DOT Pipeline Compliance News

September 2007 Issue

In This Issue

DOT Pipeline Compliance Workshop – September 25 & 26

RCP will be hosting our very popular workshop on DOT Pipeline Compliance on September 25 and 26 in Houston, TX. Join us for an informative, lively, and interactive workshop on DOT Pipeline Compliance. This workshop has been attended by hundreds of pipeline personnel, with excellent feedback. The workshop provides an overview of the DOT pipeline regulations, and is appropriate for people who are new to pipeline regulations, or who could use a refresher.

Day 1 (September 25): Gas Pipeline Regulations (49CFR192): Covering all the topics below but special emphasis will be placed on the changes in **GAS GATHERING** regulations.

Day 2 (September 26): Liquid Pipeline Regulations (49CFR195)

Each day of the workshop will address the following issues as they specifically relate to either Gas or Hazardous Liquid pipelines:

  • PHMSA Overview
  • PHMSA Jurisdictional Boundaries
    • Production / Gathering / Transmission
    • Onshore / Inlets to the Gulf of Mexico / Offshore
  • Compliance Requirements:
    • Design
    • Construction
    • Operation
    • Maintenance
    • Corrosion
    • Testing
    • Integrity Management
    • Operator Qualification
    • Emergency Response
    • Reporting
  • New/Proposed Regulations

For additional information, including a seminar brochure, go to our website here.

RCP’s Website

If you haven’t checked out our website recently, we encourage you to do so now. Same web address with a new look, easier to navigate, search capabilities and a client log-in feature. Visit us at

PHMSA Published Gas Gathering FAQ’s

PHMSA has posted several Frequently Asked Questions relating to Onshore Gas Gathering. Since the issuance of the new gas gathering regulations in 2006, PHMSA has hosted several industry workshops in an attempt to review the new gas gathering regulations and answer questions regarding its interpretation of API RP 80. The FAQ’s include several schematics that represent PHMSA’s interpretation for issues such as

  • Gas gathering endpoints
  • Gas processing
  • Gas compression
  • Point of last commingling
  • Classification of fuel gas return lines
  • Implementation and compliance
  • End of production

For a copy of the Onshore Gas Gathering FAQ’s, contact Jessica Roger.

Has the new Gas Gathering definition affected your pipelines?

RCP can conduct a detailed analysis of your gas pipelines to determine end points of production and gathering based upon the recently finalized definition of gas gathering pipelines. The analysis will also determine whether your gathering pipelines are regulated and whether they are classified as Type A or B regulated gas gathering. For more information, click here.

PHMSA Issues Hazardous Liquid IMP FAQ’s

PHMSA has published two new Frequently Asked Questions and updated a previously published FAQ regarding hazardous liquid integrity management.

FAQ # 6.32
Can the “ECDA” assessment option be applied to significant portions of above ground portions of pipelines that cannot be assessed with ILI tools or hydrostatic testing?

No. Per 195.588 (b) (1), the use of direct assessment on an onshore pipeline to evaluate the effects of external corrosion must follow the requirements of NACE Standard RP0502–2002. As stated in NACE RP0502-2002 Section 1.1.5 “ECDA as described in this standard is specifically intended to address buried onshore pipelines constructed from ferrous materials.” While the NACE standard (Section does, in certain cases, allow for the substitution of 100% direct examination at bellhole locations in lieu of a minimum of two indirect examination tools, PHMSA does not apply this exception to significant lengths of above ground piping. Operators may be able to technically justify a “direct” approach for assessing above ground lines, but such approaches are considered to be “other technology” that require a Notification to PHMSA per 195.452 (c) (1) (i) (D) and 195.452 (j) (5) (iv).

FAQ # 9.13
Can the evaluation of additional preventive and mitigative (P&M;) measures be excluded for portions of HCA-affecting lines determined to be sufficiently “low” in risk by an operator’s risk analysis process?

No. 195.452 (i) (1) requires that “An operator must take measures to prevent and mitigate the consequences of a pipeline failure that could affect a high consequence area. These measures include conducting a risk analysis of the pipeline segment to identify additional actions to enhance public safety or environmental protection.” Therefore, regardless of the perceived level of risk, additional P&M; measures must be identified and evaluated. This is particularly important when qualitative-oriented risk analysis approaches are utilized that classify risk levels on a relative basis. Risk that is judged to be “low” relative to other pipeline sections does not necessarily imply that risk cannot be reasonably lowered via additional or enhanced P&M; measures.

The rule, however, does not require that all identified measures be implemented. Once potential P&M; measures are identified, operators must exercise technical judgments in determining which to implement, and when. PHMSA recognizes that not all possible actions can be taken and that all actions taken may not be able to be completed immediately. PHMSA does not prescribe a specific set of criteria for P&M; measure implementation but expects that operators establish an adequate, documented basis for deciding which candidate measures are implemented and when based upon operational conditions.

FAQ # 5.10
What is the difference between the “periodic evaluation” required by 195.452 (j) (2) and the process for determining reassessment intervals required by 195.452 (j) (3)?

The “periodic evaluation” process is distinct from the reassessment interval process. Periodic “evaluations” involve a different process than “assessments.” Periodic evaluations are analytical reviews of a wide range of data and information regarding the pipeline integrity that includes but goes beyond simply “assessment” results. “Assessments” of pipelines on the other hand are tests, or actual measures of the pipeline’s condition and can be performed using a variety of tools or inspection techniques.

As specified in 195.452 (j) (2), the continual evaluation must, at a minimum, consider the results of the baseline and periodic integrity assessments, risk analysis, decisions about remediation, and preventive and mitigative actions. The rule does not specify if the continual evaluation process should be stand-alone or combined with other integrity management program processes; this is left to the discretion of each operator. The frequency at which periodic evaluations are performed must all be determined as required by the rule. The requirements for establishing reassessment intervals are separate from those for periodic evaluations and are listed in 195.452 (j) (3).

Integrity Management Plan Up-to-Date?

RCP has the tools and expertise to develop comprehensive Integrity Management Plans for both liquid and gas pipelines. Click here if you would like information on RCP’s Integrity Management Services.

DOT/PHMSA Notice & Request for Comments on Transporting Ethanol

The Department of Transportation Pipeline and Hazardous Materials Safety Administration (DOT/PHMSA) issued a notice in the Federal Register to set forth a formal determination (for purposes of 49 U.S.C. 60101(a)(4)(B)) that the transportation of unblended biofuels by pipeline is subject to the agency’s jurisdiction. DOT is prepared to facilitate pipeline options by sponsoring research and development, resolving technical issues, and clarifying safety standards.

Most biofuels used in the U.S. today are transported exclusively by marine vessel, rail, and/or highway. PHMSA’s Hazardous Materials Regulations govern the transportation of ethanol and other biofuels and blends by rail, air, motor carrier, and barge. PHMSA’s Pipeline Safety Regulations cover the transportation by pipeline of all petroleum products, including gasoline blended with biofuel.

DOT/PHMSA is seeking comments on technical issues, adequacy of standards, and research and development needs associated with the transportation of biofuels by pipeline. All submissions should reference Docket No. PHMSA–2007–28136 and may be submitted in the following ways:

  • DOT Web Site:
  • Fax: 1–202–493–2251
  • Mail: U.S. Department of Transportation, Docket Operations, M– 30, Room W12–140, 1200 New Jersey Avenue, SE., Washington, DC 20590.
  • E-Gov Web Site: http://

Comments should be submitted by September 10, 2007.

For further information contact one of the following:

For a copy of the Federal Register Notice, contact Jessica Roger.

Texas Railroad Commission – Increase in Service Line Fees / Reporting Dates

The Railroad Commission of Texas has proposed amendments to 16 TAC §8.201, relating to Pipeline Safety Program Fees, to implement provisions of House Bill 1, 80th Texas Legislature (2007), and, specifically, Article VI, Railroad Commission Rider 11, which makes the amounts appropriated from general revenue for State fiscal years 2008 and 2009 for the pipeline safety program and the underground pipeline damage prevention program, as well as other direct and indirect costs for the programs, contingent upon the Commission assessing fees sufficient to generate, during the 2008-2009 biennium, revenue to cover that general revenue appropriation.

The proposed amendments in §8.201(b) change the deadline for filing the DOT Distribution Annual Report, Form 7100.1-1, from 2006 to an annual requirement without a specified year; change the deadline by which the annual pipeline safety program fee is to be paid from April 20, 2007, to an annual requirement of March 15 of each year; and increase the assessment rate from $0.37 to $0.50 annually for each service line reported to be in service at the end of each calendar year. The Commission proposes the increase in the annual service line fee in order meet the requirements of House Bill 1 with respect to funding not only the established pipeline safety program, but the underground pipeline damage prevention program as well, for which the Commission adopted rules that go into effect on September 1, 2007.

TSA Issues Pipeline Security Awareness Training and Brochures

The Transportation Security Administration has made available to pipeline operators and their subsidiaries a employee training program on security awareness. TSA’s Pipeline Security Division determined that improved security awareness training for pipeline company employees would be useful. To increase the security awareness levels across the pipeline industry, TSA developed compact disc-based security awareness training titled “Pipeline Security Awareness for the Pipeline Industry Employee” (CD-1). The course is intended for distribution to interested pipeline companies and is centered on heightening pipeline employees’ awareness of suspicious activity and their importance in keeping our nation’s pipeline system secure. The course is useful to all pipeline company employees – administrative, operations, and security personnel – who need a basic level of awareness and understanding of pipeline security. To obtain a copy of the training program or other brochures from TSA, click here.

China Bans Reincarnation of Tibetan Lamas

August 4, 2007
Beijing, China
The Times of London reports that the China has issued a new ban designed to prevent Tibetans from recognizing reincarnations of the living Buddha without the approval of the Chinese government. The edict, which will enter into force on September 1st, states that the “so-called reincarnated living Buddha” is “illegal and invalid” without the approval of the government, and is one item of a fourteen-part document issued by China’s State Administration for Religious Affairs. The order is the latest step by China to limit the authority of reincarnate lamas, or tulkus, who have the power to influence large religious communities in Tibet.

Editor’s Quote of the Month

“Training means learning the rules. Experience means learning the exceptions.”

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