DOT Pipeline Compliance News

June 2011 Issue

In This Issue

Low Stress Liquid Pipeline Jurisdiction Final Rule

[Docket PHMSA-2008-0186; Amdt. 195-96]

On May 5, 2011, PHMSA finalized their Phase II rulemaking for low stress liquid pipelines, as required by the PIPES Act. This rulemaking creates 3 (actually 4) categories of low stress pipelines. Low stress pipelines that are in non-rural areas or which cross navigable waters have long been regulated by PHMSA. That is the 4th category of low stress liquid pipelines, in your editor’s humble opinion, which he has taken the liberty of calling Category 0 pipelines.

Category 1 pipelines are those that are greater than or equal to 8″ o.d. and within 1/2 mile of a USA. These pipelines were regulated by the earlier Phase I rulemaking (see related article in the June 2008 edition of the DOT Pipeline Compliance News for additional details). The latest rulemaking creates Category 2 pipelines, which are identical to Category 1 pipelines but are less than 8″ o.d., and with later compliance deadlines. The latest rule also establishes Category 3 pipelines, which are any low stress pipelines that are not Categories 0, 1 or 2. Category 3 pipelines have the same compliance deadlines as Category 2 pipelines, but are not required to develop a pipeline integrity management plan.

It is important to note that, while the deadlines for compliance may be in the future, these newly regulated low stress pipelines are required to comply with the complete set of DOT pipeline safety regulations (except for IMP, for Category 3 pipelines). This includes Control Room Management, Public Awareness, Corrosion Control, and O&M procedure manuals.

Contact Jessica Roger for a simplified table that contains all the compliance deadlines for each category of low stress pipeline and a copy of the Final Rule.

Jurisdictional Determination

Is there uncertainty as to whether a pipeline meets the applicability of 49 CFR 195 or 192? RCP can answer your questions regarding the jurisdictional status related to pipelines that may be regulated by the Department of Transportation Pipeline and Hazardous Materials Safety Administration (DOT/PHMSA). Click here to request more information on how RCP can help.

PHMSA Advisory Bulletin (ADB-11-03) Deadline for 2010 Mapping Reports

[Docket No. PHMSA–2011–0121]

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) recently published advisory bulletin (ADB-11-03) advising owners and operators of gas transmission and gathering systems and Liquefied Natural Gas (LNG) facilities that they have until August 15 to submit their Calendar Year 2010 Annual Reports.

The Pipeline and Hazardous Materials Safety Administration (PHMSA) published a final rule on November 26, 2010, under Docket No. PHMSA 2008-0291 [75 FR 72878], titled: “Pipeline Safety: Updates to Pipeline and Liquefied Natural Gas Reporting Requirements” (One Rule). This rulemaking revised the Pipeline Safety Regulations (49 CFR Part 190-199) to improve the reliability and utility of data collections from operators of natural gas pipelines, hazardous liquid pipelines, and LNG facilities. As a result of the rulemaking, several annual and incident report forms were created while other forms were revised. Included among these forms, PHMSA created a new Annual Report for LNG facilities (LNG Annual Report; PHMSA F-7100.3-1) and revised the Annual Report for Natural or Other Gas Transmission and Gathering Systems (Gas Transmission and Gathering Annual Report; PHMSA F-7100.2-1). The One Rule revised §191.17 to specify that these reports should be submitted no later than March 15 for the preceding year, except for Calendar Year 2010, where reports should be submitted by June 15, 2011. This delayed reporting date for Calendar Year 2010 was added to allow companies time to update their information for submission according to the revised form.

After the One Rule was published, PHMSA received a petition from the American Gas Association (AGA) on December 22, 2010, asking for reconsideration of the information collected on the LNG Annual Report form. PHMSA reviewed the petition and has revised the form based on AGA’s recommendation. PHMSA is using this notice to extend the reporting date for the LNG Annual Report form to August 15, 2011, to allow further time to prepare the electronic system PHMSA will use to collect the information. Next year, the filing date will go back to the March 15 date specified in the regulation.

PHMSA also received a number of questions regarding NPMS submissions. The NPMS consists of geospatial data, attribute data, public contact information, and metadata pertaining to the interstate and intrastate hazardous liquid trunklines and hazardous liquid low-stress lines as well as gas transmission pipelines, LNG plants, and hazardous liquid breakout tanks regulated by PHMSA. Most operators submit their NPMS data to PHMSA at the same time they file their annual report. Although PHMSA is extending the filing date for annual report submissions, operators are encouraged to file their NPMS data at their regularly scheduled times.

For a copy of ADB-11-03, contact Jessica Roger.

DIMP Inspection Forms Updated

PHMSA has issued newly released inspection forms for the Distribution Integrity Management Program (DIMP) from the DIMP Implementation team:

  • DIMP Inspection Form for 192.1015: For Master Meter and Small LPG Operators of Gas Distribution Systems – Version 4/11/2011
  • DIMP Inspection Form for 192.1005 – 192.1011: For Operators of Gas Distribution Systems – Version 5/2/2011

Contact Jessica Roger for more information.

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.

Advisory Committee Meetings & New Subcommittee Meetings

[Docket No. PHMSA-2011-0127]

PHMSA has announced meetings of the Technical Pipeline Safety Standards Committee (TPSSC) and the Technical Hazardous Liquid Pipeline Safety Standards Committee (THLPSSC) and the creation of a subcommittee to assist PHMSA in the preparation of a pipeline safety report to the nation. PHMSA will host a series of meetings with a newly formed subcommittee to review and consider information gathered in response to the U.S. Department of Transportation’s and PHMSA’s action plan and information related to a recent pipeline safety forum. PHMSA is also requesting general public comments including comments on a report titled, “The State of the National Pipeline Infrastructure-A Preliminary Report.” (See related article in this issue of the DOT Pipeline Compliance News.)

Following several major pipeline accidents, the Secretary of Transportation issued a “Call to Action” and held a pipeline safety forum to engage pipeline safety experts, researchers, industry representatives, state partners, other Federal agency officials, and members of the public to identify actions to address America’s pipeline transportation infrastructure. In response to the “Call to Action,” the U.S. Department of Transportation and PHMSA published a report titled: “State of the National Pipeline Infrastructure-Preliminary Report” and launched a website for public engagement and regular reporting to the public. This website includes information such as ongoing pipeline rehabilitation, replacement and repair initiatives along with all forum-related comments. PHMSA continues to invite comments on the Preliminary Report in addition to any other ideas that may be relevant to pipeline safety. Following the forum, a subcommittee of the TPSSC and THLPSSC was established to work with PHMSA staff to assist in the creation of a pipeline safety report to the nation. The subcommittee is made up of six members, three each from the TPSSC and THLPSSC, with equal representation from government, industry, and the public. At the joint advisory committee meeting in August, the subcommittee will present its recommendations and a draft of the pipeline safety report to the nation for the joint committees’ review and deliberation.

The meeting dates are as follows:

  • June 15, 2011, 9 a.m. to 4 p.m., subcommittee kick-off meeting, Washington, DC. The agenda includes an introduction of the subcommittee and discussion of the subcommittee’s task. This meeting will provide the public an opportunity to participate in an exchange of ideas and recommendations, including a discussion of the report outline, prior to the subcommittee’s preparatory meetings.
  • June 16, 2011, 9 a.m. to 4 p.m., subcommittee preparatory meeting, Washington, DC (no public statements accepted).
  • July 13-14, 2011, 9 a.m. to 4 p.m., subcommittee preparatory meeting, Washington, DC (no public statements accepted).
  • August 2-3, 2011, 9 a.m. to 5 p.m., TPSSC and THLPSSC joint public meeting, Washington, DC. The agenda will include an overview of the subcommittee’s deliberations and summary of the draft final report. Public statements can be accepted.

The meeting locations and any new information or changes will be posted on the PHMSA/Office of Pipeline Safety “Pipeline Safety Awareness” website 15 days before the meeting takes place. The public is encouraged to attend the subcommittee kick-off meeting and the joint Advisory Committee meetings. Members of the public may make a statement during the public committee meetings. Statements previously submitted at the forum should not be repeated. If you intend to make a statement, please notify the relevant contact at least 15 days prior to the meeting date. The meetings’ presiding officer may deny a nonscheduled request to make a statement and may also limit the time of any speaker.

Attendees should register for the June 15 and August 2-3 meetings in advance at: On-site registration for each meeting will be available 30 minutes prior to the meeting start time. The meetings will not be webcast; however, presentations will be available on the meeting Web site and posted in the E-Gov website under docket number PHMSA-2011-0127 within 30 days following the meeting.

Comments on “The State of the National Pipeline Infrastructure-A Preliminary Report” must be received on or before July 13, 2011, to be considered by the subcommittee members prior to submission of their draft recommendations to the parent committees.

For further information contact:

  • Technical Advisory Committee Meeting Details: Cheryl Whetsel 202-366-4431 or by e-mail.
  • Report to the Nation on Pipeline Safety: Linda Daugherty 202-366-4595 or by e-mail.

State of the National Pipeline Infrastructure Report

[Docket No. PHMSA–2011–0127]

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) issued a Preliminary report on the “State of the National Pipeline Infrastructure.” This preliminary report serves as an introduction to what is known about our nation’s pipeline infrastructure, what we need to know better, and what PHMSA is already doing and planning to do to address pipelines of concern.

The report states that, “The vast majority of pipelines are in good condition. . . And the overall trend in pipeline safety has been steadily improving.” The report goes on to state that, “The percentage of pipe that is or has become unfit for service is small, and the vast majority of pipelines are well built, monitored, inspected, assessed, operated, and maintained.”

Their statistics indicate that corrosion is the leading cause of releases on gas transmission and hazardous liquid pipelines, followed by material/weld failures, equipment failures, and excavation damage. For gas distribution pipelines, which are concentrated in populated areas where excavation activity is particularly active, excavation damage and other outside force damage are the major causes.

Recent accidents in San Bruno, California and Allentown, Pennsylvania have raised questions in the public’s mind about the safety of older pipelines. PHMSA is taking a hard look at the causes and characteristics of these failures to see how future incidents can be prevented. PHMSA is assessing how to accelerate the replacement of pipe to ensure public safety and the reliability of our critical pipeline system into the future.

The Department of Transportation has issued a call for action to identify pipe with the poorest performing characteristics within our nation’s pipeline system and to determine the course of action needed regarding the repair, rehabilitation, or replacement of these pipelines; which may include the need to:

  • oversee the replacement of this pipe to ensure that it is being replaced
  • oversee operators and take interim actions to step up the monitoring of these facilities to reduce the risk of incidents while the pipe is being replaced.
  • expand funding for research and development of new tools to improve pipeline assessments.
  • ensure through inspections that operators are performing these practices and performing them effectively.

PHMSA is planning a broad-based workshop in August to discuss these issues, share experiences, and improve knowledge. This workshop may lead to new or more stringent requirements for assessing and reducing pipeline risks.

For a copy of this 12-page preliminary report, contact Jessica Roger.

Public Awareness Effectiveness Program Inspections

In October, 2009, the NTSB issued a Safety Recommendation that PHMSA initiate a program to evaluate pipeline operators’ public education programs, including pipeline operators’ self-evaluations of the effectiveness of their public education programs. Since then, PHMSA organized an ad hoc team which developed inspection forms and guidance information regarding these inspections, which are scheduled to begin soon.

These two-day public awareness effectiveness inspections will take a close look at the administration and development of operator public awareness programs; program implementation; and the program evaluation process ( including annual audits and effectiveness evaluations). RCP can help you prepare for these inspections. For more information, contact Jessica Roger.

Public Meetings on Managing Challenges with Pipeline Seam Welds and Improving Pipeline Risk Assessments and Recordkeeping

[Docket ID PHMSA-2011-0125]

Recent pipeline incidents involving seam weld anomalies and gaps in data and recordkeeping are driving a stronger focus on better managing these challenges. PHMSA is holding important public meetings to discuss its review of inspection reporting and incident findings in these areas. In addition, these public meetings are part of PHMSA’s efforts to address the Secretary of Transportation’s “Call to Action” to address pipeline infrastructure risks, drive for more aggressive safety efforts and to be more transparent when executing these safety measures. These public meetings are designed to provide an open forum for exchanging information on the challenges associated with pipeline seam welds and improving pipeline risk assessments and recordkeeping.

On July 20, 2011, from 8 a.m. to 4 p.m. EDT, PHMSA will host a meeting on Managing Challenges With Pipeline Seam Welds. This meeting will not be webcasted. The objectives for the meeting include:

  1. Further determining the nature and extent of the seam weld issue from industry and government data.
  2. Presenting perspectives on how anomalies in seam welds are identified and managed employing risk assessments, technology and standards or best practices.
  3. Presenting the scope of a recently awarded PHMSA research study on seam welds.
  4. Providing specifically designed working groups to further craft the scope for this PHMSA research study and other related topics.

Preliminary Agenda:
8 a.m. Welcome
8:10 a.m. Panel 1: What is the Nature/Extent of the Issue?
9:40 a.m. Break
9:55 a.m. Panel 2: Identifying/Managing Seam Weld Challenges
11:10 a.m. Presentation: Seam Weld Research Project and Input/Refinement of this Targeted Research
12 p.m. Lunch-On your Own
1:30 p.m. (Concurrent Sessions)

  • Working Group 1: Identifying Gaps in Risk Assessments
  • Working Group 2: Identifying Gaps in Technology
  • Working Group 3: Identifying Gaps with Assessment Methods

4 p.m. Adjournment

On July 21, 2011, from 8 a.m. to 4:30 p.m. EDT, PHMSA will host a meeting on Improving Pipeline Risk Assessments and Recordkeeping. This meeting will be webcasted. The objectives for the meeting include:

  1. Provide a U.S. and International regulatory perspective on pipeline integrity risk assessments.
  2. Provide an operator overview of the challenging factors with conducting risk assessments, canvassing effective approaches, and case studies.
  3. Identify options with addressing interactive threats, legacy pipelines and approaches for dealing with recordkeeping gaps.

Preliminary Agenda:
8 a.m. Welcome
8:10 a.m. Panel 1: U.S. & Canadian Regulatory Perspective on Risk Assessments
9:30 a.m. Panel 2: Pipeline Operator Perspective on Risk Assessments
Break taken during panel 2
11:30 a.m. Lunch-On your Own
1 p.m. Panel 3: How Should Recordkeeping Gaps Influence Risk Assessments?
2:30 p.m. Break
2:45 p.m. Panel 4: Identifying Interactive Threats and Understanding Options
4:30 p.m. Summary and Adjournment

Please visit and click on these public meetings to register.

These public meetings will be held at The Westin Arlington Gateway, 801 North Glebe Road, Arlington, VA 22203, Phone: 703-717-6200. Please contact the Westin to reserve a room using “USDOT/PHMSA” for the room block name at the rate of $157/night. This room rate is available for Tuesday night July 19 and Wednesday night July 20 until the reserved rooms at this rate are taken. A very limited number of rooms are available at this rate on July 21.

For further information contact: Robert Smith by e-mail or by phone at 919-238-4759.

Control Room Management Services

RCP is able to provide pipeline operators with fully compliant, customized Control Room Management Programs that take advantage of any existing processes that are currently in place and develop new processes that are tailored to your organization’s ability to successfully implement.

RCP also has the expertise to conduct readiness assessments as well as compliance analysis of your existing Control Room Management programs. This independent analysis will take into consideration what others within the industry are doing as a benchmark as well as what the final regulations require.

For more information on how RCP can help with your Control Room Management Program, contact Jessica Roger.

PHMSA Hazardous Liquid Annual Report Webinar

June 9, 2011 1:30 PM – 3:00 PM EDT

PHMSA has scheduled a webinar to demonstrate its online reporting system for the new hazardous liquids pipeline operator annual report (Form PHMSA F 7000-1.1): June 9, 1:30 – 3:00 PM EDT. You can register at PHMSA welcomes your questions in advance of the event to assure that operator issues are addressed by subject matter experts during the webinar or in FAQs. Send them to Roger Little, Team Lead – Data Analysis, at An archived copy of the webinar will also be available in early July.

The June 9 webinar for hazardous liquids operators will be followed by a series of webinars for gas transmission and gathering operators, as noted in RCP’s May DOT Compliance Newsletter:

  • Intrastate operators only
    6/21/2011 1:00 PM – 2:30 PM EDT Gas Transmission Annual Report Training – This webinar will show operators with only INTRAstate miles how to complete the new Transmission Annual Report
  • INTERstate operators only
    6/22/2011 1:00 – 2:30 PM EDT Gas Transmission Annual Report Training – This webinar will show operators with only INTERstate miles how to complete the new Transmission Annual Report.
  • Gas Gathering operators only
    6/22/2011 3:00 – 4:30 PM EDT Gas Transmission & Gas Gathering Annual Report Training – This webinar will show operators with only gas gathering miles how to complete the new Transmission Annual Report.
  • INTERstate & INTRAstate operators (and/or gas gathering miles too)
    6/23/2011 1:00 PM EDT – 2:30 PM EDT Gas Transmission Annual Report Training – This webinar will show operators with both INTERstate & INTRAstate miles how to complete the new Transmission Annual Report. If you have INTERstate & INTRAstate and gathering miles as well, attend this session.

REMINDER: the annual report filing deadline as required by the U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration (PHMSA) Pipeline Safety Regulations is extended until August 15, 2011 for the CY 2010 submission.

Important Changes: The Hazardous Liquid Annual Report form [PHMSA F 7000-1.1] was revised in 2010. A new online data entry tool will be demonstrated at the Webinar, and we will also answer questions about the new filing format.

You can register for the webinar by going to the following URL: and clicking on “June 9 – PHMSA Hazardous Liquid Operator Annual Report Webinar”.

What if I have questions? If you have any questions about the Webinar, please contact Roger Little at (202) 366-4569 or via email. If you have questions you want to submit in advance of the webinar for consideration during the webinar, please send them to me at the email provided.

Summer Gas Conferences

RCP will be exhibiting or attending several gas conferences this summer. We would love the opportunity to discuss the regulatory compliance services we have to offer — including solutions to your MAOP and Control Room Management issues. When it comes to pipeline regulatory compliance, we are the experts. We hope to see you there!

Texas Gas Association – Operations & Management Annual Conference
June 12 – 15, 2011 at La Torretta Lake Conference Center & Hotel on Lake Conroe in Montgomery, Texas

Southern Gas Association – Operating Conference
July 12 – 14, 2011 at the Hyatt Regency Jacksonville Riverfront, Jacksonville, Florida

Louisiana Gas Association – 49 CFR 191/192 & 195 Pipeline Safety Conference
July 25 – 29, 2011 at the Royal Sonesta Hotel, in New Orleans, Louisiana

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