DOT Pipeline Compliance News

November 2013 Issue

In This Issue

Advisory Bulletin – Reminder of Requirements for LPG Pipeline Systems

[Docket No. PHMSA-2013-0097]

The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) issued advisory bulletin ADB-2013-03 to Owners and Operators of LPG and Utility LP-Gas Plants concerning the Requirements for Liquefied Petroleum Gas and Utility Liquefied Petroleum Gas Pipeline Systems.

PHMSA published an Advisory Bulletin in the Federal Register on July 18, 2013, (78 FR 42889) reminding owners and operators of liquefied petroleum gas (LPG) and utility liquefied petroleum gas (Utility LP-Gas) plants of their obligation to follow certain sections of Part 192 in addition to the American National Standards Institute/National Fire Protection Association (ANSI/NFPA) standards 58 or 59. This document supersedes the July 18, 2013, Advisory Bulletin by correcting a typographical error in the sixth bullet and removing the exemption for small utility LP gas systems from Subpart N (Qualification of Pipeline Personnel) from the bulleted list.

When ANSI/NFPA 58 or 59 (2004) does not address a specific subject, then a conflict has not occurred and the operator must follow Part 192 requirements. Part 192 covers areas that are not addressed in ANSI/NFPA 58 or 59 (2004). These areas include:

  • Inspection requirements for distribution mains (§§ 192.305 and 192.307)
  • Backfill requirements for installing pipe in a ditch (§ 192.319)
  • Underground pipe clearance requirements (§ 192.325). Valve requirements for service lines (§§ 192.363 and 192.365)
  • Continuing surveillance (§ 192.613)
  • Public awareness (§ 192.616)
  • Operator qualification (Subpart N)
  • Distribution Pipeline Integrity Management (Subpart P)

For a copy of ADB-2013-03, please contact Jessica Roger.

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.

Arkansas Gas Regulations

On October 8, 2013 the Arkansas Public Service Commission updated the following sections of their gas regulations to match the latest version of 49 CFR 191:

  • 191.7 Addressee for Written Reports
  • 191.11 Distribution System: Annual Report
  • 191.15 Transmission Systems, Gathering Systems, and Liquefied Natural Gas Facilities: Incident Report (changed reporting to 30 days from detection rather than 20)
  • 191.21 OMB Control Number Assigned to Information collection.
  • 191.22 National Registry of Pipeline and LNG Operators
  • 192.951 Where does an operator file a report?

In addition, the following changes were made independent of federal regulation:

  • Added a new section 191.27 Status of Leaks requiring each natural gas distribution operator to submit a leak report to the Commission’s Pipeline Safety Office twice annually, no later than January 15th and July 15th, of each calendar year.
  • Added a definition for Private Line System to section 192.3
  • Added section 192.724 Hazardous Facilities allowing suppliers to a master meter system or private line system the ability to terminate service if the system experiences a lost and unaccounted for gas percentage of 10% (rolling average over the prior year) or more, or has an operating condition causing it to deliver gas in an unsafe manner endangering life and property.

For a copy of revised Arkansas Gas Pipeline Code, revised October 16, 2013 (13-027-R), click here.

Louisiana Hydrocarbon Storage Wells in Salt Dome Cavities – Proposed Rule Change

(LAC 43:XVII.Chapter 3)

The Department of Natural Resources, Office of Conservation proposes to amend LAC 43:XVII. Chapter 3. The proposed action will adopt Statewide Order No. 29-M (Revision 3), which provides comprehensive regulations for hydrocarbon storage wells in salt dome cavities, and will amend existing Statewide Order No. 29-M, as enacted by Act 368 and Act 369 of the 2013 Legislative Session.

The proposed rule change makes changes regarding the location, operational and reporting requirements for both proposed and existing Class II injection wells used for the storage of hydrocarbons in solution-mined salt caverns. Changes found in the proposed rule include:

  1. Documentation of the method by which proof of financial security is to be maintained for closure and post closure costs;
  2. Maintaining an updated site assessment to include a geological, geomechanical and engineering assessment of the stability of salt stock and overlying/surrounding sediment based on past, current and planned well and cavern operations;
  3. Locations of caverns and proposed caverns in relation to other caverns and the periphery of the salt stock are to be provided on maps and cross-section depictions based on the best available information and updated at least every five years;
  4. Mandatory setback distance locations for salt caverns in relation to the periphery of salt stock and in relation to other man-made structures within salt stock;
  5. Mandatory monitoring plan implementation for existing caverns within the requirement for setback distance to periphery of salt stock;
  6. Provisions for consideration of approval to plug and abandon hydrocarbon storage cavern wells;
  7. Mandatory submission and maintenance of an updated post-closure plan to include subsidence monitoring, corrective action, site remediation, etc., as may be necessary following plugging and abandonment, and
  8. Increases to minimum testing and monitoring requirements for hydrocarbon storage wells and related caverns.

The proposed Rule change will result in increased costs to the regulated community subject to the proposed Rule change. These costs are a result of: 1) an increase in frequency of required sonar tests, and 2) a vapor detection plan. A majority of cavern operators and/or owners are currently meeting these standards as required by specific provisions of permits issued by the Office of Conservation.

A significant increase to all operators will be the casing inspection log, which is required every 10 years for liquid storage and every 15 years for natural gas storage. Updated maps and cross-sections of caverns in relation to the periphery of salt stock and other man-made structures within the salt stock are required to be submitted every five years to the Office of Conservation, potentially including 3-D seismic data.

RCP Receives 3 Patents for MAOP Software

RCP has received 3 patents (#8,548,756; #8,548,757; and #8,548,758) for our industry-leading MaxOp* software. RCP is the unquestioned market leader providing MAOP Validation Services, including over 100,000 miles of gas and liquid pipeline analysis and support. Not only does RCP bring a wealth of experienced professional engineers and support staff, we have brought the most comprehensive and complete MAOP validation tool to the market, MaxOp*.

MaxOp* Features:

  • NEW Section Q & R, Gas Transmission Annual Report: output MAOP reports compliant with PHMSA requirements
  • Data agnostic: works with all common database and GIS data formats
  • Traceable: connects data to source document image files
  • Verifiable: identifies exact 192/195 code sections driving MAOP results

MAOP Validation Services:

  • Turnkey: document review & imaging, data extraction, gap analysis, MAOP reporting
  • Quality Assurance: review existing validation efforts, compare calculations using MaxOp*
  • Annual Report: Import data to MaxOp*, export Section Q & R report
  • Remediation: develop strategies to close gaps and/or re-establish MAOP

For more information about RCP’s MAOP validation services or the MaxOp* calculator tool, please contact Jessica Roger. * MaxOp is a registered trademark of RCP, Inc., in the United States.

Excavation Damage Prevention Toolbox

The American Petroleum Institute (API) and Association of Oil Pipe Lines (AOPL) launched the Excavation Damage Prevention (DP) Toolbox on Wednesday, October 9th during their Damage Prevention Workshop in Houston, TX. The toolbox was compiled by a team of liquids pipeline damage prevention specialists who shared numerous damage prevention practices across more than a dozen different topics. The DP Toolbox is expected to continue to grow and evolve as additional topics, suggestions, and materials are received. Realizing that there is no “one size fits all” answer to Damage Prevention, the DP Toolbox provides a wide variety of practices, forms, and procedures, that pipeline operators may chose to adopt or modify as appropriate to their particular situation.

The DP Toolbox is being made publicly available in hopes that all interested parties can learn from, and contribute to, these materials. Click here for the toolbox. To submit to the toolbox, please email submissions and feedback to

Pipeline Safety Trust Meeting in New Orleans New Orleans – Nov 21-22, 2013

Join us in New Orleans for the 8th annual Pipeline Safety Trust Conference. RCP’s President, Bill Byrd, will participate in a “Food for Thought” session at 10 am on Thursday concerning consequences as part of pipeline risk management.

Personal note from your beloved newsletter editor: the response to my “Buy Bill a Beer by Proxy” campaign to fund travel for members of the public to this conference was, well, rather unimpressive. My peeps have let me down. Note that you can still make a donation to fund the travel of a member of the public if you feel so inclined. Any amount will help. Make me proud.

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