DOT Pipeline Compliance News

January 2019 Issue

In This Issue

PHMSA 2019 Random Drug Testing Rate

[Docket ID PHMSA-2018-0103]

The minimum random drug testing rate for covered employees will remain at 50 percent during calendar year 2019. Drug and alcohol testing information must be submitted for contractors who are performing or are ready to perform covered functions. For electronic reporting, the “user name” and “password” for the Drug and Alcohol Management Information System (DAMIS) will be available in the PHMSA Portal.

PHMSA Revision to OPID Assignment Request & Registry Notification

[Docket No. PHMSA-2018-0078]

The National Registry of Pipeline and LNG Operators serves as the storehouse for the reporting requirements for an operator regulated or subject to reporting requirements under 49 CFR Part 192, 193, or 195. This registry incorporates the use of two forms: OPID Assignment Request (PHMSA F 1000.1) and National Registry Notification (PHMSA F 1000.2). PHMSA proposes revising certain parts of these forms and instructions after receiving comments that it could be improved by more detailed reporting instructions. PHMSA has placed instructions for completing the Operator Assignment Request and the National Registry Notification forms in the docket. PHMSA will request a three-year term of approval for the information collection: National Registry of Pipeline and Liquefied Natural Gas (LNG) Operators. Current Expiration Date: 7/31/2020.

Comments to the Office of Management and Budget are invited on: (a) The need for the proposed information, including whether the information will have practical utility in helping the agency to achieve its pipeline safety goals; (b) The accuracy of the agency’s estimate of the burden of the proposed collection; (c) Ways to enhance the quality, utility, and clarity of the information to be collected; and (d) Ways to minimize the burden on those who are to respond.

Interested persons are invited to submit comments on or before January 17, 2019. Submit comments regarding the burden estimate, including suggestions for reducing the burden, to the Office of Management and Budget, Attention: Desk Officer for the Office of the Secretary of Transportation, 725 17th Street NW, Washington, DC 20503.

For a copy of this Notice from the Federal Register, contact Jessica Foley.

PHMSA GPAC and LPAC Meeting Status – Postponed!

[Docket No. PHMSA-2016-0136]

Due to the Government shut-down, the Gas Pipeline Advisory Committee (GPAC), and a joint meeting of the GPAC and the Liquid Pipeline Advisory Committee (LPAC) that was scheduled on January 8-10, 2019 has been postponed. Please be sure to cancel your hotel and airline arrangements. The GPAC had planned to discuss the proposed rule titled Safety of Gas Gathering Pipelines. It appears that PHMSA’s initial proposal will be to regulate all gas gathering lines greater than 16-inches in class 1 locations and gas gathering lines greater than 12-inches up to 16-inches within class 1 locations that have at least one dwelling located within a potential impact radius. Following this meeting, the GPAC and LPAC planned to jointly discuss a variety of policy issues and topics relevant to both gas and liquid pipeline safety. For more information and updates on the rescheduled meeting dates, including copies of PHMSA’s presentations, go to the meeting page.

PHMSA Public Awareness and Engagement Workshop

March 13-14, 2019

The PHMSA Public Awareness and Engagement Workshop has been scheduled for March 13-14 and will be held in Washington, DC at the US DOT HQ Atrium. Mark your calendars if you are interested in attending, or participating via webcast. We will post more information as it becomes available.

BSEE Notice Regarding Pipeline Decommissioning in Deep Water

[Docket No. BSEE-2018-0017]

The Bureau of Safety and Environmental Enforcement (BSEE) is soliciting information and public comments regarding potential impact [including impacts on future use of the Outer Continental Shelf (OCS)] related to decommissioning-in-place (DIP) of certain pipeline-related infrastructure in deep water (i.e., depths of at least 600 feet) on the OCS. Responses to this Request for Information (RFI) will help identify technical, safety and environmental factors, as well as potential impacts to other uses of the OCS, that will inform BSEE’s consideration of requests to allow DIP of such pipeline-related infrastructure in deepwater in lieu of decommissioning by removal.

Written comments and other information in response to this RFI must be submitted on or before February 26, 2019. Include docket number BSEE–2018– 0017 as an identifier when submitting comments via the Federal eRulemaking Portal.

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

2019 Industry Conference Schedule

(January 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!

January 28-31, 2019
Galveston Island Convention Center, Galveston, Texas
RCP Booth #200

Sheri Baucom, RCP’s Director, Integrity Services, will be presenting “A Practicum on Pressure Testing – Compilation of Best Practices” on Tuesday, January 29th, at 1:00 p.m. Pressure testing is one of the oldest methods of ensuring the integrity and fitness for service of pipelines. By this fact alone, much of the information that exists on the topic is outdated, inconsistent with other information sources and in some cases, factually incorrect regarding federal requirements and/or basic scientific principles. This presentation will seek to address these identified issues.

This four-day summit includes three days of presentations spanning over 120 topics. In addition, an optional day of training is conducted by subject matter experts. Each day focuses on presentations relevant to upstream, midstream, downstream operation and integrity management. API Inspection Summit provides an opportunity to learn about new and existing industry codes and standards, to hear about emerging trends from experts, and to discuss new and existing issues in inspection and AIM technology. The API Summit is the only networking event for inspectors and other inspection support professionals in the industry.

February 18-21, 2019
George R. Brown Convention Center, Houston
RCP Booth #406

RCP’s Integrity team, Sheri Baucom and Jerry Rau, will co-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 present 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

PPIM is 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.

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 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 600 operations management in attendance, 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. The 2019 exhibition will be held in conjunction with the conference. The exhibition attracts approximately 250 domestic/international vendors.

DOT Pipeline Compliance Workshop

JANUARY 8-10, 2019

Join us January 8-10, 2019 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, 196, 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.

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.