DOT Pipeline Compliance News

February 2019 Issue

In This Issue

Missouri Updated Chapter 40 Gas Regulations

The Missouri Public Service Commission has updated its regulations for Gas Utilities and Gas Safety Standards, effective January 30, 2019. The updates included:

  • New and revised definitions.
  • Clarifying that the PHMSA additional design and construction requirements for steel pipe using alternative maximum allowable operating pressure are not adopted for state requirements.
  • Added conditions and requirements for the installation of excess flow valves for new and modified service lines and to require operators to negotiate with customers for a date to install an excess flow valve if the customer does not meet the conditions necessary for a required installation.

PHMSA Plastic Pipe Rule

[DOCKET NO. PHMSA-2014-0098]

On December 20, 2018, the American Gas Association filed a petition for reconsideration of the Plastic Pipe Rule. The AGA raised concerns about the ability of operators to fully implement the rule by the effective date of January 22, 2019. Specific concerns were raised regarding implementation timeframe for training, operator qualification, modifications to processes and availability of equipment from third party suppliers.

In light of the recent federal lapse in funding, PHMSA could not process the request before the January 22nd effective date. PHMSA will complete a review and act upon the petition after the shutdown ends, and publish the final determination in the Federal Register. Until PHMSA issues its determination, PHMSA will suspend enforcement action on the new rule implementation date and recommend state regulators exercise similar discretion. PHMSA expects all operators are moving forward with due diligence to implement the new rule effectively across their respective organizations.

Proposed Changes to Oklahoma Gas and Hazardous Liquid Pipeline Safety Regulations


The Transportation Division of the Oklahoma Corporation Commission (“Commission”) recommended that the Commission amend the Gas and Hazardous Liquid Pipeline Safety rules that are set forth in the Oklahoma Administrative Code (“OAC”) 165:20. The proposed rules from December 20, 2018, have been revised. In addition to misc. updates and amendments which mostly follow federal pipeline safety changes, the proposed rule changes include these additions:

  • OAC 165:20-17-6 would be added as a new permanent rule requiring operators to provide additional information to excavators.
  • OAC 165:20-17-7 would be added as a new permanent rule listing requirements for reporting damages.
  • OAC 165:20-17-8 would be added as a new permanent rule requiring a written report of damages caused by excavation.
  • OAC 165:20-17-9 would be added as a new permanent rule outlining the procedure for filing a complaint against an excavator for failing to comply with the Oklahoma Underground Facilities Damage Prevention Act.

The Commission is amending the operator obligations under the Oklahoma Underground Facilities Damage Prevention Act. An operator must notify the excavator of the size and material of an active underground facility. Additionally, operators must notify the Commission’s Pipeline Safety Department within one hour of confirmed discovery of damage as well as submit a semi-annual damage summary report. Complaints against an excavator or pipeline operator for failure to comply can be made to the Commission’s Pipeline Safety Department.

The Commission invites all interested persons to submit comments regarding the proposed changes to the Rules on or before February 20, 2019. The Commission will hold a public hearing on and consider adoption of the proposed permanent rule(s) at 9:30 a.m., February 27, 2019 in Courtroom 301 of the Jim Thorpe Office Building, 2101 North Lincoln Boulevard, Oklahoma City, Oklahoma.

Further information and inquiries regarding this proposed rulemaking should be directed to Michael Copeland, Deputy General Counsel, by telephone (405) 522- 1638 or by e-mail; or Darren Ferguson, Assistant General Counsel by telephone (405) 522-5491, or by e-mail.

For a copy of the revised proposed rulemaking, contact Jessica Foley.

New Mexico Pipeline Safety Excavation Damage Prevention

[TITLE 18.60.5 NMAC / CASE #18-00262-PL]

Effective January 15, 2019 the New Mexico Public Regulation Commission updated requirements regarding excavation area locate requests pertaining to the state One-Call system. Excavators must now contact the one-call notification system 2 working days prior to any excavation reasonably expected to take more than 15 days. This replaces the previous 10 working days expectation. Additionally, excavators must now pre-mark the actual intended excavation route or site(s). Excavation activity shall be suspended if location markings have been removed, or are no longer visible, in which case a relocate request must be initiated for the area yet to be excavated.

Texas Railroad Commission Pipeline Mileage Fees Due April 1, 2019

Operators of intrastate pipelines that begin and end in Texas, placing them under the Railroad Commission of Texas (RRC) pipeline safety regulation, can get a jump on 2019 pipeline mileage fees due April 1, 2019 by preparing now. The annual pipeline mileage fee is one of two fees authorized by the 85th Texas Legislature in 2017 to fund RRC’s pipeline safety regulatory program. On Oct. 1, 2018, the Commission began charging a $500 permit processing fee for each new and renewed permit.

The annual pipeline mileage fee due April 1 is calculated using pipeline permit mapping information supplied by operators in their T-4 permits. The Commission has divided intrastate pipelines into two groups defined below:

  • Group A (RRC Regulated = Yes) includes transmission and gathering pipelines that are required by RRC rules to have a valid T-4 permit to operate and are subject to the regulations in 49 Code of Federal Regulations (CFR) Parts 192 and 195. Group A pipelines include natural gas transmission and storage pipelines, natural gas gathering pipelines, hazardous liquids transmission and storage pipelines, and hazardous liquids gathering pipelines.
  • Group B (RRC Regulated = No) includes gathering pipelines that are required by RRC rules to have a valid T-4 permit to operate but are not subject to the regulations in 49 CFR Parts 192 and 195. Group B pipelines include intrastate production and gathering pipelines leaving a lease.

The miles in each permit of Group A and Group B pipelines respectively, are added together and rounded up to the nearest mile. The sum is used to calculate the annual mileage fee. Operators will use the number of miles permitted as of Dec. 31, 2018 to calculate their 2019 pipeline mileage fee. The deadline for payment without incurring late penalties is April 1, 2019.

Operators may review the mileage chart showing their permits for which a fee is owed by visiting the RRC website and selecting “Mileage Chart – 2019” under “Helpful Links”.

All mileage fees are required to be paid through the Pipeline Online Permitting System (POPS) in the RRC Online System. For instructions, visit the RRC website.

For additional information, contact RRC at 512-463-7058 or

CEPA Foundation and INGAA Foundation release “The Practical Guide for Facility Inspectors”


The Canadian Energy Pipeline Association (CEPA) Foundation and the Interstate Natural Gas Association of America (INGAA) Foundation released “The Practical Guide for Facility Inspectors,” designed to provide guidance to personnel who inspect a company’s construction of facilities.

2019 Industry Conference Schedule


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

February 18-21, 2019
George R. Brown Convention Center, Houston
RCP Booth #406 / Be our Guest and Click Here for a Free Exhibition Pass.

Members from RCP’s Integrity Services team, Sheri Baucom and Jerry Rau, will present “A Practicum on Pressure Testing – Compilation of Best Practices” on Thursday, February 21st, at 2:30 p.m. They will present their observations regarding the current state of pressure testing for hazardous liquid and natural gas pipelines, and the many issues identified during the review and revision of Operators’ engineering standards. The presentation is accompanied by a white paper that seeks to:

  1. Present the federal Code requirements for the pressure testing of hazardous liquid and natural gas pipelines in a clear way that identifies the minute but significant differences and where and why the confusion
  2. Clearly delineate Code-defined tests from non-Code-defined pressure tests
  3. Define the various test objectives and test parameters for Code-defined pressure tests and their corresponding acceptance criteria
  4. Provide resolution and clarity where industry standards conflict and
  5. Be a tool that operators can utilize to review and update their internal engineering standards

April 9-11, 2019
Pointe Hilton Tapatio Cliffs Hotel, Phoenix, AZ

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.

April 29-May 3, 2019
Gaylord Opryland, Nashville, TN
RCP Booth #1303

The Operations Conference is AGA’s largest forum including 80 speakers and over 100 technical presentations that run the gamut of topics, such as gas measurement, operations advocacy, safety, environment, storage, engineering, construction and maintenance, gas control, supplemental gas, corrosion control and plastic materials. Mark your calendar and plan to attend one of these sessions from RCP Staff:

W. R. “Bill” Byrd, RCP President
Thursday, May 2nd, 10:55 – 11:35
Track C5: Quality Management/Construction Operations/Integrity Management
“Management Systems and Goldilocks: How Much Process Rigor Is Just Right for Your PSMS?”

Sheri Baucom, RCP Director of Integrity Services
Thursday, May 2nd, 3:55 – 4:35
Track D2: Engineering/Customer Field Services & Measurement
“Pressure Testing Objectives and Acceptance Criteria”

Sheri Baucom, RCP Director of Integrity Services
Friday, May 3rd, 8:30 – 9:10
Track E2: Integrity Management
“ILI Data – Closing the Loop”

NEW 1-Day Pressure Test Design & Analysis

RCP is now offering a 1-Day Pressure Test Design & Analysis Workshop at its facilities in downtown Houston. This workshop is appropriate for all those responsible for the design, execution and/or evaluation of any type of pipeline pressure test on liquid or gas pipelines whether it be new construction or in-situ. With specific focus on the engineering aspect of pressure testing, project managers & engineers as well as compliance staff of pipeline operating companies would benefit the most from this training.


The principles of good pressure test design and evaluation will be the focus for the morning session. All pressure types will be covered, including discussion on calculating the MAOP or MOP from test pressures. The afternoon session will discuss the execution of pressure tests including reviewing a test plan, case studies and how to properly document and close the loop on pressure tests.


  • Designing a Pressure Test
  • Pressure Test Acceptance Criteria
  • Evaluating a pressure test
  • Planning and Documentation
  • Case Studies
  • Pressure Test Myths and Misinformation

For more information and registration, click here.

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?

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.

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


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