DOT Pipeline Compliance News

January 2014 Issue

In This Issue

Summary of Pending PHMSA Regulations

A summary of pending PHMSA rulemakings is given below, based on PHMSA’s presentation at the December 17, 2013 Technical Advisory Committee teleconference.

Rulemakings “In Process”
Integrity Verification Process: This rulemaking would define testing and materials verification requirements to ensure the integrity of grandfathered and vintage pipelines.

Notice of Proposed Rulemaking (NPRM) – in PHMSA
Gas Transmission Misc Changes (ANPRM 8/25/2011): This rulemaking would make various changes to the Gas Transmission Integrity Management regulations, including the following topics: Expansion of IM requirements beyond HCA’s, Definition of a HCA, Repair criteria for both HCA and non-HCA areas, assessment methods, valve spacing, corrosion control, and Integrity Management for gas gathering pipelines.

Operator Qualification, Cost Recovery and Other Pipeline Safety Proposed Changes: This rulemaking would address various issues that are included in the most recent Pipeline Safety Act, including: Operator Qualification for new construction, incident reporting criteria, cost recovery processes, transportation of non-supercritical carbon dioxide, and renewal process for special permits.

Plastic Pipe: This rulemaking would address various issues specific to plastic pipe used for gas transportation, including: use of PA12 at higher pressures, increase in design factor from 0.32 to 0.40 for PE pipe, enhanced tracking and traceability, misc. revisions for PE and PA11 pipelines, and additional provisions for fittings used on plastic pipe.

Rupture Detection and Valve Rule: This rule would establish and define rupture detection and response time metrics including the integration of Automatic Shutoff Valves (ASV) and Remote Control Valve (RCV) placement as necessary, with the objective of improving overall incident response. This rule responds to requirements of the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 (The Act):

  1. Section 4: ASV/RCV or equivalent technology be installed on newly constructed or entirely replaced natural gas and hazardous liquid transmission pipelines 2 years after the act was issued;
  2. Section 8: Require operators of hazardous liquid pipeline facilities to use leak detection systems and establish standards for their use; and,
  3. NTSB Recommendation P-11-10 (gas) which requires transmission and distribution operators to equip SCADA systems with tools to assist with recognizing and pinpointing leaks.

The Act also mandated two studies of leak detection and response, one by the GAO, and one by PHMSA. In March of 2012, PHMSA commissioned the Oak Ridge Laboratory to study the ability of transmission pipeline facility operators to respond to a hazardous liquid or natural gas release from a pipeline segment located in a high consequence area (HCA).

NPRM – (Proposed rule is past PHMSA)
Liquid Misc Changes (ANRPM 10/18/2010): This rule would address various liquid pipeline issues, including: assessments beyond High Consequence Areas (HCAs), leak detection beyond HCAs, repair criteria in HCA and non-HCA areas, Stress Corrosion Cracking (SCC) , management, piggability of lines, reporting requirements for gathering lines, and gravity line exemption.

EFV Expansion beyond Single Family Residences (ANPRM 11/25/2011): This rule proposes to require EFVs for: branched service lines serving more than one single family residence, multi-family residential dwellings, and commercial buildings.

Final Rule – in PHMSA
Standards Update (NPRM 8/16/2013, Adv. Committee OK 12/2013): This rule would update 22 of the 60+ standards Incorporated By Reference (IBR) throughout Parts 192, 193 and 195. Note: All IBR standards pertaining to the pipeline safety regulations must be available for free to the public. ANSI has developed an IBR portal at, to assist people in finding those standards.

Final Rule – past PHMSA
Miscellaneous Rulemaking (NPRM 11/29/2011; Adv. Committee OK 7/2012): This rule would make various modifications and clarifications to the gas pipeline regulations, including: performance of post-construction inspections, leak surveys of Type B onshore gas gathering lines, requirements for qualifying plastic pipe joiners, regulation of ethanol, and the transportation of pipe.

Excavation Damage Prevention (NPRM 4/2/2012; Adv. Committee OK 12/2012): This rule would establish procedures for PHMSA to enforce damage protection laws in States that have inadequate enforcement to protect safety. Complies with PIPE’s Act 60114(f).

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Ohio Updates Gas Regulations

On December 19, 2013 the Ohio Public Utilities Commission published updates to their regulations in 4901.1.16. Substantial changes in that update include:

  • Added definitions for “gas gathering pipeline”, “gas gathering / processing plant pipeline operator”, “Gas processing plant”, “horizontal well”, “MAOP”, “Natural Gas Pipeline Safety Act”, “processing plant gas stub pipeline”, “raw natural gas”, and “raw natural gas liquids.”
  • Updated definition for “transportation of gas”
  • Extended regulation to cover gas gathering / processing plant pipeline operator’s.
  • Updated Section 4901:1-16-04 Record, maps, inspections, and leak classifications to include gas gathering/processing plant pipeline operators to comply with the requirements of this section.
  • Throughout the regulation, the website for the commission was updated to be
  • Expanded Section 4901:1-16-08 Service of notices and investigative reports, Section 4901:1-16-11: Settlement agreements and stipulations, Section 4901:1-16-12 Commission Proceedings and Section 4901:1-16-14 Payment of forfeitures and payments made pursuant to stipulation to include gas gathering/processing plant pipeline operators.
  • Added Section 4901:1-16-15 outlining the requirements for gas gathering pipelines and processing plant stub pipelines. These requirements cover:
    • Design, installation, initial inspection and testing,
    • Corrosion control,
    • Damage prevention programs,
    • Public education programs,
    • Establishing MAOP,
    • Pipeline markers,
    • Leakage surveys, and
    • Reporting of pipeline construction.

For a copy of these Ohio gas updates, contact Jessica Roger.

RCP Receives 3 Patents for MAOP Software

RCP has received 3 patents (#8,548,756; #8,548,757; and #8,548,758) for our industry-leading MaxOp* software. RCP is the unquestioned market leader providing MAOP Validation Services, including over 100,000 miles of gas and liquid pipeline analysis and support. Not only does RCP bring a wealth of experienced professional engineers and support staff, we have brought the most comprehensive and complete MAOP validation tool to the market, MaxOp*.

MaxOp* Features:

  • NEW Section Q & R, Gas Transmission Annual Report: output MAOP reports compliant with PHMSA requirements
  • Data agnostic: works with all common database and GIS data formats
  • Traceable: connects data to source document image files
  • Verifiable: identifies exact 192/195 code sections driving MAOP results

MAOP Validation Services:

  • Turnkey: document review & imaging, data extraction, gap analysis, MAOP reporting
  • Quality Assurance: review existing validation efforts, compare calculations using MaxOp*
  • Annual Report: Import data to MaxOp*, export Section Q & R report
  • Remediation: develop strategies to close gaps and/or re-establish MAOP

For more information about RCP’s MAOP validation services or the MaxOp* calculator tool, please contact Jessica Roger. * MaxOp is a registered trademark of RCP, Inc., in the United States.

Pipeline System Operator Security Information (TSA Notice) OMB Control Number: 1652-0055

Under the Aviation and Transportation Security Act (ATSA) (Pub. L. 107-71, 115 Stat. 597 (November 19, 2001) and delegated authority from the Secretary of Homeland Security, the Transportation Security Administration (TSA) has broad responsibility and authority for “security in all modes of transportation, including security responsibilities, over modes of transportation that are exercised by the Department of Transportation.” As the lead Federal agency for pipeline security, it is important for TSA to have contact information for company security managers and knowledge of security incidents and suspicious activity within the mode. And, to facilitate the exchange of security information in a timely fashion, contact data is necessary for pipeline operators’ security operations or control centers.

TSA has forwarded the Information Collection Request (ICR), Office of Management and Budget (OMB) control number 1652-0055, to OMB for review and approval of an extension of the currently approved collection under the Paperwork Reduction Act. The ICR describes the nature of the information collection and its expected burden. TSA published a Federal Register notice, with a 60-day comment period soliciting comments, of the collection of information on August 16, 2013, 78 FR 50077. The collection involves the submission of contact information for a pipeline company’s primary and alternate security manager and the telephone number of the security operations or control center, as well as data concerning pipeline security incidents. In preparation for OMB review and approval of the information collection, TSA is soliciting comments to:

  1. Evaluate whether the proposed information requirement is necessary for the proper performance of the functions of the agency, including whether the information will have practical utility;
  2. Evaluate the accuracy of the agency’s estimate of the burden;
  3. Enhance the quality, utility, and clarity of the information to be collected; and
  4. Minimize the burden of the collection of information on those who are to respond, including using appropriate automated, electronic, mechanical, or other technological collection techniques or other forms of information technology.

Submit written comments before January 22, 2014 on the proposed information collection to the Office of Information and Regulatory Affairs, OMB, Attn: Desk Officer, Department of Homeland Security/TSA, via email.

For further information contact: Joanna Johnson, TSA PRA Officer, (571) 227-365. Or, for a copy of this TSA Notice, contact Jessica Roger.

ASME Training Week – Denver April 14 – 18

Check out the pipeline training programs offered by ASME in Denver the week of April 14-18, 2014. Subject Matter Experts from RCP will provide training on the first day regarding pipeline pressure testing. Other courses are offered on ASME B31.4 (liquid transmission) and ASME B31.8 (gas transmission), as well as Composite Repairs, Defect Assessment, Inline Inspection, Integrity Management, and Onshore Design and Construction. Additional information can be found on the ASME website.

DOT Pipeline Compliance Workshop – March 25 – 27, 2014

Join us March 25 – 27, 2014 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.

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