DOT Pipeline Compliance News

October 2018 Issue

In This Issue

Comments Posted for PHMSA ANPRM “Pipeline Safety: Class Location Change Requirements”

On July 31, 2018 PHMSA issued an Advance Notice of Proposed Rulemaking (ANPRM) seeking public comment on its existing class location requirements for natural gas transmission pipelines as they pertain to actions operators are required to take following class location changes due to population growth near the pipeline. (See related article in the August 2018 edition of the DOT Pipeline Compliance News.)

Operators have suggested that performing integrity management measures on pipelines where class locations have changed due to population increases would be an equally safe but less costly alternative to the current requirements of either reducing pressure, pressure testing, or replacing pipe.

Comments were due October 1, 2018 and roughly 25 submittals were made by the general public, state regulators, inline inspection vendors, pipeline operating companies and industry trade associations. To view the comments submitted, click here. Comments made by the joint industry trade associations (AGA, APGA, API and INGAA) include specific redlined text for which they recommend modifications to §192.611 Change in Class Location: Confirmation or revision of maximum allowable operating pressure.

Texas RRC T-4 Pipeline Permit Fees Start in October

Operators of intrastate pipelines, which are pipelines that begin and end in Texas, are required to file a T-4 pipeline permit with the Commission and renew these permits every year. Beginning October 1, the Commission will charge a $500 permit processing fee for each new and renewed permit. The permit fee is one of two new fees authorized by the Texas Legislature to fund the TRRC’s pipeline safety regulatory program. Operators’ annual pipeline mileage fees were due to the Commission on August 31.

The permit renewal date for a pipeline operator who has an existing permit in the Commission’s online filing system will be the date shown in the online filing system on June 29, 2018, when pipeline mileage was calculated for operators. A permit renewal date will not be affected or changed by an operator requesting or receiving a permit amendment.

Operators are required to use the Commission’s Pipeline Online Permitting System (POPS) to file an application for a new permit, renew an existing permit, amend an existing permit, or cancel an existing permit and to pay any associated fees. This system will be available beginning October 1.

For more details on the requirement to file and renew a T-4 permit with the Commission, see Rule §3.70 Pipeline Permits Required. Questions about pipeline permit fees or pipeline permits may be directed to 512-463-7058 or

RCP has been providing HCA, Class Location, Mapping and Permitting services for our Texas clients since 1995. If you need help renewing, revising or filing for new T-4 permits in Texas, contact Jessica Foley at

Illinois Proposed Amendment to Accident Reporting

Ill Register, Vol. 42, Issue 38 [Docket No. 18-1447]

The proposed amendment for 83 Ill. Adm. Code 220, Reports of Accidents by Fixed Public Utilities Other Than Pipelines Transporting Liquids, would change Section 220.60, Instructions for Reporting, to increase the monetary threshold in subsection (a) for required reports of accidents not involving death or personal injury. The proposed amendment would raise the dollar amount from $1,000 in damages to the property of the utility to $20,000 in damages. This proposed change applies to intrastate gas utilities.

Submit comments within 45 days after the date of this issue (9/21/2018) of the Illinois Register, in Docket No. 18-1447 to: Elizabeth Rolando, Chief Clerk, Illinois Commerce Commission, 527 East Capitol Avenue, Springfield IL 62701.

For a red-lined copy of the proposed amendment, contact Jessica Foley.

New Mexico One Call Law Change

NMR, Vol. 29, Number 18, 09/25/2018 [Case No. 18-00262-PL]

The New Mexico Public Regulation Commission (Commission) gave notice of proposed revisions to Part 5 of Title 18, Chapter 60 of the New Mexico Administrative Code (18.60.5 NMAC) regarding Excavation Damage to Pipelines and Underground Utility. The purpose of the proposed rulemaking is to clarify that the rule applies to all underground facilities, with the exemption of those preempted by federal law; to implement or revise particular procedures, reporting requirements, and deadlines used to prevent damage to underground utilities; and to address procedures to be taken when damage occurs during pipeline excavation activities.

Written comments may be filed with the Commission’s Records Management Bureau at P.O. Box 1269, Santa Fe, NM 87504-1269 or by hand delivery to the Commission Records Management Bureau at 1120 Paseo de Peralta, Room 406, Santa Fe, NM 87501 by no later than October 31, 2018, Reference Case No. 18-00262-PL when submitting comments. All written comments will be posted on the Commission’s website under Case No. 18-00262-PL.

A rulemaking public hearing will be held on November 16, 2018 beginning at 2:00 p.m. at the offices of the Commission located in the 4th Floor Hearing Room of the old PERA Building, at 1120 Paseo de Peralta, in Santa Fe. The purpose of the rulemaking public hearing is to receive oral comments about the proposed rule revisions.

For a redlined copy of the proposed changes, contact Jessica Foley.

Delaware Damage Prevention Rule Change

On October 2, 2018, the Delaware Underground Utility Prevention and Safety Act (Title 26 Chapter 8 Subchapter I) was updated to require Operators to report all facility damage, as defined in Title 26 Section 802(2)(c), caused by excavation that exceeds $3,000 within 15 days to the Public Service Commission. If the notification cannot be made within 15 days, it must be made as soon as practicable. The rule does not require notification of damage to abandoned lines. However, any such damage to gas distribution and transmission lines, oil and petroleum products distribution and transmission lines, or dangerous materials, product lines or steam lines must be reported as soon as practicable.

Each notification may be reviewed by the Public Service Commission and the Attorney General to determine if a penalty will be imposed based off the circumstance and seriousness of the violation. It should also be noted that an individual receiving such a civil penalty may also incur additional civil damages for personal injury.

Pressure Test Basics and TestOp® User’s Group Meeting

November 1, 2018

Registration is now open for RCP’s first Pressure Test Basics and TestOp® User’s Group Meeting at its facilities in downtown Houston. (This meeting is for Operators only.) During the morning session, attendees can expect to gain a basic understanding of how to plan, design, analyze, troubleshoot and document a pressure test. The afternoon session is open to all current and potential TestOp clients and provides an opportunity to meet other license-holders as well as learn more about the current and proposed features.

Morning: Pressure Test Basics
  • Pressure Test Acceptance Criteria
  • Analyzing the pressure test data & troubleshooting
  • Designing a Pressure Test
  • Pressure Test Myths and Misinformation
  • Case Studies
Afternoon: TestOp Users Group Meeting
  • Training for new and existing TestOp license-holders
  • Discussion of new features to be implemented in next update
  • Discussion of requests from TestOp license-holders for improvement
  • Opportunity to complete competency test (Part 2 training) for Energy Transfer users

You are invited to attend the morning and/or afternoon session. Each attendee of the morning session will receive a hard copy of the presentation. Lunch and refreshments will be provided.

To register for this 1-day event, click here.

PHMSA Awards $90 million in Grants to Support State Pipeline and Hazardous Materials Safety Programs

The U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) is issuing a combined $89.9 million in Fiscal Year 2018 grants from its Pipeline and Hazardous Materials Safety programs. The grants will be awarded to states, local communities, tribal entities, and non-profit organizations to support state pipeline and hazardous materials safety programs. Grantees will use awarded funds to train first responders; educate the public on local safety initiatives, including pipeline damage prevention; and develop community incident response plans.

PHMSA will award $3.7 million to four states as part of a new federal-state partnership in the oversight of underground natural gas storage safety. Other grants to states include $56 million Pipeline State Base Formula Grants to 46 states, the District of Columbia, and Puerto Rico to support their participation in the federal-state base pipeline safety program, as well as $20.5 million in Hazardous Materials Emergency Preparedness (HMEP) grants to all 50 states, five U.S. territories, and eight federally recognized Tribes and Tribal organizations. The other grant awards include:

  • $1.1 million under One Call Grants to support 46 projects in 31 states
  • $3.6 million under Hazardous Materials Instructor Training (HMIT) grants
  • $1 million under Supplemental Public Sector Training (SPST) grants
  • $1.5 million under the State Damage Prevention Program (SDPP) grant that will support 24 projects in 24 states
  • $1.5 million under Technical Assistance Grants (TAG) for 20 projects in 14 states
  • $1 million under Community Safety Grants (CSG) that will support three projects in three states.

PHMSA will continue to support states and localities in further promoting the use of 811, so that everyone knows to Call Before You Dig. PHMSA also issued several additional grants to state entities, local communities, and non-profit organizations to support the design and implementation of hazardous materials planning and training programs, projects that address pipeline safety challenges related to damage prevention, and projects that promote more involvement in local pipeline safety awareness.

For additional grant information and a detailed listing of states, territories, tribes, and organizations receiving PHMSA’s FY18 safety grants, visit PHMSA’s website.

PHMSA Awards $3.8 Million to 11 Universities to Support Pipeline Safety Tech Research

The U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration’s (PHMSA) announced that it is providing a total of $3,855,575 to 11 universities as part of its Competitive Academic Agreement Program (CAAP) for pipeline safety research and innovation. The awards will go to: Arizona State University, The Ohio State University, The University of Akron, University of Alaska-Anchorage, University of Texas at Austin, Montana State University, and the University of Oklahoma to spur the development of research projects that could prevent or mitigate pipeline corrosion.

“This funding supports engineering and science students at universities across our country engaging in innovative solutions to some of our greatest challenges in pipeline safety,” said PHMSA Administrator Skip Elliott. “Students participating in CAAP research projects will evaluate new approaches to reducing corrosion across our nation’s 2.7 million mile pipeline network.”

Established in 2013, the CAAP, through cooperative agreement awards, has invested more than $5.9 million in research, and is responsible for introducing science and engineering students to pipeline design, mitigation, and corrosion issues as part of 33 sponsored projects. Previous CAAP projects to advance pipeline safety include measuring pipe strength, corrosion prevention, and detecting methane emissions.

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?

2018 Industry Conference Schedule

October 10, 2018
San Luis Hotel, Galveston, TX

October 15-18, 2018
Hyatt Regency Austin, Texas
Stop by RCP’s Booth #10

API Storage Tank Conference & Expo will give attendees an opportunity to learn about new and existing industry codes and standards, and to hear about emerging trends from industry experts. This conference offers over 25 sessions addressing the needs of individuals involved in production systems, pipelines, terminals, refining and chemical manufacturing, and storage facilities. Each day focuses on presentations relevant to upstream, midstream and downstream.

October 18-19, 2018
Hotel Monteleone, New Orleans

Each year since 2006, the Pipeline Safety Trust has hosted pipeline safety conferences. What makes them unique among pipeline conferences is the mix of attendees, who come with experience as the affected public, the pipeline industry, and government regulators. All these people come together to discuss barriers to safer pipelines.

October 30-November 1, 2018
The Chattanooga Hotel
Chattanooga, TN

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.