DOT Pipeline Compliance News

March 2016 Issue

In This Issue

PHMSA Advisory ADB-2016-03 Snow & Ice on Gas Distribution Systems

[DOCKET NO. PHMSA-2016-0013]

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) issued an Advisory Bulletin (ADB-2016-03) to advise owners and operators of petroleum gas and natural gas facilities of the need to take the appropriate steps to prevent damage to pipeline facilities from accumulated snow or ice. Past events on natural gas distribution system facilities appear to have been related to either the stress of snow and ice or the malfunction of pressure control equipment due to ice blockage of pressure control equipment vents.

For a copy of ADB-2016-03, contact Jessica Foley.

PHMSA FAQ-41 TIMP Reassessment Intervals

[REVISED 2/22/2016]

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) recently revised FAQ-41 to reflect the language in the Pipeline Safety Act of 2011.

FAQ-41. Does the requirement that gas pipeline operator establish assessment intervals not to exceed a specified number of years mean calendar years (i.e., pipe assessed in 2004 must be re-assessed during 2011) or actual years?

Re-assessments must be conducted in accordance with an operator’s procedures for determining the appropriate reassessment interval. Prior to the enactment of the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011, the maximum interval was set using actual years from the date of the previous assessment. Effective January 3, 2012, this was modified such that the maximum interval may be set using the specified number of calendar years. For example, a pipe segment assessed on March 23, 2004 with a seven year interval must be re-assessed before December 31, 2011, using at least confirmatory direct assessment. This segment would need to be re-assessed using one of the methods specified in the rule before December 31, 2014, December 31, 2019 or December 31, 2024, depending on its operating stress (see § 192.939). Note that this change from actual years to calendar years is specific to gas pipeline reassessment interval years and does not alter the actual year interval requirements which appear elsewhere in the code for various inspection and maintenance requirements.

FAQ-41 can be found on the PHMSA website along with the other FAQs.

Pipeline Safety Program Reauthorization and Gas Pipeline NPRM

[REVISED 2/22/2016]

Both the House and the Senate are moving forward with bills to reauthorize the federal Pipeline Safety Act. The House Subcommittee on Railroads, Pipelines, and Hazardous Materials held a hearing on February 25th on reauthorization of the Department of Transportation’s pipeline safety program. There was testimony from the federal safety agency, industry stakeholders, and safety advocates. During the Q&A session of the hearing, PHMSA Administrator Dominguez stated that PHMSA is working diligently to publish the Notice of Proposed Rulemaking (NPRM) for the Gas Transmission Rule “within a month” or “in the coming weeks.”

Meanwhile, the Senate approved a pipeline safety bill on March 3rd, proposed by a bipartisan group of lawmakers led by Sens. Deb Fischer (R-Neb.) and Cory Booker (D-N.J.), which reauthorizes the Pipeline and Hazardous Materials Safety Administration (PHMSA) through 2019 and takes new steps to cut down on spills and other problems with the American pipeline network.

Work will continue to reconcile the various drafts and bills, to develop and approve a single bill for approval by the President.

TRRC New Versions of Form T-4 Adopted and Online

[REVISED 2/22/2016]

On February 3, 2016, the Texas Railroad Commission (TRRC) adopted new versions of the Form T-4, Application for Permit to Operate a Pipeline in Texas (Liquid Pipelines) and Application for Permit to Operate a Pipeline in Texas (Natural Gas Pipelines). The new versions of the Form T-4 now include the Texas Pipeline Questionnaire (Form PS-8000A).

The new form became effective February 3, 2016 and is available for download in fillable PDF format from the TRRC’s website.

If there are any questions regarding this announcement, email

DOT Pipeline Compliance Workshop – Gas & Liquid

APRIL 12-14, 2016

Join us April 12-14, 2016 in Houston at our corporate office and dedicated training facility for an informative, lively, and interactive workshop on DOT Pipeline Compliance topics. The workshop provides an overview of the DOT pipeline regulations in 49 CFR 191, 192, 194, 195, and 199. It also describes pipeline operations and engineering concepts. It is appropriate for people who are new to pipeline regulations, who could use a refresher, or anyone who needs to know the latest developments in these areas. This workshop will be a combined format, addressing both gas and liquid pipeline topics in parallel. This will eliminate some redundancy of materials, and will allow more time for in-depth discussions for each topic.

Topics to be addressed in the workshop include:
  • An overview of DOT/OPS pipeline compliance requirements
  • State and Federal agency roles for pipeline safety
  • PHMSA Jurisdiction
  • PHMSA Inspections and Enforcement Processes
  • Engineering Concepts and Stress – Strain Relationships; %SMYS
  • Design Requirements
  • Construction Requirements
  • Corrosion Control Concepts and Requirements
  • Operations and Maintenance Requirements
  • Emergency Response Requirements (including spill response planning requirements for liquid pipelines)
  • Damage Prevention Programs
  • Operator Qualification Programs
  • Drug and Alcohol Programs
  • Public Awareness Programs
  • Integrity Management (gas and liquid) Programs
  • Control Room Management Programs

We will also discuss the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 (pipeline reauthorization bill), recent Advisory Bulletins from PHMSA, and new, pending and proposed rulemakings.

Each attendee will receive the presentation as well as applicable handouts in a hardcopy notebook, and electronic copies of the applicable regulations and voluminous reference materials including rulemakings, letters of interpretation, and other guidance documents. The workshop will adjourn at 2 p.m. on the third day, for those who need to fly out Thursday evening.

To register for our workshop, click here.

API RP 1174 Assessment

API recently published Recommended Practice (RP) 1174 for Onshore Hazardous Liquid Pipeline Emergency Preparedness and Response (1st Edition, December 2015). API RP 1174 provides operators with an enhanced framework to enable continual improvement of pipeline emergency planning and response processes. RCP can assist operators with preparing for a safe, timely, and effective response to a pipeline emergency. Contact Jessica Foley if you need a review of your Facility Response Plan, Contingency Plan, Integrated Contingency Plan; or, if you are interested in a third party review.

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.

API RP1173 Assessment Services

API recently published a new Recommended Practice (RP) concerning safety management systems for pipelines. API RP 1173 provides pipeline operators with a comprehensive way to make safe operations and continuous safety improvement a constant focus of their operations. The first step for most pipeline operators will be to assess their current safety management system maturity – from nothing in place to a sustainable, improving system. RCP can assist operators in the evaluation of the maturity levels of each element of the recommended practice, and establish an action plan for further development / maturity. Contact Jessica Foley for API RP 1173 Assistance.

API Safety Management System (SMS) Tools

If you have not already done so, check out the Pipeline SMS website for documents and tools to assist with your organizations’ SMS. Here’s a sampling of what you can find:

  • Booklets describing the benefits and implementation of a Pipeline SMS to the basic question, “What is a Pipeline SMS?”
  • Pipeline SMS Workshop Materials
  • Pipeline SMS Tools for API RP 1173

2016 Pipeline Conference Schedule

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

API Pipeline Conference
April 5 – 7, 2016
Omni La Costa / Carlsbad, CA

API’s Pipeline Conference is the premier event of its kind in the U.S. Held every year in April the conference provides attendees with an opportunity to hear about the latest in pipeline-related developments. Included in the program for 2016 will be Pipeline Integrity, Safety Management Systems, Training, OQ, Regulatory, Process Safety, Emergency Response, and a host of other relevant topics. Once again, RCP is a proud sponsor of this event and looks forward to seeing you there!

AGA Operations Conference
April 19 – 22, 2016
Arizona Biltmore / Phoenix, AZ

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. The Operations Conference is AGA’s largest forum with regularly more than 500 operations management in attendance, including 80 speakers, and over 100 technical presentations, including two presentations from RCP staff:

PHMSA Incident and Annual Data Analysis

RCP can provide detailed and timely analysis of PHMSA historical incident and annual data for clients needing to compare their performance against the industry averages, respond to press inquiries, or analyze trends. Contact Jessica Foley for more information.

Save the Dates!

RCP Workshop Schedule for 2017

  • DOT Gas & Liquid Pipeline Workshop: March 21-23 (Tuesday, Wednesday & Thursday)
  • Fundamentals of Pipeline Operations Workshop: May 24-25 (Wednesday & Thursday)
  • Pressure Test Workshop: June 20-21 (Tuesday & Wednesday)

Visit our training website for updates, registration, and hotel information.

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