DOT Pipeline Compliance News

July 2014 Issue

In This Issue

Updated OQ Enforcement Guidance

On June 24, 2014 PHMSA published updated guidance to assist PHMSA pipeline safety investigators and other enforcement personnel in undertaking their compliance inspection and enforcement activities. Some of the changes include:

  • Added API 1161 and ASME B31Q as other Reference Material and Sources to all sections
  • Changes were made to the “Examples of Probable Violation” deleting some and adding others throughout the document.
  • Additional guidance, definitions, and information on record retention was added to sections: 49 CFR 192.801 and 195.501, 49 CFR 192.803 and 195.503, 49 CFR 192.805(b) and 195.505(b), 49 CFR 192.805(c) and 195.505(c), 49 CFR 192.805(e) and 195.505(e), 49 CFR 192.807(a) and 195.507(a), Code Section 49 CFR 192.807(b) and 195.507(b).
  • Added guidance to 49 CFR 192.805(a) and 195.505(a) requiring Operators transporting multiple commodities through its pipeline system, to clearly identify the commodity to which the covered task applies in the Operator’s covered tasks list.

The updated OQ Enforcement Guidance can be downloaded from the PHMSA website under Section III. Staff Manuals and Instructions, or click here.

Need to Update Your Current Operator Qualification Program?

We have the expertise to update your current operator qualification program to satisfy the upcoming regulation change and inspection protocols. Click Here to request more information.

RP 1172 Construction Parallel to Existing Underground Transmission Pipelines – FINAL

1st Edition, April 2014

The American Petroleum Institute (API) recently published the first edition of recommended practice (RP) 1172 for Construction Parallel to Existing Underground Transmission Pipelines. This new RP is intended as a resource to assist all parties to safely manage construction activities of new or modified facilities parallel to existing underground transmission pipelines. Activity of concern includes construction activity that could impact an existing facility, such as excavation or movement of equipment across the pipeline or within the easement that could affect the safe operation of the existing pipeline.

The primary emphasis of these guidelines is on the interaction between existing transmission pipeline operators and those planning to construct in a parallel fashion. Contractors working on behalf of the constructing party, including environmental and survey professionals, design engineers, construction contractors, and operators of excavation and earth moving equipment, are encouraged to engage in work practices that are in conformance with these guidelines. These guidelines have been developed such that they can be incorporated into contract documents executed with contractors and subcontractors by whichever party is involved in or responsible for construction activities.

This RP is available online at the API Publications Store: Product No. D11721.

The final draft Pipeline Safety Management System Recommended Practice, API 1173 (PSMS), is being balloted by API and ANSI for final approval and public comment. The final draft incorporates comments from the previous review and critique by safety management system subject matter experts. Public comments on the document will be accepted online only until August 1, 2014 via

The ballot ID number is 3266. No Login ID is required to submit comments only and that field should be left blank. Any fields requiring completion are identified with an asterisk (*). You will not be able to access the ballot site until all required fields have been completed. To access the document, click the “DOWNLOAD BALLOT DOCUMENT” text at the top left corner of the page. For a comment to be considered, you must provide the following items for each comment:

  1. The applicable clause number [from the document]
  2. The applicable paragraph/figure/table/note within the clause [If there is only one paragraph and the other do not apply, you may leave this field blank]
  3. Your comment (1000 character limit)
  4. Your proposed change based on your comment (1000 character limit)

These fields are included on the comment form. To download the comment form, click on the link. [Note, if you exceed the character limit, your comment or proposed change may be truncated or clipped – not all of the information will be recorded]. Click “ADD” after each comment submitted.

You must complete the review process of the entire document and submit your comments before 11:59 PM, Eastern Time on August 1, 2014. No comments will be accepted after the deadline has been reached.

Editor’s note: Thanks to AGA for this article. We couldn’t improve on it, and they gave permission for us to use it verbatim from their weekly update.

Colorado Oil and Gas Conservation Commission – Risk-Based Inspections

The Colorado State Legislature has directed the Colorado Oil and Gas Conservation Commission (COGCC) to develop and use a risk-based strategy when inspecting oil and gas operations, including pipelines. This risk-based approach will prioritize the phases of oil and gas operations by the likelihood of spills, excess emissions and other types of violations. Those with high priority of having an issue are more likely to get inspected by the COGCC. In order to prioritize production facilities for audits and inspections, COGCC is developing a risk based model that will be tested and modified throughout 2014. The model should be fully implemented in FY 2015-2016.

The auditing and inspection process will consider how Operators comply with pipeline regulations found in COGCC Pipeline Rule 1101. This rule provides requirements governing the following:

  • Installation including the materials that may be used; the design of each component; the amount of cover required; excavation, backfill and reclamation; and pressure testing.
  • Operations, maintenance, and repair including:
    • taking reasonable precautions to prevent failures, leakage, and corrosion;
    • correcting within a reasonable time any condition found that could adversely affect safe and proper operation;
    • ensuring repairs are made in a safe manner to prevent injury to people and damage to property;
    • ensuring pipe and components used in repairs meet the installation requirements;
    • ensuring pipelines are properly marked;
    • participating in One Call programs;
    • preparing and submitting an Emergency Response plan for gathering lines with segments subject to safety regulation by the Office of Pipeline Safety, U.S. Department of Transportation to the Commission, the county sheriff and each local government jurisdiction traversed by the pipeline.
  • Abandonment.

Pending Audits?

Has the DOT notified you of a pending audit? RCP can provide confidential internal auditing to help ensure that your facilities are up to the agency’s latest standards.
Click Here.

Texas Proposed Change to Farm Tap Odorization Requirements

On June 17, 2014, the Texas Railroad Commission proposed the following changes to 16 TAC §8.215 Odorization of Gas.

(a) – (d) (No change.)
(e) Malodorant concentration tests and reports.
(1) (No change.)
(2) Wick-type farm [Farm] tap odorizers shall be exempt from the odorization equipment reporting [testing] requirements of paragraph (1)(B) [(1)] of this subsection.
(3) (No change.)

The earliest possible date of adoption for this rule change is August 3, 2014. For further information, please call: (512) 475-1295.

State Damage Prevention Activities

The 2006 PIPES ACT provided PHMSA the authority “to enforce excavation damage laws in those states that have inadequate enforcement.” In order to do so, PHMSA is expected to publish the final rule known as the “Pipeline Safety: Enforcement of State Excavation Damage Laws” in August 2014. State legislators have been busy updating and rewriting Damage Prevention and One-Call laws this legislative session. Many updates and rewrites strengthen penalties and enforcement, clarify excavation definitions, remove or limit exemptions, and require new facilities to be locatable. States from coast to coast have passed legislation that update part or all of their Damage Prevention and One-Call Laws. Several states passed legislation earlier in the 2013-2014 sessions while others are conducting studies on various ways to improve damage prevention and utility communication. Georgia, Iowa, and Rhode Island passed updates which become effective July 1, 2014.

Georgia SB117: Amends Chapter 9 of Title 25 of the Official Code of Georgia Annotated (O.C.G.A.), relating to blasting or excavating near utility facilities. These changes revise in add definitions including providing clarification on the locate request process and marking.

Iowa HF2408: A bill modifying notification requirements applicable to underground facility excavations where underground facilities are present including requiring operators to update ticket status information in Iowa’s States Electronic Positive Response System (EPRS).

Rhode Island HB7714/SB2450: This legislation requires excavators to provide additional specific information regarding any excavation location to the Public Utilities Commission and also includes updated provisions for violations.

Is there uncertainty as to whether your Damage Prevention Procedures meet your state’s new requirements? RCP can answer your questions regarding state legislative changes regarding One-Call and Damage Prevention. Click here to request more information on how RCP can help.

RCP’s Web-Based Compliance Management Systems

CP’s Compliance Management System (CMS) is an invaluable tool for managing all aspects of regulatory workflow. Some examples of how our clients are using the CMS include:

  • O&M Scheduling and Data Acquisition;
  • Cathodic Protection Inspection and Data Management;
  • One-Call Screening and Ticket Management;
  • Repair / Replacement Programs;
  • Operator Qualification Administration and Workflow Integration;
  • Leak Life Cycle Management;
  • Environmental, Health and Safety Compliance;
  • Audit Action Item Tracking; and
  • Customer Data Management.

DIMP Integration

For gas distribution operators looking for a powerful tool to implement DIMP, the RCP CMS integrates O&M data captured from field personnel along with inherent system attributes to provide real-time risk analysis, performance reporting, as well as track additional and accelerated actions taken to mitigate risks.

Key Features

  • GIS integrated workflow management
  • Custom tailored e-mail notifications and reporting
  • Runs on any web-enabled device, no software to download
  • Powerful reporting and custom query functionality
  • Multiple security and user privilege settings
  • Document storage and control (ex. procedures, maps, images, and completion documentation)
  • Automatic recurrence setting for routine tasks (example: leak surveys, CP surveys, etc.)
  • Create work orders for unscheduled / unplanned activities (ex. release reporting)

To request a demonstration or to request more information, please contact Jessica Roger.

RCP in the News / Pipeline & Gas Journal June 2014 edition

Check your mail box for the recent Pipeline & Gas Journal magazine. Under the Pipeline Integrity section, don’t miss Bill Byrd’s article on “PHMSA Shifts Emphasis toward Preventing Highest Risk Events” where he explains PHMSA’s strengthened stance regarding accident prevention. If you don’t have a hard copy of the magazine, click here for the online version of the article.

RCP Employee Receives ASME Old Guard Early Career Engineer Award

RCP’s Jennifer S. Cooper recently received 2nd prize in the 2014 ASME Old Guard Early Career Engineer Award for her work in the development of ASME student and early career programs including the Safety Engineering and Risk Analysis Division’s Student Paper Competition, ASME’s Early Career Web Content, and the ASME ECLIPSE Affinity group.

Jennifer is a project engineer at RCP supporting a variety of regulatory compliance projects, including development of the API/AOPL Excavation Damage Prevention Toolbox, a collaborative industry project to create a shared learning tool on excavation damage prevention for energy pipelines. She had an article published this spring in Damage Prevention Professional highlighting the efforts of the API/AOPL Damage Prevention Team and the Toolbox. Jennifer earned a bachelor’s degree in mechanical and industrial engineering from the University of Tennessee-Martin in 2009; a graduate certificate in safety engineering and a master’s degree in engineering management from the Missouri University of Science and Technology in 2011 and 2014, respectively.

Public Workshop on Managing Pipeline Cracking Challenges

[Docket No. PHMSA-2014-0090] August 5, 2014 – Rosemont, IL]

The Department of Transportation, Pipeline and Hazardous Materials Safety Administration (PHMSA) and the National Association of Pipeline Safety Representatives are holding this event to gather and disseminate information on the state of the art of crack detection in hazardous liquid and natural gas pipelines. Perspectives on the challenges involved with detecting and characterizing crack like defects, including environmentally assisted cracks and cracks with corrosion, will be provided from operators and regulators. This event will provide an update on technology developments via research, the success rate in deploying such technology for detection and a discussion on the level of and types of data collected in support of engineering assessments. It will also discuss other information in support of criteria for determining when a probable crack defect in a pipeline segment must be excavated, the time limits for completing those excavations and in support of models for determining crack growth rates.

Date: The public workshop will be held on Tuesday, August 5, 2014, from 9:00 a.m. to 5:00 p.m. CDT.

Location: Crowne Plaza Chicago O’Hare, 5440 North River road, Rosemont, IL 60018. Hotel reservations can be made under the room block “DOT/PHMSA” by clicking here or call 877-337-5793. A small room block is available at the Federal Government rate of $166/night for the nights of August 4 & 5 on a first come, first served basis, and must be made by July 21, 2014.

Registration: Members of the public may attend this free public workshop. All attendees are encouraged to register for the workshop in advance. Online registration and a draft agenda can be found on PHMSA’s website.

Webcast: This public workshop will be webcasted. Webcast information will be provided in the hour before the start time and can be found at

For more information, contact Robert Smith at 919-238-4759 or by email.

Pipeline Safety: Government/Industry Pipeline R&D Forum

[Docket No. PHMSA-2014-0091] August 6 & 7, 2014 – Rosemont, IL]

The Department of Transportation, Pipeline and Hazardous Materials Safety Administration (PHMSA) and the National Association of Pipeline Safety Representatives periodically hold this event to generate a National research agenda that fosters solutions for the many challenges with pipeline safety and with protecting the environment. The forum allows public, government and industry pipeline stakeholders to develop a consensus on the technical gaps and challenges for future research. It also reduces duplication of programs, factors ongoing research efforts, leverages resources and broadens synergies. The national research agenda coming out of these events is aligned with the needs of the pipeline safety mission, makes use of the best available knowledge and expertise, and considers stakeholder perspectives.

Date: The public forum will be held on Wednesday, August 6, 2014, from 8:00 a.m. to 5:00 p.m. and Thursday, August 7, 2014, from 8:00 a.m. to 4:30 p.m. CDT.

Location: Crowne Plaza Chicago O’Hare, 5440 North River road, Rosemont, IL 60018. Hotel reservations can be made under the room block “DOT/PHMSA” by clicking here or call 877-337-5793. A small room block is available at the Federal Government rate of $166/night for the nights of August 5 – 7 on a first come, first served basis, and must be made by July 21, 2014.

Registration: Members of the public may attend this free public forum. All attendees are encouraged to register for the forum in advance. Online registration and a draft agenda can be found on the PHMSA website.

Webcast: This public forum will not be webcasted.

For more information, contact Robert Smith at 919-238-4759 or by email.

Summer / Fall Conference Schedule

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

Louisiana Gas Association (LGA) 2014 Pipeline Safety Conference
July 21 – 25, 2014
New Orleans, LA

Southern Gas Association (SGA) Operating Conference & Exhibits
July 28 – 30, 2014
New Orleans, LA

Western Regional Gas Conference (WRGC)
August 19 – 20, 2014
Tempe Mission Palms Hotel
60 E. Fifth Street
Tempe, AZ

New! Pipeline Pressure Testing Workshop:
Come early and join us for RCP’s 1-day training session on Pipeline Pressure Testing on Monday, August 18, at the Tempe Mission Palms Hotel from 10 a.m. to 6 p.m. RCP personnel have established themselves as industry experts, designing, implementing and validating pressure test programs for various operators. Recent PHMSA advisories and pending regulations will soon mandate pressure tests for operating gas and liquid pipelines that have not previously been subjected to pressured leak and strength tests. This course will provide an overview of the planning and implementation processes necessary to plan, execute and document pipeline pressure tests efficiently to satisfy code requirements as defined by 49 CFR Parts 192 and 195, consistently. Topics covered include discussion of code terminology and requirements, planning, permitting, preparation of the test segment, testing, returning the line to service and documentation. The price to attend is $250 per person (lunch included). More details and registration can be found on RCP’s website.

Arkansas Gas Association Annual Conference
September 14 -16, 2014
Fayetteville, Arkansas

International Pipeline Conference & Exposition (IPC /IPE)
September 29 – October 3, 2014
Calgary, AB, Canada
RCP will be exhibiting in Booth #531 at the Expo.

Don’t miss this opportunity to meet RCP’s President, Bill Byrd, and attend his presentation on “Site-Specific Quantitative Pipeline Risk Analysis using Monte Carlo Methods” (Track 12). The paper was co-authored by Matthew Wylie, Chief Information Officer and General Counsel at RCP Inc.

This paper will compare a site specific quantitative risk analysis using traditional “average” risk ranking methods to a more complex Monte Carlo analysis which uses a range of possibilities and consequences for each threat – each with their own probability. The comparison is based on the California “Guidance Protocol for School Site Pipeline Risk Analysis,”” a quantitative risk analysis protocol which uses average probability and consequence values, and will extend it to explain how a more complex Monte Carlo analysis of those same risk factors can give a more comprehensive understanding of anticipated risks and consequences.

New RCP Pipeline Pressure Testing Workshop August 26 & 27

For the first time, RCP is offering a 2-day workshop on Pipeline Pressure Testing. RCP personnel have established themselves as industry experts, designing, implementing and validating pressure test programs for various operators. Recent PHMSA advisories and pending regulations will soon mandate pressure tests for operating gas and liquid pipelines that have not previously been subjected to pressured leak and strength tests. This course will provide an overview of how to efficiently plan, execute and document pipeline pressure tests that consistently satisfy code requirements as defined by CFR 49 Parts 192 and 195.

More information and class registration can be found on the RCP website.

DOT Pipeline Compliance Workshop – August 5 – 7, 2014

Join us August 5 – 7, 2014 in Houston at our new 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 (unlike our previous workshops), 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 recently enacted Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 (pipeline reauthorization bill), recent Advisory Bulletins from PHMSA, and new, pending and proposed rulemakings.

Each attendee will receive speaker’s PowerPoint presentation handouts in hard copy, 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.

API Damage Prevention Webinar – Save the Date!

API will conduct a webinar on pipeline Damage Prevention (DP) issues on Wednesday, September 24, from 9:30 to 11:30 Central time. Topics to be addressed include tips to manage DP programs for exempt and / or rural excavators, and how to work effectively to improve DP legislation at the state level. Participants will also receive an overview of recent trends in damage prevention statistics. Additional registration information will be included in next month’s newsletter. For now, please save the date!

Send us your tired, your poor, your huddled masses of Pipeline Samples, yearning to breathe free.

Is your pipeline company merging? Divesting? Moving? Are old hands retiring, and clearing out their offices? No matter the reason, if you have interesting pipeline samples that need a new home, please let us know. We do training frequently, and would like to have physical pipe samples of corrosion, cracking, welding defects, seam defects, etc. Miniature models of smart pigs and other tools are also welcome. We promise to give them a good home – but call before shipping those 40’ pipe joints.

For more information, contact Jessica Foley. Or ship direct to: RCP Inc., 801 Louisiana Street, Suite 200, Houston, TX 77002.

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