DOT Pipeline Compliance News

June 2016 Issue

In This Issue

PHMSA Webinar: “Safety of the Nation’s Gas Transmission Pipelines – NPRM”

JUNE 8, 2016

The webinar scheduled for May 12th for the gas mega-rule was cancelled and rescheduled for June 8th at 1:30 p.m. EDT. This public webinar is being hosted by the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) to discuss the proposed rulemaking for the safety of the nation’s gas transmission pipelines. PHMSA senior staff will present factual information about the regulatory proposal and will answer clarifying questions. Among a number of topics in the rulemaking proposal, PHMSA is proposing to update integrity management (IM) requirements and to address issues related to non-IM requirements for natural gas transmission and gathering pipelines. (See related article in the “DOT Pipeline Compliance News,” April 2016 Special Edition.)

PHMSA is extending the comment period from June 7, 2016, to July 7, 2016. Comments can be submitted via the E-Gov Website and reference Docket No. PHMSA-2011-0023. Additional information and online registration can be found on the PHMSA Public Meeting website.

DOE and PHMSA to Host Underground Storage Workshops

JULY 12 – 14, 2016

The U.S. Department of Energy (DOE) will host a Workshop on Well Integrity for Natural Gas Storage in Depleted Reservoirs and Aquifers in Denver, CO on July 12-13. The objective of this workshop is to assemble operators, regulators and technical experts to examine the current state of natural gas storage wellbore integrity, and to consider ways to reduce the possibility of future subsurface containment failures. For more information, including registration and instructions on how to submit an abstract, visit: This workshop will not be webcast.

Immediately following the DOE workshop, the Pipeline and Hazardous Materials Safety Administration (PHMSA) will conduct their Workshop on Underground Natural Gas Storage Safety at the same location on July 14. This workshop will bring stakeholders, including federal and state agencies, industry and interested members of the public together to participate in shaping a future of 49 CFR 192 safety regulations for underground natural gas storage. If you are unable to attend in person, this workshop will be webcast live. Meeting information and registration can be found on PHMSA’s meeting website.

RCP Underground Storage Services & Gas Storage Facility Procedures

Does your company have underground storage assets? Do you know what is included in the new PHMSA advisory bulletin and RPs 1170 & 1171?

RCP has extensive expertise in the underground storage recommended practices for both reservoirs and salt caverns which we would like to put to work for your company. We have developed integrity management programs and operating procedures for many storage facilities across the US. We can provide a wide variety of related services such as:

  • Assess current operations against new RP 1170/1171
  • Develop underground storage programs
  • Complete risk assessments
  • Develop risk mitigation plans

We are well-positioned to support your organization’s response to the recent PHMSA advisory bulletin as well as the California Emergency rule on underground gas storage. For more information, please contact Jessica Foley.

PHMSA Proposes Changes to Incident and Accident Reports

[DOCKET PHMSA-2015-0205]

On May 13, 2016, PHMSA proposed revisions to the incident and accident reports for gas distribution, gas transmission and gathering, LNG facilities, and hazardous liquid pipelines. Numerous changes are proposed for each form, including costs, consequences, causes and sub-causes, contributing factors, incident response actions, detection methods, volumes lost and recovered, how the MAOP / MOP was established (and when), etc. Comments are due on or before July 12, 2016 and can be submitted via the E-Gov Website. For a copy of the proposal, contact Jessica Foley.

PHMSA Releases Joint Pipeline Public Awareness SWOT Report

The Pipeline and Hazardous Materials Safety Administration (PHMSA) posted the joint Pipeline Public Awareness Program Working Group’s (PAPWG) Strengths, Weaknesses, Opportunities, and Threats (SWOT) Report to the Agency’s Stakeholder Communications website today. The report highlights key findings from SWOT results to foster continuous improvement in pipeline public awareness efforts. The full report can be accessed on the PHMSA website.

PHMSA plans to hold a public workshop on pipeline safety public awareness in July 2016. At the workshop, stakeholders, including Federal and state regulators, industry, pipeline operators, members of the public, emergency response officials, local public officials, land planners, and excavators will review the findings from the PAPWG’s SWOT report and to discuss best practices and future actions to advance public awareness and stakeholder engagement. This workshop will be webcasted and recorded for pipeline stakeholders who are unable to travel. PHMSA will publish a notice in the Federal Register with additional details about the workshop soon.

PHMSA Gas & Liquid Advisory Committee Member Nominations

[DOCKET NO. PHMSA–2016–0033]

PHMSA is requesting nominations for individuals to serve on the Gas Pipeline Advisory Committee (GPAC) and the Liquid Pipeline Advisory Committee (LPAC). The GPAC is composed of 15 members appointed by the Secretary of Transportation after consulting with public and private agencies concerned with the technical aspect of transporting gas or operating a gas pipeline facility. The LPAC is composed of 15 members appointed by the Secretary after consulting with public and private agencies concerned with the technical aspect of transporting hazardous liquid or operating a hazardous liquid pipeline facility.

PHMSA is seeking nominations for two individuals from the general public: one on the LPAC and one on the GPAC. Additionally, PHMSA is seeking to fill four state commissioner vacancies, two on each committee and one federal government vacancy on the GPAC committee.

Information about the GPAC and LPAC can be obtained by visiting PHMSA’s Website. Nominations must be received by June 23, 2016. All nomination material should be emailed to Advisory Committee Program Manager Cheryl Whetsel at or mailed to the Pipeline and Hazardous Materials Safety Administration, 1200 New Jersey Ave. SE, PHP–30, E24–445, Washington, DC 20590.

For a copy of PHMSA’s notice requesting these nominations, contact Jessica Foley.

Louisiana Dig Law Changes Effective Immediately

[LA HOUSE BILLS 249 & 250]

For the past year, the Louisiana Dig Law Advisory Committee has worked on revising the Louisiana Underground Utility and Facility Damage Prevention Law (Dig Law). The purpose of these discussions was to define the intent of the law. On June 2nd at the 2016 Regular Legislative Session House Bill 249 (which became Act 85) and House Bill 250 (which became Act 245) were both signed into legislation.

Certification of Non-Profit Regional Notification Center
When the dig law was enacted in 1988, it was not envisioned that there would be competition between multiple non-profit regional notification centers (one call programs). On behalf of the stakeholders who utilize Louisiana One Call, the Dig Law Advisory Committee requested that the Louisiana State Legislature address concerns that relate to public safety, cost effectiveness and ease of use for multiple one call programs. Act 85 states that, a regional notification program shall have specifically defined geopolitical services areas that are coterminous with parish boundaries and do not overlap any other defined service area. This provision in the law helps to ensure that there should be a single non-profit regional notification center that operates in the State of Louisiana.

Notification Center Holidays Added
The legislature also added holidays to be observed by regional notification center. These additional holidays include Memorial Day and Christmas Eve.

Excavation Redefined
As a result of an accident involving an offshore pipeline, the definition of “excavation or excavate” has changed. The new definition is, “Excavation” or “excavate” means any operation causing movement or removal of earth, rock, or other materials in or on the ground or submerged in a marine environment by the use of powered or mechanical or manual means, including but not limited to pile driving, digging, blasting, auguring, boring, back filling, dredging, compaction, plowing-in, trenching, ditching, tunneling, land-leveling, grading, and mechanical probing or any other activity that could reasonably result in damage to underground or submerged utilities or facilities. “Excavation” or “excavate” shall not include manual probing or any force majeure, act of God, or act of nature.

Gas and Liquid Advisory Committee Meetings

[DOCKET NO. PHMSA-2016-0032

PHMSA held public meetings of the Gas Pipeline Advisory Committee (GPAC) and the Liquid Pipeline Advisory Committee (LPAC) on June 1-3, 2016. Topics discussed included GPAC’s consideration and voting on the notice of proposed rulemaking (NPRM) titled: Pipeline Safety: Plastic Pipe Rule (80 FR 29263; May 21, 2015), and in a joint meeting of the GPAC and LPAC, members were to consider and vote on the NPRM titled: Pipeline Safety: Operator Qualification, Cost Recovery, Accident and Incident Notification, and Other Pipeline Safety Proposed Changes (80 FR 39916; July 10, 2015). Other topics of discussion included the regulatory agenda and agency and stakeholder priorities, including several regulatory and policy initiatives. A briefing on the NPRM, titled: Pipeline Safety: Safety of Gas Transmission and Gathering Pipelines (81 FR 20722; April 8, 2016), was presented to both committees and the public. Presentations from the meeting will be available on the meeting websiteand posted on the E-Gov website under docket number PHMSA-2016-0032 within 30 days following the meeting.

Pressure Testing Webinar – Advantages of Using TestOp®

RCP will be hosting webinar presentations to discuss pipeline pressure testing practices and demonstrate the advantages of utilizing new technology for planning, designing, and capturing real-time data to validate and document whether it was a successful test. The same technology that RCP has used for the past six years to validate our customer’s pressure tests has been greatly enhanced and is now being made available as a web-hosted solution for operators to use themselves.

TestOp® takes the confusion out of pressure testing by providing real-time determination of whether the test segment is experiencing potential issues, such as yielding or air entrapment volume absorption, all while modeling the mass balance relationship of pressures, volumes and temperatures of the test. TestOp® will provide real-time indicators and corresponding data to confirm whether the test is successfully performing to plan or if there might be a small pin-hole leak that would otherwise go undetected before taking the line segment off test. TestOp® generates comprehensive and consistent reports, including a certification letter, pressure test plan versus actual test results, pressure/spike test log, test instrument and pump calibrations, pipe volume calculations sheet, stress/strain and pressure/volume plots as well as upload capability for pictures and other document scans associated with the test.

We encourage any liquid or gas pipeline operator who has upcoming projects that involve replacement, integrity verification, new construction, uprates, conversions and/or reversals to sign up for the 45 minute webinar. Some of the largest and most respected pipeline operators are now using TestOp® because they see the value it brings to their overall pipeline integrity assurance program and we are confident you will too once you have seen it in person.

Mark your calendar and plan to attend one of these sessions or request an individual demonstration for your company at a date convenient to you.

Pipeline Pressure Testing Workshop: August 16-17, 2016

RCP is now offering a 2-day Pipeline Pressure Testing Workshop at its facilities in downtown Houston. The workshop will begin by outlining the objectives for performing a pressure test and how those relate to DOT requirements. The workshop will then build upon these foundations to answer many specific pressure testing questions including:

  • What are the different types of tests commonly conducted and how do you design each one?
  • What is the theory and physical science behind a pressure test?
  • How do you plan for a pressure test from start to finish:
    • Cleaning the line
    • Environmental hazards and permitting
    • Landowner and operations safety
    • Customer/stakeholder impact
    • Logistical details and scheduling
    • Pipeline modifications and anticipating failures
  • What is the required instrumentation and how does it need to be configured?
  • What data is absolutely necessary to validate a pressure test?
  • How do you determine and prove a successful pressure test?
  • What does a good test report look like (that will also satisfy PHMSA)?

Each attendee will receive the presentation as well as applicable handouts in a hardcopy notebook. Attendees will also have the opportunity to work through several exercises specifically covering 1) calculating the SMYS, MAOP and test pressures for various pipeline segments at various elevations 2) calculating the volume of water required for a hydrotest, fill times and velocities, and determining how the volume of test water changes with pressure and 3) designing a complete test plan for a hypothetical pipeline i.e. dividing the line into test sections and determining the test parameters for each section.

To register for our workshop, click here.

Pipeline Regulations for iPhone

There’s an app for that! In 2009, at our request, Tekk Innovations developed an iPhone application containing the federal pipeline safety regulations (49 CFR 40, and 190-199). It has keyword search and the capability to e-mail excerpts of the regulations to others. There have been several updates since the original app was released and was last updated on May 20, 2016. The app can be found in the iTunes store. The cost is $19.99.

Tekk Innovations has also developed apps for all the other CFRs, including all of 49 CFR for those who want all the transportation regulations, not just the pipeline ones; Louisiana Law, California Law and FAA FAR for Pilots.

Editor’s Note: I like the app with just the pipeline parts of 49 CFR, since I can search the pipeline regulations easier that way without getting hits from the other transportation regulations.

Summer Conference Schedule

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

SGA Operating Conference & Exhibits
July 25-27, 2016
George R. Brown Convention Center – Houston, TX

Mark your calendar and plan to attend the 2016 “Mega Rule” Notice of Proposed Rule Overview session on Monday, July 25th, from 4:00 p.m. – 5:00 p.m. RCP’s Vice President, Chris Foley, will be the presenter. It’s a session that is sure to generate a lot of discussion. RCP staff will also be onsite at Booth #101 with innovated solutions to assist with all your compliance needs.

LGA 2016 Pipeline Safety Conference
August 8-12, 2016
Astor Crowne Plaza Hotel – New Orleans, LA

RCP is once again a proud sponsor and exhibitor at this year’s conference, which has been referred to as the “Premier Pipeline Safety Conference.” We are excited to see you at this new venue in New Orleans. Laissez les bons temps rouler! (Let the good times roll!)

Western Regional Gas Conference
August 23-24, 2016
Tempe Mission Palms Hotel – Tempe, AZ

Mark your calendar and plan to attend the session, “IVP: Development of Industry Guidelines for the Engineering Critical Assessment (ECA) Process” on Tuesday, August 23rd, at 9:00 a.m. Presented by RCP’s Executive Consultant, Mr. Jerry Rau.

2016 RRC Pipeline Safety Conference
August 24-26, 2016
Embassy Suites Riverwalk Hotel – San Antonio, TX

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

Best regards, 

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