DOT Pipeline Compliance News

October 2009 Issue

In This Issue

PHMSA Advisory on Weldable Compression Couplings


The Pipeline and Hazardous Materials Safety Administration (PHMSA) recently issued Advisory Bulletin ADB-09-02 to the owners and operators of hazardous liquid and natural gas pipelines regarding weldable compression couplings. The background statement in the introduction to the advisory is rather lengthy, and describes numerous factors related to a specific incident in 2007 that resulted in 2 fatalities.

Advisory: PHMSA advises operators of hazardous liquid and natural gas pipelines installing or planning to install weldable compression couplings and similar repair devices to follow manufacturer procedures to ensure correct installation. In addition, PHMSA also advises these operators to follow the appropriate safety and start-up procedures to ensure the safety of personnel and property and protect the environment. The failure to install a weldable compression coupling correctly, or the failure to implement and follow appropriate safety and start-up procedures, could result in a catastrophic pipeline failure. PHMSA strongly urges operators to review, and incorporate where appropriate into operators’ written procedures, the manufacturer’s installation procedures and any other necessary safety measures for safe and reliable operation of pipeline systems.

For a complete copy of Advisory ADB-09-02, contact Jessica Roger.

EPA Mandatory Reporting of Greenhouse Gases Rule

EPA signed the final Mandatory Reporting of Greenhouse Gases (GHG) Rule on September 22, 2009. It should be published in the Federal Register in the next month. The rule requires that facilities that emit 25,000 metric tons or more per year of GHG emissions submit annual reports to the EPA. In 2010, the primary reporting obligation for pipeline operators will be reporting GHG emissions from fuel combustion sources (Subpart C) from facilities emitting above the GHG emission threshold. Some handy rules of thumb for activities that would emit 25,000 metric tons of GHG emissions are:

  • burning 2.8MM gallons motor gasoline,
  • 2.5MM gallons diesel fuel, or 457MM scf of natural gas (about $2M worth per year, at $5 / kscf); or
  • running an engine (or engines), assuming 35% efficiency, on diesel fuel full time for a year at 5,000 HP, or on natural gas at 7,000 HP.

A monitoring plan will be required at each location to document procedures for collecting data for GHG emission calculations, as well as QA/QC procedures.

The first reports are due March 31, 2011 for 2010 emissions. The primary reporting obligation will be for GHG emissions from combustion sources (Subpart C), i.e., engines, turbines, heaters, boilers, based on fuel consumption (flares are not included). There is more detail in the rule related to fuel measurement.

The EPA has delayed finalization of “Subpart W” for Oil and Natural Gas Systems. As a result, there is no requirement to submit reports for 2010 emissions from fugitives, tanks, vents, dehydrators, flares, treaters, etc. EPA may re-issue Subpart W as a proposed rule for public comment late this year or early 2010, with the goal to have this subpart finalized such that data collection can begin on January 1, 2011.

Data for the January – March 2010 period has a lower standard and allows using “best available data.” This allows 3 additional months to put the required measurement equipment in place. If more than 3 months are needed, an extension is available to use “best available data” through Dec. 31, 2010. Any requests for an extension must be submitted within 30 days after the rule is published in the Federal Register.

For more information click here.

Pending Audits?

Has the DOT notified you of a pending audit? RCP can provide confidential internal auditing to help ensure that your facilities are up to the agency’s latest standards.
Click Here.

API Updates Greenhouse-Gas Emissions Guide

The American Petroleum Institute has published a new edition of its guide for estimating greenhouse-gas emissions, the “Compendium of Greenhouse Gas Emissions Methodologies for the Oil and Natural Gas Industry.” The compendium provides standardized methods for estimating carbon dioxide and other GHG emissions from all common sources throughout the oil and natural gas value chain. The compendium and other tools for estimating emissions are available for free on API’s Website or by requesting a copy here.

TRRC Approves Pipeline Safety Program Fee Increase

The Railroad Commission of Texas (TRRC) has approved adoption of amendments to §8.201, relating to Pipeline Safety Program fees, without changes to the version published in the July 3, 2009 issue of the Texas register which increases the maximum annual natural gas pipeline safety inspection fee from $.50 per service line to $1.00 per service line. TRRC also adopted amendments to section 8.201 (b) to increase the annual assessment rate from $.50 to $.70 for each service line reported to be in service at the end of each calendar year by each system operator on the Distribution Annual Report, Form F7100.1-1 (to be filed on March 15 of each year) in order to meet the requirements of the pipeline safety program. (See related article in the DOT Pipeline News July 2009 edition.)

The effective date of the amendments is September 21, 2009.

For a copy of this final rule, contact Jessica Roger.

RCP Web-Based Tracking Systems

We’ve developed two (extremely handy) web-based applications that will organize your compliance information.

RCP’s Compliance Management System manages all of your permit requirements, inspections, procedures and data requirements. The Compliance Management System’s email reminders and document links provide you with the information that you need to stay in compliance with the hundreds of regulatory tasks.

RCP’s Leak Tracking System tracks all leaks through their life span and compiles the data into annual DOT reports or semi-annual TRRC reports. (The TRRC report can be quickly uploaded into the TRRC Electronic Document Interchange process.) RCP’s Leak Tracking System is customizable so that field personnel can load data from laptops or hand-held devices. It’s simple to use, easy to access and can be integrated so that the leak data can be automatically sent to your GIS system.

Because these are web-based applications, there are no IT issues to struggle through to get started. For more information on either of these systems, please contact Jessica Roger.

TRRC Proposed Amendments to LP Gas Safety Rules

The Railroad Commission of Texas (TRRC) has proposed amendments to §9.3 and §9.41 that would:

  • change the testing method of LP-gas systems in school facilities from pressure testing to leakage testing,
  • require school districts to retain testing documentation for five years, and
  • allows the Commission to review that documentation.

The proposed conforming amendments to §9.3 would add new LPG Form 30, Texas School LP-Gas Leakage Test Report. The Commission is requesting comments on the proposed amendments to the rules, as well as the proposed new form. Submit comments on the rules or the form by November 16, 2009 to: Rules Coordinator, Office of General Counsel, Railroad Commission of Texas, P.O. Box 12967, Austin, Texas 78711-2967; online at; or by electronic mail to For a copy of the proposed amendments and new LPG Form 30, contact Jessica Roger.

Pipeline Leak Detection and Monitoring Conference October 28, 2009 in Houston

Attend the Pipeline Leak Detection and Monitoring Conference (PLDM) in Houston on October 28 to hear RCP’s President Bill Byrd present methods for compliance with the pipeline leak detection requirements. The 2nd annual Pipeline Leak Detection & Monitoring Conference is the leading forum where newcomers, seasoned professionals and regulatory officials network together for the common purpose of improving pipeline operations and increasing public safety. The Conference will be held at The Omni Woodway. Click here to get more information about the conference.

Pipeline Safety Trust Conference November 5 & 6, 2009 in New Orleans

Meet us at the Pipeline Safety Trust Conference in New Orleans on November 5th and 6th at the Hotel Monteleone. The Pipeline Safety Trust brings together a unique mix of experience from the affected public, local government, the pipeline industry, and pipeline regulators to discuss the hard issues and create greater understanding to move pipeline safety initiatives forward. This year’s conference is going to focus on the new Community Technical Assistance Grants provided by the Pipeline and Hazardous Materials Safety Administration (PHMSA). Click here to get more information about the conference.

ASME Conference November 18, 2009

Attend the International Mechanical Engineering Conference and Exhibition for the Safety Engineering, Risk Analysis and Reliability Methods (SERAD) presentations track, co-chaired by our president Bill Byrd, on November 18, 2009. At the conference, you will get unique insights into engineering’s cutting-edge research and development and how it will determine the evolution of technology worldwide. You will also discover trend setting innovations and tools being showcased by industry leading companies. The conference will be held at the Walt Disney World Swan & Dolphin Hotel in Lake Buena Vista, Florida. Click here for more information on the conference.

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