DOT Pipeline Compliance News

November 2012 Issue

In This Issue

PHMSA ADB 2012-09 Pipeline Safety: Communication During Emergency Situations

[Docket No. PHMSA–2012–0201]

PHMSA issued Advisory Bulletin ADB 2012-09 to remind operators of gas, hazardous liquid, and liquefied natural gas pipeline facilities that operators should immediately and directly notify the Public Safety Access Point (PSAP) that serves the communities and jurisdictions in which those pipelines are located when there are indications of a pipeline facility emergency. Furthermore, operators should have the ability to immediately contact PSAP(s) along their pipeline routes if there is an indication of a pipeline facility emergency to determine if the PSAP has information which may help the operator confirm an emergency or to provide assistance and information to public safety personnel who may be responding to the event.

For a copy of ADB 2012-09, contact Jessica Roger.

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

PHMSA Soliciting New Pipeline Safety Research

[RA# DTPH56-13-RA-000001]

October 10, 2012 – PHMSA announced its latest round of solicited research topics that are targeting a wide range of challenges identified from the July 2012 R&D Forum. These topics are covering technology development and the generation of new knowledge in the areas of Threat Prevention, Leak Detection, Anomaly Detection/Characterization, Anomaly Repair and Remediation and in Design/Materials/Welding/Joining/Valves. PHMSA anticipates a $10M base investment to fund awards in these topic areas. Please find more information on PHMSA’s R&D Program website.

Gas Pipeline DIMP Regulations in New York – Proposed Rule Making

[I.D No. PSC-42-12-00006-P]

The New York Public Service Commission has proposed a consensus rule making to revise Chapter III, Gas Utilities, Subchapter C, Safety, Part 255, Transmission and Distribution of Gas; by adding Sections 255.1001, 255.1003, 255.1005, 255.1007, 255.1009, 255.1011, 255.1013 and 255.1015. The proposed rule will identify, and take measures to reduce, integrity risks to gas pipelines. It conforms the Commission’s regulations to federal regulations with which operators of gas distribution pipelines and small LPG operators must currently comply. The language of the proposed regulation differs from the Federal Regulation in minor part in:

  • The definition of “hazardous leak” which cross references the definition of that term with that which appears in other areas of Part 255 in order to maintain consistency.
  • The waiver process to recognize the authority and established procedures of the Public Service Commission.
  • Utilization of the One-Call Notification System as the “notification center” for increased efficiency because Local Distribution Companies are required to participate in that system.
  • The term “master meter” is removed because sub-metering is not recognized as a valid method of service.

Staff has discussed these proposed revisions with various stake holders. Based on communications with stakeholders, no person is likely to object to the adoption of the proposed rule as written. In accordance with the provisions of the State Administrative Procedure Act (SAPA) § 202(1)(b)(2)(i), this therefore, should be considered a consensus rule making. No hearing has been scheduled.

For a copy of the proposed rulemaking, contact Jessica Roger.

RCP’s Web-Based Compliance Management Systems

CP’s Compliance Management System (CMS) is an invaluable tool for managing all aspects of regulatory workflow. Some examples of how our clients are using the CMS include:

  • O&M Scheduling and Data Acquisition;
  • Cathodic Protection Inspection and Data Management;
  • One-Call Screening and Ticket Management;
  • Repair / Replacement Programs;
  • Operator Qualification Administration and Workflow Integration;
  • Leak Life Cycle Management;
  • Environmental, Health and Safety Compliance;
  • Audit Action Item Tracking; and
  • Customer Data Management.

DIMP Integration

For gas distribution operators looking for a powerful tool to implement DIMP, the RCP CMS integrates O&M data captured from field personnel along with inherent system attributes to provide real-time risk analysis, performance reporting, as well as track additional and accelerated actions taken to mitigate risks.

Key Features

  • GIS integrated workflow management
  • Custom tailored e-mail notifications and reporting
  • Runs on any web-enabled device, no software to download
  • Powerful reporting and custom query functionality
  • Multiple security and user privilege settings
  • Document storage and control (ex. procedures, maps, images, and completion documentation)
  • Automatic recurrence setting for routine tasks (example: leak surveys, CP surveys, etc.)
  • Create work orders for unscheduled / unplanned activities (ex. release reporting)

To request a demonstration or to request more information, please contact Jessica Roger.

New Mexico Pipeline Regulations Updates

On October 29, 2012 the pipelines regulations governing intrastate pipelines in New Mexico were revised to include the following:

  • Adoption of the definitions found in 49 CFR 193 and 194.
  • Requiring hazardous liquid operators to make telephonic notices to the pipeline safety bureau in accordance with 49 CFR Section 195.50 for accidents.
  • Requiring intrastate gas and hazardous liquid operators to submit annual reports, written incident / accident reports and safety related condition reports as prescribed in 49 CFR 191 and 195 to the transportation division director or his designee at PO Box 1269, Santa Fe, NM 87504-1269.
  • Established requirements for regulated intrastate gathering operators in
  • Interpretation of the following terms from federal regulation: “replaced service line”, “procedures for making safe any actual or potential hazard to life or property” and accidents or failures” in
  • Requiring hazardous liquid pipeline operators to provide notice of intent to construct to the Transportation Divisions Director in writing if total construction value is $50, 000 or more (already required for gas pipelines).

In addition to the general pipeline regulation updates, the requirements for handling emergency excavation and damage reporting were updated. Underground Facility Operators (UFO) must retain records of underground facility damage information for 5 years in addition to locate requests and excavation notices. If an UFO utilizes contractors to perform damage investigation, the UFO is responsible for compliance with excavation rules.

Excavators are encouraged to make a locate request for excavation projects that involve purely non-mechanical means.

In every incorporated area, or when an excavation site cannot be clearly and adequately identified on the locate ticket, the excavator shall pre-mark the actual intended excavation route or site(s) in that area in accordance with American Public Works Association (APWA) marking guidelines to communicate to facility owners where the actual excavation will take place for standard ten (10) working day ticket requests only. All locate requests shall include, if available, an alternate contact name and their contact information for the excavator. Incomplete line locate requests may be held in suspension until complete by the one-call notification system.

Excavators are no longer required to contact non-member UFOs to request wide area locate conferences.

The requirements for marking excavation sites were also updated. Prior to these updates, excavators were encouraged to mark all proposed excavation sites in accordance with APWA standards; now, these markings are mandatory. When accessing penalties for damage, the commission may consider how well the proposed site was marked. UFOs may either write “clear” or “non underground facilities” with their name at the site in the appropriate color or may contact the notification system within two working days to report no underground facilities in the proposed area of excavation. Prior to beginning excavation, excavators must call the notification system if one or more facilities have not been marked by a member UFO to verify the area as clear. Note: homeowners of residential property are not required to clear a facility.

If an excavator damages a facility he must contact 911, the operator of the damaged facility and 811 to report. Both the operator and excavator must request an emergency locate anytime there has been damage, not just during normal business hours. Anytime an underground facility is damaged, the UFO must report the damage using the commission’s website at This repot must be completely filled out.

Underwater Inspection Procedures & Inspection Interval Risk Model Updates

Now that Hurricane season is almost over, this is a reminder to those that have UIP and IIRM plans that you may want to review them soon.

RCP’s latest Inspection Interval Risk Model (IIRM) has been improved to include additional inspection trigger results for hazardous liquid pipelines that cross navigable waterways within Inlets of the Gulf of Mexico. We’ve also created an optional module that will incorporate risk-based evaluation for deeper water pipelines in addition to the shallow water pipelines already included in the IIRM. Several improvements have been incorporated in the Underwater Inspection Procedure based upon suggestions from PHMSA, other affected operators, and survey vendors.

For more information on RCP’s Underwater Inspection Program or Interval Risk Model, contact Jessica Roger.

Florida Gas Pipeline Regulation Updates

On October 18, 2012 the Florida Department of Public Service updated their gas pipeline regulations to adopt the 2011 versions of 49 CFR 191,192 and 199 by reference from the 2008 and 2009 versions. In addition, Section 25-12.052 was retitled and rearranged for better flow. The requirement for cathodic protection survey procedure qualification including a potential survey conducted longitudinally directly above the pipeline at 10 feet spacing was removed. Lastly they added a requirement to 25-12.082 for construction notices. These must be given to the Commission at least 15 days prior to the start of construction.

PHMSA Technical Advisory Committee Meetings December 11-13, Washington, DC

PHMSA plans to host meetings of the gas and liquid pipeline advisory committees on December 11 – 13. The agenda will include briefings on the notices of proposed rulemakings for Damage Prevention Programs and Administrative Procedures; Updates and Technical Corrections, along with any comments received, followed by a committee vote.

The tentative meeting schedule will include a full day joint meeting (liquid and gas) on Wednesday, December 12 followed by a half day meeting for gas industry representatives on Thursday, December 13. PHMSA is still working to finalize the meeting location, but it will be in the DC Metro area. The meeting location will be posted on the website. (No webcast will be available for this meeting.)

Further information will be provided as soon as possible so attendees can make their travel arrangements. If you have any questions, please contact PHMSA’s Cheryl Whetsel,

PHMSA Public Meeting on Pipeline Data January 7 – 8, 2013 Hyatt Regency Washington on Capitol Hill

[Docket ID PHMSA–2012–0244]

The Pipeline and Hazardous Materials Safety Administration (PHMSA) meeting on Pipeline Data that was originally scheduled for October 29 & 30 has been rescheduled for January 7 & 8, 2013. The purpose of the meeting is to discuss how pipeline data is currently used by stakeholders and identify potential improvements in pipeline safety performance measures, including:

  1. Summarize the data OPS collects, who we collect it from, and why we collect it
  2. How do Stakeholders, including OPS, industry, and the public use the data? Industry collections beyond OPS data
  3. Data quality improvement – past efforts and future opportunities – universally understood definitions
  4. Performance Measures – how industry and PHMSA currently measure performance – how could these be improved and what additional data is needed
  5. Discuss best method(s) for collecting, analyzing, and ensuring transparency of additional data needed to improve performance measures

This meeting provides an opportunity for pipeline safety stakeholders to suggest improvements to existing performance measures and new measures representing meaningful pipeline safety metrics. The meeting will include breakout sessions on voluntary reporting, data discrepancies, data collected but not needed, and performance measures.

The meeting will be webcast and the link is posted on the registration page. For registration, agenda, address and hotel information, click here.

For further information contact: Blaine Keener at 202–366–0970 or by email.

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