DOT Pipeline Compliance News

September 2021 Issue

In This Issue

TestApp is a complete hardware and software solution for gas distribution operators to simplify how pressure tests are conducted for pipelines operating less than 100 psig. 

Available soon in the Apple and Google Play Stores.
  • TestApp eliminates any concerns whether a test actually met an operator’s test acceptance criteria.
  • TestApp eliminates the need for hand written records, providing a digital record of:
    • what was tested,
    • who performed the test,
    • when it was conducted,
    • the data that was captured during the test, and
    • whether the test met the operator’s test acceptance criteria.
  • TestApp can be customized to receive lists of lines for selection by the user.
  • Operators can authorize both employees and external contractors to use its license.
  • TestApp works offline even if cell or Wi-Fi service is not available at the jobsite.

How does it work?

  • TestApp allows authorized users to download testing metadata to any iOS or Android device.
  • TestApp connects an authorized user’s mobile device via Bluetooth or USB to a compatible pressure gauge that can log time stamped pressure and temperature readings.
  • TestApp syncs with the compatible gauge to gather collected test data and analyze whether the test successfully met the operator’s test acceptance criteria.
  • TestApp exports all of the test data to the operator’s data site as soon as the test is completed.

Iowa Updated Permit Requirements

On September 9, 2021, the Iowa Department of Commerce, Utilities Division, issued an updated Chapter 13 under Title 199. Except for the new requirement to submit copies of all PHMSA reports to the Utilities Board, most of the update is a re-ordering of Chapter 13 and adding details to existing requirements for requesting, amending and renewal of pipeline permits. Many of the changes are concerned with the Informational Meeting requirements. The changes primarily are additional details to existing requirements. For example, the additions include timelines for setting the date of the Informational Meeting, obtaining approval to hold the Informational Meeting, and communicating the meeting date to potentially impacted persons along the pipeline right of way. An example of a new requirement is to submit a copy of all presentation material to the Utility Board within 14 days of the Meeting.

Some parts of the regulation now have more detail, such as a public notice for the Informational Meeting, which includes adding a requirement to notify the board of supervisors for every county that will be impacted by the pipeline. The permit application content requirements have been re-organized with some additional details that have typically been included in an application but were previously not required. For example, one change will be to require information about authorizations from other authorities (highway and railroad crossing) for inclusion in the permit request, instead of just recommending the information for inclusion.  

The Reporting Rule was updated to include reporting to the Iowa Utility Board when a PHMSA report is required. This only applies to the portions of the pipeline that is located within Iowa.

Ohio PUCO Chapter 16 Gas Pipeline Safety Updated Regulation

The Ohio Public Utilities Commission (PUCO) published an updated Gas Pipeline Safety regulation on August 17, 2021. The regulation was updated to include the results of the five-year review. The next schedule review is due July 26, 2026. One new requirement was included in this update. Starting August 5, 2023, each operator will have to prepare a plan for tracking inactive service lines until the service line is abandoned as outlined in 49 CFR 192.727. Inactive service lines are defined as no billing activity for 36 months. Inactive service lines are to be considered and treated as active lines until they are abandoned. If a leak is discovered on an inactive service line, the operator must begin the process of abandonment as soon as practicable but must be completed within 12 months. When a leak investigation identifies an inactive service line, the plan must be updated within 10 days with the information about the inactive service line.

The update also includes some changes to existing reporting requirements. The 24-Hour Contact report must now include the total mileage of gas gathering pipelines by county. The Start of Construction report has been deleted.

The last update changes the dollar amounts for settlement agreements. The $1,000 trigger was updated to $10,000.

The Enforcement Corner

The Enforcement Corner summarizes recent PHMSA enforcement actions, indicating where PHMSA is putting its enforcement efforts and the fines they are proposing for various types of violations.

In July 2021, PHMSA issued 1 CAO, 2 NOPVs, 4 NOAs, and 2 WLs accompanied by $2,308,100 in proposed fines. Significant proposed fines were attributed to the following code sections:

  • $823,800 – 49 CFR 193.2507 Monitoring Operations
  • $705,600 – 49 CFR 193.2101(a) Valve & Valve Control
  • $685,500 – 49 CFR 193.2017(c)(1) Plans & Procedures
  • $46,600   – 49 CFR 195.402(a) Procedure Manuals
  • $46,600   – 49 CFR 195.440(c) Public Awareness

Please note:

  1. Pipeline operators may disagree in whole or in part with each proposed violation cited by PHMSA. 
  2. Proposed fines may be reduced or eliminated before an enforcement action becomes final.
  3. A Corrective Action Order (CAO) usually addresses urgent situations arising out of an accident, spill, or other significant, immediate, or imminent safety or environmental concern.
  4. A Notice of Probable Violation (NOPV) is not proof that a violation actually occurred.
  5. A Notice of Amendment (NOA) is frequently a result of a difference of opinion regarding written procedure requirements.
  6. A Proposed Compliance Order (PCO) frequently documents actions the pipeline operator already planned to do.
  7. Warning Letter (WL) is an official notice by PHMSA that an operator needs to make improvements but that no further enforcement is proposed for those findings at this time.

RCP maintains a detailed database of all PHMSA enforcement actions dating back to 2007 and is routinely asked for data analysis of various enforcement actions. For more information on how RCP can assist with enforcement action data analysis services, contact Jessica Foley.

Need to respond to a PHMSA enforcement action?
Need to know if your enforcement action is an outlier, or par for the course? 

RCP maintains a detailed database of all PHMSA enforcement actions and their resolution which enables us to compare and contrast individual enforcement actions to nationwide actions and trends.  We can help put things into context to ensure an effective reply for each citation.  For more information on how RCP can assist with enforcement action data analysis services, contact Jessica Foley.

2021 Conference News

AGA Operations Conference & Biennial Exhibition (In-Person!)
October 5 – 8, 2021 | Gaylord Palms, Kissimmee, Florida

RCP is proud to be a Platinum Sponsor of the annual AGA Operations Conference — a gathering of natural gas utility and transmission company operations management from across North America and a forum for sharing technical knowledge, ideas and practices to promote the safe, reliable, and cost-effective delivery of natural gas to the end-user. Technical presentations cover topics such as gas measurement, operations advocacy, safety, environment, storage, engineering, construction and maintenance, gas control, supplemental gas, corrosion control and plastic materials.

GTI CH4 Methane Conference
October 12 – 13 | Fort Collins, Colorado

GTI and the Colorado State University Energy Institute are proud to host the 8th annual CH4 Connections conference. “Accelerating Transition to a Low Carbon World” will highlight stakeholders in the energy industry that are facilitating reduction in methane emissions across the energy value chain as a pathway to a low carbon world. The conference will dive into how effective regulations, scientifically sound methane accounting principles, advancing methane emission research, and leak detection technology are needed to accelerate the transition to a low carbon world.

SGA Natural Gas Connect Conference
October 17 – 20, 2021 | Charlotte, North Carolina

Natural Gas Connect is moving forward as an in-person conference combining with the Natural

Gas Expo (formerly Spring Gas) scheduled for October 17-20 in Charlotte, North Carolina. Keep checking SGA’s website for updated information.

API Pipeline SMS Workshop (Gone Virtual)
October 19-20, 2021

Originally scheduled for an in-person workshop in Dallas, Texas,  the PSMS Workshop will now be a one-day virtual event. The program is being revised to reflect the new schedule and will be posted within the next couple of weeks. API is in the process of informing registered attendees. Please check API’s website for more information.

APGA Operations Conference and Committee Meetings
October 24 – 28 | Memphis, TN

The 2021 APGA Operations Conference has speakers and panels of experts on topics such as leak detection, regulatory compliance, integrity management, and new technology. The conference will also include an exhibitor hall of the latest in products and services for natural gas distribution operations.

LGA Pipeline Safety Conference
November 1 – 4, 2021 | Hilton Riverside in New Orleans

Save the dates! Another in person event is in the works. More information coming soon or check LGA’s website for conference updates.

Pipeline Safety Institute

Coming soon! The Pipeline Safety Institute will be your one-stop destination for DOT pipeline training in 49 CFR 191, 192, 194, 195, and 199. RCP’s DOT Workshops will be transitioning over to the Pipeline Safety Institute. Additional training topics will cover pipeline operations and engineering concepts, with future course offerings for Integrity Management programs, including: ILI, material testing, fitting and component selection, and qualifying welders. Our curriculum is growing to meet the changes and challenges in the energy industry.

The Pipeline Safety Institute has a team of experienced instructors and subject matter experts from all disciplines. With over 25 years of training experience, we are committed to providing the best pipeline safety training in the industry for all you Really Cool People.

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


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