DOT Pipeline Compliance News

March 2014 Issue

In This Issue

PHMSA Updates DIMP Enforcement Guidance

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) updated its Gas Distribution Pipeline Integrity Management Enforcement Guidance for 49 CFR Subpart P. The document is intended for internal use by the PHMSA pipeline safety enforcement staff – but is also available to the public and pipeline operators. This guidance document describes the practices used by PHMSA pipeline safety investigators and other enforcement personnel in undertaking their compliance, inspection, and enforcement activities. For each section of the rule, the guidance document gives:

  • The rule language and citations
  • Interpretation Summaries
  • Advisory Bulletin/Alert Notice Summaries
  • Other Reference Material & Source
  • Guidance Information
  • Examples of a Probable Violation or Inadequate Procedures
  • Examples of Evidence
  • Other Special Notations

This DIMP guidance document can be downloaded from the PHMSA website.

PHMSA Advisory Committee Meetings

As mentioned in our last newsletter, PHMSA held a day and a half of joint gas and liquid advisory committee meetings in the DC area on February 25-26. Only one official vote was taken, regarding the use of re-worked materials for plastic gas piping. The committee was unanimous that they did not support this option for regulated gas pipelines. Other presentations were made concerning class locations for gas pipelines, PHMSA and OSHA jurisdictional issues for midstream pipeline facilities, and the current priorities for PHMSA, State Regulators, the public, and gas and liquid pipeline operators. PHMSA wrapped up the meeting with an update on congressional mandates, NTSB, OIG, and GAO recommendations, and a review of their regulatory agenda. The meeting presentations can be downloaded here.

NPMS Data Submission

As a reminder, gas transmission operators are requested to submit their NPMS data (or notification of no changes) by March 15, 2014. The data should reflect assets as of 12/31/13. Hazardous liquid operators are requested to submit their NPMS data (or notification of no changes) by June 15, 2014. The data should reflect assets as of 12/31/13.

The NPMS staff has prepared an Operator Submission Guide to assist you in preparing your NPMS submission this year. Click here for a copy of the guide; or by clicking the NPMS Operator Submission Guide link on the left-hand side of

RCP Receives 3 Patents for MAOP Software

RCP has received 3 patents (#8,548,756; #8,548,757; and #8,548,758) for our industry-leading MaxOp* software. RCP is the unquestioned market leader providing MAOP Validation Services, including over 100,000 miles of gas and liquid pipeline analysis and support. Not only does RCP bring a wealth of experienced professional engineers and support staff, we have brought the most comprehensive and complete MAOP validation tool to the market, MaxOp*.

MaxOp* Features:

  • NEW Section Q & R, Gas Transmission Annual Report: output MAOP reports compliant with PHMSA requirements
  • Data agnostic: works with all common database and GIS data formats
  • Traceable: connects data to source document image files
  • Verifiable: identifies exact 192/195 code sections driving MAOP results

MAOP Validation Services:

  • Turnkey: document review & imaging, data extraction, gap analysis, MAOP reporting
  • Quality Assurance: review existing validation efforts, compare calculations using MaxOp*
  • Annual Report: Import data to MaxOp*, export Section Q & R report
  • Remediation: develop strategies to close gaps and/or re-establish MAOP

For more information about RCP’s MAOP validation services or the MaxOp* calculator tool, please contact Jessica Roger. * MaxOp is a registered trademark of RCP, Inc., in the United States.

Safety Management Systems Meeting

PHMSA hosted a workshop on the pending API Recommended Practice 1173 on Pipeline Safety Management System Requirements. The agenda and presentations from the workshop are available here. The draft document can be accessed here.

Public comments on the draft will be accepted until April 11, 2014. Comments must be submitted online at The ballot ID number is 3178 and no Login ID is required – leave the field blank. After clicking submit, the API legal disclaimer will open and must be accepted to proceed. After completing your contact information (this is required in case the development group needs to contact you about your comments) the actual page to enter comments appears.

ASME Training Week – Denver April 14 – 18

Check out the pipeline training programs offered by ASME in Denver the week of April 14-18, 2014. Subject Matter Experts from RCP will provide training on the first day regarding pipeline pressure testing. Other courses are offered on ASME B31.4 (liquid transmission) and ASME B31.8 (gas transmission), as well as Composite Repairs, Defect Assessment, Inline Inspection, Integrity Management, and Onshore Design and Construction. Additional information can be found on the ASME website.

RCP Integrity Services

Looking for more pipeline integrity and corrosion control services? Check out the new website for RCP Integrity Services at We have a new look that is also mobile friendly.

RCP Integrity Services (RCPIS) supports RCP’s pipeline integrity and corrosion control services including Operational Reliability Assessments and Integrity Management Programs. RCP Integrity Services, along with RCP Inc., comprise the perfect team to support all of your pipeline integrity requirements.

Spring Conference Schedule March – May 2014

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

NACE Corrosion 2014 Conference & Expo
March 9-13, 2014
Henry B. Gonzalez Convention Center; San Antonio, Texas

RCP Integrity Services is a proud sponsor of Corrosion 2014. Click on the interactive map to find us at Booth #1603 and register to win a free Yeti – the extreme cooler!

AGA Transmission Pipeline Workshop
March 18 – 19, 2014
OMNI Royal Orleans Hotel; New Orleans, LA

This workshop will feature presentations and case studies from pipeline operators and service providers on actions being taken to proactively address provisions in the 2011 Pipeline Safety Reauthorization. RCP’s Executive Consultant, Mr. Larry Decker will be giving a presentation on “Producing and documenting a quality pipeline pressure test report.” There will also be regulatory updates provided on the status of federal rule makings. Regulators, pipeline operators, and service providers are all invited to participate in this forum.

API Pipeline Conference and Cybernetics Symposium
April 8 – 10, 2014
Hyatt Regency Hill Country, San Antonio, Texas

This conference includes presentations on Safety Management, Aboveground Facility/Integrity, Effective Internal and External Communication, Alternative Forms of Transportation, Emergency Response, Control Room Management, Corporate Security and a host of other timely subjects.

AGA Operations Conference 2014
May 20 -23, 2014
Omni William Penn, Pittsburgh, PA

The annual AGA Operations Conference is the natural gas industry’s premier gathering of natural gas utility and transmission company operations management from across North America and the world for the sharing of technical knowledge, ideas and practices to promote the safe, reliable, and cost-effective delivery of natural gas to the end-user.

Join RCP’s MS150 Team from Houston to Austin April 12 – 13

RCP hosts a small but enthusiastic team of riders in MS150 bike rides, including the upcoming BP MS150 on April 12-13 from Houston to Austin. Your humble newsletter editor is happy to suffer a bit for a good cause, but he has his limits. The RCP team rents a ranch outside LaGrange for the overnight stop on Saturday. Soft beds. Hot showers. Home cooked food. If you are interested. you can join our merry band here.

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