requirements. Among other provisions, PHMSA is adding a specific time frame for telephonic or electronic notifications of accidents and incidents and adding provisions for cost recovery for design reviews of certain new projects, for the renewal of expiring special permits, and setting out the process for requesting protection of confidential commercial information. PHMSA is also amending the drug and alcohol testing requirements, and incorporating consensus standards by reference for in-line inspection (ILI) and Stress Corrosion Cracking Direct Assessment (SCCDA). The specific amendments codified by this final rule are listed in detail below:

  • Specifying an operator’s accident and incident reporting time to not later than one hour after confirmed discovery and requiring revision or confirmation of initial notification within 48 hours of the confirmed discovery of the accident or incident;
  • Setting up a cost recovery fee structure for design review of new gas and hazardous liquid pipelines with either overall design and construction costs totaling at least $2,500,000,000 or that contain new and novel technologies;
  • Addressing the National Transportation Safety Board’s (NTSB) recommendation to clarify training requirements for control room personnel;
  • Providing a renewal procedure for expiring special permits;
  • Excluding farm taps from the requirements of the Distribution Integrity Management Program (DIMP) requirements while proposing safety requirements for the farm taps;
  • Requiring pipeline operators to report to PHMSA a change in product (e.g., from liquid to gas, from crude oil to highly volatile liquids (HVL)) or a permanent reversal of flow that lasts more than 30 days;
  • Providing methods for assessment tool selection by incorporating consensus standards by reference in part 195 for stress corrosion cracking direct assessment (SCCDA) that were not developed when the Integrity Management (IM) regulations were issued;
  • Requiring electronic reporting of drug and alcohol testing results in part 199;
  • Modifying the criteria used to make decisions about conducting post-accident drug and alcohol tests and requiring operators to keep for at least 3 years a record of the reason why post-accident drug and alcohol tests were not conducted;
  • Including the procedure to request protection for confidential commercial information submitted to PHMSA;
  • Adding reference to appendix B of API 1104 related to in-service welding in parts 192 and 195; and
  • Amending minor editorial corrections.

This final rule was published with an effective date of March 24, 2017, but it will be subject to the new administration’s executive order which extends recent rule effective dates, and it is also subject to further review / revision during that time. Stay tuned! For a copy of the Final Rule, 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.

2017 Pipeline Conference Schedule (February thru May)

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

Pipeline Pigging and Integrity Management (PPIM) Conference
February 27 – March 2, 2017
George R. Brown Convention Center – Hall A3 / Houston, TX
Visit RCP Booth #329 / Be our Guest and Click Here for a Free Exhibition Pass.

The industry’s only forum devoted exclusively to pigging for maintenance and inspection, as well as pipeline integrity evaluation and repair, this event will draw engineering management and field operating personnel from both transmission and distribution companies concerned with improved operations and integrity management.

API Pipeline Conference and Control Room Forum
April 25 – 27, 2017
Hyatt Regency Hill Country, San Antonio, TX

API’s Pipeline Conference is the premier event of its kind in the U.S. Held every year in April the conference provides attendees with an opportunity to hear about the latest in pipeline-related developments. Once again, RCP is a proud sponsor of this event and we look forward to seeing you there.

AGA Operations Conference and 2017 Exhibition
May 2 -5, 2017
Gaylord Palms, Orlando, FL
Visit RCP Booth #1223 for a TestOp™ Demo

The annual AGA Operations Conference is the natural gas industry’s premier gathering of natural gas utility and transmission company operations management from across North America and the world for the sharing of technical knowledge, ideas and practices to promote the safe, reliable, and cost-effective delivery of natural gas to the end-user. Make plans to attend one of these sessions from RCP staff:

  • “Underground Natural Gas Storage Risk Assessment Process – An Implementation Tool for API RP 1171” presented by Rick Gentges.
  • “Assessment of MAOP Validation and the NPRM” presented by Michael Berg.

Underground Gas Storage Compliance

How does RCP deliver a comprehensive solution for natural gas storage operational integrity assurance?

Experienced Resources
  • Highly respected underground storage & risk management SME’s (the past Chair of PRCI’s and AGA’s underground storage committees is on our staff)
  • Professional engineering support
  • Written program development / improvement from knowledgeable technical standards developers (Our lead technical writer was the editor for the API RP1170 development team.)
State-Of-The-Art Tools (TaskOp™)
  • Program gap assessment and corrective action tracking
  • Storage risk assessment
  • Integrity assessment and remediation process tracking

For more information regarding our capabilities or to request an online demonstration of our TaskOp™ underground gas storage solution, visit our website or contact Jessica Foley.

Save the Dates!

RCP Workshop Schedule for 2017

  • DOT Gas & Liquid Pipeline Workshop: March 21-23 (Tuesday, Wednesday & Thursday)
  • Fundamentals of Pipeline Operations Workshop: May 24-25 (Wednesday & Thursday)
  • Pressure Test Workshop: June 20-21 (Tuesday & Wednesday)

Visit our training website for updates, registration, and hotel information.

Fundamentals of Transmission Pipeline Operations Workshop

May 17 – 18, 2017

RCP is now offering a 2-day course that is designed to give a comprehensive overview of gas and liquid energy transmission pipelines and how they are operated and maintained. It is appropriate for both technical and non-technical personnel who are new to the energy transmission pipeline industry, as well as those who need a broader understanding of pipeline operations and management in general. The course walks through the practical things that a typical pipeline company’s operations organization does on a regular basis to operate and maintain the pipeline system as a whole. Course topics include:

  • Components of a pipeline system (types of pipe, coatings, tanks, valves, pumps, compressors, pressure vessels, pig traps, meters, instrumentation, control systems / SCADA)
  • Operations activities (starting / stopping, batching, managing receipts and deliveries, measurement, monitoring, pressure control, leak detection)
  • Inspection and Maintenance (valves, ROWs, tanks, pumps, compressors, instrumentation, pigging, cathodic protection)
  • Repair (in-service repair techniques, welding, OOS repairs / replacements)
  • Integrity Management (ILI, Pressure Tests, Direct Assessment), including assessment processes, analysis, follow-ups
  • Emergency Response (planning, organization / ICS, drills, response)
  • Public Awareness / Damage Prevention / One Calls

The course involves many hands-on demonstrations and examples using RCP’s in-house Pipeline Flow Loop*. To promote an optimal learning environment, class size will be limited. Online registration is now open. Questions about course content can be directed to Bill Byrd at

*RCP’s in-house Pipeline Flow Loop is an engineering marvel (!). It is a working 2″ diameter pipeline system incorporating many of the components of a transmission pipeline system including state-of-the-art SCADA control system and instrumentation for flow, pressure, temperature, and volume, as well as automated valves, pig traps, variable speed pump, and more. It also incorporates clear pipe segments so that students can see a pig in operation, see phase separation as it occurs, and understand the importance of elevation change. It occupies 2 walls outside our training room. Students can monitor and control the pipeline from the training room (“control room”), and then step into the hall to see the pipeline in action.

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

Best regards,

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