DOT Pipeline Compliance News

November 2017 Issue

In This Issue

PHMSA Notice UGS Interim Final Rule

[DOCKET NO. PHMSA–2016–0016; AMDT. NOS. 191–24; 192–122]

The Pipeline and Hazardous Materials Safety Administration (PHMSA) has re-opened the comment period for the Underground Natural Gas Storage Facilities (UGS) Interim Final Rule based upon a petition for reconsideration filed by the American Gas Association, American Petroleum Institute, and the American Public Gas Association. (See related articles in the January 2017 Edition and July 2017 Edition of the DOT Pipeline Compliance News.) PHMSA will consider all public comments and address the petition for reconsideration in the final rule. Comments must be received by November 20, 2017. You may submit comments identified by the docket number PHMSA–2016–0016 via the Federal eRulemaking Portal.

PHMSA’s Underground Gas Storage Facility Safety Site Assessment Report

On October 20, 2017, PHMSA issued the “Underground Gas Storage Facility Safety Site Assessment Report.” The document reviews PHMSA’s assessment of eight underground storage sites throughout the continental US. A team of PHMSA inspectors and underground natural gas storage (UGS) subject matter experts visited these facilities from May to July 2017. These site assessments were conducted in preparation for a January 18, 2018 deadline, when the UGS Interim Final Rule goes into effect and where mandatory and non-mandatory provisions set forth in API Recommended Practices 1170 and 1171 are to be made mandatory for UGS operators nationwide. In June 2017 after some site assessments had already been completed, PHMSA softened their stance and issued a statement that no non-mandatory provisions in API 1170 and 1170 will be enforced until January 18, 2018 at the earliest (see related articles in the July edition of the DOT Pipeline Compliance News).

The site assessments were voluntary and not classified as inspections – thereby no deficiencies, notices, reports, or enforcement actions were made by PHMSA. The assessments took place in California, Colorado, Illinois, Louisiana, Mississippi, Michigan and Texas and encompassed five depleted fields, three salt cavern fields, and one aquifer field. These site assessments were conducted at operating fields so PHMSA’s main focus was on operating and maintenance factors aspects of the API RPs. Each assessment visit consisted of high-level discussions with respective UGS personnel, a half-day site tour, and a detailed questionnaire filled out by the personnel. These questions focused mainly on Procedures & Training; Site Security & Safety, Site Inspections, and Emergency Response; Integrity Demonstration, Verification & Monitoring; and Risk Management. PHMSA summarized observations from these four categories within the document. Each assessment took an average of 2-1/2 days to conduct.

PHMSA expects to issue the Final Rule for UGS in early 2018. For a copy of this report, contact Jessica Foley.

Underground Gas Storage Compliance

How does RCP deliver a comprehensive solution for natural gas storage operational integrity assurance?

Experienced Resources

  • Highly respected underground storage & risk management SME’s (the past Chair of PRCI’s and AGA’s underground storage committees is on our staff)
  • Professional engineering support
  • Written program development / improvement from knowledgeable technical standards developers (Our lead technical writer was the editor for the API RP1170 development team.)

State-Of-The-Art Tools (TaskOp™)

  • Program gap assessment and corrective action tracking
  • Storage risk assessment
  • Integrity assessment and remediation process tracking

For more information regarding our capabilities or to request an online demonstration of our TaskOp™ underground gas storage solution, visit our website or contact Jessica Foley.

Proposed Revisions to Gas Distribution Annual Report (PHMSA F 7100.1-1)

[DOCKET NO. PHMSA-2017-0110]

PHMSA is preparing to request Office of Management and Budget (OMB) approval for revisions to the Natural Gas Distribution Annual Report form. The revisions will occur to the instructions and Part A of the annual report form. Please note the following proposed changes:

  • Instructions
    • Concerning Part G – Percent of Unaccounted for Gas, proposes to calculate percent lost and unaccounted for (LAUF) gas by dividing the LAUF volume by the gas consumption volume and allowing a negative value to be reported. The proposed change will harmonize PHMSA’s data with the Energy Information Administration (EIA) calculations.
  • Part A – Operator Information
    • PHMSA will remove the selection for “Other” as an Operator Type in Part A7 in addition to adding guidance in the instructions for the proper selection.

Interested parties are invited to submit comments on the website at by December 18, 2017. Identify the docket number, PHMSA–2017–0110, at the beginning of your comments. For a copy of PHMSA’s Notice from the Federal Register, contact Jessica Foley .

DOT Regulatory Review Comment Period Reopened

[DOCKET NO. DOT-OST-2017-0069]

The US Department of Transportation (DOT) is reopening the comment period for their Notification of Regulatory Review seeking comment from the public on existing rules and other agency actions that are good candidates for repeal, replacement, suspension, or modification. The original comment period ended on November 1, 2017 and the new deadline for comments is now December 1, 2017. Comments can be submitted on the Federal eRulemaking Portal.

Oklahoma Pipeline Safety Fine Limit Removed

The State of Oklahoma has modified its regulations in Title 165 – Corporation Commission, Chapter 20 – Gas and Hazardous Liquid Pipeline Safety, 165:20-13-1. Scope and Fines, to remove the explicit limit of $500k per violation. The new section reads (underline is modified text):

This Subchapter prescribes the procedures utilized by the Oklahoma Corporation Commission in carrying out its responsibilities regarding pipeline safety under 52 O.S. 1981, Section 5 and 52 O.S. Supp. Sections 47.1 through 47.8, and is designed to utilize enforcement procedures already in place by hereby adopting the Commission’s Rules of Practice, OAC 165:5, that are pertinent and necessary to carry out the enforcement of pipeline safety rules and regulations. (1) For each violation of a Commission rule in Subchapters 5 and 10, the Commission may issue an order pursuant to 17 O.S. Section 1 et seq. fining an operator up to the maximum amount provided by 17 O.S. Section 6.1.

RCP Employees Recognized in National Academy of Sciences, Engineering, and Medicine Report

RCP’s Bill Byrd and Jenn Randolph have been recognized by the Transportation Research Board (part of the National Academy of Sciences, Engineering, and Medicine) for their contributions to an upcoming report, “Safely Transporting Hazardous Liquids and Gases in a Changing U.S. Energy Landscape (Special Report 325)”. This study was initiated and sponsored by the Transportation Research Board (TRB) Executive Committee in response to the rapid development of domestic sources of energy and questions about the safest ways to move these products. The study was sponsored by PHMSA, the National Academies of Sciences, Engineering, and Medicine’s Transportation Research Board, and the Gulf Research Program. A pre-publication version of the report can be downloaded by clicking here.

IPC 2018 Call for Abstracts

The 12th International Pipeline Conference (IPC 2018) will be held from September 24-28, 2018 in Calgary, Alberta, Canada. Organized by volunteers representing international energy corporations, energy and pipeline associations and regulatory agencies, the IPC has become internationally renowned as the world’s premier pipeline conference. IPC 2018 is now accepting Abstracts. The deadline for submission is December 15, 2017. Full details for the Call for Papers can be found on the IPC conference website .
For any questions or additional information contact or

Underwater Inspection Procedures & Inspection Interval Risk Model Updates

One of the most active hurricane seasons in recent history is driving the need for operators with assets in the Gulf of Mexico and its inlets subject to 49 CFR 192.612 and 195.413 to re-evaluate their inspection intervals and risk assessments. RCP’s proprietary Underwater Inspection Interval Risk Model analyzes key operator information, National Oceanic and Atmospheric Administration charts and state game and fisheries department maps of navigational channels, shipping lanes, anchorage areas and commercial fishing locations with the latest information tabulated by the National Hurricane Center on storm paths and intensity to help identify new or changed threats and reassess previous risk rankings for determining inspection interval timelines. For more information on RCP’s Underwater Inspection Procedures or Inspection Interval Risk Model, contact Jessica Foley.

Coastal Ecological Unusually Sensitive Areas (USAs) Public Meeting

[DOCKET NO. PHMSA-2017-0094]

Section 19 of the Protecting our Infrastructure of Pipelines and Enhancing Safety Act of 2016 (Pub. L. 114-183) requires PHMSA to expand the definition of an Ecological resource USA (as defined in 49 CFR 195.6(b)) to include the Great Lakes, coastal beaches and marine coastal waters. All USAs are treated as high consequence areas (HCAs) for liquid pipelines, which are subject to stricter safety and maintenance standards (such as 49 CFR 195.452). To address this mandate, PHMSA must define and map these areas.

PHMSA will host a one-day public meeting in the Washington, D.C. area on November 17, 2017, from 8:30 a.m. to 5:00 p.m. ET, to discuss applicable definitions and available geospatial information system (GIS) data sources for marine coastal waters, coastal beaches and the Great Lakes, pertaining to Coastal Ecological Unusually Sensitive Areas (USA). The Coastal Ecological USA public meeting will include discussions from government and industry stakeholders on proposed definition, available GIS data sources, and how Coastal Ecological USA protect the public and environment through integrity management planning. The meeting will also include facilitated discussions with meeting participants and experts to understand additional perspectives on proposed definitions and recommended GIS data sources. Stakeholder feedback may inform future policy efforts impacting the definition of a Coastal Ecological USA.

Members of the public who wish to attend in person are asked to register on the PHMSA Meetings website no later than November 7, 2017, to facilitate entry and guarantee seating. Members of the public who attend in person will also be provided an opportunity to make a statement during the meeting. The meeting will be held at a location yet to be determined in the Washington, DC Metropolitan area. The meeting location, agenda and any additional information will be published once they are finalized on the following public meeting registration page.

The meeting will not be webcast; however, a conference call number and presentation slides will be available to remote participants, and any documents presented will be available on the meeting website and posted on the E-Gov Website in docket number PHMSA-2017-0094 within 30 days following the meeting. For information about the meeting, contact Leigha Gooding by phone at 202-366-0667 or by email.

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.

MaxOP Training

RCP is now offering a one-day workshop on how to use MaxOp software. This training session can be scheduled onsite or at RCP’s corporate office in Houston, Texas. MaxOp is the most comprehensive MAOP tool on the market. RCP’s MaxOp tool can link documentation to MAOP algorithm variables, dynamically segment data, run MAOP calculations, identify potential discrepancies between the established and calculated MAOP values, and export calculated data sets and customizable reports back to their own native data sets. The tool will accept common pipeline database formats, including Excel, PODS, APDM and others. For more information, contact Jessica Foley.

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

Best regards,

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