DOT Pipeline Compliance News

June 2019 Issue

In This Issue

Public Awareness and Engagement Workshop/USA Definition Meeting

[Docket No. PHMSA-2017-0094 and PHMSA-2018-0026] June 12-13, Washington, DC

PHMSA is holding a two-part public meeting to discuss amending: 1. the applicable Unusually Sensitive Areas (USA) definition for the Great Lakes, coastal beaches, and marine coastal waters, and 2. public awareness and engagement. During this meeting, PHMSA will provide updates on amending the applicable USA and/or high consequences area (HCA) definitions to include the Great Lakes, coastal beaches and marine coastal waters and seek input on applicable definition options and available geospatial information system (GIS) data. In addition, PHMSA will seek input to determine the most effective methods to inform all stakeholders on their shared responsibilities in relation to pipeline safety.

The meeting will be held at the DOT Headquarters in the West Building Atrium. The discussion on public awareness and engagement will take place on June 12 from 1:30 p.m. to 5:00 p.m. and on June 13 from 8:30 a.m. to 5:00 p.m. The discussion on amending the USA and HCA definition will take place on June 12 from 8:30 a.m. to 12:30 p.m. Click here for registration information.

The agenda and additional information for the meeting can be found on PHMSA’s meeting webpage. Both parts of the meeting will be webcast and presentations will be available on the meeting website and posted on the E-Gov website under docket number PHMSA-2017-0094 for the USA Definition meeting and docket number PHMSA-2018-0026 for the Public Awareness and Engagement meeting, within 30 days following the meeting.

PHMSA Public Meeting to Solicit Input for 2020 Emergency Response Guidebook

June 17, 2019 Washington, DC

PHMSA’s Office of Hazardous Materials Safety has scheduled a public meeting for June 17, 2019, to solicit input on the development of the 2020 edition of the Emergency Response Guidebook (ERG). The ERG is a guidebook intended for use by first responders during the initial phase of a transportation incident involving dangerous goods/hazardous materials and has been updated and published every four years. It has been PHMSA’s goal that all public emergency response personnel have free and immediate access to the ERG. To date, nearly 14.5 million free copies have been distributed to the emergency response community through state emergency management coordinators.

During the June 17 meeting, PHMSA will discuss methodology used to determine the appropriate response protective distances for poisonous vapors resulting from spills involving dangerous goods considered toxic by inhalation in the “green pages” of the 2016 ERG. PHMSA will also solicit comments related to new methodologies and considerations for future editions of the ERG; and discuss outcomes of field experiments, as well as ongoing research, to better understand environmental effects on airborne toxic gas concentrations, and the updates that will be published in the 2020 ERG.

The meeting will be held at the U.S. Department of Transportation Conference Center at 1200 New Jersey Ave. SE, Washington, DC 20590 on June 17, 2019, from 8:30 a.m. to 2:30 p.m. EST. Click here for registration and conference call-in information. For questions about the meeting, contact Ryan Vierling (202) 366-4620 or Shante Goodall (202) 366-4545.

PHMSA Sends Gas Transmission Rule to OMB

PHMSA has indicated that the first of the three gas transmission and gathering final rules (Safety of Gas Transmission Pipelines: MAOP Reconfirmation, Expansion of Assessment Requirements, and Other Related Amendments) has been sent to the Office of Management and Budget for their review.  This review can take up to 90 days to complete, but it does not always require that much time.  The DOT’s significant rulemaking website lists August 20, 2019 when they expect to publish the final rule in the federal register.

Reminder: PHMSA has split the original gas “mega-rule” into three separate regulations.  The first rule includes the congressional mandates and is the only final rule to be submitted to OMB for review.

  1. Safety of Gas Transmission Pipelines: MAOP Reconfirmation, Expansion of Assessment Requirements, and Other Related Amendments
  2. Safety of Gas Transmission Pipelines: Repair Criteria, Integrity Management Improvements, Cathodic Protection, Management of Change, and Other Related Amendments
  3. Safety of Gas Gathering Pipelines

For more information, contact Jessica Foley.

Gas Mega-Rule Support
Are you ready for the three pending gas transmission and gathering regulations? RCP has been heavily involved throughout this rulemaking process and is ready to assist operators as they get prepared.  Whether it’s a deep dive into MAOP records reconfirmation, assessing where your Moderate Consequence Areas exist, reviewing existing pipeline integrity programs, developing action plans to get into compliance, or simply providing training to your team on what’s coming, RCP can help.  Visit or contact Jessica Foley for more information.

Proposed Pipeline Safety Act Modifications

On June 3, 2019, U.S. Transportation Secretary Elaine L. Chao Announced DOT’s 2019 Pipeline Safety Legislative Proposal.  According to Secretary Chao, the proposed legislation prioritizes safety, promotes innovation, and encourages reliable energy infrastructure in the United States.  The proposed legislation would reauthorize pipeline safety programs at the Department’s Pipeline and Hazardous Materials Safety Administration (PHMSA) for fiscal years 2020-2023.  Among its provisions are measures that would modernize PHMSA’s incident and construction data collection, establish a voluntary safety information sharing program, encourage replacement for aged local pipeline systems, and clarify certain regulatory measures to prevent incidents from occurring on our nation’s pipeline system.

“This proposal renews our commitment to pipeline safety by encouraging innovation and greater stakeholder collaboration, as well as by clarifying certain pipeline replacement practices for local distribution systems to help prevent future incidents,” said PHMSA Administrator Skip Elliott.

The legislation also includes provisions that would streamline and enhance PHMSA’s support for new liquefied natural gas (LNG) facilities, enabling the United States to export natural gas globally.  Moreover, the proposal embraces innovation by promoting research and development initiatives aimed at deploying new technologies to enhance pipeline safety and reliability.

The proposed legislation can be found at this link.

Aliso Canyon Gas Storage Incident Findings Published

The California Public Utility Commission (CPUC) and the Division of Oil, Gas, and Geothermal Resources (DOGGR) published their findings for the Southern California Gas Company, Aliso Canyon Gas Storage SS-25 Incident. The report concludes the ruptured production casing was due to external microbial corrosion.  Root cause analysis findings included:

  1. Risk assessments were not conducted to assess the wells for integrity
  2. Previous casing failures were not investigated
  3. Casing wall thickness inspections were not required by regulations and were not routinely performed in all wells
  4. Well flow rate was underestimated for well SS-25
  5. Well kill modeling was not conducted for the first 6 kill attempts
  6. No well surveillance at Aliso Canyon
  7. Single barrier production casing

The report does indicate that new regulations from DOGGR and Southern California Gas Company’s current integrity management practices address most of the root causes. The report, and a really interesting video that summarizes the history of SS-25 and the events leading up to and immediately after the failure, can be found on the CPUC website.

Underground Gas Storage
RCP is the market leader for underground gas storage integrity and risk management.  We have unmatched industry leaders, including Rick Gentges, Steve Nowaczewski, Terry Rittenhour, Phil Baker and more available to assess your program and provide practical feedback and recommendations for improving your gas storage integrity and risk programs.  For more information about RCP’s underground gas storage integrity management and risk analysis services, visit our website  or contact Jessica Foley.

American Gas Association Recommends Adoption of API RP 1173 Pipeline Safety Management Systems

The American Gas Association (AGA) Board of Directors approved a resolution recommending that all members implement Pipeline Safety Management Systems (PSMS) within three years.  From the AGA news release:

“. . . At the heart of PSMS is a safety culture promoting non-punitive reporting and consistent self-evaluation to help identify top-priority risks, taking steps to reduce these risks in an effort to prevent incidents from occurring. PSMS manages pipeline safety through continuous monitoring and improvement and its ‘Plan-Do-Check-Act’ cycle.” . . . “Since the publication of API RP 1173 in 2015, AGA has been integrally involved in promoting the benefits of safety management systems and providing members implementation assistance, including a PSMS Discussion Group that meets 3-4 times per year, developing a white paper on “Guidelines for Understanding Pipeline Safety Management Systems” specific to natural gas companies, and holding workshops to drive robust discussions around PSMS and share tools for PSMS planning and evaluation. AGA has also worked with other energy trade associations to create a PSMS website, which includes a variety of tools to assist operators. All of these activities will continue to help support this ongoing focus in advancing the safety of the industry.”

To read the full news release, click here. RCP is a proud AGA Associate Member and commends AGA and its members for voluntarily taking this bold step towards improving pipeline safety.

RCP Safety Management System
RCP has experience assisting our clients implement API RP 1173 – Pipeline Safety Management Systems (PSMS) as the basis for their safety management system.  RCP can perform gap assessments and prepare project plans to close the identified gaps with the goal of having a fully functional safety management system. RCP continues to work with the joint industry group, developing much of the material on the website and is currently working to create a formal auditing program for RP 1173.  For more information on how RCP can assist with your company’s PSMS implementation, contact Jessica Foley.

AGA White Paper for Natural Gas Systems

[Released April 8, 2019]

The American Gas Association (AGA) has published a white paper, “Skills and Experience for Effectively Designing Natural Gas Systems,” that provides guidance to operators on workforce knowledge, skills and communications. The report details a tiered approach to developing a foundational understanding of natural gas systems, improving knowledge about operator-specific processes and procedures, and building technical knowledge. The report also highlights the importance of pipeline safety management systems to promote safety awareness and cooperation company-wide. Additional information can be found on AGA’s website.  

Fundamentals of Pipeline Operations Workshop

June 26-27, 2019

Join us June 26-27, 2019 in Houston at our corporate office and dedicated training facility for this new workshop on the fundamentals of pipeline operations. This 2-day course is designed to give a comprehensive overview of gas and liquid energy transmission pipelines and how they are operated and maintained. It is appropriate for both technical and non-technical personnel who are new to the energy transmission pipeline industry, as well as those who need a broader understanding of pipeline operations and management in general. The course walks through the practical things that a typical pipeline company’s operations organization does on a regular basis to operate and maintain the pipeline system as a whole. Course topics include:

  • Components of a pipeline system (types of pipe, coatings, tanks, valves, pumps, compressors, pressure vessels, pig traps, meters, instrumentation, control systems / SCADA)
  • Operations activities (starting / stopping, batching, managing receipts and deliveries, measurement, monitoring, pressure control, leak detection)
  • Inspection and Maintenance (valves, ROWs, tanks, pumps, compressors, instrumentation, pigging, cathodic protection)
  • Repair (in-service repair techniques, welding, OOS repairs / replacements)
  • Integrity Management (ILI, Pressure Tests, Direct Assessment), including assessment processes, analysis, follow-ups
  • Emergency Response (planning, organization / ICS, drills, response)
  • Public Awareness / Damage Prevention / One Calls

Each attendee will receive the presentation as well as applicable handouts in a hardcopy notebook.

The course involves many hands-on demonstrations and examples using RCP’s in-house Pipeline Flow Loop*. To promote an optimal learning environment, class size will be limited. To register for our workshop, click here.

*RCP’s in-house Pipeline Flow Loop is an engineering marvel (!). It is a working 2” diameter pipeline system incorporating many of the components of a transmission pipeline system including state-of-the-art SCADA control system and instrumentation for flow, pressure, temperature, and volume, as well as automated valves, pig traps, variable speed pump, and more. It also incorporates clear pipe segments so that students can see a pig in operation, see phase separation as it occurs, and understand the importance of elevation change. It occupies 2 walls outside our training room. Students can monitor and control the pipeline from the training room (“control room”), and then step into the hall to see the pipeline in action.

California Proposed One Call Changes

[CRNR, Register 2019, Volume No. 20-Z, 05/17/2019, pages 780-784]

The California Underground Facilities Safe Excavation Board is proposing to add sections 4000 through 4361 under California Code of Regulations, Title 19, Division 4, Chapters 1 – 4. The regulations proposed in this rulemaking action would establish definitions for certain terms used in the proposed regulations, investigation and enforcement processes, and onsite meeting and agreement requirements for areas of continual excavation near high priority subsurface installations. Highlights of this proposed rulemaking include:

  • The proposed rules in Title 19, Division 4, Chapters 1 – 4 give definitions for “Damage,” any excavation work that causes breaks, leaks, nicks, dents, strikes, gouges, grooves, cracks, or punctures, to subsurface facilities.
  • Regional notification centers shall maintain valid and current contact information of all members and provide such information to the Board upon request.
  • Excavators are required to notify regional notification centers of damages to natural gas or hazardous liquid pipelines, high priority subsurface installations, or if any injuries or fatalities have occurred no less than 2 hours after the event.
  • Investigators are authorized to investigate damages, probable violations, or reports of incidents. They may also issue notices of probable violations and information letters.
  • Upon request, excavators and operators shall provide access to sites and information and, if hindering an investigation, are subject to sanctions. Sanctions for any violations may include an Order for Corrective Actions or fines beginning July 1, 2020. Operators and excavators will be able to respond to any assessed violations.
  • In addition, the Operator shall locate and field mark facilities prior to an onsite meeting and plan at the site of the subsurface installation. Onsite meetings must include the excavator and the Operator, and should complete the Area of Continual Excavation Agreement for Flood Control Facilities or Agricultural Operations near subsurface installations.

Written comments regarding these proposed changes will be accepted through July 1, 2019. Comments can be sent via email. Include in the subject line of the email “Comments: Investigation & Enforcement.”

For a copy of California’s (DIG) Notice of Proposed Rulemaking, contact Jessica Foley.

Illinois Gas Regulations Update

On May 21, 2019, the Illinois Commerce Commission revised their regulations in Title 590 – Minimum Safety Standards for Transportation of Gas and for Gas Pipeline Facilities. These revisions updated Section 590.10(a) to exclude Section 49 CFR 192.12 from the Federal Standards Incorporated by Reference. In addition, the revisions state Operators are not required to submit reports required by 49 CFR 191 that pertain only to the downhole portion of an “underground natural gas storage facility,” as defined in 49 CFR 192.3 as of July 1, 2018, to the Commission. Section 590.20 was also updated to reflect this exemption.

Job Opening – Executive Director of the Pipeline Safety Trust

Carl Weimer, the executive director of the Pipeline Safety Trust since its inception in 2003, has announced his intention to retire at the end of this year.  The board of the PST is actively seeking a replacement, and is accepting resumes until June 12, 2019.  Additional information can be found here.

On a personal note, I have known and respected Carl for many years now, and he will be a very tough act to follow.  In addition to the posted job description, I’ll add a few additional requirements from my perspective:

  • Skin thickness must be similar to vulcanized rubber
  • Must be able to listen politely and respond civilly to all types of people in all types of situations
  • Must be willing to answer the same questions and explain the same issues, ad nauseum, from reporters and news organizations after every pipeline incident
  • Must be able to testify before congress and respond to questions from both sides of the aisle, while biting tongue

And lastly

  • Must be willing to do a lot of work for a little money

2019 Summer Industry Conference Schedule

TGA Operations and Management Conference
July 9-12, 2019
Embassy Suites | San Marcos, TX
Registration opening soon.

SGA Natural Gas Connect
July 15-17, 2019
J.W. Marriott Hill Country Resort & Spa | San Antonio, TX

RCP is a proud sponsor and exhibitor of this new conference with a new name. Also known as NGC, this new conference will offer more than 30 roundtables, opening up limitless cross-learning opportunities. It will also help bridge any gaps in your business outlook and connect you with other engaged peers in the industry.

LGA Pipeline Safety Conference
July 29 – August 1, 2019
Astor Crowne Plaza | 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.”

APGA Annual Conference
July 28-31, 2019
Stowe Mountain Lodge | Stowe, Vermont
A conference for public natural gas professionals and industry experts.

Western Regional Gas Conference
August 20 & 21, 2019
Tempe Mission Palms Hotel | Tempe, Arizona

The Western Regional Gas Conference provides a forum for the free exchange of information between natural gas companies and their state and federal regulators, and with associated industry organizations, consultants, manufacturers and vendors that serve the pipeline industry.

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


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