DOT Pipeline Compliance News

May 2016 Issue

In This Issue

National Safe Digging Month

April is National Safe Digging Month (NSDM) and the Common Ground Alliance (CGA) wants to hear about the creative ways that you will be spreading the word about the importance of calling 811 before digging. They’ve created several easy-to-use tools and templates to get you started:

However you’re spreading the 811 safety message this month, please be sure to email with information and photos as well as filling out this quick NSDM survey.

Updated PREP Guidelines Available for Comment

The U.S. Coast Guard (USCG) announced that the updated draft PREP Guidelines are available for public comment. In simple terms, the PREP guidelines lay out exercise and training requirements for companies that have oil spill response plans required by OPA-90 (including those required by PHMSA in 49 CFR 194). Below is a summary of the changes made to the revised update of the PREP Guidelines.

Definitions and Terminology: The NSCC has changed certain exercise-related terms in order to harmonize PREP with other national-level exercise programs. In particular, the term “Spill Management Team (SMT)” has been replaced by the term “Incident Management Team (IMT).” The term “Tabletop Exercise (TTX)” has been removed from the PREP terminology and will now simply be referred to as an exercise. For example, an SMT TTX will now be called an IMT exercise.

Salvage and Marine Firefighting (SMFF) Additions: The draft PREP Guidelines now include guidance for including SMFF providers and equipment into a plan holder’s exercise program, in response to regulatory requirements at 33 Code of Federal Regulations (CFR) 155.4052. These updates appear throughout the Guidelines in applicable sections.

NTV Additions: The PREP Guidelines now include guidance for exercises for NTV response plans, in response to regulatory requirements at 33 CFR 155.5060.

Use of Alternative Worst Case Discharges (WCD) Scenarios during IMT Exercises: The draft Guidelines have been revised to allow for alternative WCD scenarios to be exercised. Some Facilities and Complex Facilities have more than one possible WCD, for example a storage tank and a pipeline section. Such plan holders are encouraged to consider adverse environmental impacts and to exercise more than just their largest volume WCD scenario.

Exercise Frequency: The draft Guidelines have been updated to ensure consistency among NSCC agencies regarding the frequency of equipment deployment exercises. In particular, the frequency of deployment exercises for equipment that is owned by the facility, operated by Oil Spill Removal Organizations (OSROs), and listed in EPA-regulated plans has been changed from annually to semi-annually. This change will ensure the readiness of equipment that is not regularly used in actual spill response operations.

Oil Spill Surveillance and Tracking Systems: USCG and BSEE regulations require plan holders to ensure available resources for oil spill surveillance and tracking. The PREP Guidelines establish a list of the types of equipment to be exercised during internal deployment exercises. This latest version of the Guidelines specifically identifies oil spill surveillance and tracking systems as a type of response equipment to be exercised during internal equipment deployment exercises in order to test the plan holders abilities to effectively support and direct other response activities and equipment, such as the use of dispersants, in-situ burning, mechanical recovery, shoreline protection, or wildlife recovery.

Area-level Exercise Cycle: The exercise frequency for Area-level exercises has been changed from three to four years. This change applies only to the Area-level exercise cycle and does not change an industry plan holder’s exercise cycle as recommended in the draft PREP Guidelines, nor does it change the frequency of any industry plan holder exercises required by any oil spill planning regulations.

Although this document responds to comments received in the BSEE docket BSEE-2014-0003, all further comments should be directed to the docket USCG-2011-1178. Comments must reach USCG by April 28, 2015. You may submit comments and additional materials to docket number USCG-2011-1178.

For a copy of the latest proposed PREP guidelines, contact Jessica Foley.

Utah Gas Pipeline Regulations – Misc. Revisions

The state of Utah has revised its gas pipeline safety regulations in Title R746 – Public Service Commission: Administration; Rule 409 – Pipeline Safety and in Title 54 – Public Utilities; Chapter 13 – Natural Gas Pipeline Safety. It changes a previous requirement for operators to file their O&M manuals with the commission, and instead requires operators to provide them to the commission upon request. It also increases the civil penalty caps to $100,000 per violation and $1,000,000 for any related series of violations. It also adds a definition of “State Reportable Incident”, as follows (emphasis added):

means an event that falls within the definition of a federally reportable incident or a safety-related condition as identified in CRF Title 49, Part 191.23, Reporting safety-related conditions, or meets one or more of the following:

  1. Results in damage to any segment of:
    • steel main, twelve inches or greater in diameter, or
    • transmission pipeline;
  2. Requires removal from service or repair of any segment of:
    • steel main, twelve inches or greater in diameter, or
    • transmission pipeline;
  3. Results in property damage of $15,000 or more, including the loss to the operator and others, or both, but excluding the cost of gas that is lost;
  4. Results in the loss of gas service to ten or more customers; or
  5. Results in the known evacuation of any highly populated areas including commercial businesses, office buildings, eateries, schools, churches or public meeting places.

Note that these “state reportable incidents” would NOT require the release of gas in order to meet the reporting criteria.

RCP Adds 2 World-Class Experts to its Roster of Employees

RCP is proud to announce that 2 world-class experts have recently decided to join the RCP team.

Dwight Johnston: Executive-Level Management Systems Expert
Dwight is on the Board of the Center for Offshore Safety (COS), which assists offshore operators in the development and execution of Safety and Environmental Management Systems (SEMS), and Chairperson of new Ocean Energy Safety Institute (OESI), a group of leaders from industry, academia and regulators, which conducts research and shares best practices around all aspects of safety, environmental and risk management systems. He is also a long time member of the Mary Kay O’Connor Process Safety Center at Texas A&M University. Dwight’s expertise includes all aspects of successful development and implementation of Safety Management Systems and operational excellence improvements. Dwight’s expertise in Process Safety Management Systems (PSMS) can help our clients with PSMS development and implementation to meet API’s Recommended Practice 1173.

Richard (Rick) Gentges: Underground Storage Expert
Rick has expertise in the design, construction, and operation of underground natural gas storage facilities. He chaired both the AGA and PRCI committees on underground gas storage, and was a member of the National Petroleum Council Underground Storage Team. During his career he managed construction projects that involved enhancements to existing gas storage facilities and construction of new gas storage facilities, including construction of the first commercial underground gas storage facility in Alaska. His technical experience includes performing and analyzing well tests, reservoir performance analysis, reservoir simulation, and overall storage facility optimization. Rick’s experience and knowledge will be an asset to pipeline operators with their integrity management challenges with the recent changes concerning underground storage facilities.

We look forward to Dwight and Rick’s valuable contributions to RCP and our clients.

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.

Public Workshop on Liquefied Natural Gas Regulations

[DOCKET NO. PHMSA-2016-0005]

PHMSA is co-sponsoring a two-day Liquefied Natural Gas (LNG) Workshop with the National Association of Pipeline Safety Representatives on May 18-19, 2016 at the U.S. Department of Transportation (DOT), 1200 New Jersey Avenue SE, Washington, DC 20590. This workshop will bring federal and state regulators, emergency responders, NFPA 59A technical committee members, industry, and interested members of the public together to participate in shaping future modifications to 49 CFR part 193, Liquefied Natural Gas Facilities. PHMSA will also describe requirements for transporting LNG in commerce by rail, highway, and waterway, as authorized in the Federal Hazardous Materials Regulations in 49 CFR parts 100-185.

Name badge pick up and on-site registration will be available starting at 7:00 a.m., with the workshop taking place from 8:30 a.m. until approximately 4:30 p.m. eastern time in the atrium of the west building (New Jersey Avenue entrance, across the street from the Navy Yard Metro station). Attendees should arrive early to allow for time to go through security. Click here for directions to the DOT.

Members of the public may attend this free workshop. To help assure that adequate space is provided, attendees, both in person and by webcast, should register in advance at the PHMSA public meeting Website.Onsite registration will also be available for those attending in person. Refer to the meeting Web site for the latest information about the meeting including agenda and the webcast. Presentations and a recording of proceedings will be available within 30 days after the event.

Please be sure all representatives who plan to attend are registered. If you do not register for this meeting in advance, your entrance into the building may be delayed due to security processing. To enter the facility, all U.S. citizen visitors must have a valid U.S. or state government issued photo identification (driver’s license, passport, etc.). If you do not have valid photo identification, you will not be permitted to enter the facility. DOT is a secure U.S. Government building. All visitors and any items brought into the facility will be required to go through security screening each time they enter the building. NOTE: Screening luggage takes additional time at the entry checkpoint. If possible, please avoid bringing luggage.

If you are a non-U.S. citizen/foreign national and will be attending the meeting in person, please contact or 202-366-2392 to provide the following information: full name, official title or position, date of birth, country of citizenship, passport number or diplomatic identification number, and passport expiration date. Guest information is required at least five business days in advance of the meeting.

For further information contact: Julie Halliday, Engineering and Research Division, at 202-366-0287 or

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.

PHMSA Public Awareness Workshop


We’ve heard through the grapevine that PHMSA is planning to conduct a workshop on Public Awareness programs in Houston on Wednesday, May 25th, in the Galleria area. Be on the lookout for additional information, and start working on your shopping list if you are interested. Registration details will probably be posted on the PHMSA Public Meeting Website.

PHMSA Incident and Annual Data Analysis

RCP has designed a Pipeline Database Query tool, PDQ™, which researches gas transmission, gas distribution, or hazardous liquid pipelines based on PHMSA accident or infrastructure data. Have you ever wondered: How does your company stack up against your peers in accident rates? How do you weigh the risk based on the materials and age of your pipeline against industry trends? PDQ™ can answer these questions and more. For more information, contact Jessica Foley.

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.