DOT Pipeline Compliance News

March 2019 Issue

In This Issue

PHMSA Grants Compliance Deadline Extension for the Recent Plastic Pipeline Rule

On November 20, 2018, PHMSA issued a final rule that amended the federal pipeline safety requirements for the design, construction, and maintenance of plastic piping systems used in the transportation of natural or other gas (83 FR 58694). Subsequently, the American Gas Association (AGA) submitted a Petition for Reconsideration, requesting that PHMSA extend the compliance deadline for certain regulations and exempt mechanical fittings with nominal pipe sizes of 4 inches or greater from 49 CFR 2.281(e)(4). 

AGA requested an additional 90 days to implement training and operator qualification programs and work with equipment suppliers, and an additional six months to comply with certain provisions that require the development of new programs.  PHMSA notified AGA that the compliance deadlines suggested in the Petition are appropriate and do not compromise safety.

AGA also raised specific concerns about the category 1 requirements for larger diameter mechanical joints between plastic and metallic pipe and the applicability of § 192.281(e)(4).  PHMSA will delay the compliance deadline for category 1 requirements in § 192.281(e)(4) for joints between metallic and plastic pipe with a nominal pipe size of 4 inches or greater, until January 22, 2020.

For a copy of the AGA petition or PHMSA’s response, click here.

California OSFM Title 19 Notice of Proposed Rulemaking


The California Office of the State Fire Marshall (OSFM) has published a Notice of Proposed Rulemaking (NPRM) for the adoption of regulations/requirements for pipelines near environmentally and ecologically sensitive areas. The primary objective of the proposed regulations is to protect these areas and state waters and wildlife by reducing the volume of hazardous liquid released in the event of a spill using best available technology (BAT). The proposed regulations identified for adoption include approximately twenty (20) new sections.

OSFM predicts the proposed regulations will cover approximately 600 miles of California’s intrastate pipelines and cost operators approximately $220 million over the next three years. The proposed regulations will require pipelines that operate in the coastal zone to use BAT for existing as well as new and replacement pipelines. The draft regulations attempt to define several key terms and outline processes to implement the BAT requirements.

BAT is defined as the “technology that provides the greatest degree of protection by limiting the quantity of oil released in a spill” and must consider processes used or available for purchase anywhere in the world.  Pipeline operators are tasked with reviewing available processes and equipment and proposing BAT for their pipelines. The operators must consider leak detection technology, automatic shutoff systems, and/or remote controlled sectionalized block valves. OSFM will review proposals submitted by the operators and determine whether the proposal meets BAT requirements. The proposed regulations outline factors OSFM will consider including feasibility and site-specific conditions. The regulations would require operators of all existing pipelines to submit a risk analysis and an initial BAT implementation plan by July 2020.

Submit written comments to by April 2, 2019, 5:00 p.m. Pacific time.

Include in the subject line of the email:  Comments – Pipeline Safety-New Technologies, T19, Division 1.

Additional information regarding this NPRM can be found on the OSFM website, or contact Jessica Foley for a copy of the proposed regulations.

API RP 1160 Pipeline Integrity Management Standard for Hazardous Liquid Pipelines

API released the third edition of API RP 1160: Managing System Integrity for Hazardous Liquid Pipelines. The third edition of RP 1160 incorporates recent industry experiences surrounding pipeline mechanics, while embracing a proactive approach to pipeline safety management. This standard will assist pipeline operators in building safe, contemporary, and comprehensive integrity management systems

RP 1160 also provides a process for establishing safe pipeline operations, including assessments of potential risks and the establishment of systems to safely and effectively manage day-to-day operations. The document contains references to leading industry publications, such as pipeline leak detection (API RP 1175), assessment and management of cracking in pipelines (API RP 1176), integrity data management and integration (API RP 1178), and hydrotechnical hazards for pipelines located onshore or within coastal areas (API RP 1133).

RP 1160 is available at the API Publications Store website.  For questions, contact John Buflod at

API Pipeline Conference – PHMSA Administrator Speaker Confirmed

PHMSA Administrator Howard “Skip” Elliott will be the luncheon speaker on Tuesday, April 9 at the 2019 API Pipeline Conference. Elliott joined PHMSA following his retirement from CSX Transportation in Jacksonville, FL, where he served as Vice President of Public Safety, Health, Environment, and Security. Elliott’s portfolio at CSX included hazardous materials, transportation safety, homeland security, railroad policing, crisis management, environmental compliance and operations, occupational health management, and continuity of business operations.

PHMSA GPAC Meeting Status – Rescheduled for June

[Docket No. PHMSA-2016-0136]

The Gas Pipeline Advisory Committee (GPAC) meeting originally planned for January 2019 has been rescheduled for June 25th and 26th.  (See related article in the January 2019 edition of the DOT Pipeline Compliance News). The agenda for the meeting is the Gas Gathering NPRM.  This meeting will be Webcast. The Joint PAC meeting will be rescheduled for a later date. For more information and updates on the rescheduled meeting dates and registration, go to the meeting page.

PHMSA Public Awareness/Engagement Workshop Rescheduled!

The PHMSA Public Awareness and Engagement Workshop that was originally scheduled for March 13-14 has been rescheduled. The tentative date for the workshop is June 12-13, 2019 at the DOT HQ Building in Washington, DC. Save the dates if you are interested in attending, or participating via webcast. More information will be posted as it becomes available.

2019 Industry 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!

API Pipeline Conference and Control Room Forum
April 9-11, 2019
Pointe Hilton Tapatio Cliffs Hotel, Phoenix, AZ

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.

AGA Operations Conference and Biennial Exhibition & Spring Committee Meetings
April 29-May 3, 2019
Gaylord Opryland, Nashville, TN
RCP Booth #1303 / Be our Guest and Click Here for a Free Exhibit Hall Pass.

Complimentary Customer Day Passes

Complimentary exhibit hall passes are free and authorize a passholder admission to the exhibit hall.  The free admission exhibit hall passes authorize a passholder admission to the exhibit hall on Wednesday, May 1 from 12:30 pm to 5:30 pm (no exceptions to admittance times). Use the Click Here link above to request a Free Exhibit Hall Pass. RCP can help you meet your integrity and compliance requirements. Stop by booth #1303 where we can walk through any of our services and software solutions

Mark your calendar and plan to attend one of these sessions from RCP Staff:

W. R. “Bill” Byrd, RCP President
Thursday, May 2nd, 10:55 – 11:35
Track C5: Quality Management/Construction Operations/Integrity Management
“Management Systems and Goldilocks: How Much Process Rigor Is Just Right for Your PSMS?”

Sheri Baucom, RCP Director of Integrity Services
Thursday, May 2nd, 3:55 – 4:35
Track D2: Engineering/Customer Field Services & Measurement
Pressure Testing Objectives and Acceptance Criteria”

Sheri Baucom, RCP Director of Integrity Services
Friday, May 3rd, 8:30 – 9:10
Track E2: Integrity Management
ILI Data – Closing the Loop”

RCP Workshops – Which one should I attend?

Introduction to DOT Pipeline Regulations
The DOT pipeline workshop covers federal regulatory requirements and their applicability to both hazardous liquid and natural gas gathering, transmission, and distribution pipeline operators.

It is appropriate for people who are new to pipeline regulations, need a refresher course or better understanding of current and pending DOT rule makings as well as how they are applied to their job or their group, including operational, supervisory, and managerial personnel.

Fundamentals of Energy Transmission Pipelines (FETP)
The Fundamentals of Energy Transmission workshop provides participants an overview of how transmission pipelines operate and walks them through the practical things that a typical pipeline company does on a regular basis to operate and maintain the pipeline system as a whole.

It is appropriate for both technical and non-technical personnel who are new to the transmission pipeline industry, as well as those who need a broader understanding of the pipeline operations and management such as new hires, managers and executives from outside the pipeline industry, including attorneys, and business development professionals.

The table below gives some examples of the differences between these courses:

Introduction to DOT PL RegulationsFundamentals of Energy Transmission Pipelines
What are the regulatory requirements for energy transmission pipelines?Why do we have energy transmission pipelines?

How do they make money?

What do the operations and engineering people do in our company, and why?
What are the inspection requirements for a mainline valve?What are the different types of valves? When is each type used?
How are breakout tanks defined?What are the different types of tanks? When is each type used?
What is the definition of line pipe?How is pipe made? What are the important differences?
What are the requirements for integrity management?Why are we doing integrity management?
What are the procedure requirements for pumps and compressors?What are the various types of pumps and compressors, and how do they differ?

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.

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


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