DOT Pipeline Compliance News

September 2016 Issue

In This Issue

DOT Pipeline Compliance Workshop – Gas & Liquid

OCTOBER 4-6, 2016

Join us October 4-6, 2016 in Houston at our corporate office and dedicated training facility for an informative, lively, and interactive workshop on DOT Pipeline Compliance topics. The workshop provides an overview of the DOT pipeline regulations in 49 CFR 191, 192, 194, 195, 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 Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 (pipeline reauthorization bill), recent Advisory Bulletins from PHMSA, and new, pending and proposed rulemakings.

Each attendee will receive the presentation as well as applicable handouts in a hardcopy notebook, and electronic copies of the applicable regulations and voluminous reference materials including rulemakings, letters of interpretation, and other guidance documents. The workshop will adjourn at 2 p.m. on the third day, for those who need to fly out Thursday evening.

To register for our workshop, click here.

PHMSA Advisory Bulletin ADB-2016-05 Clarification of Terms Relating to Pipeline Operational Status / Abandoned Pipelines

[DOCKET NO. PHMSA-2016-0075]

PHMSA issued an advisory bulletin to all owners and operators of hazardous liquid, carbon dioxide, and gas pipelines to clarify the regulatory requirements that may vary depending on the operational status of a pipeline. This advisory bulletin identifies regulatory requirements operators must follow for the abandonment of pipelines. Pipeline owners and operators should verify their operations and procedures align with the regulatory intent of defined terms as described under this bulletin. PHMSA regulations do not recognize an “idle” status for a hazardous liquid or gas pipelines. The regulations consider pipelines to be either active and fully subject to all parts of the safety regulations or abandoned.

The process and requirements for pipeline abandonment are captured in §§ 192.727 and 195.402(c)(10) for gas and hazardous liquid pipelines, respectively. Pipelines abandoned after the effective date of the regulations must comply with requirements to purge all combustibles and seal any facilities left in place. The last owner or operator of abandoned offshore facilities and abandoned onshore facilities that cross over, under, or through commercially navigable waterways must file a report with PHMSA.

PHMSA regulations define the term “abandoned” to mean permanently removed from service. Companies that own pipelines abandoned prior to the effective date of the abandonment regulations may not have access to records relating to where these pipelines are located or whether they were properly purged of combustibles and sealed. To the extent feasible, owners and operators have a responsibility to assure facilities for which they are responsible or last owned do not present a hazard to people, property or the environment.

Owners and operators of pipelines that are not operating, but contain hazardous liquids and gas, must comply with all applicable safety requirements, including periodic maintenance, integrity management assessments, damage prevention programs, response planning, and public awareness programs.

The advisory bulletin goes into effect immediately. For a copy of ADB-2016-05, contact Jessica Foley.

Underground Natural Gas Storage Services

RCP has extensive expertise in the underground storage operations and integrity for depleted reservoirs which we would like to put to work for your company. RCP has developed a comprehensive solution that allows underground natural gas storage operators to:

  • Assess current operations against new RP 1171
  • Develop written standards and procedures for underground natural gas storage
  • Complete risk assessments
  • Develop integrity assessment risk mitigation plans
  • Track progress of all remedial actions from beginning to end

We are well-positioned to support your organization’s response to the recent PHMSA advisory bulletin as well as the California Emergency rule on underground gas storage. For more information, including a demonstration of the advanced tools we have developed, please contact Jessica Foley.

Texas Audit Act §3(a)(4)

There is new legislation in Texas allowing pipeline operators to avoid penalties for violations disclosed. Under the Texas Environmental, Health, and Safety Audit Privilege Act (“Audit Act”), TEX. CIV. STAT. art. 4447cc, persons that conduct voluntary environmental or health and safety audits of regulated facilities and operations can claim immunity from administrative penalties for violations discovered, disclosed, and corrected within a reasonable amount of time. The Audit Act also provides a limited privilege for audit reports developed in accordance with the Audit Act. An audit that qualifies for protection under the Audit Act is defined as “a systematic voluntary evaluation, review, or assessment of compliance with environmental or health and safety laws or with any permit issued under an environmental health and safety law conducted by an owner or operator.” An audit conducted for the purposes of a merger or acquisition of a regulated facility or operation qualifies for protection under the Audit Act, but special rules apply to those types of audits.

There are three types of submissions under the Audit Act: (1) a notice of audit letter; (2) a disclosure of violations letter; and (3) a request for an extension. The Railroad Commission of Texas (TRRC) requests that a courtesy copy of submissions be email to their General Counsel at

TRRC published a Guide to Submissions including information on immunity and privilege under the Audit Act, sample notices and a Q&A section. For a copy of the TRRC Guide to Submissions under the Audit Privilege Act (updated August 2016), contact Jessica Foley.

Audit Assistance

Has the DOT or TRRC notified you of a pending audit? Are your O&M and IMP programs ready for their next PHMSA audit? RCP can review your plans based on Advisory Bulletins and Enforcement Guidelines to ensure compliance. RCP is well versed in PHMSA and TRRC audit preparation and will help you identify opportunities for improvement and track each item to closure using RCP’s audit tracking tool, TaskOp™. RCP can provide confidential internal auditing to help ensure that your facilities are up to the agency’s latest standards. For more information, contact Jessica Foley.

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.

API Pipeline Information eXchange (PIX) and Pipeline Integrity Workshop


The 2016 API Pipeline Information eXchange (PIX) and Pipeline Integrity Workshop will be held at the Hyatt Regency Houston Galleria, 2626 Sage Road, Houston, Texas on October 11 and 12. An agenda at a glance is below. Click here for hotel and registration information.

October 11 – PIX: The purpose of the PIX is to allow for the open exchange of lessons learned from recent pipeline incidents or near miss events. PIX is limited to participation by pipeline operating company personnel.

October 12 – Pipeline Integrity Workshop: API has worked with its members to recently publish several new or revised RPs providing best practice guidance on many areas of pipeline integrity management, including data integration, appropriate uses of hydrostatic testing, pipeline cracking, and water crossing integrity management. On October 12th, these documents will be highlighted to operators, and representatives from pipeline companies will share on their efforts to implement the guidance in the RPs. There will also be break-out sessions allowing operators to share amongst each other how they address pipeline integrity challenges, with particular focus on data integration, appropriate uses of hydrostatic testing, pipeline cracking, and water crossing integrity management.

Pipeline Safety Trust Conference


Join us in New Orleans at the Hotel Monteleone on October 20-21, 2016, for the annual conference hosted by the Pipeline Safety Trust. This conference provides a unique forum to gather pipeline operators, regulators, local governments and concerned citizens for two days to talk all things pipeline safety. A stroll to the Café Du Monde for beignets will certainly occur at some time in the evening, and much powdered sugar may fly. Meanwhile, people who frequently stake out diametrically opposed positions on various pipeline topics will find plenty of opportunities to talk with each other and share their perspectives. It’s all good. We hope to see you there. Online registration, the agenda and hotel information can be found on the Pipeline Safety Trust website.

Pipeline Leak Detection-Program Management Webinar


API, along with the support of the API RP 1175 Pipeline Leak Detection-Program Management, Implementation Team, is hosting a Webinar for pipeline operators on November 3rd from 10 – 11:30 AM (CST). For registration details and other information, send your name, company name and contact information to:

Last Call for RCP’s DOT Workshop in 2016!

If you were unable to attend a workshop earlier this year, here’s your final chance in 2016. Join us at our corporate office and dedicated training facility in downtown Houston for RCP’s DOT Gas & Liquid Pipeline Workshop on October 4-6 (Tuesday, Wednesday, Thursday). Visit our Training Website for registration information and links to hotels in the downtown area. The class is filling up fast, so register soon.

We have scheduled another DOT Gas & Liquid Pipeline Workshop in January 24-26, 2017. Make your plans early to attend and reserve hotel space now. If you haven’t heard, Houston is the Host for Super Bowl LI on February 5, 2017!

The 2017 schedule for additional Gas, Liquid and Pressure Testing Workshops is in the works. Updates will be posted in the newsletter and on our website. Stay tuned!

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

Best regards,

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