DOT Pipeline Compliance News

October 2015 Issue

In This Issue

PHMSA NPRM: Safety of Hazardous Liquid Pipelines

[Docket No. PHMSA-2010-0229]

PHMSA has published a Notice of Proposed Rulemaking (NPRM) for the Hazardous Liquid Pipeline Safety Regulations in 49 CFR Part 195. This NPRM proposes to:

  • extend annual safety and incident reporting requirements to gravity lines and all hazardous liquid gathering lines;
  • require inspections of pipelines 72 hours after in areas affected by extreme weather, natural disasters, and other similar events;
  • require periodic assessments of pipelines that are not already covered under the IM program requirements at least once every 10 years;
  • expand the use of leak detection systems on hazardous liquid pipelines outside of HCAs;
  • modify the IM repair criteria by eliminating the 60-day and 180-day repair categories and adding a new consolidated 270-day repair category for HCAs; and,
  • increase the use of inline inspection tools by requiring that any pipeline that could affect an HCA be capable of accommodating these devices within 20 years unless its basic construction will not permit that accommodation.

PHMSA also seeks to clarify other existing requirements to improve compliance and enforcement. Notably, this includes requiring that an operator develop a written integrity management (IM) program before pipeline operations begin instead of the current one-year after operations begin (§195.452(b)(1)). PHMSA also proposes to specify pipeline attributes to be included within in the information analyzed for integrity management. Clarification on other IM requirements including deadlines and applicability to line pipes or facilities are also being sought in these updates.

Comments on this proposed rulemaking are due by January 8, 2016. For a copy of the NPRM, please contact Jessica Foley.

PHMSA Final Rule on Misc. Changes to Pipeline Safety Regulations

[Docket No. PHMSA-2010-0026; Amdt. Nos. 191-23; 192-120;195-100]

This final rule responds to petitions for reconsideration of the final rule that PHMSA published on March 11, 2015, amending the pipeline safety regulations to make miscellaneous changes that updated and clarified certain regulatory requirements. PHMSA is delaying the effective date of the amendment to 49 CFR 192.305 indefinitely. During this delay, PHMSA will be evaluating the ways operators are currently complying with § 192.305, developing guidance (based on input from industry and other regulatory bodies) and hosting a series of workshops on the guidance. Upon completion of this evaluation, PHMSA will determine the efficacy of the amendment and decide if any additional amendments to the current regulations are warranted and to propose any necessary amendments to § 192.305. Please note, the effective date for all the other amendments contained in the final rule remains October 1, 2015. Take note, this amendment did not change the hazardous liquids self-inspection limitations found within § 195.204 Inspection—general.

The amendments published on March 11th addressed several subject matter areas, including the performance of post-construction inspections, Type B onshore gas gathering line leak surveys, qualifying plastic pipe joiners, ethanol regulation, pipe transportation, offshore pipeline condition report filing, pressure reduction calculations for hazardous liquid pipeline anomalies, and components fabricated by welding.

The effective date of the amendment to 49 CFR 192.305, published at 80 FR 12779, March 11, 2015, is now delayed indefinitely. For a copy of this Final Rule, Response to Petitions for Reconsideration, contact Jessica Foley.

Introducing TestOp®

The software that RCP utilizes on-site to validate our customer’s pressure tests is now available to license. The license allows operators to create, plan, simulate, execute and generate comprehensive reports of pressure tests using a web-based platform with optional offline data upload capabilities. Some key features of TestOp® include:

  1. Useful for any pressure test conducted under
    • 49 CFR 192 Subpart J Test Requirements
      • Gas transmission
      • Gas distribution
      • Regulated gas gathering
      • 49 CFR 195 Subpart E Pressure Testing
    • ASME B31.3 Process Piping, Section 345 Testing
  2. All allowable test mediums
    • Water
    • Inert gas
    • Air
    • Natural gas
    • Petroleum
    • Carbon dioxide
  3. Applications
    • New construction
    • Repairs & replacements
    • Uprates
    • Conversion of service
    • Integrity / MAOP verification
    • Grandfathered pipe
    • Spike / elevated pressure testing
    • Pipeline integrity assessments, including ASME B31.8S, Table 3
Pressure Test Services

RCP is a leading industry expert on pressure testing. We design and validate pressure tests using a proprietary web-based program (TestOp®) that calculates the allowable pressure/temperature change for a particular test segment, confirming or denying the presence of pin-hole leaks while also detecting possible pipe yielding or air entrapment during a spike. RCP also offers Pressure Test Workshops that teach you how to plan for a pressure test from start to finish, and how to determine/prove if the test was successful.

To request a demonstration or obtain more information on RCP’s pressure test services, contact Jessica Foley.

Maine Gas Pipeline Regulation Updates

On October 7, 2015 the Public Utilities Commission in Maine updated their safety regulations for natural gas and liquefied natural gas facility operators. Along with minor clarifications, the rule may require Operators of gas pipelines to update both their Public Awareness Program and their OQ Written Program. In addition, requirements were added or changed for installing regulators, providing minimum cover for shallow mains; tracking materials installed in mains and service lines; filing plans with MPUC; providing copies of reports made to PHMSA to MPUC; and submitting monthly reports by the 20th of the month.

For a copy of this regulation update contact Jessica Foley.

TRRC Notice to Operators: Hazardous Liquid Accident Reporting Requirements

On September 21, 2015, the Railroad Commission of Texas (TRRC) issued a news release regarding hazardous liquid and carbon dioxide pipelines accident reporting requirements. In accordance with 16 Texas Administrative Code (TAC) §8.301, Required Records and Reports, an operator is required to notify the Railroad Commission of Texas (Commission) by telephone of any intrastate pipeline incidents involving hazardous liquids and carbon dioxide, which are required to be reported to the U.S. Department of Transportation under 49 CFR 195, Transportation of Hazardous Liquids by Pipeline.

The operator must report the following information to the Commission by telephone to 512-463-6788 or toll free to 844-773-0305 within two hours of discovery of the incident:

  • company/operator name;
  • location of leak or incident;
  • time and date of accident/incidents;
  • fatalities and/or personal injuries;
  • phone number of operator;
  • phone number of the operator’s on-site person; and
  • other significant facts relevant to the accident or incident, including information on ignition, explosion, rerouting of traffic, evacuation of any building and media interest.

If the operator is also required to file with the Commission a written report of the incident using the appropriate U.S. Department of Transportation form (Accident Report – Hazardous Liquid Pipeline Systems) within 30 days of discovery of an incident, the operator can submit confirmation and a copy of the accident report to the Commission via email to

To reference 16 TAC §8.301, visit the Texas Secretary of State website. If you have any questions, contact the Commission at or 512-463-7058.

TRRC Updates Website Domain, Email Addresses and more!

Effective September 1, 2015, the Railroad Commission of Texas (TRRC) has updated its website domain to

In addition to the website domain change, the TRRC email addresses have been updated. Emails directed to TRRC staff members should be sent to:

The new domain is consistent with the State of Texas government domain standard for state agencies. The previous website domain and email addresses will remain operational for a year-long transition period.

Also, there is a new URL to access webcasts and archives of the Railroad Commission’s open meetings, workshops, demonstrations and other special events. Please update your bookmarks or favorites to the new URL:

Information can be found on the Open Meetings webpage on TRRC’s website in the right panel under “Links” and “Webcasts”.

Public Awareness Emergency Response Guidelines

2015 Edition

The Pipeline Association for Public Awareness (PAPA) issued its 2015 edition of “Pipeline Emergency Response Guidelines.” The Guidelines provide tips and techniques needed to help protect life, property and the environment. The ERG can be downloaded from the PAPA website.

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.

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.

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