DOT Pipeline Compliance News

March 2017 Issue

In This Issue

PHMSA Underground Natural Gas Storage Comment Period Ended

On December 19, 2016, PHMSA published the Safety of Underground Natural Gas Storage Facilities Interim Final Rule [81 Federal Register 91860] (See related article in the January edition of the DOT Pipeline Compliance News.) This IFR is effective January 18, 2017 and currently sets a timeline for implementation of API RP 1170, sections 9, 10, and 11; and API RP 1171, sections 8, 9, 10, and 11 by January 18, 2018. PHMSA solicited comments on the IFR before issuing a final rule on the Safety of Underground Natural Gas Storage Facilities. The comment period ended on February 17, 2017. Commenters have addressed concerns over the following issues:

  • Timeline and implementation
  • Requiring all “non-mandatory” language of the recommended practices as mandatory, and
  • Incorporating Gas Storage Rules as a part of 49 CFR 192

To read all comments visit the current PHMSA rule docket. For more information, contact Jessica Foley.

Underground Gas Storage Compliance

How does RCP deliver a comprehensive solution for natural gas storage operational integrity assurance?

Experienced Resources
  • Highly respected underground storage & risk management SME’s (the past Chair of PRCI’s and AGA’s underground storage committees is on our staff)
  • Professional engineering support
  • Written program development / improvement from knowledgeable technical standards developers (Our lead technical writer was the editor for the API RP1170 development team.)
State-Of-The-Art Tools (TaskOp™)
  • Program gap assessment and corrective action tracking
  • Storage risk assessment
  • Integrity assessment and remediation process tracking

For more information regarding our capabilities or to request an online demonstration of our TaskOp™ underground gas storage solution, visit our website or contact Jessica Foley.

Annual Inspections of Intra-State Liquid Pipelines and Operators in California

As a result of the May 19, 2015 pipeline incident at Refugio Beach in Santa Barbara County that spilled over 100,000 gallons of crude oil and impacted over 25 miles of coastline and ocean water, the State of California has mandated the Office of the State Fire Marshal (OSFM) to adopt regulations and conduct annual inspections of each intrastate hazardous liquid pipeline to reduce the potential pipeline accidents in California and protect the environment.

The State Fire Marshal has provided notice to adopt proposed regulations related to the annual pipeline inspection of every intrastate hazardous liquid pipeline and operators of intrastate hazardous liquid pipelines. The OSFM annual inspection will ensure compliance with federal and State regulations, enhance public safety, protect California’s vital natural resources, and reduce the risk of future jurisdictional hazardous liquid pipeline accidents. The OSFM annual inspection is a two phase risk-based inspection approach with 4 main components:

  1. Gather Operator Information: Beginning in 2017, each pipeline operator will be required to annually complete and submit to the OSFM the Form PSD-101 by July 1st. The completed form will contain data and validated inspection results from the previous calendar year for each jurisdictional pipeline and scheduled projects for the next calendar year. Operators must maintain documentation to substantiate the information provided in their Form PSD-101. If an operator is unable to submit the Form PSD-101 by July 1st, they may submit a written request to the OSFM asking for a 30-day extension. This written request must be submitted to the Pipeline Safety Division Lakewood Office no later than June 1st.
  2. Internal OSFM Review/Identify Inspection Modules: OSFM staff will review each submitted Form PSD-101 for completeness. OSFM will also review leak, violation, and inspection history from internal databases to identify risks, trends, and other pipeline safety issues on each pipeline. The OSFM will assign inspection modules for each jurisdictional hazardous liquid pipeline based on pipeline operating history, integrity testing, preventative and mitigative measures, construction activities, and the OSFM internal review.
  3. Annual Operator Inspection: The OSFM will schedule an annual operator inspection after the OSFM has assigned inspection modules to an operator?s jurisdictional hazardous liquid pipelines. This operator inspection will include reviewing records associated with the completed Form PSD-101 and discussing the inspection modules that have been assigned to each of the operator’s pipelines for the coming year. Prior to the inspection, operators will be informed as to which documents must be available during the annual operator inspection. This will allow the operator to compile the required documentation from regional offices and have essential personnel available during the inspection. NOTE: Additional inspection modules may be assigned to a pipeline based on information obtained during the annual operator inspection.
  4. Annual Pipeline Inspection: The OSFM staff will conduct an annual pipeline inspection on each pipeline listed on the operator?s Form PSD-101 using the annual inspection modules that were assigned to each pipeline.

By May 1st of each year, the OSFM will provide each California intrastate pipeline operator an electronic version of each Form PSD-101 to the operator staff that has been designated to complete the annual OSFM Pipeline Questionnaire. The Form PSD-101 will be populated with the company information (Name, ID, Inspection Units, and CSFM Line ID) that is currently on file with the OSFM. The Form PSD-101 will be divided by OSFM Inspection Unit and will include each OSFM jurisdictional pipeline that was included in the OSFM Annual Questionnaire for the previous year. Each pipeline operator is required to annually complete and submit a Form PSD-101 to OSFM by July 1st that represents the operator?s pipeline assets as of December 31st of the previous calendar year. The completed Form PSD-101 will identify scheduled projects for the next calendar year and will contain inspection data and validated inspection results from the previous calendar year for each jurisdictional pipeline. Operators must maintain documentation to substantiate the information provided in their Form PSD-101.

These new regulations can be found in California State Regulations, Title 19 – Public Safety, Division 1 – State Fire Marshal, Division Chapter 14 – Hazardous Liquid Pipeline Safety.

There is a new article 2 (sections 2020-2030) filed 2-9-2017; operative 2-9-2017 pursuant to Government Code section 11343.4(b)(3) (Register 2017, No. 6). Article 2 states:

Article 2. Annual Inspection of Intrastate Hazardous Liquid Pipelines and Operators of Intrastate Hazardous Liquid Pipelines

§ 2020. Annual Inspection.

In order to implement Section 51015.1 (a) of the Government Code, the Office of the State Fire Marshal shall conduct an annual inspection of every intrastate hazardous liquid pipeline and every operator of an intrastate hazardous liquid pipeline. The inspection shall include the following:

  • Evaluation of the risks to each intrastate hazardous liquid pipeline based upon the operator history, integrity testing results, preventative and mitigative measures, construction activities, leak history, and compliance history.
  • An annual inspection of each operator of an intrastate hazardous liquid pipeline in accordance with California State Fire Marshal Annual Inspection Procedures (dated July 1, 2016) which is hereby incorporated by reference.
  • An annual inspection of each intrastate hazardous liquid pipeline in accordance with California State Fire Marshal Annual Inspection Procedures (dated July 1, 2016) which is hereby incorporated by reference.
§ 2021. Form PSD-101 Requirements.
  • The following forms, in the format developed by the Office of the State Fire Marshal, which are hereby incorporated by reference, shall be used for hazardous liquid pipeline annual inspections
    • California Intrastate Pipeline Operator Annual Report, PSD-101 (dated July 1, 2016).
    • Instructions for Form PSD-101 (dated July 1, 2016).
  • Each operator of an intrastate hazardous liquid pipeline shall complete and submit to the Office of the State Fire Marshal Form PSD-101 for each intrastate hazardous liquid pipeline no later than July 1st annually.
  • Each operator of an intrastate hazardous liquid pipeline shall have available for review by the Office of the State Fire Marshal documentation to substantiate the information provided in the Form PSD-101.
§ 2030. Violations.

Failure to comply with any of the above provisions of this chapter shall be subject to enforcement action under Section 51018.6 of the Government Code.

Audit Assistance

Has the DOT or a State agency notified you of a pending audit? Are your O&M and IMP programs ready for their next PHMSA audit? RCP can review your plans based on Advisory Bulletins and Enforcement Guidelines to ensure compliance. RCP is well versed in PHMSA audit preparation and will help you identify opportunities for improvement and track each item to closure using RCP’s audit tracking tool, TaskOp?. RCP can provide confidential internal auditing to help ensure that your facilities are up to the agency’s latest standards. For more information, contact Jessica Foley.

Grammar Police on the March in California

Several revisions were recently made to California Public Resources Code, Title Division 7.8 – Oil Spill Prevention and Response. A reference to another section of the CA Code was updated from (k) to (n). All the other changes were limited to changing the word ?which? to ?that?. So there?s that, apparently.

DOT Pipeline Compliance Workshop – Gas & Liquid

March 21 – 23, 2017

Join us March 21-23, 2017 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 PIPES Act of 2016; 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.

Florida Regulation Updates

On February 17, 2017 the State of Florida published an update to their gas pipeline regulations found in Division 25 Chapter 12. This update adopts and incorporates by reference the 49 CFR 191, 192 and 199 through the most recent version. Note the previously adopted version of the federal regulations was 2011. These changes are effective March 2, 2017. Additional changes to the regulations include:

  • 25-12.008 – Converted Facilities: minor word changing removing “significant” for the inspections that must be performed to ensure the pipeline is constructed with standards applicable at the time of installation. In addition rather than stating visual inspection “may” not be required if construction and testing records have been maintained, the regulation now states “will not.”
  • 25-12.022 – Requirements for Distribution System Valves:
    • Adds emergency valves to the valves that must be identified on drawings or maps. In addition, it now allows the centerline of the road or highway, property line or right-of-way to be used as one of the referenced structures. In addition, the marking requirements of buried valves or valves operated by a key wrench were clarified.
    • Adds emergency valves to the sectionalizing valves that must be inspected and maintained annually.
  • 25-12.027 – Welder Qualification: Updates the reference for API Standard 1104 that may be used for Welder Qualification.
  • 25-12.0400 Leak Surveys, Procedures and Classification:
    • Leak Surveys – Clarifies the required inspection intervals for conducting gas detector instrument surveys to locate leaks in areas not required to have annual leak surveys.
    • Leak Classification ? Requires operators to immediately repair Grade 1 Leaks to protect life and property.
    • Adds a requirement to monthly monitor and inspect areas where residual gas is detected on follow-up inspections until gas is no longer detected.
  • 25-12.085 ? Written Annual Reports Required: Updates references to completing PHMSA annual reports for distribution and transmission systems.

Pennsylvania Senate Bill 242 Amending the Underground Utility Line Protection Law

Pennsylvania General Assembly introduced Senate Bill 242 into committee on January 26, 2017. The bill seeks to amend the Underground Utility Line Protection Law of December 10, 1974 (P.L.852, No.287) by further defining the duties of facility owners, the One Call system, excavators, designers, and project owners. The bill also provides further definition of penalties, enforcement, and compliance, and provides for a underground utility line protection fund and the authority of the One Call System.

ASME B31Q Pipeline Personnel Qualification

The ASME B31Q Pipeline Personnel Qualification Standard (part of the ASME B31 suite of pipeline standards) establishes the requirements for developing and implementing an effective Pipeline Personnel Qualification Program. The technical standards committee met in February to continue work on updates for the 2018 edition. Additionally, the committee discussed a variety of other operator qualification topics including security of operator testing and natural gas storage operator qualification (for the 2020 edition).

The committee is also starting to consider the potential impacts of any future rulemakings related to the PHMSA NPRM – Accident Notification-OQ June 2015 [Docket No. PHMSA-2013-0163]. (See related article in the DOT Pipeline Compliance News July 2015 edition .) The technical committee meets again in April to continue work on the 2018 edition updates.

Operators Encouraged to Register for Public Awareness Study

Registration is now open for the 2017 Public Awareness Program Effectiveness Research Study (PAPERS). PAPERS is a national public awareness effectiveness survey developed and sponsored by API, AOPL and INGAA to assist pipeline operators in meeting the regulatory requirements for effectiveness measurement and evaluation of public awareness programs. The deadline to register is May 31st. Pipeline operators are encouraged to register and participate in the study. More information on the 2017 PAPERS program , including a registration form, is available online and also by contacting API: Crystal Harrod by email at or by phone 202-682-8492; or Karen Simon by email at or by phone 202-682-8224.

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.

PRCI Program Manager Job Posting


The Pipeline Research Council International (PRCI) is seeking qualified applicants for the position of Program Manager, Integrity & Inspection. The Program Manager is responsible for the day-to-day management of PRCI research contracts and plays a number of key roles, including to facilitate the participation of PRCI member company technical representatives in the planning, implementation and management of the PRCI research program. The program is comprised of a large set of individual research projects that span a range of pipeline design, operation and integrity management issues. The Program Manager works closely with research contractors, member company representatives and other PRCI staff, and reports directly to the PRCI Vice-President, Operations. The position is located at the PRCI Technology Development Center in Houston, Texas. Excellent communication skills, the ability to work in a collaborative environment, a working knowledge of current pipeline integrity management issues and being a self-starter are key requirements of the position. Click here for the full job posting. Please send a resume and a brief letter of interest, via email, to Mike Whelan at Additional information about PRCI can be found at .

Washington UTC Director of Pipeline Safety Position

The Washington Utilities and Transportation Commission (UTC) is seeking an experienced individual to lead its pipeline safety program that enhances public safety through compliance inspections, technical assistance to local governments and pipeline operators, public education, and enforcement. Alan Rathbun, current Director of Pipeline Safety, plans to retire in May. For more information on the position and how to apply click here to be redirected to the UTC website.

2017 Pipeline Conference Schedule

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

AGA Pipeline Safety Management Systems Workshop
April 12 – 13
Omni Jacksonville, Florida

This workshop will feature presentations and case studies from pipeline operators, regulators, and service providers. Presentations will focus on information about pipeline safety management systems and their implementation. Regulators, pipeline operators, and service providers are all invited to participate in this forum. RCP’s President, Bill Byrd, will be speaking on:

  • Implementation Solutions: Bill will review tools and methods available to track progress for Pipeline Safety Management Systems deployment and effectiveness.

API Pipeline Conference and Control Room Forum
April 25 – 27, 2017
Hyatt Regency Hill Country, San Antonio, TX

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. Once again, RCP is a proud sponsor of this event and we look forward to seeing you there. The Pipeline Conference is followed by a Control Room Forum and a Leak Detection Forum which will run simultaneously (Wednesday afternoon through Thursday noon). The Leak Detection Workshop is the first of its kind, and will be a great opportunity for leak detection personnel in member companies to learn more about implementing API RP 1175, Leak Detection Program Management. In addition to learning more about the document and how to put its guidance into practice, attendees will get to hear from 3 pipeline executives on their efforts to ensure their company has the right leak detection culture. PHMSA will give their input on what they would like to see from industry, as well as an update on the regulator’s R&D efforts related to leak detection. You can learn more about the Leak Detection Workshop, including viewing the preliminary program and registering, by visiting here.

AGA Operations Conference and 2017 Exhibition
May 2 -5, 2017
Gaylord Palms, Orlando, FL
Visit RCP Booth #1223 for a TestOp® Demo

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. Make plans to attend one of these sessions from RCP staff:

  • “Underground Natural Gas Storage Risk Assessment Process – An Implementation Tool for API RP 1171” presented by Rick Gentges.
  • “Assessment of MAOP Validation and the NPRM” presented by Michael Berg.

ILTA’s 2017 International Operating Conference & Trade Show
June 12-14, 2017
George R. Brown Convention Center in Houston, Texas

The International Liquid Terminals Association (ILTA) annual international operating conference and trade show offers unparalleled opportunities for terminal professionals. It brings together more than 4,000 people from across the U.S. and around the world to learn, network, and share best practices. The conference features in-depth presentations by industry experts who provide insight on effective solutions for improving terminal operations. The trade show offers the latest in products, services and technologies that terminals need to stay competitive.

Make plans to attend and visit RCP’s Booth #481 to learn how TaskOp® can keep your terminal on track. TaskOp is a web-based, modular system, capable of handling implementations from basic work orders through complex, asset-driven compliance and training management solutions.

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

Best regards,

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