DOT Pipeline Compliance News

September 2019 Issue

In This Issue


Ohio Public Utilities Commission Seeking Public Comments on Gas Pipeline Safety

The Public Utilities Commission of Ohio (PUCO) is seeking comments from interested parties and the public on the draft rules, Chapter 4901:1-16 Gas Pipeline Safety, regarding gas pipeline safety. The proposed rules, which are part of the commission’s regular five-year review cycle, incorporate the following:

  • Adoption of the 2019 federal gas pipeline safety regulations
  • Requiring gas pipeline operators to have a plan for abandoning inactive service lines
  • Creation of detailed reporting requirements for gas gathering line owners
  • Allow commission staff to serve gas pipeline owners via emails

Comments on the proposed draft rules are due September 13, 2019. A copy of the proposed rule changes are available on the PUCO website. Click on the link to Docketing Information System (DIS) and search for case 19-47-GA-ORD.


Texas Changes Hydrostatic Test Water Discharge Authority

Texas is changing how it will authorize the discharge of hydrostatic test water. It was previously under the permitting authority of the Railroad Commission of Texas. The permitting authority will be moving to the Texas Commission on Environmental Quality (TCEQ) when the agency is given that delegation by the EPA.

The TCEQ will meet September 17, 2019 at the TCEQ Austin Campus to authorize a request for delegation. The meeting will be available via webcast and will later be posted to YouTube.

The TCEQ is building a stakeholder list for this change. If you wish to be included in future meeting notices and correspondence, submit your name by email: HB2771@tceq.texas.gov .


PSMS Key Performance Indicators

Pipeline Safety Management System (API RP 1173) has a requirement for establishing Key Performance Indicators (KPIs). Developing good KPIs is always difficult. US OSHA has recently published a guidance document for developing leading KPIs, which includes KPIs for safety management systems. The guidance document can be accessed here.

RCP has developed a library of leading KPIs for the PSMS elements using a similar approach to the OSHA guidance. If you would like assistance in setting up leading KPIs, RCP is available to help you develop KPIs specific to your situation and the supporting procedures for the gathering and recording of input data, calculating the KPI and interpreting the trends. For additional information please contact Jessica Foley.


US DOT Funding for State Pipeline UNGS Safety Programs

The US DOT announced that PHMSA is awarding $60.3 million in formula grants to support pipeline and underground natural gas storage (UNGS) safety programs at the state level. Pipeline Safety State Base Grants reimburse up to 80 percent of a state’s annual operating costs based on state estimates and each state’s most recent program performance scores. PHMSA-certified state pipeline safety programs inspect more than 80 percent of the nation’s 2.8 million miles of gas and liquid pipelines.  

In 2018, PHMSA began awarding grants designed to support state inspection and enforcement of applicable UNGS regulations. Like the State Base Grants, UNGS grants reimburse up to 80 percent of total actual costs related to personnel, equipment, and essential activities to participating states. For more information, visit the DOT/PHMSA Grants website.

Underground Gas Storage
RCP is the market leader for underground gas storage integrity and risk management.  We have unmatched industry leaders, including Rick Gentges, Steve Nowaczewski, Terry Rittenhour, Phil Baker and more, available to assess your program and provide practical feedback and recommendations for improving your gas storage integrity and risk programs.  For more information about RCP’s underground gas storage integrity management and risk analysis services, visit our website  or contact Jessica Foley.


RCP’s 2019/2020 Workshop Schedule

DateEventLocation
Nov 21 2019Understanding MAOP Reconfirmation Requirements WebinarOnlineMore Info
Jan 9 2020What can TaskOp do for you? WebinarOnlineMore Info
Jan 28 2020 – Jan 30 2020DOT Gas & Liquid WorkshopHoustonMore Info

Visit our events page for updates, registration, and hotel information.

RCP Safety Management System
RCP has experience assisting our clients implement API RP 1173 – Pipeline Safety Management Systems (PSMS) as the basis for their safety management system.  RCP can perform gap assessments and prepare project plans to close the identified gaps with the goal of having a fully functional safety management system. RCP continues to work with the joint industry group, developing much of the material on the PipelineSMS.org website and is currently working to create a formal auditing program for RP 1173.  For more information on how RCP can assist with your company’s PSMS implementation, contact Jessica Foley.


2019 Industry Conference Schedule

API Storage Tank Conference
October 14-17, 2019
Westin Denver Downtown, Denver, CO

The Annual API Storage Tank Conference provides attendees with new information on tank-related research, latest technologies, and API petroleum standards. Stop by RCP’s exhibit and learn how TaskOp is changing workflow management.

APGA Operations Conference
October 27-31, 2019
Huntsville Marriott at the Space and Rocket Center in Huntsville, Alabama

The APGA conference will be preceded by committee and board meetings to be held October 27-29. Who should attend: Natural gas utility operations and engineering professionals; gas utility procurement personnel; organizations providing products and/or services used in natural gas distribution; and state and federal pipeline safety regulators.  We’ll be there, how about you?

Pipeline Safety Trust Annual Conference
November 7-8, 2019
Hotel Monteleone, New Orleans, LA

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. Early Bird registration ends August 9th!