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.”

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.

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


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