DOT Pipeline Compliance News

September 2018 Issue

In This Issue

PHMSA Revisions to OPID Assignment Request and National Registry Notification

[Docket No. PHMSA-2018-0078]

PHMSA published a notice & request for comments for the revision of the Operator Assignment Request (PHMSA F 1000.1) and National Registry Notification (PHMSA F 1000.2) currently approved under OMB control number 2137–0627.

PHMSA intends to revise the OPID Assignment Request form and its instructions by adding ‘‘Underground Natural Gas Storage’’ as an additional facility type in step 2 of the form, and proposes modifying step 3 to indicate the safety programs required for underground natural gas storage facilities. PHMSA proposes modifying the instructions to explain PHMSA’s past actions for small LPG and master meter operators and future expectations for these operators. Adding this information to the instructions would provide clarity for operators and state agencies inspecting the operators.

PHMSA intends to revise the National Registry Notification form and its instructions, including changing the name of the form from ‘‘Operator Registry Notification’’ to ‘‘National Registry Notification’’ to match the wording of the PHMSA regulations requiring the notifications. PHMSA proposes adding ‘‘Underground Natural Gas Storage’’ as an additional facility type in steps 1 and 3 of the form. Other changes to the form include:

  • PHMSA proposes modifying the type C portion of the form to indicate the safety programs required for underground natural gas storage facilities.
  • Operators report various types of construction projects to PHMSA in type F notifications. PHMSA proposes adding a single-select field to describe the main purpose of the construction project.
  • The type J notification section assumes that all LNG construction builds new facilities. PHMSA proposes modifying the type J section to recognize that a notification may be submitted for rehabilitation or replacement of LNG facilities.
  • In step 3 of the form, PHMSA collects data about the location of the facilities covered by the notification. When the notification covers onshore gas gathering, gas transmission, or hazardous liquid pipelines, step 3 data includes the county(ies) for the pipelines. PHMSA uses this county data to associate the notification to a specific portion of the operator’s pipeline system. When the notification covers onshore gas gathering, gas transmission, hazardous liquid facilities, or offshore pipelines or facilities, county data is not collected. PHMSA proposes modifying the form to collect county data for onshore gas gathering, gas transmission, and hazardous liquid facilities, and offshore pipelines and facilities. This change would allow PHMSA to associate each notification to a specific portion of the operator’s pipeline system.

PHMSA invites comments on the proposed revisions on or before October 9, 2018. Use the Docket number when submitting comments via the E-Gov Website. For a copy of PHMSA’s notice from the Federal Register, contact Jessica Foley.

PHMSA Underground Natural Gas Storage Facility User Fee

[Docket No. PHMSA-2017-0129]

On December 8, 2017, PHMSA published a notice and request for comments in the Federal Register titled: ‘‘Underground Natural Gas Storage Facility User Fee’’ seeking comments from underground natural gas storage facility (UNGS) operators on a proposal to use UNGS annual report data in the user fee rate structure. (See related article in the January 2018 edition of the DOT Pipeline Compliance Newsletter.) During the one-month response period, PHMSA received comments on the proposed UNGS user fee billing methodology from WBI Energy Transmission Inc., and National Fuel Gas Supply Corporation. The comments can be found at in Docket Number PHMSA–2017–0129.

PHMSA responded that each well penetrating an underground natural gas storage reservoir represents a risk. Currently, PHMSA intends to apply a consistent level of regulatory oversight to all wells, regardless of size. As PHMSA implements its underground storage inspection program, they may gain insights leading to a user fee methodology more reflective of regulatory oversight effort. PHMSA has used UNGS annual report data about the number of wells in the FY 2018 user fee rate structure for the Pipeline Safety Fund’s Underground Natural Gas Storage Facility Safety Account. In future years, the final tier boundaries and user fee per operator may differ slightly from those listed based on the annual report data at the time the rate structure is established

For a copy of the full notice addressing the comments received, contact Jessica Foley.

PHMSA Notice: Gas & Hazardous Liquid Pipeline Risk Models

[Docket No. PHMSA-2018-0050]

PHMSA published this notice seeking public comments on a report developed to support improvements in gas and hazardous liquid pipeline risk models titled “Pipeline Risk Modeling-Overview of Methods and Tools for Improved Implementation” (Pipeline Risk Modeling Report). Pipeline risk models are a foundational part of the assessment of operational pipeline risk. Federal pipeline safety integrity management (IM) regulations require pipeline operators to use risk assessments. Based on the results of pipeline inspections and failure investigation findings, both PHMSA and the National Transportation Safety Board (NTSB) have identified general weaknesses in the risk models often used by pipeline operators in performing risk assessments for their IM programs. The Pipeline Risk Modeling Report considers the major types of pipeline risk models, and the effectiveness of each type in supporting risk assessments, as applied to pipeline operator decisions.

The original deadline to submit comments was September 17, 2018. PHMSA received a request to extend the comment period to allow stakeholders more time to evaluate the notice. PHMSA has concurred with this request and has extended the comment period for an additional 30 days. The closing date for filing comments on the notice published August 16, 2018, (83 FR 40843) is extended from September 17, 2018, to October 17, 2018. Comments should reference Docket No. PHMSA–2018–0050 and may be submitted via the E-Gov website.

For a copy of this Notice from the Federal Register, contact Jessica Foley.

Meeting of the Voluntary Information-Sharing System Working Group

[Docket No. PHMSA-2016-0128]

The Voluntary Information-sharing System (VIS) Working Group will convene on October 3, 2018, from 8:30 a.m. to 5:00 p.m. ET. at U.S. Department of Transportation, 1200 New Jersey Ave. SE, Washington, DC 20590 to discuss and identify recommendations to establish a voluntary information-sharing system. Members of the public who wish to attend in person should register no later than September 26, 2018. Individuals requiring accommodations, such as sign language interpretation or other ancillary aids, may notify PHMSA by September 26, 2018. The meeting agenda and additional information will be published on the following VIS Working Group registration page. The meetings will not be webcast; however, presentations will be available on the meeting website and posted on the E-Gov website, under docket number PHMSA-2016-0128 within 30 days following the meeting.

The VIS Working Group agenda will include briefings on topics such as mandate requirements, subcommittee considerations, lessons learned, examples of existing information-sharing systems, and proposed subcommittee recommendations. As part of its work, the committee will ultimately provide recommendations to the Secretary, as required and specifically outlined in Section 10 of Public Law 114-183, addressing:

  • The need for, and the identification of, a system to ensure that dig verification data are shared with in-line inspection operators to the extent consistent with the need to maintain proprietary and security-sensitive data in a confidential manner to improve pipeline safety and inspection technology;
  • Ways to encourage the exchange of pipeline inspection information and the development of advanced pipeline inspection technologies and enhanced risk analysis;
  • Opportunities to share data, including dig verification data between operators of pipeline facilities and in-line inspector vendors to expand knowledge of the advantages and disadvantages of the different types of in-line inspection technology and methodologies;
  • Options to create a secure system that protects proprietary data while encouraging the exchange of pipeline inspection information and the development of advanced pipeline inspection technologies and enhanced risk analysis;
  • Means and best practices for the protection of safety and security-sensitive information and proprietary information; and
  • Regulatory, funding, and legal barriers to sharing the information described in paragraphs (a) through (d).

The Secretary will publish the VIS Working Group’s recommendations on a publicly available DOT website and in the docket. The VIS Working Group will fulfill its purpose once its recommendations are published online.

PHMSA Pipeline Safety Research & Development Forum

September 11 – 12 in Baltimore, MD

PHMSA has released the Agenda for the upcoming Pipeline Safety Research & Development Forum on September 11 & 12th. The forum is a 2-day event held periodically to generate a National research agenda that fosters solutions for the various challenges associated with pipeline safety and with protecting the environment. The agenda can be found on the PHMSA Meetings webpage.

PHMSA, FERC Sign Memorandum of Understanding to Strengthen Safety Review and Permitting Process for LNG Facility Proposals

On Friday, August 31, 2018, the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) and the Federal Energy Regulatory Commission (FERC) announced that the two agencies have signed a Memorandum of Understanding (MOU) to coordinate the siting and safety review of FERC-jurisdictional LNG facilities. PHMSA is responsible for standards governing the location and design of LNG facilities. FERC is responsible for determining whether proposed FERC-jurisdictional LNG facilities are in the public interest.

The MOU clarifies each agency’s responsibilities related to the application review process for potential LNG projects, including PHMSA’s review for compliance with the siting requirements contained in Part 193 of the Federal Pipeline Safety Regulations. The MOU establishes a framework for coordination between FERC and PHMSA to process LNG applications in a timely and expeditious manner while ensuring decision-makers are fully informed on public safety impacts. The MOU provides that PHMSA will review LNG project applications to determine whether a proposed facility complies with the safety standards set forth in PHMSA’s regulations, and that PHMSA will issue a letter to FERC stating its findings regarding such compliance. FERC will then consider PHMSA’s compliance findings in its decision on whether a project is in the public interest.

“PHMSA’s LNG safety experts are fully prepared to analyze current and future project proposals, evaluate their potential impact on public safety, and reduce barriers to moving these projects forward,” said PHMSA Administrator Skip Elliott.

The agreement also refines information-sharing practices between the agencies, including all documents, information, and data submitted by facility applicants.

For more information, contact: FERC: Mary O’Driscoll, 202-502-8680; or, PHMSA: Bobby Fraser, 202-366-4831

PHMSA Staff Appointment

[From AGA’s Weekly Update]

PHMSA this week announced the appointment of Massoud Tahamtani as the Deputy Associate Administrator for Policy and Programs with PHMSA’s Office of Pipeline Safety. Massoud is a career public servant, with over 38 years of service. He brings with him extensive leadership experience through his tenure as Director of the Division of Utility and Railroad Safety with the Virginia State Corporation Commission, administering programs overseeing the safe operation of thousands of miles of underground utility lines, railroad track and equipment throughout Virginia. He has actively promoted underground utility damage prevention, pipeline safety and railroad safety on the national stage by testifying before Congress and the National Transportation Safety Board, fostering strategic partnerships with industry and government groups, and serving on numerous national task forces and committees including the American Petroleum Institute’s Committee on Pipeline Safety Management Systems. Massoud has served on the Common Ground Alliance (CGA) Board of Directors, and in 2011, received CGA’s Jim Barron Award for his dedication and commitment to reduce excavation damage to underground facilities. He was appointed by the Secretary of Transportation to serve on PHMSA’s Liquid Pipeline Advisory Committee for multiple terms. He is also the past Chairman of the National Association of Pipeline Safety Representatives and received the NAPSR Lifetime Leadership Award in both 2013 and 2017. Before retiring from the Virginia State Corporation Commission, he was appointed Senior Policy Advisor to the Commissioners for Infrastructure Safety and Security.

Illinois Gas Pipeline Reporting via Electronic Submission

The Illinois Commerce Commission (Commission) issued a Notice of Proposed Amendment to Part 595: Report of Accidents or Incidents by Persons Engaged in the Transportation of Gas, or Who Own or Operate Gas Pipeline Facilities; Section 595.120 Reporting of Accidents or Incidents. Reports required under this Part shall be filed with the Commission in electronic form by a person who has an external user account provided under 83 Ill. Adm. Code 590.40.

For a copy of this Notice from the Illinois Register, contact Jessica Foley.

Texas RRC New Pipeline Safety Director

The Railroad Commission of Texas announced that Stephanie Weidman has been appointed Pipeline Safety Director effective September 1, 2018. She will continue to serve in a dual role in her position as Pipeline and Hazardous Materials Safety Administration Program Director for the Commission’s Oversight and Safety Division. Weidman represents the Commission before PHMSA, the National Association of Pipeline Safety Representatives, other state and federal agencies, as well other public forums. In addition, she provides oversight to the agency’s pipeline safety inspectors in six regional offices throughout Texas.

Weidman has been with the Commission since 2010 and has held various positions in the Pipeline Safety department including inspector, inspector team lead and inspection regional manager. Her job responsibilities included leading inspections, reviewing plans of correction and meeting with pipeline operators. Weidman holds a Bachelor of Science degree in Petroleum Engineering from the University of Texas at Austin.

New! NEI Damage Prevention Campaign Featuring Mike Rowe

[Thanks to AGA for sharing this blurb.]

The National Excavator Initiative (NEI) has announced work is under way on a series of new videos and public service announcements (PSAs) with Mike Rowe, known for his television work on Dirty Jobs, Deadliest Catch, and his promotion of 811, damage prevention and workforce issues. Two videos are now available for viewing from the website. The first video welcomes people to the website. The second includes interviews filmed with various stakeholders discussing the consequences and impacts of failing to contact 811 before digging. Both of these videos are available for a limited time and will be replaced with media that was filmed at San Diego Gas and Electric last month.

NEI will host a series of webinars regarding the effort and next steps. The webinars will cover:
  • Drivers behind the initiative
  • What materials are available, including themes and limitations
  • Outreach plans for the next 18 months
  • How to get involved from a company, organization or collaborative effort perspective
  • Benefits of supporting
Webinars are scheduled for the following dates and times (CST):
  • Tuesday, September 4th at 2 pm
  • Wednesday, September 5th at 10 am
  • Monday, September 10th at 10:30 am
  • Wednesday, September 12th at 1:30 pm
  • Thursday, September 13th at 10 am
  • Friday, September 14th at 10 am

To reserve a spot or learn more, please email or contact Lindsay Sander at (713) 208-0273.

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. 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.

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.

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

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


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