DOT Pipeline Compliance News

January 2020 Issue

In This Issue

PHMSA 2020 D&A Testing Rate

[Docket No. PHMSA-2019-0208]

PHMSA published in the Federal Register (page 72134-5) on December 30, 2019 the minimum random drug testing rate for covered employees for 2020. The test rate will remain at 50%.

PHMSA LNG by Rail Proposed Rule, Extension of Comment Period

[Docket No. PHMSA-2018-0025 (HM-264); Notice No. 2019-14]

On October 24, 2019, PHMSA published a notice of proposed rulemaking (NPRM), entitled ‘‘Hazardous Materials: Liquefied Natural Gas by Rail (HM–264)’’ proposing changes to the Hazardous Materials Regulations to allow for the bulk transport of Methane, refrigerated liquid, commonly known as liquefied natural gas (LNG), in rail tank cars.

In response to a request for an extension of the comment period from the Offices of the Attorneys General of New York and Maryland, PHMSA is extending the comment period for the HM–264 NPRM for an additional 21 days. Comments to the HM–264 NPRM will now be due on or before January 13, 2020.

Comments should reference Docket No. PHMSA–2018–0025 and may be submitted on the Federal eRulemaking Portal.

TRRC Updates 16 TAC 8B Requirement for All Pipelines

Effective January 6, 2020, the Railroad Commission of Texas (TRRC) has made changes to 16 TAC 8B Requirement for All Pipelines regarding the regulation of gathering lines, new construction requirements and numerous new entries into the Typical Penalties and Penalty calculation tables.

Operators of natural gas gathering pipelines located in Class 1 locations and hazardous liquids and carbon dioxide gathering pipelines located in a rural areas are to take actions to correct hazardous conditions that create risk to public safety. This includes following existing reporting requirements; conducting investigations into accidents, incidents, threats to public safety and operational safety complaints; taking corrective action to prevent recurrence; and to cooperate with the Commission and to provide reasonable access to facilities and records.

New construction notification rules have been amended and replace the previous rule for notification 30 days prior to commencement of construction of any installation totaling greater than on mile or more of pipe. Depending on the length and type of installation, new construction notification can now range from no notification, 30 days or 60 days. New construction commencement rules can be found in 16 TAC 8.115.

For a copy of 16 TAC 8B Requirement for All Pipelines, contact Jessica Foley.

TRRC Updates 16 TAC 8D Accident Reporting Deadlines

Effective January 6, 2020, the Railroad Commission of Texas (TRRC) has made changes to accident reporting deadlines, annual report retention, and Facility Response Plan retention for intrastate Hazardous Liquids and Carbon Dioxide pipelines under 16 TAC 8D.

All annual reports required under 49 CFR 195 are to be retained by the operator, rather than submitted to the TRRC, and be available upon request by the Commission. Similarly, Facility Response Plans required under OPA 90 need not be filed concurrently with the DOT but retained and kept available upon request.

New accident reporting requirements have the operator retain accident records submitted to the DOT and provide the records to the TRRC upon request rather than submit concurrently. Operators of TRRC-regulated hazardous liquids gathering pipelines will now file with the TRRC a written report utilizing the applicable form from the DOT within 30 calendar days after the date of the accident.

For a copy of the updated 16 TAC 8D regulations, contact Jessica Foley.

Colorado Proposed Gas Rule Changes

[Proceeding #19R-0703GPS]

The Colorado Public Utilities Commission proposed in the December 25, 2019 Colorado Register a significant gas rule change. The Public Utilities Commission is proposing the removal of most of the Gas Pipeline Safety section of 4 CCR 723-4 (4900) and republishing it as a new section 11 of 4 CCR 723. The new section has new definitions and some revised definitions. Section 11 does have some proposed new requirements that are not present in Section 4. The proposed new requirements include:

  • How to obtain waivers or variances to these rules in emergency and non-emergency situations,
  • Requirement for expanding Colorado 811 to include MMO/LPG and Type C gathering pipeline systems,
  • Making direct sales pipelines subject to transmission pipelines regulations,
  • Making small operator systems (1000 services or less) distribution systems with different requirements based on actual number of services.

For a copy of the proposed rule changes for CCR 723-4 or CCR 723-11, contact Jessica Foley.

LDNR Notice of Intent to Amend Chapter 27 Damage Prevention Regulation

[Docket No. PRA 2020-01]

In the December 20, 2019 Louisiana Register Vol. 45, No. 12, the Louisiana Department of Natural Resources (LDNR) published a Notice of Intent (NOI) to amend the Damage Prevention regulations in LAC 43:XI, Subpart 6, Chapter 27.

LDNR is accepting public comments on this NOI. Written comments will be accepted by hand delivery or USPS only, until 4 p.m., February 10, 2020, at Office of Conservation, Pipeline Division, P.O. Box 94275, Baton Rouge, LA 70804-9275; or Office of Conservation, Pipeline Division, 617 North Third Street, Room 931, Baton Rouge, LA 70802. Reference Docket No. PRA 2020-01.

All inquiries should be directed to Steven Giambrone at the above addresses or by phone to (225) 342-2989.

For a copy of the proposed Damage Prevention Regulation, contact Jessica Foley.

Pipeline Incident Prevention Best Practices Guide

The Council for Dredging & Marine Construction Safety (CDMCS) has published “Pipeline Incident Prevention,” a damage prevention guide for both the dredging and marine industries. This recommended best practices guide is for the safe dredging near underwater gas and hazardous liquid pipelines located in U.S. Army Corps of Engineers federal navigation channels.

The “Pipeline Incident Prevention” (PIP) and Hazard Mitigation Checklist are available for download and production here.

The PIP comes in two sizes (Letter 8.5 x 11.0 and Pocket 6.25 x 9.25), while the Hazard Mitigation Checklist is formatted for one size – 4.5 x 11.0. Both were designed to be double-sided. If you are not a member of the CDMCS, please review this link for booklet creation directions.

Pipeline Advisory Committee Spring Meeting Postponed

Due to unforeseen circumstances, the planned March PAC meeting has been postponed and will be rescheduled. Check the PHMSA Meetings webpage for updated information.

What can TaskOp™ do for you? Webinar

february 17, 2020

New Regulations have you Stressed Out…Don’t Panic…TaskOp™ has your back

This webinar will demonstrate how TaskOp™ can be used to track all of the complex activities associated with the new gas transmission and hazardous liquid regulations.

  • Manage inventory of all segments with non-TVC records through the lifespan of MAOP reconfirmation and material verification efforts.
  • This is done with easy-to-use dashboards to:
    • Track reconfirmation mileage progress.
    • Track all your scheduled projects to get your newly regulated pipelines in step with regulations.
    • Manage workloads across your compliance team.
  • Track implementation progress of new regulatory requirements, including procedure updates, material verification digs, data analysis, assignments of responsibility.
  • Utilize the calendar for upcoming agency audits and internal field training / audits:
    • Keep up to date with what is coming up and be better prepared for any type of audit.
    • Keeps track of all your audit details, findings, follow up records, etc.
    • Manage your audit findings by assigning them to personnel, track their progress, and keep track of documentation.
  • After everything is in order, you can manage your new workflow tasks for all the newly regulated pipelines within TaskOp™.
    • Track inspections, maintenance, and other tasks related to your pipelines.
    • Keep everything traceable, verifiable, and complete all in one system.

Click here to register for our What can TaskOp™ do for you? webinar.

TaskOp now has the ability to track inventory and work with barcodes. 
We’re taking TaskOp to the next level with barcoding. Let TaskOp track your warehouse inventory of spare valves, meters, parts, etc. and track when they are pulled for projects in the field. Know when you need to reorder items, where items are used and track invoices for accounting purposes.  Barcode scanning allows users to quickly scan a barcode to find the part. If you are just starting a warehouse, or barcoding assets, TaskOp can generate those barcodes to print and stick to your inventory – the data required to find records quickly, via scanning the barcode, will already be in TaskOp.

As an added bonus, use barcodes to quickly pull up the latest field tasks without having to search the system.  If your assets have barcodes on them and that information is in the asset data in the system, you can scan the barcode and the latest active tasks for that asset will appear in a report,  greatly reducing the time needed to find those tasks that a field technician will be doing.

Visit or contact Jessica Foley for more information.

2020 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!

Pipeline Pigging and Integrity Management (PPIM) Conference
February 17-21, 2020
George R. Brown Convention Center; Houston, TX
RCP Booth #412

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.

AIChE Spring Meeting & 16th Global Congress on Process Safety
March 29 – April 2, 2020
Hilton Americas and George R. Brown Convention Center; Houston, TX

The AIChE Spring Meeting is the year’s key technical conference for practicing chemical engineers. A wide range of subjects relevant to the current needs of industry is covered. Plus, the Global Congress on Process Safety covers the critical needs of process safety practitioners more broadly and deeply than any other conference.

API Pipeline Conference, Control Room Forum and Cybernetics Symposium
April 28-30, 2020
Hyatt Regency Mission Bay; San Diego, 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.  Once again, RCP is a proud sponsor of this event and we look forward to seeing you there.

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


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