DOT Pipeline Compliance News

January 2018 Issue

In This Issue

PHMSA Random Drug Testing Rate

[Docket No. PHMSA-2018-0137]

Effective January 1, 2018, the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) has determined that the minimum random drug testing rate for all covered employees will be 50% during calendar year 2018. Operators of gas, hazardous liquid, and carbon dioxide pipelines and operators of liquefied natural gas facilities must randomly select and test a percentage of all covered employees for prohibited drug use. The minimum annual random drug testing rate was 25% of all covered employees for calendar year 2017. However, the PHMSA regulations require the Administrator to raise the minimum annual random drug testing rate from 25% to 50% of all covered employees when the data obtained from the Management Information System reports (required to be filed by covered entities under PHMSA regulations) indicate the positive test rate is equal to or greater than 1%. In calendar year 2016, the random drug test positive test rate was greater than 1%. Therefore, the PHMSA minimum annual random drug testing rate shall be 50% of all covered employees for calendar year 2018.

Operators are also reminded that drug and alcohol testing information must be submitted for contractors performing or ready to perform covered functions. For calendar year 2017 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.

For further information, contact Wayne Lemoi, Drug & Alcohol Program Manager, at 909–937–7232 or by email; or Blaine Keener, Director of Safety Data Systems and Analysis, at 202–366–0970 or by email.

For a copy of PHMSA’s notice from the Federal Register, contact Jessica Foley.

DOT Pipeline Compliance Workshop

JANUARY 23 – 25, 2018

Join us January 23-25, 2018 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.

PHMSA Notice for Underground Natural Gas Storage Facility User Fee

[Docket No. PHMSA-2017-0129]

On August 16, 2017, the Office of Management and Budget approved the collection of calendar year (CY) 2017 Underground Natural Gas Storage Facility Annual Reports. PHMSA issued a Notice of their proposal to use CY 2017 annual report data in the user fee rate structure for both fiscal year (FY) 2018 and 2019. During the FY 2018 user fee process, PHMSA will use CY 2016 annual report data for gas transmission pipelines, hazardous liquid pipelines, and liquefied natural gas facilities. Using CY 2016 data ensures adequate time to verify annual report data quality.

PHMSA proposes the following steps for developing the user fee rate structure. PHMSA will sum the number of wells from sections C7 and C8 of the UNGS annual report for each operator. The operator well counts will be parsed into 10 tiers. The lowest values will be in tier 1 and the highest values in tier 10. The minimum and maximum well counts for each tier will be selected to place an equal number of operators in each tier. The tier fee structure is designed to place a larger share of the user fee on operators with higher well counts. The following percentages of the total user fee would be billed to each tier:

TierPercentage of Total

PHMSA invites interested persons to comment on the underground natural gas storage facility data collection described in this notice by January 8, 2018. Comments may be submitted on the E-Gov web site. Reference Docket No. PHMSA–2017–0129 at the beginning of your comments.

For of copy PHMSA’s Notice from the Federal Register, contact Jessica Foley.

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.

INGAA Construction Safety Guidelines

The INGAA Foundation, a membership-based organization of over 200 natural gas pipeline operators, manufacturers and service providers, released two more installments of its “Construction Safety Guidelines” (“CSGs”) this December – Establishing Quality Metric for Natural Gas Pipeline Construction and Developing a Site-Specific Safety Plan.

The CSG initiative began in 2009 to steer the creation of safety guidance documents on a variety of construction topics, with the goal of enhancing safety culture and creating consistency across the natural gas industry. CSGs originate from highly demanded topics within the Foundation, and the suggestion process is open to all Foundation members. Each document begins with a collaborative base, produced from a representative industry sample of internal practices collected among member companies. This collection is evaluated to identify both commonly shared construction safety management practices as well as unique ones. A committee of safety experts reviews this information, examining both the consensus practices for accuracy and the unique practices for inclusion if they are innovative to safety. The membership then offers changes and suggestions, which are voted on by the committee. After a sufficient review period, the committee reviews, finalizes and distributes the guideline to the membership for integration into their own safety management procedures. Past CSGs, as well as information about the INGAA Foundation, can be found by clicking on this link to the INGAA Foundation.

PHMSA Pipeline Advisory Committee Meeting Recap

PHMSA held a joint meeting with the Liquid Pipeline Advisory Committee (LPAC) and the Gas Pipeline Advisory Committee (GPAC) on December 13th and a GPAC-only meeting the following two days. Transcripts and presentations made at the meetings can be found here. Issues discussed at the joint LPAC and GPAC meeting included:

  • Voluntary Information-Sharing Working Group
  • Underground Gas Storage Interim Final Rule
  • Pressure Vessel Testing Requirements
  • Safety Management Systems
  • Enforcement Update
  • Excavation Damage Enforcement

The GPAC meeting was the third in a series of meetings to specifically discuss the Safety of Gas Transmission and Gathering NPRM. The committee was able to vote on 192.607 Material Verification with several modifications, including but not limited to the following:

  • Remove applicability criteria and change this section to a process for material verification where required by other sections of Part 192.
  • Remove requirements for a material verification plan.
  • Retain the opportunistic approach of obtaining unknown or undocumented material properties when excavations are performed for other repairs or other reasons.
  • Incorporate language stating that, if an operator does not receive an objection letter from PHMSA within 90 days of notifying PHMSA of an alternative sampling approach, the operator can proceed with their method.
  • Reduce number of quadrants at which NDE tests must be made from 4 to 2.
  • Delete specified program requirements for how to address sampling failures and replace with a requirement for operators to determine how to deal with sample failures through an expanded sample program that is specific to their system and circumstances.

Future GPAC meetings are planned for March and June.

2018 Industry Conference Schedule

July 22 – 25, 2018
Hilton Portland Downtown
Portland, OR

The American Public Gas Association (APGA) Annual Conference is the largest gathering of municipal natural gas professionals across the nation. From the educational sessions with key industry figures generating new ideas to networking opportunities with hundreds of colleagues from across the nation, the APGA Annual Conference is the event of the year for city- and community-owned natural gas utility professionals and industry experts.

July 30 – August 1, 2018
Tampa Marriott Waterside Hotel & Marina
Tampa, Florida

The SGA Operating Conference format is a focused round table discussion. Attendees learn smart practices and lessons learned from their peers with 22 concurrent facilitated sessions to choose from. Breakout sessions with presentations from subject matter experts open the conference following the keynote address. Make plans to visit the exhibit hall, which will include over 100 services and product service organizations showcasing the latest products and services available to the industry.

July 30 – August 3, 2018
Astor Crowne Plaza, New Orleans

RCP is once again a proud sponsor and exhibitor at this year’s conference, which has been referred to as the “Premier Pipeline Safety Conference.” We are excited to showcase our newest developments and all our services for Pressure Test support.

August 28 – 29, 2018
(Note: Updated conference dates!)
M Resort in Henderson, Nevada

The Western Regional Gas Conference provides a forum for the free exchange of information between natural gas companies and their state and federal regulators, and with associated industry organizations, consultants, manufacturers and vendors that serve the pipeline industry.

August 21 – 22, 2018
AT&T Conference Center in Austin, TX

This year the Railroad Commission of Texas (RRC) combines its two largest regulatory conferences, the Pipeline Safety Conference and the Oil & Gas Regulatory Conference, into one event. Registration is now open for the 2018 RRC Regulatory Conference: Environmental Protection, Pipeline Safety and Well Filings. Early bird registration ends July 23rd. For additional conference information and to register, visit the RRC’s website.

October 10, 2018
San Luis Hotel, Galveston

October 18-19, 2018
Hotel Monteleone, New Orleans

Each year since 2006, the Pipeline Safety Trust has hosted pipeline safety conferences. What makes them unique among pipeline conferences is the mix of attendees, who come with experience as the affected public, the pipeline industry, and government regulators. All these people come together to discuss barriers to safer pipelines.

October 30 – Nov 1, 2018
The Chattanooga Hotel
Chattanooga, TN

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.