DOT Pipeline Compliance News

January 2016 Issue

In This Issue

“Significant” Pipeline Rule Updates

At the start of 2016, there are 4 “Significant” pipeline rulemakings currently underway at PHMSA. Under Executive Order 12866, Significant regulatory actions are defined as those that:

  • Have an annual effect on the economy of $100 million or more or adversely affect in a material way the economy, a sector of the economy, productivity, competition, jobs, the environment, public health or safety, or State, local, or tribal governments or communities;
  • Create a serious inconsistency or otherwise interfere with an action taken or planned by another agency;
  • Materially alter the budgetary impact of entitlements, grants, user fees, or loan programs or the rights and obligations of recipients thereof; or
  • Raise novel legal or policy issues arising out of legal mandates, the President’s priorities, or the principles set forth in this Executive order.

A short description of each rulemaking is provided below. DOT’s full Significant Rulemaking Report can be seen here.

Excess Flow Valves
[Docket No. PHMSA-2011-0009]
An NPRM was published 7/15/2015 that would require excess flow valves (EFVs) be installed in all new and renewed gas service lines, for structures other than single family dwellings, when the operating conditions are compatible with readily available valves. These changes are in response to NTSB and PHMSA investigations of current EFV installation practices. The comment period ended on 9/14/2015, and the rule is expected to be finalized by 1/17/2017.

Safety of On-Shore Liquid Hazardous Pipelines
[Docket No. PHMSA-2010-0229]
An NPRM was published on 10/13/2015 which addresses effective procedures that hazardous liquid operators can use to improve the protection of High Consequence Areas (HCA) and other vulnerable areas along their hazardous liquid onshore pipelines. PHMSA proposed changes to the regulations covering hazardous liquid onshore pipelines, adding other areas as HCAs for integrity management (IM) protections, repair timeframes for areas outside the HCAs that are assessed as part of the IM program, leak detection standards, valve spacing requirements for new construction or existing pipelines, and extended regulation to certain pipelines currently exempt from regulation. The comment period ends 1/8/2016.

Amendments to Parts 192 and 195 to require Valve installation and Minimum Rupture Detection Standards
[Docket No. (not assigned yet) / RIN 2137-AF06]
An NPRM is being prepared for publication to address installation of automatic shutoff valves, remote controlled valves, or equivalent technology and to establish performance based meaningful metrics for rupture detection for gas and liquid transmission pipelines. The overall intent is that rupture detection metrics will be integrated with ASV and RCV placement with the objective of improving overall incident response. Rupture response metrics would focus on mitigating large, unsafe, uncontrolled release events that have a greater potential consequence. The areas proposed to be covered include High Consequence Areas (HCA) for hazardous liquids and HCA, Class 3 and 4 for natural gas (including could affect areas). The NPRM is expected to be published on 5/31/2016.

Gas Transmission
[Docket No. PHMSA-2011-0023]
An ANPRM (Advanced Notice of Proposed Rulemaking) was published on 8/25/2011. In this rulemaking, PHMSA plans to revisit the requirements in the Pipeline Safety Regulations addressing integrity management principles for Gas Transmission pipelines. In particular, PHMSA will address: repair criteria for both HCA and non-HCA areas, assessment methods, validating & integrating pipeline data, risk assessments, knowledge gained through the IM program, corrosion control, change management, gathering lines, and safety features on launchers and receivers. An NPRM is expected to be published on 1/11/2016.

Pipeline Pressure Testing Workshop: February 23-24, 2016

RCP is now offering a 2-day Pipeline Pressure Testing Workshop at its facilities in downtown Houston. The workshop will begin by outlining the objectives for performing a pressure test and how those relate to DOT requirements. The workshop will then build upon these foundations to answer many specific pressure testing questions including:

  • What are the different types of tests commonly conducted and how do you design each one?
  • What is the theory and physical science behind a pressure test?
  • How do you plan for a pressure test from start to finish:
    • Cleaning the line
    • Environmental hazards and permitting
    • Landowner and operations safety
    • Customer/stakeholder impact
    • Logistical details and scheduling
    • Pipeline modifications and anticipating failures
  • What is the required instrumentation and how does it need to be configured?
  • What data is absolutely necessary to validate a pressure test?
  • How do you determine and prove a successful pressure test?
  • What does a good test report look like (that will also satisfy PHMSA)?

Each attendee will receive the presentation as well as applicable handouts in a hardcopy notebook. Attendees will also have the opportunity to work through several exercises specifically covering 1) calculating the SMYS, MAOP and test pressures for various pipeline segments at various elevations 2) calculating the volume of water required for a hydrotest, fill times and velocities, and determining how the volume of test water changes with pressure and 3) designing a complete test plan for a hypothetical pipeline i.e. dividing the line into test sections and determining the test parameters for each section.

To register for our workshop, click here.

Drug and Alcohol Programs – Notice

PHMSA has determined that the minimum random drug testing rate for covered employees will remain at 25 percent during calendar year 2016. Operators are reminded that drug and alcohol testing information must be submitted for contractors performing or ready to perform covered functions. For calendar year 2015 reporting, PHMSA will not attempt to mail the “user name” and “password” for the Drug and Alcohol Management Information System (DAMIS) to operators, but will make the user name and password available in the PHMSA Portal.

Report on the Spills of Diluted Bitumen from Pipelines Published

In 2012, Congress tasked the Secretary of Transportation to “determine whether any increase in the risk of release exists for pipelines transporting diluted bitumen.” The US Department of Transportation turned to the National Academies of Sciences, Engineering, and Medicine, which recently published its report on its study. In addition to discussing the chemical properties, physical properties, and environmental behaviors of diluted bitumen in comparison to more commonly transported crude oils, the report examines spill response planning and regulations. The report notes that the chemical, physical, and environmental differences of diluted bitumen indicate areas for improvement in current spill response planning and regulations.

The report makes several recommendations concerning The Pipeline and Hazardous Materials Administration’s (PHMSA) spill response planning regulations including identification and standardization of product names included within the spill response plans with Safety Data Sheets noting all spill relevant properties, and publicly available annual reports online by volume of product. The report also calls for further coordination between PHMSA, the Environmental Protection Agency (USEPA), and the Coast Guard (USCG), including PHMSA gathering USEPA and/or USCG input on spill response plans and the sharing of spill response best practices between federal, state, and local governments. Additional recommendations and research opportunities can be found in the full report at the National Academies Press.

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.


API has recently published RP 1174, Recommended Practice for Onshore Hazardous Liquid Pipeline Emergency Preparedness and Response. This RP was developed as part of the pipeline industry’s initiatives to proactively address emergency response in an ongoing and systematic manner. The document provides operators with an enhanced framework to enable continual improvement of pipeline emergency planning and response processes. The development of this document was a joint effort involving pipeline industry emergency response subject matter experts, EPA, PHMSA, and several emergency response organizations. The RP will provide another tool to support the pipeline industry’s commitment to safe, timely and effective response to a pipeline emergency.

The RP can be ordered here.

API Pipeline Safety Management System Workshop


The American Petroleum Institute (API) will be hosting a Pipeline Safety Management System (PSMS) workshop regarding API’s Recommended Practice (RP) 1173 requirements. The Workshop will be held at the Hyatt Regency Houston Galleria on February 16, 2016. Click here for a link to the API RP 1173 Workshop which includes a preliminary program, online registration and hotel information.

API RP1173 Assessment Services

API recently published a new Recommended Practice (RP) concerning safety management systems for pipelines. API RP 1173 provides pipeline operators with a comprehensive way to make safe operations and continuous safety improvement a constant focus of their operations. The first step for most pipeline operators will be to assess their current safety management system maturity – from nothing in place to a sustainable, improving system. RCP can assist operators in the evaluation of the maturity levels of each element of the recommended practice, and establish an action plan for further development / maturity. Contact Jessica Foley for API RP 1173 Assistance.

Ohio Underground Damage Prevention Enforcement

In December 2014, Ohio Governor John Kasich signed Senate Bill 378 updating Ohio’s underground damage prevention laws in Section 3781 of the Ohio Revised Code, which will take effect January 1, 2016. These updates placed enforcement of the state damage prevention laws with the Public Utilities Commission of Ohio (PUCO)and created the Underground Technical Committee (UTC) to assist the PUCO in technical and legislative recommendations. Additional legislative updates were recently made to the Ohio Revised Code in creating Section 4901:1-2 Protection of Underground Utility Facilities to further clarify and define the processes by which the PUCO and the UTC will work together to investigate and hear inquiries of damage prevention law violations. This section also addresses how the PUCO will administer damage prevention grants, collect fines, and oversee meetings, one-call registrations, and general assembly reports.

TRRC Year in Review

The Railroad Commission of Texas (TRRC) released the agency’s 2015 Year in Review highlighting the accomplishments, milestones and improvements achieved at the agency over the past year. For the first time the Commission is releasing its Year in Review in digital format. The interactive 2015 Year in Review includes video, photos, infographics and links to additional information and may be found online here.

2016 Pipeline Conference Schedule

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

Pipeline Pigging & Integrity Management Conference
February 8 – 11, 2016
Marriott Westchase Hotel / Houston, Texas
RCP Booth #512

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
April 5 – 7, 2016
Omni La Costa / Carlsbad, CA

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. Included in the program for 2016 will be Pipeline Integrity, Safety Management Systems, Training, OQ, Regulatory, Process Safety, Emergency Response, and a host of other relevant topics. Once again, RCP is a proud sponsor of this event and looks forward to seeing you there!

AGA Operations Conference
April 19 – 22, 2016
Arizona Biltmore / Phoenix, AZ

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. The Operations Conference is AGA’s largest forum with regularly more than 500 operations management in attendance, including 80 speakers, and over 100 technical presentations, including two presentations from RCP staff:

  • Development of Industry Guidelines for the Engineering Critical Assessment (ECA) Process Under IVP
  • Is an 8-hour pressure test long enough?

Join RCP for a special reception in The Biltmore “Gold Room” on April 20 (Wednesday) from 6 – 9 p.m. for cocktails, hors d’oeuvres, live entertainment and more!

PHMSA Incident and Annual Data Analysis

RCP can provide detailed and timely analysis of PHMSA historical incident and annual data for clients needing to compare their performance against the industry averages, respond to press inquiries, or analyze trends. Contact Jessica Foley for more information.

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.

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