DOT Pipeline Compliance News

May 2012 Issue

In This Issue

PHMSA Advisory Bulletin ADB-2012-06 MAOP MOP Records Verification

[Docket No. PHMSA-2012-0068]

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) issued Advisory Bulletin ADB 2012-06 to remind operators of gas and hazardous liquid pipeline facilities to verify their records relating to operating specifications for maximum allowable operating pressure (MAOP) required by 49 CFR 192.517 and maximum operating pressure (MOP) required by 49 CFR 195.310. ADB 2012-06 informs gas operators of:

  • anticipated changes in annual reporting requirements to document the confirmation of MAOP,
  • how they will be required to report total mileage, and mileage with adequate records,
  • when they must report, and
  • what PHMSA considers an adequate record.

In addition, this Advisory Bulletin informs hazardous liquid operators of adequate records for the confirmation of MOP.

This advisory will have a major impact to both gas and liquid pipelines. As you may recall, last year, PHMSA issued Advisory Bulletin 11-01 reminding operators that if they are relying on the review of design, construction, inspection, testing and other related data to establish MAOP and MOP, they must ensure that the records used are reliable, traceable, verifiable, and complete. (See related article in the January 2011 Edition of the DOT Pipeline Compliance News.) ADB 2012-06 provides definitions for these terms (traceable, verifiable, and complete) and states that Operators should ensure all records establish confidence in the validity of the records. If a document and records search, review, and verification cannot be satisfactorily completed to meet the need for traceable, verifiable, and complete records, the operator may need to conduct other activities such as in-situ examination, measuring yield and tensile strength, pressure testing, and nondestructive testing or otherwise verify the characteristics of the pipeline to support a MAOP or MOP determination.

PHMSA will require each owner or operator of a gas transmission pipeline and associated facilities to verify that their records confirm MAOP of their pipelines within Class 3 and Class 4 locations and in Class 1 and Class 2 locations in HCAs.

PHMSA intends to require gas pipeline operators to submit data regarding mileage of pipelines with verifiable records and mileage of pipelines without records in the annual reporting cycle for 2013, via the Gas Transmission and Gathering Systems Annual Report.

ADB 2012-06 also notes PHMSA’s intent to amend 192.619(a)(3), the MAOP grandfather clause, after receiving operator data submitted for the year 2012.

For a copy of ADB-2012-06, or for help in addressing these issues, contact Jessica Roger.

DOT Pipeline Compliance Workshop – May 15, 16 & 17, 2012

Join us May 15, 16 & 17 in Houston at our new office and dedicated training facility for an informative, lively, and interactive workshop on DOT Pipeline Compliance and OPA Planning for DOT Pipelines. This workshop has been attended by hundreds of pipeline personnel, with excellent feedback. The workshop provides an overview of the DOT pipeline regulations, and is appropriate for people who are new to pipeline regulations, who could use a refresher, or anyone who needs to know the latest information in these areas.


Day 1 (May 15): Gas Pipeline Regulations (49CFR192)
The workshop will include an introduction to DOT/OPS pipeline compliance; State and Federal program variations; roles and responsibilities; design, construction, operations, maintenance, and emergency response requirements; how to monitor rulemaking activity and stay current with your compliance program; operator qualification, public awareness; with a specific emphasis on the gas integrity management regulations. Each attendee will receive general training materials which include the applicable DOT 49 CFR 192 regulations for gas pipelines (cd-rom), inspection checklists, and speaker’s PowerPoint presentation handouts.

Day 2 (May 16): Special Topics
Back by popular demand! RCP is conducting a special workshop day to discuss topics that many of our clients have expressed an interest in. The workshop topics will include a detailed review of the recently enacted Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 (pipeline reauthorization bill), recent Advisory Bulletins from PHMSA, and new, pending and proposed rulemakings.

Day 3 (May 17): Liquid Pipeline Regulations (49CFR195)
The workshop will include an introduction to DOT/OPS pipeline compliance; State and Federal program variations, roles and responsibilities; design, construction, operations, maintenance, and emergency response requirements; spill response planning requirements; how to monitor rulemaking activity and stay current with your compliance program; operator qualification and public awareness. Each attendee will receive general training materials which include the applicable DOT 49 CFR 195 regulations for hazardous liquid pipelines (cd-rom), inspection checklists, and speaker’s PowerPoint presentation handouts.

To register, or for additional information, click here.

Engineering Ethics Course

May 31, 2012 – Houston, TX

In support of the TBPE Outreach Program, RCP is hosting an engineering ethics course in our offices on May 31, conducted by the Texas Board of Professional Engineers. Mr. Charles Pennington, P.E., Engineer Specialist with the Board, will be the guest speaker for a presentation on, “Texas Board of Professional Engineers – Professional Practice Update / Ethics: Updates on Board rule changes within the last year, general updates on initiatives the Board is working on, information on enforcement statistics, and the engineering Code of Conduct.”

Time: 11:30am-12:30pm CST
Location: 801 Louisiana Street, Suite 200 / Houston, TX 77002

The 1-hour course is free, but there is limited space. Please email Donna Williams or call (918) 518-5327 to register.

Introducing MaxOp*

RCP is extremely proud to announce the launch of a web-based version of our popular MAOP calculator model. Just like the model we built to conduct MAOP studies as a service, MaxOp* is the most comprehensive MAOP tool on the market. Through a secure web service, our customers can now push their MAOP data sets into RCP’s MaxOp* tool, link documentation to MAOP algorithm variables, dynamically segment their data, run MAOP calculations, identify potential discrepancies between the established and calculated MAOP values, and export calculated data sets and customizable reports back to their own native data sets. The tool will accept common pipeline database formats including Excel, PODS, APDM and others.

MAOP Validation Services

RCP has developed a turnkey process by which pipeline operating companies will have a traceable, verifiable and complete MAOP dataset. It starts with our MAOP document review services where RCP conducts detailed reviews of relevant MAOP documents, extracts the necessary data onto our MaxOp* cover sheets and posts the data into the database for future dynamic segmentation and calculation. For each document, a MaxOp* cover sheet is attached and re-filed, awaiting digitization by the market leading document management services company, Iron Mountain. Once these documents are scanned and posted, MaxOp* will retain a permanent link from the data set to the document image. Finally, once the document review is complete, MaxOp* will dynamically segment any spatially related data and run the MAOP calculations. The resulting values and data sets can then be exported to our customer’s in-house pipeline data set (ex. Excel, PODS, APDM, other). At the completion of this effort, the basis for an MAOP management of change has been established and our customers can be confident that their MAOP values are capable of being traced back to source documentation, the calculated values have been validated with the most comprehensive calculator tool on the market, and the MAOP values have been completely evaluated and any potential deficiencies identified.

For more information about RCP’s MAOP services or the MaxOp* calculator, please contact Jessica Roger.

* MaxOp is a US Trademark and property of RCP Inc

Revised PHMSA Reporting Requirements – Notice and Request for Comments

[Docket No. PHMSA–2012–0024]

PHMSA plans to make several minor revisions to the hazardous liquid pipeline systems accident report and the gas transmission and gathering pipeline systems incident report. In addition, PHMSA is considering a number of revisions to the annual report form for gas transmission and gathering pipeline systems.

Incident and Accident Report Revisions:

PHMSA is revising the gas transmission and gathering pipeline systems incident report (PHMSA F 7100.2, gas transmission incident report) and hazardous liquid pipeline systems accident report (PHMSA F 7000-1, hazardous liquid accident report) to collect additional information relative to incidents involving girth welds. The revisions to these forms will allow for the reporting of detailed information regarding the pipe involved with the weld. This information includes basic information such as pipe size, diameter, and thickness. Several other minor changes are being made to align the form with the online system used to collect the reports from pipeline operators. The gas transmission incident report is approved under OMB control number 2137-0522 and the hazardous liquid accident report is approved under OMB control number 2137-0047. PHMSA does not anticipate any change to the burden of the information collection due to the proposed revision of these forms.

Gas Transmission and Gathering Pipeline Systems Annual Report Revisions:

On September 26, 2011, the National Transportation Safety Board issued recommendations to PHMSA regarding improvements in pipeline safety. These recommendations include requiring that all gas transmission pipelines installed before 1970 be subjected to pressure testing, that manufacturing- and construction-related defects only be considered stable if a gas pipeline has been subjected to a post-construction hydrostatic test of at least 1.25 times the maximum allowable operating pressure (MAOP), and that all gas transmission pipelines be able to accommodate in-line inspection tools. On January 3, 2012, President Obama signed the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 which requires that PHMSA:

  • Issue a regulation for the testing of previously untested gas transmission pipelines located in high consequence areas (HCAs) and operating at a pressure greater than 30 percent of specified minimum yield strength;
  • Require each owner or operator to verify that their records accurately reflect the physical and operational characteristics of their pipelines and associated facilities within Class 3 and 4 locations and Class 1 and 2 HCAs; and
  • Require each owner or operator to identify and submit documentation relating to each pipeline segment for which records are insufficient to confirm the established MAOP.

PHMSA intends to revise the gas transmission and gathering pipeline systems annual report (PHMSA F 7100.2-1, gas transmission annual report) to provide a mechanism for owners and operators to identify those segments of pipelines for which it is unable to verify the MAOP. For the purpose of reporting, “verification records” are records that can be used to validate the MAOP for the subject pipelines such as as-built drawings, alignment sheets, specifications, and design, construction, inspection, testing, maintenance, manufacturer, or other related documents. These records should be traceable, verifiable, and complete. The purpose of this verification is to ensure that the records accurately reflect the physical and operational characteristics of the pipelines. In an upcoming Advisory Bulletin, PHMSA will inform operators of their responsibilities to verify that their records accurately reflect the physical and operational characteristics of their pipelines and associated facilities. In addition, the Advisory Bulletin will further clarify what PHMSA considers to be a “verifiable” record.

PHMSA also intends to revise the gas transmission annual report to collect other information related to the NTSB Recommendations and the recently signed legislation detailed above. In addition to the MAOP verification reporting, these revisions will allow for the collection of information regarding the methodology used to determine the MAOP of gas transmission pipelines, the total miles of pipelines which have not been subjected to a post-construction hydrostatic pressure test of at least 125% of the MAOP, and total miles of pipelines which are not able to accommodate the passage of instrumented internal inspection devices. PHMSA is also revising the gas transmission annual report to improve the granularity of the data, remove sections of limited value, collect data about anomalies removed from gas transmission pipeline systems, and make several minor changes to improve the quality of the data. Background for these topics is as follows:

  • Pipeline Material Reporting by State: Pipeline mileage by material type was collected state-by-state prior to 2010. This data allowed PHMSA to determine the amounts and types of pipeline materials used in each state. The proposed change would restore this granularity which was lost during the 2010 revision to the gas transmission annual report. Parts D and E of the gas transmission annual report are used to collect information regarding pipeline material type. PHMSA proposes to collect this information in the state-specific section of the report and to combine Parts D and E of the report into a single table. This change will not impact the burden of the information collection.
  • Additional Commodities: In the current gas transmission annual report, operators have the ability to report “other” as the commodity transported and then enter text describing the commodity. Based on a review of 2010 data, many operators submitted text equivalent to landfill gas to describe the “other” commodity. PHMSA proposes to add landfill gas as a commodity choice to reduce the mileage reported under the “other” category. This change will not impact the burden of the information collection.
  • Additional Material Type: PHMSA recognizes that composite pipe materials are currently being used, or considered for use, by the pipeline industry. Outside of reinforced thermosetting plastic, in certain and limited use, composite pipe can only be used if PHMSA issues a special permit. In an effort to determine the amount of composite pipe currently in use, PHMSA proposes to add “composite pipe” as a material type to Parts D and N of the gas transmission annual report. This change will not impact the burden of the information collection.
  • Removal of Sections A6 and A8: Section A6 in the gas transmission annual report allows each submitter to characterize the facilities covered by their Operator Identification (OPID) and commodity group with respect to whether they are included in an integrity management program subject to 49 CFR part 192. Section A8 allowed submitters to identify whether or not there were any changes from the previous year’s filing. PHMSA has determined that these sections provide limited value to all stakeholders and should be removed. This change will not impact the burden of the information collection.
  • Anomalies Removed from Gas Transmission Systems: The gas transmission annual report currently collects information about the number of anomalies repaired in response to integrity assessments. During data quality checks of the 2010 data, PHMSA learned that many anomalies are eliminated from gas transmission systems by pipe replacement or abandonment. This data helps to demonstrate the benefits of integrity management programs. Therefore, PHMSA proposes to revise the gas transmission annual report to collect the number of anomalous conditions eliminated by pipe replacement and abandonment in Part F of the report.

Interested persons are invited to submit comments on or before June 12, 2012 [Docket No. PHMSA-2012-0024]. Comments are invited on:

a) The need for the proposed collection of information for the proper performance of the functions of the agency, including whether the information will have practical utility;
b) The accuracy of the agency’s estimate of the burden of the proposed collection of information, including the validity of the methodology and assumptions used;
c) Ways to enhance the quality, utility, and clarity of the information to be collected; and
d) Ways to minimize the burden of the collection of information on those who are to respond, including the use of appropriate automated, electronic, mechanical, or other technological collection techniques.

For further information contact: Cameron Satterthwaite, 202-366-1319, DOT, PHMSA, 1200 New Jersey Avenue SE., PHP-30, Washington, DC 20590-0001.

Nebraska Major Oil Pipeline Act

The state of Nebraska has recently passed an act regulating “major oil pipelines.” As defined by the act: “Major oil pipeline means a pipeline which is larger than six inches in inside diameter and which is constructed in Nebraska for the transportation of petroleum, or petroleum components, products, or wastes, including crude oil or any fraction of crude oil, within, through, or across Nebraska, but does not include in-field and gathering lines or any major oil pipeline that has submitted an application to the United States Department of State pursuant to Executive Order 13337 prior to the effective date of this act.” The act requires various submittals and approvals for construction and siting of major oil pipelines.

For a copy of the act, please contact Jessica Roger.

Changes to New Mexico Pipeline Regulations March 2012

The New Mexico Public Regulation Commission updated their regulations (18.60.2 and 8) concerning pipeline operations and maintenance in March. These updates affected many parts of the regulations including the following:

  • Variances to the adopted federal regulations including reporting and items required for gathering pipelines. (
  • Items incorporated by reference and terms in the federal regulations (
  • Definitions (
  • Registry of nonmember Underground Facility Operators (UFOs) (
  • Responsibilities of UFOs (
  • Procedures for locate requests (
  • Requirements for marking excavation sites (
  • Excavation procedures (
  • Emergency excavation provisions, to include damage reporting (
  • Requirements for reports of third party damage (

Damage Prevention Plans

RCP can develop or update your Damage Prevention plan. For more information about how RCP can assist you with your Damage Prevention Plan, click here.

Louisiana Dig Law Has Changed

Late last year Governor Jindal signed into law significant changes in the Louisiana Underground Utilities and Facilities Damage Prevention Act R.S. 40:1749, otherwise known as the state’s “dig law.” These changes affect everyone involved in excavation in Louisiana, including homeowners, contractors and utility operators.

Waiting Period Changed
Under the revised statute, utilities, pipelines and other operators will have a little more time to mark their underground facilities. The waiting period is now two full business days beginning at 7 a.m. on the next working day after the excavator files their request to have the site marked.

Emergency Excavations Redefined

The revised law now defines emergencies more strictly. The new definition requires that excavators who declare an emergency must have a crew on site when an emergency is declared, and provides for penalties up to $5,000 for repeated violations of this requirement.

Markings Valid Longer
Once the site is marked, the markings are considered valid so long as they are visible for up to 20 calendar days on non-agricultural sites, doubling the time allowed before such sites must be marked again. Farmers and other agricultural excavators get an additional 10 days and therefore need not request re-marking for 30 days so long as the marks remain visible.

More Time to Plan Large Jobs
Excavators working on large projects may now request utility location up to 20 days in advance.

Utility Operators May Elect Not to Receive Notifications
Finally, the new law will allow utility operators excavating near their own underground systems to elect not to receive notifications involving their own work.

The revised law can be reviewed here on the LA One Call 811 website, where links are provided to the original text on the Louisiana Legislature’s web site.

[Reprinted with permission. The original article appeared in the LA One Call 811 Newsletter, Vol. 6 No. 3, May 1, 2012.]

PHMSA Recruiting for a Compliance Officer Open Period from May 3 – May 14, 2012

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) will be recruiting for a Compliance Officer, reporting to the Director, Enforcement Division. This person will help develop PHMSA’s pipeline enforcement program; guide the risk-based application of pipeline safety regulations, technical consensus engineering standards and compliance practices by natural gas and hazardous liquid pipeline operators; work with Region Directors and the Office of Chief Counsel to ensure compliance with Federal pipeline safety regulations; and provide technical expertise in analyzing issues underlying policy and regulatory development, accident investigation and follow-up compliance actions.

For more information or to apply online, click on the links below:

US Citizen Position | Status Candidate Position

Those having questions about the position are welcome to call Rod Dyck, Director of the Enforcement Division, at 202-366-3844 or by e-mail at

Government/Industry Pipeline R&D Forum July 18-19 – Arlington, VA

The Pipeline and Hazardous Materials Safety Administration and the National Association of Pipeline Safety Representatives are pleased to announce the next Pipeline Research & Development Forum is this July! These events are held periodically to generate a National research agenda that will foster solutions for the many challenges with pipeline safety and with protecting the environment.

The forum allows public, government and industry pipeline stakeholders to develop a consensus on the technical gaps and challenges for future research. It also reduces duplication of programs, factors ongoing research efforts, leverages resources and broadens synergies. The national research agenda coming out of these events is aligned with the needs of the pipeline safety mission, makes use of the best available knowledge and expertise, and considers stakeholder perspectives. For more information on the forum visit the event page.

Summer / Fall Industry Conferences

Have you planned your summer agenda yet? RCP will have representatives attending these upcoming conferences. Mark your calendar and come join us!

TGA Operations & Management Conference
San Marcos, TX
June 10 – 13

LGA 191/192 & 195 Pipeline Safety Conference
New Orleans, LA
July 23 -27

SGA Operating Conference & Exhibits
Ft. Worth, TX
July 23 – 25

Western Region Gas Conference
Tempe, AZ
August 21 & 22

Oklahoma Gas Association Annual Conference & Expo
Norman, OK
August 27 – 29

International Pipeline Conference
Calgary, Canada
September 24 – 28

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