DOT Pipeline Compliance News

January 2024 Issue

In This Issue

Changes to the Gas Transmission and Gathering Pipeline Systems Annual Report Form F 7100.2-1

Revised Announcement for Gas Transmission and Regulated Gas Gathering Annual Report Changes: 

For the 2024 report to be filed in 2025, any modifications to the gas transmission and regulated gas gathering annual report, approved by the Office of Management and Budget (OMB), will come into effect. Currently, OMB approval has been granted for certain changes, while others are pending and expected to be requested during the next information collection renewal. 

Approved Changes in Part F: 

  • Part F, Section 2 & 5.d: Report only conditions meeting the definitions in §192.714(d) that were repaired. 
  • Part F, Section 4.d: Report only conditions meeting the definitions in §192.714(d) or Appendix F that were repaired. 

Approved Changes in Part M: 

Part M4 and M5: Require reporting of gas transmission and regulated gas gathering excavation damages that were repaired in the Calendar Year, categorized by root cause. Also, report the number of excavation tickets received during the year. 

Pending Changes in Part Q:  

Pipelines subject to §192.624(a) must have their Maximum Allowable Operating Pressure (MAOP) reconfirmed using a method from §192.624(c). Specific instructions for these methods are included in the “§192.624(c) Completion Table.” Pipeline mileage reconfirmed under §192.624(c) methods will no longer be reported in the §192.319 section of Part Q but in the appropriate class location in the §192.624(c) section of Part Q. Accompanying this change is specific language outlining how mileage should be reported in each section of Part Q. Note that OMB approval for these changes is pending and expected during the next information collection renewal. 

For more information about the changes to this annual report form or for assistance filing your annual report, contact Jessica Foley

Unlocking the Power of Legacy Knowledge: A Knowledge Transfer Success Story

In 2023, RCP had the opportunity to collaborate with an Operator on a vital knowledge transfer project, aiming to preserve valuable insights from the client’s retiring staff. Below is a summary of the effort in the form of a case study:  

This case study illuminates how ‘Operator,’ a prominent utility company, effectively confronted the challenge of retaining and leveraging knowledge from departing employees. Faced with the imminent loss of crucial expertise, ‘Operator’ initiated a robust knowledge transfer program. The comprehensive approach encompassed identifying key knowledge domains, fostering collaborative mentorship and documentation processes, revising standard operating procedures, and incorporating regular feedback and evaluation. The outcomes were transformative, resulting in a seamless transition, heightened productivity, enhanced collaboration, significant cost savings, and a newfound competitive advantage. The success of this initiative underscores the critical importance of strategic investment in knowledge preservation for sustained success amidst the dynamism of today’s business environment. The unwavering commitment to knowledge transfer not only ensured a smooth transition during a pivotal retirement but also elevated the company’s overall efficiency and competitiveness. 

To read the full case study and for details of RCP can help facilitate a knowledge transfer effort for you, please contact Jessica Foley.  

Mississippi One-Call Regulation Changes 

On January 5, 2024, Significant Revisions to Mississippi’s Title 77 – Public Utilities and Carriers Chapter 13: Regulation of Excavations Near Underground Utility Facilities of the Mississippi Statutes was revised. The biggest impact of these revisions changes the minimum time for providing notice of intent to excavate to Mississippi 811 from 2 days to 3 working days. Additionally, if the excavation is not concluded within 14 days of the initial notice, the renewal period has been adjusted to a minimum of 3 days and a maximum of 4 days before the markings expire, compared to the previous range of at least 2 and not more than 3 days. All deadlines requiring at least 2 days’ notice have been extended to 3 working days. 

The regulations also introduce a reduction in the response time for operators notified through PRIS, requiring them to respond within 2 hours, down from the previous 4-hour window. Additionally, the revisions define ‘impeding emergencies’ and establish specific time constraints for excavations following these notifications. 

For more information regarding this One Call Regulation change, please contact Jessica Foley

Did you know?

DID YOU KNOW? INGAA members take several proactive steps to prepare for winter weather as part of their commitment to the safe, secure, and reliable transportation of natural gas throughout the country. INGAA members’ winterization plans generally focus on three key areas: asset integrity, stakeholder coordination, and personnel safety. Click here to read more.   

    The Enforcement Corner

    The Enforcement Corner summarizes recent PHMSA enforcement actions, indicating where PHMSA is putting its enforcement efforts and the fines they are proposing for various types of violations.

    In November 2023, PHMSA issued 5 NOAs, 5 NOPVs, and 6 WLs accompanied by $63,900 in proposed fines. Significant proposed fines were attributed to the following code sections: 

    • $30,100 49 CFR 192.465(b) External Corrosion Control 
    • $33,800 49 CFR 192.741(a) Pressure Limiting/Regulating Stations 

    Please note: 

    1. Pipeline operators may disagree in whole or in part with each proposed violation cited by PHMSA.  
    1. Proposed Civil Penalties (PCP) may be reduced or eliminated before an enforcement action becomes final. 
    1. A Corrective Action Order (CAO) usually addresses urgent situations arising out of an accident, spill, or other significant, immediate, or imminent safety or environmental concerns. 
    1. A Notice of Amendment (NOA) is frequently a result of a difference of opinion regarding written procedure requirements. 
    1. A Notice of Proposed Safety Order (NOPSO) addresses pipeline integrity risks that may not constitute a hazardous facility requiring immediate corrective action (see Corrective Action Order described above), but do need to be addressed over time. 
    1. A Notice of Probable Violation (NOPV) is not proof that a violation actually occurred. 
    1. Proposed Compliance Orders (PCO) frequently document actions the pipeline operator already planned to do. 
    1. Warning Letter (WL) is an official notice by PHMSA that an operator needs to make improvements but that no further enforcement is proposed for those findings at this time. 

    RCP maintains a detailed database of all PHMSA enforcement actions dating back to 2007 and is routinely asked for data analysis of various enforcement actions. For more information on how RCP can assist with enforcement action data analysis services, contact Jessica Foley

    Need to respond to a PHMSA enforcement action?
    Need to know if your enforcement action is an outlier, or par for the course? 

    RCP maintains a detailed database of all PHMSA enforcement actions and their resolution which enables us to compare and contrast individual enforcement actions to nationwide actions and trends.  We can help put things into context to ensure an effective reply for each citation.  For more information on how RCP can assist with enforcement action data analysis services, contact Jessica Foley.

    2024 Conference News

    Pipeline Pigging & Integrity Management Conference
    February 12-16, 2024 | George R. Brown Convention Center | Houston, TX 

    The Pipeline Pigging and Integrity Management Conference (PPIM) in Houston, Texas, serves as a pivotal gathering for professionals in the pipeline industry. This annual event brings together experts, engineers, and industry leaders to discuss the latest advancements and best practices in pipeline integrity, maintenance, and inspection. Attendees can expect insightful presentations, interactive discussions, and access to cutting-edge technologies aimed at ensuring the safe and efficient operation of pipelines. PPIM in Houston serves as a hub for networking, knowledge exchange, and collaboration, playing a crucial role in shaping the future of pipeline integrity management.

    Click here to register to attend PPIM.

    Ohio Oil and Gas Association (OOGA) Annual Meeting
    March 6-8, 2024 | Hilton Columbus at Easton | Columbus, OH

    The Ohio Oil and Gas Association (OOGA) Annual Meeting unites key figures from both state and national spheres to deliberate on the pressing matters shaping the Ohio oil and gas sector. As the foremost business gathering of the Association, it serves as a focal point for industry leaders, providing a platform for discussions on contemporary challenges and opportunities. Attendees can engage in a spectrum of activities, including Business Sessions to delve into critical topics, Breakout Sessions for in-depth exploration, a comprehensive Trade Show showcasing innovations, and Networking Receptions offering invaluable opportunities for professional connections.

    Click here to register to attend OOGA.

    Texas Gas Association (TGA) Distribution Roundtable 2024
    March 25-26, 2024 | New Braunfels Civic enter | New Braunfels, TX

    The TGA Distribution Roundtable will provide information for natural gas distribution professionals. This gathering of the best minds in the industry encourages discussions on the current state and federal regulations, best practices, and new technologies. It allows for face-to-face exchange of information and ideas on what works and what doesn’t.

    Click here to register to attend TGA Distribution Roundtable.

    AGA Operations Conference & Spring Committee Meetings
    April 28-May 2, 2024 | Hyatt Regency Seattle | Seattle, WA

    The Operations Conference is the natural gas industry’s premier gathering of utilities, distribution, and transmission operators.  Leaders and technical experts from across North America and the world attend the event. Developed by gas operators for gas operators – this event is the industry’s largest annual forum with regularly more than 800 operations management in attendance. The event offers technical sessions with topics to include but not be limited to gas measurement, pipeline integrity, operations advocacy, system safety, environment, storage, engineering, renewable natural gas, construction and maintenance, gas control, supplemental gas, corrosion control, and piping materials. Attendees share technical knowledge, leadership strategies, and learning events promoting the safe, reliable, and cost-effective delivery of natural gas to the end-user.

    Click here to register for the AGA Operations Conference & Spring Committee Meetings.

    2024 PSI Training Schedule

    February 20-22, 2024DOT Pipeline Compliance Workshop In-PersonRCP Headquarters
    June 11-13, 2024DOT Pipeline Compliance Workshop In-PersonRCP Headquarters
    On DemandFundamentals of Pressure TestingeLearning
    On DemandType R (Reported-Regulated) Gas Gathering – Annual Reports Filing CourseeLearning

    Fundamentals of Pressure Testing

    In this 8-hour eLearning course, you will be guided through the processes of designing, planning, executing, and evaluating/validating a pressure test. This course is designed for attendees from a variety of backgrounds including engineers, field techs, and other pipeline professionals. Certificates of completion are available upon successful completion of the knowledge test at the end of the course.
    To register for this course, click here!

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


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