DOT Pipeline Compliance News

November 2015 Issue

In This Issue

Oklahoma Enforces State Damage Prevention Act

[OK 165:20-17]

The Oklahoma Corporation Commission (OCC) published a new Subchapter to Oklahoma Regulation Title 165, Chapter 20: Gas and Hazardous Liquid Pipeline Safety. Subchapter 17: Obligations Under The Oklahoma Underground Facilities Damage Prevention Act Subject To Commission Enforcement gives the OCC the enforcement authority for the state’s Damage Prevention Act. The Commission previously had enforcement authority over pipeline operators who must participate in the Act; the Commission may now also enforce violations of the Act against those excavating near pipelines and pipeline systems.

For a copy of the updated regulation, please contact Jessica Foley.

TRRC Notice of Amendments to 16 TAC §12.108

[SMRD Docket Number 1-15]

At its open meeting on November 3, 2015, the Texas Railroad Commission (TRRC) adopted some amendments to 16 Texas Admin. Code §12.108 regarding permit fees. TRRC amends the calendar years to 2015 and 2016; deletes paragraph 1 to eliminate the annual fee for each acre of land within a permit area on which coal or lignite was removed during a calendar year; increases the annual fee for each acre of land within a permit area covered by a reclamation bond, and increases the annual fee for each permit in effect on December 31st from $6,540 to $6,600.

The adoption notice will be published in the Friday, November 20, 2015, issue of the Texas Register, and the amendments will become effective on Monday, November 23, 2015. To view a PDF version of the adoption and other information on this rulemaking, please see the Proposed Rules table.

National Pipeline Mapping System; Extension of Comment Period and Notice of Operator Workshop

[Docket ID PHMSA-2014-0092]

PHMSA is sponsoring a one-day National Pipeline Mapping System (NPMS) operator technical workshop on November 18, 2015, from 8:00 a.m. to 5:00 p.m. at the Marriott Key Bridge, 1401 Lee Highway, Arlington, VA 22209. The purpose of the workshop is to discuss and understand existing and future NPMS submission technical issues such as (1) the format in which operators are storing the data that is submitted to the NPMS, (2) how pipe segmentation for the submissions is determined, (3) how data is submitted in a linear referencing format, and (4) options Geographic Information Systems technicians have when an attribute includes the word “predominant” (i.e., submitting actual data or rolling up data to create a “predominant” value). This workshop will not discuss any proposed new data elements (attributes) or operators’ opinions on the new data elements (attributes). Because this workshop will rely heavily on dialogue between PHMSA staff and operators in a “whiteboard” environment, the workshop will not be webcast.

The comment period for the 60-day information collection published on August 27, 2015, (80 FR 52084) is also extended until November 25, 2015, in order to conduct this workshop that will provide PHMSA with important information as it prepares to improve the NPMS submission process to accept additional data.

All attendees are encouraged to register for the workshop. Name badge pick up and on-site registration will be available starting at 7:30 a.m., eastern time on November 18, 2015, with the workshop taking place from 8:00 a.m. until approximately 5:00 p.m. eastern time. Refer to the meeting website for agenda and times. For further information contact: Amy Nelson at 202-493-0591 or by email at

Panel on Cost-Benefit Analysis at the Pipeline Safety Trust Conference

November 19-20, 2016 – New Orleans

Your humble newsletter editor will participate in a panel discussion at the upcoming Pipeline Safety Trust (PLST) Conference in New Orleans on November 19-20 concerning cost-benefit analysis during the rulemaking process. Registration information, agenda and hotel information is available on the Pipeline Safety Trust website. Be sure to be there on Thursday night to see whether the PLST Executive Director, Carl Weimer, will at long last pay off that beer debt.

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.

API RP 1166: Excavation Monitoring and Observation, Second Edition

API has published a new edition of Recommended Practice (RP) 1166 on monitoring and observation of excavations near energy pipelines. This RP provides a consistently applied decision making process for monitoring and observing of excavation and other activities on or near pipeline rights-of-way for “hazardous liquid” and “natural and other gas” transmission pipelines. The goal is to protect the public, excavation employees, and the environment by preventing damage to pipeline assets from excavation activities. Click here to purchase and download the new RP.

New Pipeline Safety Management System RP Exceeds NTSB Recommendation

The National Transportation Safety Board (NTSB) has closed out a recommendation that it made after the Enbridge oil spill in Marshall, Michigan, concerning safety management systems. In response to NTSB’s recommendation, API developed Recommended Practice 1173 which addressed the NTSB recommendation as well as other topics including safety culture. The NTSB’s press release on this topic is available here.

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.

PHMSA Incident and Annual Data Analysis

RCP can provide detailed and timely analysis of PHMSA historical incident and annual data for clients needing to compare their performance against the industry averages, respond to press inquiries, or analyze trends. Contact Jessica Foley for more information.

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.