DOT Pipeline Compliance News

November 2014 Issue

In This Issue

PHMSA Advisory Bulletin (ADB-2014-05) Guidance for Strengthening Pipeline Safety through Rigorous Program Evaluation & Meaningful Metrics

[Docket No. PHMSA-2014-0086]

The Pipeline Hazardous Materials Safety Administration (PHMSA) issued an Advisory Bulletin to owners and operators of natural gas and hazardous liquid pipelines that PHMSA has developed guidance on the elements and characteristics of a mature Integrity Management (IM) program evaluation process using meaningful metrics. This document, “Guidance for Strengthening Pipeline Safety through Rigorous Program Evaluation and Meaningful Metrics,” should be used when operators develop and perform IM program evaluations. It provides additional specificity to several of the topics detailed in a previously issued Advisory Bulletin, ADB–2012–10, “Using Meaningful Metrics in Conducting Integrity Management Program Evaluations.”

Operators under the current regulations are required to perform program evaluations and use meaningful metrics. PHMSA’s new guidance document builds on existing standards and regulations to provide a more detailed and comprehensive description of the steps involved in program evaluations as well as the selection of meaningful performance metrics to support these evaluations. The guidance expands and clarifies PHMSA’s expectations for operator processes when measuring IM program effectiveness. Major topic areas addressed in the guidance document include:

  • Establishing Safety Performance Goals.
  • Identifying Required Metrics.
  • Selecting Additional Meaningful Metrics.
  • Metric Monitoring and Data Collection.
  • Program Evaluation Using Metrics.

The guidance document includes tables listing regulation-required metrics and other programmatic and threat-specific metrics that operators could include in their documented IM program evaluations.

PHMSA inspectors will use the program evaluation guidance within this new guidance document as criteria when evaluating the effectiveness of operator IM program evaluations to assure operators are developing sound program evaluation processes and are developing and applying a robust and meaningful set of performance metrics in their program.

For a copy of ADB-2014-05; or, a copy of the Guidance to Operators document, contact Jessica Foley.

PHMSA Revised O&M Enforcement Guidance

On October 30, 2014 The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) posted updated guidance for inspectors to use during inspections for Gas and Liquid Operations Manuals. This guidance is meant to help with consistency in inspections. The guidance describes the practices used by PHMSA inspectors and other enforcement personnel when undertaking their official duties. This document is not meant to create any new legal obligations and regulation is still the controlling factor. Changes to the guidance from the previous version include: updating the interpretation summaries; addition of Advisory Bulletins and updating probable violations. Additional guidance was added from Final Orders issued as a result of previous incidents / inspections.

For a copy of PHMSA’s O&M Enforcement Guidance document, please contact Jessica Foley.

Audit Assistance

Has the DOT or TRRC notified you of a pending audit? Are your O&M and IMP programs ready for their next PHMSA audit? RCP can review your plans based on Advisory Bulletins and Enforcement Guidelines to ensure compliance. RCP is well versed in PHMSA and TRRC audit preparation and will help you identify opportunities for improvement and track each item to closure using RCP’s audit tracking tool, TaskOp™. RCP can provide confidential internal auditing to help ensure that your facilities are up to the agency’s latest standards. For more information, contact Jessica Foley.

PHMSA Study of Impact of One-Call Exemptions

Under the requirements of Section 3 of the 2011 Pipeline Safety Legislation, The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) was required to conduct a study on the impact of excavation damage on pipeline safety. The study was to include an analysis on the frequency and severity of different types of excavation damage, including analysis and review of impact of exemptions to the one-call notification requirements in each State. The study has just been issued by PHMSA, “A Study on the Impact of Excavation Damage on Pipeline Safety.” Findings of the report include:

  • More data is needed to adequately assess the impact of exemptions on pipeline safety
  • Activity-based exemptions may be acceptable, but should be supported by sufficient data
  • Targeted education is needed for stakeholders, particularly groups exempted from excavation notification requirements

PHMSA says state damage prevention laws should apply to all excavators. PHMSA calls for increased education about damage prevention to excavators, singling out the agriculture and road maintenance sectors. PHMSA noted that some excavators wrongly assume they are categorically exempted from one-call requirements for all types of excavation, when exemptions may apply only to certain low-depth excavation activities. PHMSA says some activity-based one-call exemptions may be acceptable in certain circumstances, but should be supported by sufficient data.

PHMSA notes more data could be collected by the Common Ground Alliance Damage Information Reporting Tool (DIRT), by state agencies, locators, excavators, industry, and by PHMSA, itself. The DIRT tool collects great information about excavation damage, but little or no analysis is done to determine whether such damage is related to a state one-call exemption.

The report also provides detailed information & comments collected at PHMSA’s public workshop held March 14, 2013 to discuss One Call exemptions.

For a copy of the study, contact Jessica Foley.

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.

API RP1173 Draft Pipeline Safety Management System

A final draft is ready for approval and public comment on the Pipeline Safety Management System Recommended Practice (RP), API 1173 (PSMS). This is the second ballot and will result in a new document (1st Edition). Comments are due by December 20, 2014 and will be accepted online at The ballot ID number is 3392. See our related article in the July 2014 edition of the DOT Pipeline Compliance News for detailed information about how to download and vote on the ballot.

Illinois Pipeline Regulation Update

On November 7, 2014 the Illinois Commerce Commission released a Notice of Proposed Amendment that changed the date of the 49 CFR 192 incorporated by reference from January 1, 2013 to October 1, 2014 to capture recent revisions to the federal regulations. In addition to incorporating the new federal regulation amendments, the proposed state change would adopt two new sections 590.30 and 590.40 to require operators to electronically file copies of plans, procedures and programs already required to be filed with the agency. Comments should be filed within 45 days to Elizabeth Rolando, Chief Clerk at Illinois Commerce Commission 527 East Capital Avenue Springfield IL 62701.

Bored Reading the Federal Register? Try Texas.

The front cover and blank filler pages of the Texas Register are decorated with artwork from students in grades K-12. The drawings dress up the otherwise gray pages and introduce students to this obscure but important facet of state government.

Editor’s Note: These children’s drawings are not to be confused with work products from the legislators while in session. As one distinction, the children’s work frequently bears a strong resemblance to their stated objective.

TRRC Chapter 8 Pipeline Safety Adopts Farm Tap Regulations

The Railroad Commission of Texas (TRRC) adopted amendments to §8.1, relating to General Applicability and Standards, to update federal provisions and citations, and to §8.215, relating to Odorization of Gas, to clarify an exemption for certain farm tap odorizers. The TRRC revised its regulations to clarify that wick-type farm tap odorizers are exempt from certain equipment reporting requirements, but must continue to comply with gas odorization requirements. The TRRC adopts the amendments without changes to the proposed text as published in the July 4, 2014, issue of the Texas Register (39 TexReg 5024).

The adopted regulations became effective on October 6. For a copy of the adopted regulations published in the Texas Register, please contact Jessica Foley.

PHMSA NPMS Public Meeting

Arlington, VA – Nov. 17

PHMSA is holding a public meeting on November 17 to discuss the proposed information collection for the National Pipeline Mapping System (NPMS). PHMSA issued an Information Collection Notice (OMB Control No. 2137-0596) on 7/30/14. Comments are due by 12/1/14. The primary goals of the public meeting are to:

  1. Provide an overview of the data elements required in the NPMS Information Collection;
  2. Discuss the state of pipeline operators’ GIS systems and their ability to submit the new data elements;
  3. Discuss the security sensitivity of the new data elements; specifically, which elements will be available to PHMSA, other government officials, pipeline operators, and the general public; and
  4. Discuss ways to minimize the burden on operators related to submitting the new data elements.

The meeting is free to attend and will not be webcast. Registration and hotel information can be found here.

Pipeline Safety Trust Meeting

New Orleans – Nov 20-21, 2014

The Pipeline Safety Trust will once again gather pipeline operators, regulators, local governments and concerned citizens in the French Quarter of New Orleans to talk all things pipeline safety. Due to the increasing popularity of the conference, the meeting venue has moved to the Royal Sonesta Hotel, providing significantly larger meeting spaces to comfortably accommodate more participants. Conference registration, agenda, and more information can be found on the Pipeline Safety Trust website.

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 Foley.

Pipeline Pressure Testing Workshop: January 13-14, 2015

RCP is now offering a 2-day Pipeline Pressure Testing Workshop at its facilities in downtown Houston. RCP has established itself as a leading industry expert on pipeline pressure testing with clients securing RCP’s services specifically to validate their pressure tests.

Our Pressure Testing Workshop will begin by outlining the objectives for performing a pressure test and how that relates to DOT requirements. The workshop will then build upon these foundations to answer many specific pressure testing questions including:

  • What are the different types of tests commonly conducted and how do you design each one?
  • What is the theory and physical science behind a pressure test?
  • How do you plan for a pressure test from start to finish:
    • Cleaning the line
    • Environmental hazards and permitting
    • Landowner and operations safety
    • Customer/stakeholder impact
    • Logistical details and scheduling
    • Pipeline modifications and anticipating failures
  • What is the required instrumentation and how does it need to be configured?
  • What data is absolutely necessary to validate a pressure test?
  • How do you determine and prove a successful pressure test?
  • What does a good test report look like (that will also satisfy PHMSA)?

Each attendee will receive the presentation as well as applicable handouts in a hardcopy notebook. Attendees will also have the opportunity to work through 3 different worksheets specifically covering 1) calculating the SMYS, MAOP and test pressures for various pipeline segments at various elevations 2) calculating the volume of water required for a hydrotest and determining how the volume of test water changes with pressure and 3) designing a complete test plan for a hypothetical pipeline i.e. dividing the line into test sections, determining the test parameters for each section and specifying the pressure ratings of equipment needed.

To register for our workshop, click here.

Pressure Test Certification

RCP is an industry leader when it comes to ensuring that pipeline pressure tests are professionally executed. We consistently provide convincing, time tested arguments that a line can be safely operated as defined by CFR 49 Parts 192 and 195. RCP owns and utilizes a proprietary pressure test model that evaluates test pressure, temperature and volumetric data to confirm that the pipeline is leak free.

RCP’s certification service is an excellent way to analyze and document a pressure test, all produced by an independent, recognized and trusted third party. For more information on how RCP can assist with a pressure test validation, contact Jessica Foley.

Pipeline Training Reference Museum

Ever seen screwed pipe from 1915? A seamless pipe segment from 1917? A slice of 24″ pipe with a 4,620 psi test pressure? Ever wondered what a 3.5″ ANSI 1500# bolt really looks like? Need a good example of the effects of MIC corrosion? Slotting corrosion? Weld cracking? How about a 20″ pipeline that was crushed during a levee failure after Hurricane Katrina?

Thanks to Shell Pipeline (and their recent office relocation), we have all of that and more on display in our offices in downtown Houston. Please drop by, and we’ll be glad to show you around.

We have plenty of space left to display all of those interesting pipeline samples that YOUR company might no longer need or have room for. For more information on how to send pipe samples to RCP, please contact Jessica Foley.

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