DOT Pipeline Compliance News

October 2020 Issue

In This Issue

PHMSA ADB-2020-01 Pipeline Safety: Meters and Regulators Inside Buildings

[Docket No. PHMSA-2020-0115]

PHMSA issued an advisory bulletin to alert owners and operators of natural gas distribution pipelines to the consequences of failures of meters and regulators inside buildings. PHMSA is also reminding operators of existing Federal regulations covering the installation and maintenance of meter and regulators inside buildings, including the integrity management regulations for distribution systems to reduce the risks associated with failures of meter and regulators inside buildings installations.

For a copy of Advisory Bulletin ADB-2020-01, contact Jessica Foley.

PHMSA ADB-2020-02 Overpressure Protection on Low-Pressure Natural Gas Distribution System

[Docket No. PHMSA-2020-0025]

PHMSA issued an advisory bulletin to remind owners and operators of natural gas distribution pipelines of the possibility of failure due to an over-pressurization on low-pressure distribution systems. PHMSA also reminds pipeline operators of their obligations to comply with the gas DIMP regulations at 49 CFR Part 192, Subpart P. 

PHMSA encourages operators to review the NTSB’s Pipeline Accident Report concerning Columbia Gas of Massachusetts’ over-pressurization event in the Merrimack Valley on September 13, 2018. It may be instructive regarding a host of potential safety problems that operators of low-pressure natural gas distribution systems may need to address. A copy of NTSB’s accident report is contained within Docket No. PHMSA–2020–0025 for this advisory bulletin.

For a copy of PHMSA’s ADAB-2020-02, contact Jessica Foley.

Mega Rule FAQs

[Docket Number PHMSA-2019-0225]

On September 15, 2020, PHMSA posted Batch 1 FAQs on the Gas Transmission Final Rule (aka Mega Rule) to assist gas transmission pipeline operators in complying with the pipeline safety regulations in 49 CFR Parts 191 and 192. The FAQs include PHMSA’s responses to public comments and address a number of issues including compliance deadlines, reporting requirements, moderate consequence areas, spike hydrostatic testing, material verification, MAOP establishment and reconfirmation, non-HCA assessments, and more.

If all of these FAQs are too overwhelming for you Really Cool People, it’s not too late to sign up for RCP’s Virtual Mega-Rule Workshop.

PHMSA Announces Nearly $8 Million in Pipeline Safety R&D Awards

PHMSA announced an award package totaling $7,810,213. The awards will fund 10 pipeline safety research and development (R&D) projects that address pipeline safety priorities including Damage/Threat Prevention, Leak Detection, Anomaly Detection/Characterization, Liquefied Natural Gas (LNG), and Improved Materials. Project awardees will contribute an additional $4,082,308 in cost-share funds.

A Merit Review Panel consisting of 28 members from PHMSA, FERC and the pipeline and LNG industries reviewed 21 project applications. PHMSA solicited proposals for a total of 13 research topics. Read the complete list of awarded projects here. For more information on PHMSA pipeline R&D projects, read here.

California Adopts New Article 7 for Risk Analysis and Best Available Technology for Minimizing Releases from Hazardous Liquid Pipelines

California’s Office of the State Fire Marshal has adopted requirements that govern the requirements for hazardous liquid pipeline construction and operation near environmentally and ecologically sensitive areas in the Coastal Zone. Hazardous liquid pipeline operators are required to conduct and submit a Risk Analysis with associated Implementation Plans to the State Fire Marshal for detecting and minimizing releases. The Office of the State Fire Marshal will determine what will be best available technology for detection and for minimizing releases from these pipelines.

Enforcement of the pipeline Risk Analysis submittals for new pipelines begins May 1, 2021. Existing Pipelines in the Coastal Zone subject to the requirement must have the risk analysis and an implementation plan to retrofit the pipeline with the best available technology by October 1, 2021, and the implementation plan completed by April 1, 2023.

Chapter 14. Hazardous Liquid Pipeline Safety, Article 7 can be found on the California Code of Regulations webpage.

Corps of Engineers NOPR to Reissue Nationwide Permits 2 Years Ahead of Schedule

[Docket No. COE-2020-0002]

On September 15, 2020, the U.S. Army Corps of Engineers (Corps) published a Notice of Proposed Rulemaking (NOPR) to replace the 2017 Nationwide Permits (NWPs) by the end of 2020. NWPs provide a streamlined process for the Corps to authorize work in streams, wetlands, lakes, and tidal waters under Section 404 of the federal Clean Water Act.

The Corps is proposing to reissue its existing NWPs and associated general conditions and definitions, with some modifications. They are also proposing to issue five new NWPs.

They are proposing to divide the current NWP 12, that authorizes utility line activities, into three separate NWPs that address the differences in how different linear projects are constructed, the substances they convey, and the different standards and best management practices that help ensure those NWPs authorize only those activities that have no more than minimal adverse environmental effects. Specifically, the Corps is proposing to modify the current utility line NWP 12 to authorize only oil and natural gas pipeline activities.

The Corps is requesting comment on all aspects of these proposed nationwide permits. Submit comments on or before November 16, 2020 on the Federal eRulemaking Portal, and include the Docket Number COE-2020-0002.

For a copy of the Corps NOPR, contact Jessica Foley.

Michigan Gas Regulation Changes

The Michigan Public Service Commission has made a number of minor changes to its regulations in Chapter 460, Technical Standards for Gas Service.  It also added a new section regarding security reporting, a new section on statistical quality sampling program for diaphragm-type meters, and incorporated a number of industry standards. 

Washington State’s Proposed New Reporting Requirements for Crude Oil Movement by Rail and Pipeline

[Chapter 173-185 WAC]

The Washington State Department of Ecology proposed new reporting requirements for pipeline and rail transport of crude oil. These new requirements include reporting the gravity, vapor pressure and the type of crude oil. The new information will be reported to the Utilities and Transportation Commission (UTC). Three Public Hearings are scheduled  through online Webinars :

  • October 7, 2020 – 1 p.m.
  • October 13, 2020 – 10 a.m.
  • October 20, 2020 – 6 p.m.

The deadline for comments is November 1, 2020.  More information on this rule making can be found on the Washington State Department of Ecology webpage.

Washington State New Reporting Requirements for Gas Pipelines

[RCW 81.88.160]

Starting March 15, 2021, gas pipeline operators will be required to file an annual report with Washington’s State Department of Ecology. The reporting requirements include information about the number and size of gas leaks, pipeline repair activities, and the scheduling of future pipeline repairs. The information reported will be included in the estimated volume of the State’s greenhouse gas emissions.

Mega-Rule #1: Gas Transmission Regulation Deep Dive Virtual Workshop

Join us October 13th – 15th for a virtual deep dive into the recently finalized Safety of Gas Transmission Pipelines rule. The virtual format for this is unlike anything you have experienced before.  Attendees will receive links to the workshop materials two weeks prior to the start of the three separate live stream Q&A sessions. They will be able to review these materials at their own pace and schedule before joining the sessions with the other attendees and the trainers.  Attendees will have the ability to chat and post questions in a live forum during the pre-read period and during live Q&A sessions.  There will be homework, yes you heard that right, to ensure attendees understand how to apply what they have learned.  During the live Q&A sessions, trainers will work through the homework and answer questions from the attendees.

What You Will Learn

There is a lot to unpack with this rule.  This workshop will not only dive deep into the rule requirements and some of its nuances; there will also be several practical and interactive exercises for the audience to perform, ensuring they come away knowledgeable not only with “what” is required, but also “how” to conduct certain analyses that are new to the gas transmission pipeline regulations. These exercises will include how to conduct an Engineering Critical Assessment, how to develop material sampling plans based upon various population factors, how to determine TVC records and extract the required data for validated MAOP calculations, and how to plan and execute a spike test.  RCP has partnered with Mike Rosenfeld for portions of this workshop, so you are sure to learn from the best in the industry.

Workshop Materials

Each attendee will receive access to all presentation and homework assignment materials two weeks prior to the live Q&A sessions.

About the Trainers

RCP trainers have a wealth of industry experience and provide participants a practical perspective on operations and maintenance activities at a level all can understand and are very effective in answering any questions.

Mike Rosenfeld is an experienced consultant in pipeline fitness for service, pipeline integrity, pipeline design and construction, causes of pipeline failures, pipeline regulations and standards, and related matters. He has performed numerous pipeline failure investigations and root cause failure analyses; research funded by the pipeline industry on the effects of mechanical damage, fatigue, pipeline integrity threat interactions, and methods to determine the probable grade of undocumented pipe materials; engineering analyses of a broad range of design, operations, or integrity matters for numerous pipeline operators; and provided expert support in litigation. He chairs the Subgroup on Design, Materials, and Construction of the ASME B31.8 Gas Transmission and Distribution Piping Committee and serves on other ASME piping standards development committees. Mr. Rosenfeld has authored or co-authored over 90 published articles or public presentations dating to 1988, is an ASME Fellow, and is a Professional Engineer registered in the State of Ohio. He previously worked with Kiefner & Associates (27 years), Battelle (6 years), and Impell Corporation (4 years). He earned a Bachelor of Science in Engineering from the University of Michigan (1979) and a Master of Engineering from Carnegie-Mellon University (1981).

Chris Foley has a deep understanding of the new gas transmission regulation, including participating on the Joint Industry Trade Association Task Group to prepare for and submit comments throughout the Gas Pipeline Advisory Committee process.  Mr. Foley owns three patents for MaxOp, which is widely considered the gold standard used across the gas and hazardous liquid pipeline industry for MAOP validation. He serves on the ANSI GPTC Z380 Gas Piping Technology Committee and the American Gas Association Engineering Committee.  Mr. Foley has almost 30 years’ experience developing and implementing engineering and regulatory compliance solutions and technology for the oil and gas industry. He earned a Bachelor of Science in Industrial Engineering with a specialty in Systems Safety Engineering from Texas A&M University.

Virtual Workshop Pricing

$575.00 if registered two weeks prior to start of workshop.

For more information or to register for this course click here.

What makes RCP’s online training different?

Our online training has been built from the ground up to make the most use of the virtual learning environment. We’ve re-organized our training material into 5-10 minute bite-sized topics, and made them all available in a format that allows students to take them in any order and at any time. Topics include a video presentation, as well as external reference links and thumbnails of the slides. At the close of each lesson we will have a short quiz. The class includes live Q&A sessions each day to address questions, work through example problems, and review the quizzes.

Students will have the ability to browse the material in the manner that best suits their learning style. They can choose to watch all the topic videos, click-through the slides to skip topics they already know, browse through the reference materials and links, or a combination of all those things. They can spend more time on topics of bigger interest and skip the ones they don’t need to review (a liquid transmission operator probably isn’t interested in gas distribution topics). A three-day in-person course can be done in three days online by watching the appropriate videos each morning and attending the live Q&A sessions in the afternoon. Or, students can review the online materials in advance as their schedule allows and just log on for the live Q&A sessions when scheduled.

While there is no substitute for in-person training, we have done our best to create the next-best thing. We hope you will agree.

DOT Pipeline Compliance Virtual Workshop

November 3-5, 2020

Join us November 3-5, 2020 virtually for an informative, lively, and interactive workshop on DOT Pipeline Compliance topics. This Workshop will give a brief overview of the new rules, in addition to our standard overview of the DOT pipeline regulations in 49 CFR 191, 192, 194, 195, 196, and 199. It also describes pipeline operations and engineering concepts. It is appropriate for people who are new to pipeline regulations, who could use a refresher, or anyone who needs to know the latest developments in these areas. This workshop will be a combined format, addressing both gas and liquid pipeline topics in parallel. This will eliminate some redundancy of materials, and will allow more time for in-depth discussions for each topic.

Topics to be addressed in the workshop include:

  • An overview of DOT/OPS pipeline compliance requirements
  • State and Federal agency roles for pipeline safety
  • PHMSA Jurisdiction
  • PHMSA Inspections and Enforcement Processes
  • Engineering Concepts and Stress/Strain Relationships; %SMYS
  • Design Requirements
  • Construction Requirements
  • Corrosion Control Concepts and Requirements
  • Operations and Maintenance Requirements
  • Emergency Response Requirements (including spill response planning requirements for liquid pipelines)
  • Damage Prevention Programs
  • Operator Qualification Programs
  • Drug and Alcohol Programs
  • Public Awareness Programs
  • Integrity Management (gas and liquid) Programs
  • Control Room Management Programs

We will also discuss the PIPES Act of 2016; recent Advisory Bulletins from PHMSA; and new, pending and proposed rulemakings.

Each attendee will receive an electronic copy of the presentation as well as applicable handouts, and applicable regulations and voluminous reference materials including rulemakings, letters of interpretation, and other guidance documents.

To register for our workshop, click here.

2020 Industry Conference Schedule

The Year of the Virtual Conference Season!

APGA Operations Virtual Conference
(October 19 – November 6)
The APGA Fall Committee Meetings and Operations Conference will kick off on Monday, October 19, with a 90-minute morning session and a 90-minute afternoon session with a break in between. Then sessions will be two-hour blocks spread out over three weeks on Tuesdays (Operations & Engineering Track), Wednesdays (Transmission Pipeline Track), and Thursdays (Safety & Compliance), with one-hour bonus sessions on Fridays.

Save the date for October 28 – APGA Transmission Pipelines Track at 2:00 pm ET.
Michael Berg, RCP’s Director of Integrity Programs will be speaking on the “Gas Transmission Pipeline MAOP Reconfirmation Options.”

LGA Operations Conference – POSTPONED!
LGA’s Annual Operations Conference that was scheduled for October 25-28 has been postponed until March 14-17, 2021.  It will be held at the Vidalia Conference & Convention Center in Vidalia, LA.

2020 International Pipeline Conference Wrap Up

Your humble newsletter editor is honored to have served as the chair of the 2020 International Pipeline Conference (and relieved that it is all over!). The conference was held virtually for the first time but still included more than 200 peer-reviewed technical papers on cutting-edge energy pipeline research from throughout the world. Recorded presentations for these papers, as well as the technical papers themselves, will be available to registrants through Oct 30, 2020. A highlights video of the conference featuring many of the presenters and key participants is available here.

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


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