DOT Pipeline Compliance News

September 2020 Issue

In This Issue

PHMSA’s NPRM Offers Pipeline Operators New Alternatives to Addressing Changes in Population Density Near Natural Gas Pipelines

On September 3, 2020, PHMSA transmitted a Notice of Proposed Rulemaking (NPRM) to the Federal Register. The NPRM seeks public comment on proposed revisions to safety regulations pertaining to class location requirements for natural gas transmission pipelines. The proposals would provide new options for required actions following a change in class location due to population changes.

“Class locations are assigned to a given area based on population density and can change over time as local populations grow. This has been a mainstay of pipeline safety regulations since their inception 50 years ago.  We also recognize that technology and methods to assess these pipelines have improved over this same time,” said PHMSA Deputy Administrator Drue Pearce.

The NPRM proposes to allow operators to perform integrity management measures on pipelines that experience class location changes following population growth as an equally safe, but less costly alternative to reducing pressure or replacing pipe. The NPRM would also exclude certain pipeline segments that are known to have certain risk factors from the new alternative, and would impose additional requirements beyond the integrity management measures that apply to pipeline segments in high-consequence areas. Cost savings estimates range from $55 to $86 million annually, depending on the total pipeline mileage affected by the rule.

The proposed rule has been transmitted to the Federal Register. Comments will be accepted for 60 days following publication of the NPRM.

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.

Changes to PHMSA Portal, OMS Functions, OPID Contact Management

Over the past six years, pipeline operators have had the ability to update contacts for an OPID in the PHMSA Portal for the following:

  • Compliance Officers
  • Compliance Assistants
  • Inspections
  • Emergency Situations
  • Senior Executive Official
  • NPMS Submissions
  • Drug & Alcohol
  • User Fee

Some OPID have consistently updated contacts as they change while others have not. Also, PHMSA has identified the need for operators to provide a President/CEO contact to receive certain types of enforcement letters.

Effective August 28, 2020, operator staff have the ability to create and edit a President/CEO contact. Also, certain PHMSA staff now have edit rights to operator contacts so PHMSA can update contacts when operators have not.

If you have any questions about these changes to OPID Contact Management, please email or call the Pipeline Operator Hotline at 202-366-8075.

DOT Revised Federal Drug Testing Custody and Control Form

The Department of Health and Human Services recently announced that their revised Federal Drug Testing Custody and Control Form (CCF) was approved by the Office of Management and Budget (OMB).  In the ‘terms of clearance’, OMB is authorizing the use of the ‘old’ CCF until August 30, 2021. To learn more about what this means for DOT drug testing, visit the DOT webpage.

Senate Passes Bill S.2299 to Reauthorize Pipeline Safety Act

The Protecting our Infrastructure of Pipelines and Enhancing Safety (PIPES) Act of 2020, reauthorizing pipeline safety programs through FY 2023, passed in the U.S. Senate on August 6, 2020 and goes to the House next for consideration. The House bill would need to be reconciled with the Senate bill before legislation can be signed by the President and become law. Some key factors of Senate bill S.2299:

  • requires fees for compliance reviews of liquefied natural gas (LNG) facilities;
  • authorizes the establishment of limited safety-enhancing testing programs to evaluate innovative technologies and operational practices testing the safe operation of natural gas or hazardous liquid pipeline facilities;
  • sets forth requirements for idled natural or other gas transmission and hazardous liquid pipelines;
  • updates the standards for LNG facilities;
  • establishes the National Center of Excellence for Liquefied Natural Gas Safety and Training to include a repository of information on best practices relating to LNG operations;
  • requires each distribution integrity plan developed by an operator of a gas distribution pipeline to include the risks from the presence of cast iron pipes and mains and risks that may result from the operation of a low-pressure distribution system;
  • directs operators to establish protocols for communicating with fire, police, and other relevant public officials after a disaster that includes fires, explosions, or one or more fatalities; and
  • requires procedural manuals for operations, maintenance, and emergencies to include certain written procedures.

For a copy of Senate Bill S.2299, contact Jessica Foley.

TRRC Notice to Pipeline Operators: Recent Amendments 16 TAC §3.70 and Updates to the Pipeline Online Permitting System

On September 1, 2020, the Texas Railroad Commission (TRRC) will require pipeline operators to file for the renewal of their pipeline permits by the last day of their designated month. This is in accordance with amendments to 16 Texas Administrative Code (TAC) §3.70 which were adopted by TRRC on January 6, 2020 and take effect on September 1, 2020.

By changing the renewal dates, TRRC has made it more efficient to track and submit renewals for pipeline operators. Every permit must be renewed annually online using the Pipeline Online Permitting System (POPS) available in the TRRC Online System. The month that renewal is due is determined by the first letter of the operator’s name. To view the renewal schedule, visit the Texas Secretary of State website.

In addition, the amended rule outlines that late charges for mileage fees due in 2021 or later are reduced for companies who operate less than 50 total miles of permitted pipelines. The updated late charges are $125 for less than 30 days late, $250 for more than 30 but less than 60 days late, and $350 for more than 60 days late.  

Amendments to 16 TAC Chapter 8 were also adopted by TRRC on January 6, 2020. The term lease line was removed as a qualifier to determine if a pipeline needs a (T-4) permit to operate in Texas. TRRC has clarified the definition of a gathering line for permitting purposes. The changes outlined in 16 TAC Chapter 8 and §3.70 together determine which pipelines need a permit.

For questions, contact the Pipeline Permitting Section of TRRC’s Oversight and Safety Division at or 512-463-6802 for assistance. To view the original notice, visit the TRRC website.

RCP has been providing HCA, Class Location, Mapping and Permitting services for our Texas clients since 1995. If you need help renewing, revising or filing for new T-4 permits in Texas, contact Jessica Foley at

LDNR Notice to Adopt Federal Regulations as State Regulations

In the August 2020 Louisiana Register, LDNR published a Notice of Intent (NOI) for Pipeline Safety regulations to bring state regulations in line with federal regulations. LDNR is accepting public comment on these proposed regulations, which must be sent to the Office of Conservation by 4:00 PM on September 21, 2020. See full details on Page 50 of the NOI.

Texas Pipeline Mapping System Updates Publication

The Texas Railroad Commission’s Pipeline Mapping System (TPMS) has adopted a new name for its Attribute Definitions, Valid Codes and Digital Projection Requirements publication. It’s now known as A Guide to Shapefile Submissions.

The TPMS is a geographic information system database that requires pipeline attributes to be represented by certain codes. A Guide to Shapefile Submissions includes the required fields that pipeline operators must follow when submitting shapefiles to pass validations. This document defines the required attribute fields within the database and explains which codes are valid representations of those attributes. The revisions to the requirements, effective Sept. 1, are in response to amendments to 16 Texas Administrative Code §3.70.

New TPMS FAQs are now available. For questions, contact TRRC’s Pipeline Permitting Section at or 512-463-7058.

Okay all of you really cool people, sit up and take notice that RCP is on the TRRC Software Vendor List for submitting digital data. The vendors on this list have represented that they offer software that allows digital submission (electronic filing) of digital map data.  TRRC staff has reviewed and approved the products and services as they pertain to TRRC’s purpose for collecting data from each vendor on this list. 

GPAC Virtual Public Meeting Notice

There will be a virtual public meeting of the Gas Pipeline Advisory Committee (GPAC) to discuss the Gas Pipeline Regulatory Reform NPRM that PHMSA published in the Federal Register on June 9, 2020 (85 FR 35240).  GPAC will review the NPRM and its associated regulatory analysis.  The meeting will be held virtually on Wednesday, October 7, 2020, from 10:30 a.m. to 6:00 p.m. ET. The agenda and any additional information, including information on how to participate in the meeting, will be published on the meeting website.

Pipeline Safety Trust Announces New Executive Director

The Pipeline Safety Trust is pleased to announce the appointment of Bill Caram as Executive Director.  Caram comes to the Pipeline Safety Trust from the Deschutes River Conservancy in Bend, Oregon where he served the collaborative environmental organization as Director of Finance and Development. Caram envisions fostering a group of pipeline safety experts much broader than just industry engineers and government regulators, saying, “People should take an active interest in the pipelines in their communities and effectively advocate for their safe siting and operation.  I hope to continue the Pipeline Safety Trust’s work in helping them do that.”

Carl Weimer, who served as Executive Director since 2004, will stay on staff as Special Projects Advisor.  Weimer steps down from the role of Executive Director as a titan of pipeline safety.  Over his 16 years at the Trust, Weimer served as a member of the U.S. Department of Transportation’s Technical Hazardous Liquid Pipeline Safety Standards Committee, the Canadian Energy Pipeline Association’s External Advisory Panel, and the governor-appointed Washington Citizen Committee on Pipeline Safety.

DOT Pipeline Compliance Virtual Workshop

October 6-8, 2020

Join us October 6-8, 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.

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.

2020 Industry Conference Schedule

The Year of the Virtual Conference Season!

International Pipeline Conference 2020
(September 29-30)

There is still time to register for the 2020 International Pipeline Conference.  IPC is held every even-numbered year – and in 2020 it will be held virtually.  On Monday September 28 a variety of tutorials are offered for those who need to enhance their technical skills.  The conference on Tuesday and Wednesday, September 29-30, will feature a keynote presentation from Maria Van Der Hoeven, a previous Executive Director of the International Energy Agency, as well as an executive panel – not to mention more than 200 peer-reviewed and published technical papers from the brightest minds in the industry.  For additional information and to register, click here.

API Tank Conference
(October 12-15)

API has decided to host the 2020 API Storage Tank Conference as a fully virtual event. The API Storage Tank Conference has been an annual event since 1995. It is considered the premier, high-level meeting of storage tank professionals, and has a loyal and dedicated attendee base.

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.”

PHMSA Grants to Enhance Pipeline and Hazardous Materials Safety

PHMSA announced that it is awarding over $97 million in grants through its pipeline and hazardous materials safety programs.  The awards will be distributed to states, local communities, tribal entities, universities, and non-profit organizations to support state pipeline and hazardous materials safety programs.  Award recipients will use the funds for projects such as training first responders, educating the public on local safety initiatives, and encouraging the development of new pipeline technologies.

The awards include $61 million in Pipeline State Base Formula Grants to 46 states, the District of Columbia, and Puerto Rico to support their participation in the federal-state base pipeline safety program, as well as $20 million in Hazardous Materials Emergency Preparedness (HMEP) grants to all 50 states, five U.S. territories, and three federally recognized Tribes and Tribal organizations.  Other grant awards include:

Pipeline Safety Grants

  • $5.4 million in Underground Natural Gas Storage grants
  • $2 million in Competitive Academic Agreement Program awards
  • $1.25 million in State Damage Prevention Program grants
  • $1.2 million in Technical Assistance grants
  • $1.05 million in One Call grants

Hazardous Materials Safety Grants

  • $3.4 million in Hazardous Materials Instructor Training grants
  • $941,000 in Supplemental Public Sector Training grants
  • $750,000 in Community Safety grants

For additional grant information and a detailed listing of states, territories, tribes, and organizations receiving today’s grants, click here.

Job Posting

RCP and our clients are always on the lookout for good technical and regulatory compliance personnel.  If you know of someone who might be in need of a position, please have them send a resume to
RCP’s HR department.

RCP’s 25th Anniversary

This year marks a remarkable and very successful 25th anniversary for RCP. After our opening in 1995 in Baton Rouge, Louisiana, we now have employees throughout the U.S. Our projects range from Maine to Hawaii, Florida to Alaska, Canada and overseas.

I want to sincerely thank our clients for the privilege of being your Professional Engineers, Regulatory Experts, and Trusted Partners, and our many talented employees who make it all happen.  We could never have done it without your trust and support.

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


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