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DOT Pipeline Compliance News
February 2016 Edition

PHMSA ADB–2016–01 Damage to Pipelines Caused by Flooding
[Docket No. PHMSA-2015-0283]
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The Department of Transportation/Pipeline Hazardous Materials Safety Administration (PHMSA) issued an Advisory Bulletin (ADB–2016–01) to remind all owners and operators of gas and hazardous liquid pipelines of the potential for damage to pipeline facilities caused by severe flooding including actions that operators should consider taking to ensure the integrity of pipelines in the event of flooding, river scour, and river channel migration. Severe flooding can adversely affect the safe operation of a pipeline. Operators need to direct their resources in a manner that will enable them to determine and mitigate the potential effects of flooding on their pipeline systems in accordance with applicable regulations.

For a copy of ADB-2016-01 and the 14 action items recommend by PHMSA, contact Jessica Foley.

API RP 1174 Assessment

API recently published Recommended Practice (RP) 1174 for Onshore Hazardous Liquid Pipeline Emergency Preparedness and Response (1st Edition, December 2015). API RP 1174 provides operators with an enhanced framework to enable continual improvement of pipeline emergency planning and response processes. RCP can assist operators with preparing for a safe, timely, and effective response to a pipeline emergency. Contact Jessica Foley if you need a review of your Facility Response Plan, Contingency Plan, Integrated Contingency Plan; or, if you are interested in a third party review.

PHMSA Advisory Safe Operations of Underground Storage Facilities for Natural Gas
[Docket No. PHMSA-2016-0016]
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PHMSA issued Advisory Bulletin (ADB-2016-02) to remind all owners and operators of underground storage facilities used for the storage of natural gas, as defined in 49 CFR Part 192, to consider the overall integrity of the facilities to ensure the safety of the public and operating personnel and to protect the environment. Operators are reminded to review their operations to identify the potential of facility leaks and failures caused by corrosion, chemical damage, mechanical damage, or other material deficiencies in piping, tubing, casing, valves, and associated facilities and the importance of reviewing the location and operations of shut-off and isolation systems and reviewing and updating emergency plans as necessary.

This advisory also informs operators about recommended practices (API RP 1170, RP 1171, and IOGCC Standards) and urges operators to take all necessary actions, including but not limited to those set forth in ADB-2016-02, to prevent and mitigate breach of integrity, leaks, or failures at their underground storage facilities. In addition, PHMSA reminds operators that their operating and maintenance (O&M) processes and procedures should be reviewed and updated at least annually, unless operational inspections for integrity warrant shorter review periods.

For a copy of ADB-2016-02 with the full list of recommend practices and action items, contact Jessica Foley.

California Department of Conservation Emergency Regulations for Natural Gas Storage
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The California Department of Conservation's (DOC) Division of Oil, Gas, and Geothermal Resources emergency regulations for all underground gas storage projects in the state of California were approved on February 5, 2016. The emergency regulations were established under the emergency rulemaking process to protect public health, safety, and the environment while permanent regulations are being finalized.

Consistent with the mandate of the Governor's emergency proclamation related to the Aliso Canyon Natural Gas Storage Facility in Los Angeles County, DOC determined that there was an immediate need to require implementation of performance standards specifically designed to ensure that operators of underground gas storage facilities are properly mitigating risks and taking all appropriate steps to prevent uncontrolled releases, blowouts, and other infrastructure-related accidents. The emergency regulations accomplish all of the following:

  • Require at least a daily inspection of gas storage wellheads, using gas leak detection technology such as infrared imaging.
  • Require ongoing verification of the mechanical integrity of all gas storage wells.
  • Require ongoing measurement of annular gas pressure or annular gas flow within wells.
  • Require regular testing of all safety valves used in wells.
  • Establish minimum and maximum pressure limits for each gas storage facility in the state.
  • Require each storage facility to establish a comprehensive risk management plan that evaluates and prepares for risk at each facility, including corrosion potential of pipes and equipment.
The emergency rule is available on the DOC website.

RCP Underground Storage Services &
Gas Storage Facility Procedures

RCP is well known for DOT/PHMSA expertise, but did you know that we also focus on related assets? We have developed integrity management programs and operating procedures for both reservoir and salt dome gas storage facilities across the US. RCP can develop, review, update or verify your gas storage facility procedures as recommended in API RP 1170.

RCP's staff supported the development of the new API Recommended Practice 1170 “Design and Operation of Solution-mined Salt Caverns Used for Natural Gas Storage” (published July, 2015). Our site specific risk analysis program using Monte Carlo methods (published at the International Pipeline Conference in paper IPC2014-33171) provides an excellent tool to conduct risk analysis calculations at underground storage facilities. 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, please contact Jessica Foley.

Advisory Committee Meeting re: Liquid NPRM
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The Technical Advisory Committee (TAC) for Hazardous Liquids pipelines met on Monday, February 1, 2016, to discuss comments received and the path forward regarding the Notice of Proposed Rulemaking published on October 13, 2015 (see related article in the October edition of the "DOT Pipeline Compliance News"). It was by all accounts a productive, working meeting, resulting in a number of consensus recommendations from public, government, and the industry that should assist PHMSA in the development of a Final Rule in a timely manner. Information about the meeting, including materials developed by PHMSA prior to the meeting, are available on the TAC’s website.

Connecticut Proposes Changes to Call Before You Dig Procedures
[Docket No. 14- 10-02]
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Connecticut’s Public Utilities Regulatory Authority (PURA) recently proposed amendments to the state’s “Call Before You Dig” procedures. These updated regulations seek to address proper techniques and protocols for the excavation and demolition of underground utility facilities. The proposed amendments also incorporate technical drafting changes adopted by the Legislative Regulation Review Committee of the General Assembly. Persons wishing to submit comments may do so electronically via the state’s e-regulations system or in writing sent to PURA Executive Secretary, 10 Franklin Square, New Britain, CT 06051 by February 13, 2016. These proposed changes are available for public inspection on the PURA website.

Pipeline Pressure Testing Workshop: February 23-24, 2016
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RCP is now offering a 2-day Pipeline Pressure Testing Workshop at its facilities in downtown Houston. The workshop will begin by outlining the objectives for performing a pressure test and how those relate to DOT requirements. The workshop will then build upon these foundations to answer many specific pressure testing questions including:

  • What are the different types of tests commonly conducted and how do you design each one?
  • What is the theory and physical science behind a pressure test?
  • How do you plan for a pressure test from start to finish:
    • Cleaning the line
    • Environmental hazards and permitting
    • Landowner and operations safety
    • Customer/stakeholder impact
    • Logistical details and scheduling
    • Pipeline modifications and anticipating failures
  • What is the required instrumentation and how does it need to be configured?
  • What data is absolutely necessary to validate a pressure test?
  • How do you determine and prove a successful pressure test?
  • What does a good test report look like (that will also satisfy PHMSA)?
Each attendee will receive the presentation as well as applicable handouts in a hardcopy notebook. Attendees will also have the opportunity to work through several exercises specifically covering 1) calculating the SMYS, MAOP and test pressures for various pipeline segments at various elevations 2) calculating the volume of water required for a hydrotest, fill times and velocities, and determining how the volume of test water changes with pressure and 3) designing a complete test plan for a hypothetical pipeline i.e. dividing the line into test sections and determining the test parameters for each section.

To register for our workshop, click here.

Pressure Testing Webinar – Advantages of using TestOp®
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RCP will be hosting a webinar presentation in February 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 this session or request an individual demonstration for your company at a date convenient to you.

  • February 25, 2016 (Thursday) at 2 p.m. CST
  • April 14, 2016 (Thursday) at 2 p.m. CST
Click here to register.

API RP1173 Assessment Services

API recently published a new Recommended Practice (RP) concerning safety management systems for pipelines. API RP 1173 provides pipeline operators with a comprehensive way to make safe operations and continuous safety improvement a constant focus of their operations. The first step for most pipeline operators will be to assess their current safety management system maturity – from nothing in place to a sustainable, improving system. RCP can assist operators in the evaluation of the maturity levels of each element of the recommended practice, and establish an action plan for further development / maturity. Contact Jessica Foley for API RP 1173 Assistance.

2016 Pipeline Conference Schedule
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Have you registered and confirmed your reservations for these upcoming conferences? RCP will be attending. We hope to see you there!

Pipeline Pigging & Integrity Management Conference
February 8 – 11, 2016
Marriott Westchase Hotel / Houston, Texas
RCP Booth #512

Click Here for a Free Exhibition Pass.

The industry's only forum devoted exclusively to pigging for maintenance and inspection, as well as pipeline integrity evaluation and repair, this event will draw engineering management and field operating personnel from both transmission and distribution companies concerned with improved operations and integrity management.

API Pipeline Conference
April 5 – 7, 2016
Omni La Costa / Carlsbad, CA

API’s Pipeline Conference is the premier event of its kind in the U.S. Held every year in April the conference provides attendees with an opportunity to hear about the latest in pipeline-related developments. Included in the program for 2016 will be Pipeline Integrity, Safety Management Systems, Training, OQ, Regulatory, Process Safety, Emergency Response, and a host of other relevant topics. Once again, RCP is a proud sponsor of this event and looks forward to seeing you there!

AGA Operations Conference
April 19 – 22, 2016
Arizona Biltmore / Phoenix, AZ

The annual AGA Operations Conference is the natural gas industry's premier gathering of natural gas utility and transmission company operations management from across North America and the world for the sharing of technical knowledge, ideas and practices to promote the safe, reliable, and cost-effective delivery of natural gas to the end-user. The Operations Conference is AGA's largest forum with regularly more than 500 operations management in attendance, including 80 speakers, and over 100 technical presentations, including two presentations from RCP staff:

  • Development of Industry Guidelines for the Engineering Critical Assessment (ECA) Process Under IVP
  • Is an 8-hour pressure test long enough?
Join RCP for a special reception in The Biltmore "Gold Room" on April 20 (Wednesday) from 6 – 9 p.m. for cocktails, hors d'oeuvres, live entertainment and more!

PHMSA Incident and Annual Data Analysis

RCP can provide detailed and timely analysis of PHMSA historical incident and annual data for clients needing to compare their performance against the industry averages, respond to press inquiries, or analyze trends. Contact Jessica Foley for more information.

Save the Dates!
RCP Workshop Schedule for 2016

Start Planning for the New Year and kick it off with a DOT Workshop!

  • Pressure Test Workshop: February 23-24 (Tuesday & Wednesday)
  • DOT Gas & Liquid Pipeline Workshop: April 12-14 (Tuesday, Wednesday & Thursday)
  • Pressure Test Workshop: August 9-10 (Tuesday & Wednesday)
  • DOT Gas & Liquid Pipeline Workshop: October 4-6 (Tuesday, Wednesday & Thursday)
Visit our Training Page for updates, registration, and hotel information.


Special Note for 2016: The DOT Gas & Liquid Pipeline workshops will be taught in our combined format. There will not be a gas only or liquid only workshop in 2016.

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

Best Regards,

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



About RCP
RCP is a registered professional engineering corporation staffed by more than 50 energy pipeline experts with extensive experience in energy pipeline risk management and regulatory compliance issues. Since 1995, RCP has assisted companies and organizations of all types and sizes, including every pipeline operator in the Forbes 500 down to small municipal operators, with the challenges of energy pipeline and terminal regulatory compliance and integrity management at the federal level, in every state, and in several foreign countries. Our personnel have experience as operators, engineers, and managers, and participate at the highest levels of the gas and liquid energy pipeline industry by serving on technical research committees and developing industry standards. RCP also offers pipeline integrity and corrosion control consulting services by providing operational support and program implementation management services, including selection, contracting, and management of subcontractors in the field to implement the required program activities for corrosion control, in-line inspection, direct assessment, and more. RCP has the perfect team to support your pipeline integrity and compliance requirements - from initial consulting, to program development, to implementation and final analysis of a broad range of pipeline regulatory compliance and integrity management issues.

For more information, please contact Jessica Foley at 713-655-8080 or visit www.rcp.com.

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More About RCP
For additional information on RCP, please visit: rcp.com or Contact Jessica Foley at 1-888-727-9937 for more info.