DOT Pipeline Compliance News

November 2018 Issue

In This Issue

PHMSA Interpretation on Farm Taps and Regulator Maintenance

On November 5, 2018, PHMSA issued a letter of interpretation (LOI) to the Kentucky Public Service Commission concerning the application of 49 CFR 192.740 to Farm Taps, including Farm Taps which come directly from otherwise un-regulated gas pipelines.

The LOI says in part:

Part 192 defines a service line as a “distribution line that transports gas from a common source of supply to an individual customer” (49 CFR 192.3). A “farm tap” is not defined in Part 192, but commonly refers to a pipeline directly connected to a source pipeline that transports natural gas to a customer along the source pipeline right-of-way, and thus, meets the definition of a service line in the pipeline safety regulations. A non-regulated production or gathering pipeline may be the common source of supply for a regulated service line. The pipeline upstream of the service line retains its original functional identity or classification.

Because “farm taps” meet the definition of service lines, piping and appurtenances that comprise a “farm tap” that are owned or maintained by an entity engaged in the transportation of gas, are subject to the requirements of Parts 191 and 192 as a distribution service line, including the requirements at §192.740.

However, a service line ends at the connection to customer owned piping, or the outlet of the meter, whichever is further downstream. Such piping and appurtenances that are owned by a customer or person not engaged in the transportation of gas ( e.g., a farmer or residential customer) are not service lines and are not subject to requirements in Part 191 or Part 192. Therefore, neither the customer nor the operator are required by federal regulation to maintain a customer owned regulator on a customer fuel line in accordance with §192.740.

In other words:

  • a Farm Tap is a regulated service line, even when it starts from an un-regulated line
  • an un-regulated line can directly feed a regulated service line and still be un-regulated, and
  • downstream of the meter, any customer owned pipe and equipment, including pressure regulators, is un-regulated.

Note that this LOI is for the federal regulations published by PHMSA. State regulatory agencies might have different regulatory boundaries and additional requirements applicable to Farm Taps and their associated equipment.

Operator Submitted Forms to PHMSA

PHMSA now has two (2) options for downloading forms and instructions for reporting under various parts of 49 CFR 191 and 195:

  • A zip file containing ALL the potentially relevant forms and instructions can be downloaded here.
  • Alternatively, individual forms and instructions can be browsed and downloaded here.

Both links include both current and superseded (i.e. obsolete) versions of the forms and instructions, which can be helpful when analyzing historical data.

Update on PHMSA Rulemakings

PHMSA has posted a table summarizing the status and schedule for various rulemakings per the 2011 and 2016 pipeline safety acts. It can be found on the PHMSA website.

Project Report: Addressing Human Factors for Non-Destructive Evaluation In-The-Ditch

Non-destructive evaluation (NDE) is frequently performed in-the-ditch to evaluate potential pipeline defects that could impact safety and reliability, but these in-the-ditch inspections may lack accuracy and reliability due to human factors. PHMSA funded a project focused on this issue, led by Battelle. Extensive interviews, protocol reviews, field observations, and control tests with field pipe defects were systematically analyzed to identify and prioritize human factors which may adversely affect measurement results. Technology and human solutions were piloted.

PHMSA will host a teleconference on the project results on Wednesday, November 14, 2018, 2PM to 3PM Eastern. There will be a summary slideshow of the NDE project results with Q&A at the end.

  • Conference Call Line: 1 (877) 336-1839.
  • Access Code: 9849115

Additional information and final reporting on this NDE project can be found on PHMSA’s website. For questions, contact Robert Smith at (919) 238-4759 or via email.

FERC Guidance for Horizontal Directional Drill Monitoring, Inadvertent Return Response, and Contingency Plans (HDD Plan Guidance)

The Federal Energy Regulatory Commission’s (FERC) Office of Energy Projects (OEP) has developed draft Guidance for Horizontal Directional Drill Monitoring, Inadvertent Return Response, and Contingency Plans (HDD Plan Guidance), dated October 2018, to help industry professionals improve the quality and consistency of their HDD Plans and, as a result, increase the efficiency and effectiveness of the Commission’s environmental review. FERC is asking for public input and suggestions for modifications to the draft HDD Plan Guidance from federal and state agencies, environmental consultants, inspectors, the natural gas industry, construction contractors, and other interested parties with special expertise in regards to preparation of HDD monitoring and contingency plans associated with natural gas projects. Please note that this comment period will close on December 28, 2018.

The OEP staff anticipates issuing its final version of the HDD Plan Guidance in February 2019, and will consider all timely comments on the draft before issuing the final version. The draft HDD Plan Guidance can be found in Docket Number AD19-6-000, or click on this link.

Underwater Inspection Procedures & Inspection Interval Risk Model Updates

2018 has been one of the busiest hurricane seasons in recent history for operators with assets in the Gulf of Mexico and its inlets subject to 49 CFR 192.612 and 195.413. Because of the strength and number of tropical cyclones in the shallow waters of the Gulf it may be appropriate to re-evaluate the inspection intervals and risk assessments for shallow water piping. RCP’s proprietary Underwater Inspection Interval Risk Model analyzes key operator information and the latest storm data tabulated by the National Hurricane Center, as well as National Oceanic and Atmospheric Administration charts, and state game and fisheries department maps of navigational channels, shipping lanes, anchorage areas and commercial fishing locations to reassess previous risk rankings and inspection interval timelines.

For more information on RCP’s Underwater Inspection Procedure or Inspection Interval Risk Model, contact Jessica Foley.

Free Training on Pipeline Safety for Non-Pipeline Personnel

May 8 – 10, 2019, Houston, TX

The Pipeline Safety Trust (PST) received a grant in 2017 and again in 2018 to send 20-30 people from local and tribal government, and non-profit organizations to an in-depth training on pipeline safety. Their goal with this training is to provide attendees with the information they need to better understand pipelines and pipeline regulations. With this information, participants will be better able to understand the daily operations and potential risks from pipelines, and hopefully develop programs and engage in regulatory processes that address these risks more effectively. This training focuses on the safety of existing (or soon to be existing) pipelines, and will not get into other important related issues such as the impacts of oil and gas production methods, the impacts from the use of the fuels pipelines transport, or the regulatory system for the siting of new pipelines.

The training will be held May 8-10, 2019 and take place in downtown Houston, Texas. Over the course of this three-day training, attendees will learn how pipelines are constructed, operated, maintained, inspected and regulated, as well as a review of the different types of pipelines and the major failure causes and what is done to try to prevent those failures. The PST seeks to fund people who will continue to be involved in pipeline safety issues in years to come. This training will be provided by RCP at our headquarters in downtown Houston. All travel costs for the selected attendees will be paid by the Pipeline Safety Trust.

Application for the 2019 training is now open. To apply go fill out the short nine question application here. If you know of other people who might be interested in this training please forward them this notice.

For any questions send an email to or call at (360) 543-5686.

Editor’s Note: Those of you who work in the for-profit world should plan to attend RCP’s regular 3-day DOT training course on the following week, May 14-16. Please forward this notice to those people in the non-profit world who have a legitimate need and desire to understand pipelines and pipeline safety.

CGA Annual DIRT Report

The Common Ground Alliance (CGA) released their annual report which provides a summary and analysis of the events submitted into CGA’s Damage Information Reporting Tool (DIRT) which analyzes damage and near-miss events from excavation activities related to buried facilities. The complete report for 2017 is available for download on the CGA Website.

In addition, CGA is providing access to an interactive dashboard that allows users to filter the data more granularly by factors contributing to damages. Visit DIRT Report for 2017 Interactive Analysis to review the dashboard.

RCP Workshops – Which one should I attend?

Introduction to DOT Pipeline Regulations
The DOT pipeline workshop covers federal regulatory requirements and their applicability to both hazardous liquid and natural gas gathering, transmission, and distribution pipeline operators.

It is appropriate for people who are new to pipeline regulations, need a refresher course or better understanding of current and pending DOT rule makings as well as how they are applied to their job or their group, including operational, supervisory, and managerial personnel.

Fundamentals of Energy Transmission Pipelines (FETP)
The Fundamentals of Energy Transmission workshop provides participants an overview of how transmission pipelines operate and walks them through the practical things that a typical pipeline company does on a regular basis to operate and maintain the pipeline system as a whole.

It is appropriate for both technical and non-technical personnel who are new to the transmission pipeline industry, as well as those who need a broader understanding of the pipeline operations and management such as new hires, managers and executives from outside the pipeline industry, including attorneys, and business development professionals.

The table below gives some examples of the differences between these courses:

Introduction to DOT PL RegulationsFundamentals of Energy Transmission Pipelines
What are the regulatory requirements for energy transmission pipelines?Why do we have energy transmission pipelines?

How do they make money?

What do the operations and engineering people do in our company, and why?
What are the inspection requirements for a mainline valve?What are the different types of valves? When is each type used?
How are breakout tanks defined?What are the different types of tanks? When is each type used?
What is the definition of line pipe?How is pipe made? What are the important differences?
What are the requirements for integrity management?Why are we doing integrity management?
What are the procedure requirements for pumps and compressors?What are the various types of pumps and compressors, and how do they differ?

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.

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


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