DOT Pipeline Compliance News

November 2016 Issue

In This Issue

PHMSA Final Rule Correction on EFVs

[DOCKET NO. PHMSA-2011-0009; AMDT. NO 192-121]

In the Final Rule published on October 14, 2016, there was a typo in the modified code language for §192.383(b). The Final Rule stated “An EFV installation must comply with the performance standard in §192.381. After April 17, 2016, each operator must install an EFV on any new or replaced service line serving the following types of services before the line is activated:” (See related article in the DOT Pipeline News October Edition.)

On Friday, October 21, 2016, PHMSA issued a correction that the date should read: “After April 14, 2017, each operator…”

PHMSA Proposed Underground Natural Gas Storage Facility User Fee

[DOCKET NO. PHMSA-2016-0092]

PHMSA is seeking comments on a proposed approach to determine the user fee assessment for underground natural gas storage facility operators. This is a tiered approach that is similar to the liquefied natural gas (LNG) plant user fee rate structure. The storage capacity for each operator will be determined and operators placed in one of 10 tiers. Higher tiers represent greater storage capacity and a higher user fee obligation, from $12,308 / year for a Tier 1 operator with less than 1,550,000 MCF of storage capacity, up to $142,857 for a Tier 10 operator with more than 85,000,000 MCF of storage capacity (the capacity is calculated by Operator, not by storage site). PHMSA expects these user fees to generate $8,000,000 in revenue to fund their underground storage program, with 25% of the revenue being retained by PHMSA and 75% being shared to help fund state programs (for intra-state facilities). If Congress appropriates some amount less than $8MM, the user fees will be reduced proportionately.

According to the Energy Information Agency (EIA), there are 400 interstate and intrastate underground natural gas storage facilities currently in operation in the US. When PHMSA promulgates regulations for operators of underground natural gas storage facilities, they plan to include the collection of annual reports to incorporate both the capacity and number of wells per facility in the annual report, and discontinue use of EIA data.

Submit comments via the E-Gov Website by January 6, 2017, and reference Docket No. PHMSA–2016–0092.

For a copy of PHMSA’s Notice, which includes the proposed tier structure and fees, contact Jessica Foley.

Underground Natural Gas Storage Services

RCP has extensive expertise in the underground storage operations and integrity for depleted reservoirs which we would like to put to work for your company. RCP has developed a comprehensive solution that allows underground natural gas storage operators to:

  • Assess current operations against new RP 1171
  • Develop written standards and procedures for underground natural gas storage
  • Complete risk assessments
  • Develop integrity assessment risk mitigation plans
  • Track progress of all remedial actions from beginning to end

We are well-positioned to support your organization’s response to the recent PHMSA advisory bulletin as well as the California Emergency rule on underground gas storage. For more information, including a demonstration of the advanced tools we have developed, please contact Jessica Foley.

Washington State Chapter 173-182 WAC


On October 12, 2016, the Washington State, Department of Ecology adopted amendments to Chapter 173-182 WAC, Oil Spill Contingency Plan Rule – Pipeline Updates.

The rule requirements were last updated for pipelines in 2006. At that time the pipeline planning standards were developed to align with the marine terminal standards. In Washington pipelines exist in both marine and inland areas. After several years of implementing the rule, they have identified the need to update the standards to ensure that required oil spill response equipment is appropriate for the pipeline risks and operating environments (marine and inland). This rulemaking implements the following:

  • Updates definitions to ensure clarity and consistency with existing federal regulations.
  • Clarifies the Worst Case Discharge calculation for pipelines.
  • Creates a new pipeline geographic information planning standard which will use available geo-referenced data to support preparedness planning and initial decision making during pipeline oil spills.
  • Enhances existing air monitoring requirements for pipelines to ensure safety of oil spill responders and the general public.
  • Enhances spills to ground requirements to ensure rapid, aggressive and well-coordinated responses to spills to ground which could impact ground water.
  • Updates pipeline planning standard storage requirements to ensure the equipment required is appropriate for the environments pipelines may impact.
  • Expands the Best Achievable Protection (BAP) Review Cycle to facilities and pipelines.
  • Other changes to clarify language.

This rule becomes effective on November 12, 2016. Click here for a link to the Washington State Rulemaking documents.

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.

PHMSA Pipeline Safety Research and Development Forum


The forum is a 2-day event held periodically to generate a National research agenda that fosters solutions for the various challenges associated with pipeline safety and with protecting the environment. The forum allows public, government and industry pipeline stakeholders to develop a consensus on the technical gaps and challenges for future research. It also reduces duplication of programs, factors ongoing research efforts, leverages resources and broadens synergies. The national research agenda coming out of these events is aligned with the needs of the pipeline safety mission, makes use of the best available knowledge and expertise, and considers stakeholder perspectives. Specifically the forum:

  • Identifies key pipeline technical challenges facing industry and government;
  • Disseminates information on current research efforts; and
  • Identifies new research that can help to meet known challenges.

Registration information, hotel links, and an agenda can be found on the PHMSA Meeting website.

Voluntary Information-Sharing System Working Group Nominations

PHMSA is seeking nominations for individuals to serve as members for three-year terms on the Voluntary Information-Sharing System (VIS) Working Group. This is a newly created working group established in accordance with section 10 of the Protecting our Infrastructure of Pipelines and Enhancing Safety (PIPES) Act of 2016. The Secretary of Transportation (Secretary) must convene a working group by December 19, 2016 to consider the development of a voluntary information-sharing system to encourage collaborative efforts to improve inspection information feedback and information sharing with the purpose of improving gas transmission and hazardous liquid pipeline facility integrity risk analysis. PHMSA intends to convene this working group by December 19, 2016.

The VIS Working Group will consist of no more than 30 members appointed by the Secretary, including representatives from:

  • PHMSA;
  • Industry stakeholders, including:
    • Operators of pipeline facilities,
    • Inspection technology, coating, and cathodic protection vendors, and
    • Pipeline inspection organizations;
  • Safety advocacy groups;
  • Research institutions;
  • State public utility commissions or State officials responsible for pipeline safety oversight;
  • State pipeline safety inspectors;
  • Labor representatives; and
  • Other entities, as determined appropriate by the Secretary.

All nomination material should be emailed to the Advisory Committee Program Manager Cheryl Whetsel or mailed to the Pipeline and Hazardous Materials Safety Administration, 1200 New Jersey Avenue SE, PHP-30, E24-445, Washington, DC 20590, to the attention of Cheryl Whetsel, Advisory Committee Program Manager, PHP-30. Nominations must be received on or before November 28, 2016.

For more information email Cheryl Whetsel or call 202-366-4431. For a copy of the Federal Register Notice regarding the VIS Working Group, contact Jessica Foley.

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.

GPAC Meeting Notice / Gas Mega Rule Discussion

DECEMBER 7 & 8, 2016

PHMSA will host a meeting of the Gas Pipeline Advisory Committee (GPAC) on December 7 & 8, 2016 (Wednesday & Thursday) in the Washington, DC area. They are working on the logistics and meeting location. A notice with additional information and meeting details will be published in the Federal Register in the near future.

At this meeting, the committee will begin to consider the Notice of Proposed Rulemaking (NPRM), “Pipeline Safety: Safety of Gas Transmission and Gathering Pipelines” as published in the Federal Register (81 FR 20722) on April 8, 2016. This NPRM proposes to revise the Pipeline Safety Regulations applicable to the safety of onshore gas transmission and gathering pipelines; changes to the integrity management (IM) requirements and issues related to non-IM requirements; and modifications to the regulation of onshore gas gathering lines.

Additional information may be found on the PHMSA Technical Advisory Committee webpage.

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.

We would welcome the opportunity to discuss our services with you.

Best regards, 

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