DOT Pipeline Compliance News

October 2017 Issue

In This Issue

Underground Natural Gas Storage Facility Annual Report

[Docket No. PHMSA-2016-0016]

The Office of Management and Budget (OMB) has officially approved the annual report for Underground Natural Gas Storage Facilities. PHMSA regulations at 49 CFR 191.17 require each operator of an underground natural gas storage facility to submit an annual report on DOT PHMSA Form 7100.4-1 by March 15, for the preceding calendar year, except that the first annual report must be submitted by July 18, 2017. PHMSA extended the due date for the submission of the first annual report as stipulated in PHMSA’s posting on its website.

This annual report, originally required by July 18, 2017, would have captured data for the 2016 calendar year. PHMSA is revising the date of the first submission of the annual report. The first annual report now will be due on March 15, 2018, and will collect reported information for the 2017 calendar year. The Office of Pipeline Safety (OPS) will post this information and further filing instructions on the OPS website.

For further information contact: Crystal Stewart, Program Analyst, Office of Pipeline Safety Operations Systems Division, at 202-366-1524 or by email.

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.

DOT Notification of Regulatory Review

[Docket No. DOT-OST-2017-0069]

The U.S. Department of Transportation (DOT) is reviewing its existing regulations and other agency actions to evaluate their continued necessity, determine whether they are crafted effectively to solve current problems, and evaluate whether they potentially burden the development or use of domestically produced energy resources. There are two significant rules identified in the Notice that deal specifically with PHMSA ? pipeline safety:

  • PHMSA’s Final Rule on Pipeline Safety: Standards for Increasing the Maximum Allowable Operating Pressure for Gas Transmission Pipelines (RIN: 2137?AE25) (published on October 17, 2008, at 73 FR 62147) (annualized costs of $95 million); and,
  • PHMSA’s Final Rule on Pipeline Safety: Integrity Management Program for Gas Distribution Pipelines (RIN: 2137?AE15) (published on December 4, 2009, at 74 FR63905) (annualized costs of $95 million).

As part of these reviews, the DOT invites the public to provide input on existing rules and other agency actions that are good candidates for repeal, replacement, suspension, or modification. Comments are due on or before November 1, 2017. You may file comments identified by the docket number DOT? OST?2017?0069 on the Federal eRulemaking Portal and follow the online instructions for submitting comments.

For a copy of this DOT Notification with a complete list of regulations under review, contact Jessica Foley .

Florida One Call Legislation Revisions

The State of Florida has revised its excavation damage prevention regulations in Title XXXIII – Regulation of Trade? Commerce? Investments? and Solicitations; Chapter 556 – Underground Facility Damage Prevention and Safety, to require excavators that damage underground utilities resulting in a release of products regulated by PHMSA to call 911. It also requires the operator to report any damage to the one call system, at least annually. It also allows state agencies to share in revenues from penalties related to one call violations.

DOT Issues Nearly $2.5 Million in Grants to State Entities, Local Communities, and Non-Profit Organizations to Spur Involvement in Pipeline Safety Efforts

The U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) is issuing $2,488,497 in grants to state entities, local communities, and non-profit organizations to address pipeline safety challenges related to damage prevention and to promote more involvement in local pipeline safety initiatives and awareness efforts.

PHMSA is awarding $1,499,939 in State Damage Prevention (SDP) program grants to 16 states and Puerto Rico. Awarded annually, the grants are used to strengthen efforts in addressing pipeline failures attributed to activities such as excavation damage, one of the leading causes of pipeline accidents resulting in fatality or injury. The grants are also used to assist in establishing damage prevention programs where they do not currently exist. To accompany its SDP grants, PHMSA awarded a total of $988,558 in pipeline safety grants for technical assistance to 12 local community and non-profit organizations. PHMSA’s Technical Assistance Grant (TAG) program encourages local communities and non-profit organizations to help communities develop pipeline safety and education programs specific to their needs through technical assistance. Click here for more information and the complete breakdown of the SDP and TAG grant recipients and awarded amounts.

Gas and Liquid Technical Advisory Committee Meetings Rescheduled for December

[Docket No. PHMSA-2016-0136]

Due to the impact of Hurricane Harvey, PHMSA postponed the September public meetings of the Technical Pipeline Safety Standards Committee, also known as the Gas Pipeline Advisory Committee (GPAC) and a joint meeting of the GPAC and the Technical Hazardous Liquid Pipeline Safety Standards Committee, also known as the Liquid Pipeline Advisory Committee (LPAC). The rescheduled meetings are as follows:

  • Wednesday, December 13 ? Joint Meeting GPAC/LPAC – 8:30 a.m. to 5:00 p.m.
  • Thursday, December 14 ? GPAC Only ? 8:30 a.m. to 5:00 p.m.
  • Friday, December 15 ? GPAC Only ? 8:30 a.m. to Noon

The meetings will be held at the Hilton Arlington, 950 North Stafford Street, Arlington, Virginia 22203. Updated registration and agenda for the meetings will be published on the pipeline advisory committee meeting and registration page. For information about the meeting, contact Cheryl Whetsel by phone at 202-366-4431 or by email.

Meeting of the Voluntary Information-Sharing System Working Group

[Docket No. PHMSA-2016-0128]

The Voluntary Information-Sharing System (VIS) Working Group will meet at the Hilton Arlington, 950 North Stafford Street, Arlington, Virginia 22203 on November 29, 2017, from 8:30 a.m. to 5:00 p.m. and on November 30, 2017, from 8:30 a.m. to 5:00 p.m., ET.

The VIS Working Group is a recently created advisory committee. On December 15, 2016, the Secretary of Transportation (the Secretary) appointed 24 members to the committee. The first committee meeting convened on December 19, 2016. The last committee meeting was on June 29-30, 2017, to discuss existing integrity management regulations, assessment types and tools, geographic information system pipeline data, operator implementation, and the potential need for short-term subcommittees. The Secretary will publish the VIS Working Group’s recommendations on a publicly available DOT Web site. The VIS Working Group will fulfill its purpose once its recommendations are published online.

The VIS Working Group agenda will include briefings on topics such as the mission and objective of the VIS effort, best practices, examples of existing information-sharing systems, safety management systems, and the establishment of subcommittees. As part of its work, the committee will ultimately provide recommendations to the Secretary, as required and specifically outlined in Section 10 of Public Law 114-183, addressing:

(a) The need for, and the identification of, a system to ensure that dig verification data are shared with in-line inspection operators to the extent consistent with the need to maintain proprietary and security-sensitive data in a confidential manner to improve pipeline safety and inspection technology;

(b) Ways to encourage the exchange of pipeline inspection information and the development of advanced pipeline inspection technologies and enhanced risk analysis;

(c) Opportunities to share data, including dig verification data between operators of pipeline facilities and in-line inspector vendors to expand knowledge of the advantages and disadvantages of the different types of in-line inspection technology and methodologies;

(d) Options to create a secure system that protects proprietary data while encouraging the exchange of pipeline inspection information and the development of advanced pipeline inspection technologies and enhanced risk analysis;

(e) Means and best practices for the protection of safety and security-sensitive information and proprietary information; and

(f) Regulatory, funding, and legal barriers to sharing the information described in paragraphs (a) through (d).

The meeting agenda and any additional information will be published on the VIS Working Group and registration page . The meeting will not be web cast; however, any documents presented will be available on the meeting Web site and posted on the E-Gov website under docket number PHMSA-2016-0128 within 30 days following the meeting. This meeting will be open to the public. Members of the public who wish to attend in person are asked to register here no later than November 19, 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.

For information about the meeting, contact Cheryl Whetsel by phone at 202-366-4431 or by email at

MAOP Validation Services

RCP is the market leader in providing MAOP Validation Services, including over 100,000 miles of gas and liquid pipeline analysis and support. Whether you are just getting started, need help finishing, or not sure what to do next, RCP has a wealth of experienced professional engineers and support staff to assist in your MAOP validation efforts.

  • Turnkey: document review & imaging, data extraction, gap analysis, MAOP reporting
  • Document Grading: grade documents to determine TVC compliance
  • Traceable, Verifiable, and Complete: connects MAOP data to source document image files and identifies exact 192/195 code sections driving MAOP results
  • Audit: Provides a precise audit trail and calculation for each individual component or piece of pipe in a system
  • Written Procedures: Develop and/or improve company MAOP standards and procedures
  • Quality Assurance: review existing validation efforts, compare calculations using MaxOp
  • Reporting: Import data to MaxOp, export Section Q & R report, gap reports, and calculations
  • Remediation: develop risk and cost based strategies to prioritize, schedule, and mitigate MAOP gaps using field verification, pressure tests, additional data searches, or other engineering tools

For more information about RCP’s MAOP validation services or the MaxOp* calculator tool, please contact Jessica Foley.

MaxOp is a registered trademark of RCP, Inc., in the United States. RCP holds 3 patents (#8,548,756; #8,548,757; and #8,548,758) for our industry-leading MaxOp* software and MaxOp is a registered trademark of RCP, Inc., in the United States.

Coastal and Marine Safety, Prevention and Emergency Response Meeting

October 11, 2017 – Luling, LA

The Coastal and Marine Operators (CAMO) group was developed several years ago with a goal to diminish the gap between onshore and offshore spills, releases, and pipeline damage prevention. CAMO is hosting this Coastal and Marine Safety, Prevention and Emergency Response Meeting on Wednesday, October 11, 2017, from 11:00 AM to 2:00 PM.

Who should attend: all Marine Stakeholders, Responders, Vessel Companies and Fishermen. There is no cost to attend and lunch is provided. The meeting will facilitate dialog, awareness and ideas on prevention and response measures among a wide variety of mariners with oil and gas companies. Topics will include: Maritime Pipeline Safety, US Coast Guard, Accident Prevention and Response, Incident Reviews, Issue Scoping, and meet CAMO companies.

The meeting will be held at the Dufresne Community Center (Below the I-310 Hale Boggs Miss. River Bridge) at 274 Judge Edward Dufresne Parkway in Luling, LA. Space is limited. Please RSVP number attending and for lunch count to Ed Landgraf. For more information contact: Ed Landgraf at or (985) 209 4753.

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.

PRCI Program Manager Job Posting


The Pipeline Research Council International (PRCI) is seeking qualified applicants for the position of Program Manager, Integrity & Inspection. The Program Manager is responsible for the day-to-day management of PRCI research contracts and plays a number of key roles, including to facilitate the participation of PRCI member company technical representatives in the planning, implementation and management of the PRCI research program. The program is comprised of a large set of individual research projects that span a range of pipeline design, operation and integrity management issues. The Program Manager works closely with research contractors, member company representatives and other PRCI staff, and reports directly to the PRCI Vice-President, Operations. The position is located at the PRCI Technology Development Center in Houston, Texas. Excellent communication skills, the ability to work in a collaborative environment, a working knowledge of current pipeline integrity management issues and being a self-starter are key requirements of the position. Click here for the full job posting. Please send a resume and a brief letter of interest, via email, to Mike Whelan at Additional information about PRCI can be found at .

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

Best regards,

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