DOT Pipeline Compliance News

July 2020 Issue

In This Issue

PHMSA Response to Petition for Reconsideration: Gas Transmission Rule

[Docket No. PHMSA-2011-0023; Amdt. No. 192-127]

Several trade associations jointly petitioned PHMSA on October 31, 2019 to consider amendments to the gas transmission final rule, which became effective July 1, 2020.  On July 6, 2020 PHMSA published amendments to the final rule to address this petition.  There are two main issues that are addressed in these revisions.

  1. Clarify the Applicability of the Class Location Recordkeeping Requirements in §192.5(d)
    In the Final Rule, PHMSA added §192.5(d) to require operators to have and maintain records that document the current class location of each pipeline segment. In the preamble, PHMSA stated that this requirement applies to gas transmission pipelines. However, PHMSA inadvertently omitted language in the rule’s regulatory text that would have made clear that the recordkeeping requirements applied only to gas transmission pipelines.  PHMSA granted the Associations’ request to clarify that the recordkeeping requirements in §192.5(d) only apply to gas transmission pipelines. The recordkeeping requirements apply to records that document current class location determinations and records that demonstrate how an operator arrived at such a determination for each class location.
  1. Limit the Applicability of MAOP Reconfirmation Requirements in §192.624(a)(1)
    In the Final Rule, PHMSA defined a set of pipeline segments for which operators must reconfirm the MAOP. Specifically, §192.624(a)(1) requires operators of certain gas transmission pipelines to reconfirm MAOP if, among other things, the ‘‘records necessary to establish the MAOP in accordance with §192.619(a) are not traceable, verifiable, and complete’’ (TVC). The Associations requested that PHMSA revise §192.624(a)(1) to clarify that it does not apply where an operator already has TVC pressure test records to establish MAOP under §192.619(a)(2). In the petition, the Associations stated “Without the specific reference to §192.619(a)(2), §192.624(a)(1) could be interpreted to require a pipeline to reconfirm MAOP even for pipeline segments with a TVC pressure test record.” PHMSA granted the Associations’ request to limit the applicability of the MAOP reconfirmation requirements of §192.624(a)(1) to those pipeline segments that do not have TVC pressure test records under §192.619(a)(2).  So the bottom line is if a segment has a TVC pressure test record, but not TVC design pressure records under §192.619(a)(1), MAOP reconfirmation is not required under §192.624(a)(1).

In the amendment to the final rule, PHMSA reiterated that if operators are missing material property records during anomaly evaluations and repairs, they must confirm those material properties under §§192.607 and 192.712(e) through (g). PHMSA also emphasized that if an operator uprates a segment’s MAOP, they must have TVC material and pressure test records.

For a copy of this amendment, contact Jessica Foley.

PHMSA Pipeline Advisory Committee (Virtual) Meetings

July 22-23, 2020

The Pipeline Advisory Committee (PAC) meetings are scheduled virtually for July 22 (Gas PAC) and July 23 (Liquid PAC).  The meeting announcements and registration information can be found on the PHMSA Meeting Registration webpage. Topics for discussion include:

The GPAC will meet to discuss the NPRM titled: “Amendments to Parts 192 to Require Valve Installation and Minimum Rupture Detection Standards,” which was cleared by the Office of Management and Budget and is expected to be published soon in the Federal Register.

The LPAC will meet to discuss the NPRM titled: “Amendments to Parts 195 to Require Valve Installation and Minimum Rupture Detection Standards,” which was cleared by the Office of Management and Budget and is expected to be published soon in the Federal Register.

Delaware NPRM Underground Facilities Enforcement

[Docket No. 19-0713]

The Delaware Public Service Commission (“Commission”) has proposed regulations governing its enforcement of the Underground Utility Damage Prevention and Safety Act, which is codified at 26 Del. C. §§ 801-813.  The Order #9595 and the proposed regulations can be viewed in the Commission’s electronic filing system DelaFile at docket number 19-0713. Pursuant to 29 Del. C. § 10118(a), written comments on the proposed regulations will be accepted until Monday, August 3, 2020. They can be filed electronically in DelaFile by completing the Public Comment form located under Public Links. Written comments can also be mailed to Samantha Hemphill, Public Service Commission, 861 Silver Lake Boulevard, Suite 100, Dover, DE 19904, or emailed to her at with the subject line “Docket No. 19-0713.”

Mega-Rule #1: Gas Transmission Regulation Deep Dive – Going Virtual

Join us October 13th – 15th for a virtual deep dive into the recently finalized Safety of Gas Transmission Pipelines rule. The virtual format for this is unlike anything you have experienced before.  Attendees will receive links to workshop materials two weeks prior to live stream Q&A sessions with the trainers and other attendees.  Attendees will be able to review these materials at their own pace and schedule leading up to three separate live Q&A sessions with other attendees and the trainers.  Attendees will have the ability to chat and post questions in a live forum during the pre-read period and during live Q&A sessions.  There will be homework, yes you heard that right, to ensure attendees understand how to apply what they have learned.  During the live Q&A sessions, trainers will work through the homework and answer questions from the attendees.

What You Will Learn

There is a lot to unpack with this rule.  This workshop will not only dive deep into the rule requirements and some of its nuances; there will also be several practical and interactive exercises for the audience to perform, ensuring they come away knowledgeable not only with “what” is required, but also “how” to conduct certain analyses that are new to the gas transmission pipeline regulations. These exercises will include how to conduct an Engineering Critical Assessment, how to develop material sampling plans based upon various population factors, how to determine TVC records and extract the required data for validated MAOP calculations, and how to plan and execute a spike test.  RCP has partnered with Mike Rosenfeld for portions of this workshop, so you are sure to learn from the best in the industry.

Workshop Materials

Each attendee will receive access to all presentation and homework assignment materials two weeks prior to the live Q&A sessions.

About the Trainers

RCP trainers have a wealth of industry experience and provide participants a practical perspective on operations and maintenance activities at a level all can understand and are very effective in answering any questions.

Mr. Rosenfeld is an experienced consultant in pipeline fitness for service, pipeline integrity, pipeline design and construction, causes of pipeline failures, pipeline regulations and standards, and related matters. He has performed numerous pipeline failure investigations and root cause failure analyses; research funded by the pipeline industry on the effects of mechanical damage, fatigue, pipeline integrity threat interactions, and methods to determine the probable grade of undocumented pipe materials; engineering analyses of a broad range of design, operations, or integrity matters for numerous pipeline operators; and provided expert support in litigation. He chairs the Subgroup on Design, Materials, and Construction of the ASME B31.8 Gas Transmission and Distribution Piping Committee and serves on other ASME piping standards development committees. Mr. Rosenfeld has authored or co-authored over 90 published articles or public presentations dating to 1988, is an ASME Fellow, and is a Professional Engineer registered in the State of Ohio. He previously worked with Kiefner & Associates (27 years), Battelle (6 years), and Impell Corporation (4 years). He earned a Bachelor of Science in Engineering from the University of Michigan (1979) and a Master of Engineering from Carnegie-Mellon University (1981).

Chris Foley has a deep understanding of the new gas transmission regulation, including participating on the Joint Industry Trade Association Task Group to prepare for and submit comments throughout the Gas Pipeline Advisory Committee process.  Mr. Foley owns three patents for MaxOp, which is widely considered the gold standard used across the gas and hazardous liquid pipeline industry for MAOP validation. He serves on the ANSI GPTC Z380 Gas Piping Technology Committee and the American Gas Association Engineering Committee.  Mr. Foley has almost 30 years’ experience developing and implementing engineering and regulatory compliance solutions and technology for the oil and gas industry. He earned a Bachelor of Science in Industrial Engineering with a specialty in Systems Safety Engineering from Texas A&M University.

Virtual Workshop Pricing

$575.00 if registered two weeks prior to start of workshop.

For more information or to register for this course click here.

TaskOp Audit Tool for Social Distancing

How we conduct business may have changed due to social distancing, but RCP’s TaskOp Audit Tool fits perfectly into this new business model.

The TaskOp audit tool, with all its online document retention, tracking of findings, resolutions, etc., not only makes audits a breeze, but it is also perfectly suited for audits requiring social distancing from you really cool people.  Auditors can review documents and procedures from anywhere they are located, plug their findings into the system, and the team can immediately compare notes to find gaps or issues to fix.  Paired with Microsoft Teams, audit teams can unleash the full power of the tool to create a social distance-acceptable environment while still performing a high quality audit.  With TaskOp and Microsoft Teams, it’s like a standard on-site audit.  Once the audit is complete, operators can assess findings, schedule tasks to shore up the gaps and document everything in one spot.

Check out RCP’s TaskOp webpage for everything you need to know about TaskOp, including available modules, a quick tutorial video, informational survey and an opportunity to test-drive the system.

Click here for a free Demo or contact Jessica Foley for more information.

2020 Industry Conference Schedule

The Year of the Virtual Conference Season!

LGA Pipeline Safety Conference
(July 28-30)

LGA is going Virtual! The LGA Board has decided to cancel the physical Pipeline Safety Conference for 2020 due to COVID-19 and will be hosting a virtual conference instead. Check out the LGA conference page for updated information as it becomes available.

API 2020 Virtual Pipeline Conference Webinars
(August 5-September 30)

API couldn’t meet with you in San Diego so API is bringing the Pipeline Conference to YOU! Beginning in August and running through September API will offer Tracks and Sessions via Microsoft™ Teams on a weekly basis. The sessions will begin at 11:00 AM CT, depending on the track, will last from 1.5 to 2.5 hours. Registration is required; however, there will be no registration fee to attend. More information is on API’s website.

SGA Conferences for 2020
SGA is going virtual! Please go to SGA Calendar of Events for the most up to date information on these conferences:

  • Spring Gas Conference and Expo
  • Management Conference
  • Natural Gas Connect

AIChE 2020 Spring Meeting and GCPS
(August 17-21)

AIChE is going virtual, too! The meeting will be held using the online conference platform vFairs. More information regarding the virtual conference can be found on AIChe’s website.

API Tank Conference
(October 12-15)

The API Storage Tank Conference will be presented as both an in-person event, as well as an equally engaging virtual event. The API Storage Tank Conference has been an annual event since 1995. It is considered the premier, high-level meeting of storage tank professionals, and has a loyal and dedicated attendee base.

APGA Operations Conference

The APGA Fall Committee Meetings and Operations Conference that was originally scheduled for October 27-29 will be going virtual, too. Check the APGA website for updated information as details become available.

RCP’s 2020 Workshop Schedule – GOING VIRTUAL!

The virtual format for this is unlike anything you have experienced before.  Attendees will receive links to workshop materials two weeks prior to live stream Q&A sessions with the trainers and other attendees. Learn more…

Oct 6 2020 – Oct 08 2020DOT Gas & Liquid WorkshopHouston, TXMore Info
Oct 13 2020 – Oct 15 2020Mega-Rule #1: Gas Transmission Regulation Deep Dive – Going VirtualOnlineMore Info

Visit our events page for updates, registration, and hotel information.

RCP’s 25th Anniversary

This year marks a remarkable and very successful 25th anniversary for RCP. After our opening in 1995 in Baton Rouge, Louisiana, we now have employees throughout the U.S. Our projects range from Maine to Hawaii, Florida to Alaska, Canada and overseas.

I want to sincerely thank our clients for the privilege of being your Professional Engineers, Regulatory Experts, and Trusted Partners, and our many talented employees who make it all happen.  We could never have done it without your trust and support.

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


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