DOT Pipeline Compliance News

September 2017 Issue

In This Issue

RCP Employee Featured in Hurricane Harvey Response Article

Our thanks go out to RCP’s Director of Technical Services, Michael Berg, who has gone above and beyond the call of duty in his volunteer efforts after Hurricane Harvey. In addition to leading major projects for RCP and being the father of three (and husband of one), in his “spare” time he is the president of the Nottingham Forest Homeowners Association. While you might not know the name of that neighborhood, you’ve seen it a lot on the news. It was intentionally flooded by the Corps of Engineers when they made the difficult decision to do an emergency release of water from the Barker / Addicks reservoirs, flooding hundreds of homes in this neighborhood very rapidly. The release is ongoing and many homes are still flooded.

The story and photos in the Houstonia Magazine provides an excellent summary of the event and the aftermath, and how Michael and the neighborhood have responded. I recommend it to anyone who wants an up-close and personal perspective on this event.

If you’d like to thank Michael directly, send an email to She will compile and summarize them for him. He received 1,300 emails from the neighborhood in the first day of flooding. He’s kind of busy.

TRRC Operator Qualification and Drug Testing Waiver

The Texas Railroad Commission (TRRC) announced several actions to speed recovery from the impacts of Hurricane Harvey. Pipeline operators that need to request an emergency waiver of 49 CFR §§ 199.105 (relating to pre-employment and random drug testing for all pipeline workers), Subpart N of 49 CFR Part 192 (relating to qualification of pipeline personnel), and Subpart G of 49 CFR Part 195 (relating to qualification of pipeline personnel) for purposes of conducting an emergency response to damage and/or repairs of facilities and operations as a result of Hurricane Harvey, please send your request on company letterhead signed by an officer of the company to that includes, to the extent the information is available:

  • A description of the covered tasks that will be performed by out-of-state personnel;
  • The general location (example: facility/subdivision/town) of the work;
  • The date(s) these tasks will be performed; and
  • The number and names of individuals that will be performing the covered tasks.

The Railroad Commission of Texas is currently preparing to issue emergency waivers that are requested in the form described above to the extent necessary.

Click here for more information on TRRC’s response to Hurricane Harvey, including information for operators and links to more helpful resources. TRRC’s 24-hour, toll-free emergency line to report a pipeline, or oil & gas related release is (844) 773-0305. Additional TRRC phone numbers are below:

  • Main Number: (877) 228-5740
  • Houston District Office: (713) 869-5001
  • San Antonio District Office: (210) 227-1313
  • Corpus Christi District Office: (361) 242-3113

Temporary Licenses for Texas Professional Engineering

To help mitigate the impact of Hurricane Harvey, the Texas Board of Professional Engineers has developed and passed an emergency rule providing for the issuing of Emergency Temporary Licenses. Board Rule 22 TAC § 133.12 provides for the issuance of Emergency Temporary Licenses to engineers licensed in good standing in another US State or Territory to do work in Texas counties included in the Governor’s Proclamation for a duration of 90 days from the issuance of the license. All applicants must follow all provisions of the Texas Engineering Practice Act, including firm registration requirements (Chapter 135 of the rules) and procurement requirements (PSPA / QBS, Rule 22 TAC § 137.53).

Additionally, registered firms, applicants and licensed P.E.’s affected by Hurricane Harvey will be allowed some consideration with deadlines and requirements. Please refer to for further information.

Gas and Liquid Technical Advisory Committee Meetings

[Docket No. PHMSA-2016-0136]

Due to the impact of Hurricane Harvey, PHMSA has postponed the 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 GPAC and LPAC was originally scheduled to meet on September 6-8, 2017 to continue discussing the proposed rule titled, “Safety of Gas Transmission and Gathering Pipelines.” The new date, location, 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 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.

PHMSA Announces New Deputy Administrator

Ms. Drue Pearce was named the Deputy Administrator of the Pipeline and Hazardous Materials Safety Administration (PHMSA) effective August 7. She is a former Alaska state representative and senator, and Federal Coordinator for Alaska Natural Gas Transportation System Projects. Ms. Pearce also served on PHMSA’s Technical Hazardous Pipeline Safety Standards Committee. Most recently, Ms. Pearce was in private practice. Please join us in welcoming Ms. Pearce in her new position. She is currently serving as acting Administrator of PHMSA, pending confirmation of the new Administrator (see below).

President Nominates New PHMSA Administrator

President Donald J. Trump has announced his intent to nominate Howard R. “Skip” Elliott as Administrator of PHMSA. Mr. Elliott has 40 years of experience in the freight rail industry, and is currently the group Vice President of Public Safety, Health, Environment and Security for CSX Transportation. According to the White House announcement, Elliott’s “portfolio of responsibility included hazardous materials transportation safety, homeland security, railroad policing, crisis management, environmental compliance and operations, occupational health management and continuity of business operations. He is a pioneer and leading advocate in developing and implementing computer-based tools to assist emergency management officials, first responders, and homeland security personnel in preparing for and responding to a railroad hazardous materials or security incident.” He received a lifetime achievement award for hazardous materials transportation safety from the Association of American Railroads.

New Excavation Safety Video for Farmers

The Pipeline Operators for Ag Safety (POAS) have produced an entertaining and informative video featuring the Peterson Farm Brothers, young farmers and YouTube stars, talking (OK… rapping) to other farmers about the need to call 811 before digging.

POAS encourages all pipeline operators to incorporate this video and other messaging in their outreach activities to the agricultural / ranching community. They have developed a social media kit to assist in these efforts. For more information, contact Tina Beach (CHS, Inc. Public Awareness Specialist) at or Deanna Centurion (POAS program manager) at

DOT Pipeline Compliance Workshop – Gas & Liquid

October 24-26, 2017

Join us October 24-26, 2017 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 PIPES Act of 2016; 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.

Pipeline Conference Schedule

Have you registered and confirmed your reservations for these upcoming conferences? RCP will be attending the following conferences. We hope to see you there!

2017 RRC/PHMSA Pipeline Safety Training
September 20-22, 2017
Embassy Suites, San Antonio Riverwalk

PHMSA will have trainers available to talk about various aspects of the Pipeline Safety Rules in place at the time and to discuss upcoming PHMSA rules and regulations in the process of being passed or implemented. This will also be an excellent opportunity to meet with and get to know the Railroad Commission personnel. The Agenda, registration links and hotel information can be found on the Texas Gas Association (TGA) website.

Pipeline Safety Trust
November 2-3, 2017
Hotel Monteleone, New Orleans

Join us in New Orleans 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. Online registration, the agenda and hotel information can be found on the Pipeline Safety Trust website . Early bird registration ends September 30th.

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.