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Compliance News

May 2003 Edition

Recent Trends in DOT Pipeline Regulations

In This Issue:



RCP is a professional engineering/regulatory consulting firm that works throughout the United States.

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wrb@your-rcp.com

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DOT Pipeline Compliance Workshop - July 30-31, 2003 - Houston Top
RCP will conduct a 2 day workshop on DOT Pipeline Regulations on July 30th and 31st in Houston. Day 1 of this workshop will present an overview of all the current DOT regulations for pipeline operators. Day 2 will review recent regulatory initiatives such as pipeline integrity management, high consequence area (HCA) analysis, community education and liaison programs, operator qualification inspection protocols, and significant state regulatory proposals. Day 2 will also include a review of the new Pipeline Safety Improvement Act of 2002, which includes several important self-implementing requirements that will affect pipeline operators. This workshop is suitable for personnel who need a general introduction to DOT pipeline regulatory requirements, or who need an update on recent and proposed DOT Pipeline regulatory initiatives. We have conducted this type of seminar several times, and have received excellent feedback each time. We expect this workshop to fill up rapidly. Early registration and group discounts are available. Additional information is available on our website here.


O&M Manual Up-To-Date?
RCP has the tools and expertise to develop comprehensive procedures that you need to protect your people, facilities, and environment.  Click Here



Texas GLO Oilspill Newsletter Top
The April edition of the Facility & Maritime Affairs (FAMA) has been published, and can be downloaded from RCP's website here through the Response Planning Gateway. One article concerns penalties for vessels required to have an Oil Pollution Act 1990 plan (OPA) or Shipboard Oil Pollution Emergency Plan (SOPEP) that fail to register with the Texas General Land Office prior to entering Texas waters. Recommended penalties for failing to register start at $500 for each violation.

Texas is also proposing to amend the current law, which states that oil spills of less than 240 barrels from exploration and production facilities or crude oil pipelines are the responsibility of the Texas Railroad Commission. The legislature is proposing to assign all responsibility for all maritime oil spills to the Texas General Land Office.


API Publishes Recommended Practice On Security For Offshore Operations Top
API has published Recommended Practice 70, Security for Offshore Oil and Natural Gas Operations. The publication is intended to assist operators and drilling contractors in addressing security needs for offshore oil and natural gas operations. CONTACT: Tim Sampson, Upstream, 202-682-8153 or sampson@api.org. Copies are available from Global Engineering Documents at 800-854-7179.


Pipeline Integrity Management FAQs Top
The Office of Pipeline Safety has reactivated the Pipeline Integrity Management Frequently Asked Questions site, which can be accessed at: primis.rspa.dot.gov/iim/faqs.htm. The latest information was posted on April 17, 2003, concerning notification procedures to the Office of Pipeline Safety. The entire list of FAQs can also be downloaded from that site as a pdf file.


Integrity Management Plan Up-to-Date?
RCP has the tools and expertise to develop comprehensive Integrity Management Plans for both liquid and gas pipelines.  
Click Here




OQ-2 Summary of the OPS Series of Public Meetings Top
The Southern Gas Association will conduct an audio (telephone) conference on May 15, 2003, from 10:30 a.m. to noon, central time. The teleconference will include:
  • Update on the 13 issues of concern
  • Update on the protocols
  • Discussion on the consensus standard (ASME) effort.
  • Next steps
The registration form is available on our website at can be downloaded from RCP's website here through the DOT Gateway. SGA also provides a host of information on their website at www.sgalink.org/forum. Click on "Operator Qualification - Updates on Current Issues" for the latest information on OQ. The site includes:
  • Wrap up notes from the OPS public meetings including notes, handouts and presentations from the April 23, 2003, Atlanta meeting. That page also has links to the DOT Operator Qualification website which includes the protocols.
  • Copy of documents such as the Pipeline Safety Improvement Act of 2002
  • OQ-2 Working Group roster and notes from the OQ-2 Working Group meetings
  • Update on the path forward initiatives
  • Links to important information



Air Permit Needs?
Are you planning to expand or acquire? Air permit applications can be complex and consuming.   RCP has the expertise to navigate through the application process, develop compliance assurance systems, and submit reports.  Click Here


Liquefied Natural Gas Facilities: Clarifying and Updating Safety Standards - Notice of proposed rulemaking Top
DOT is proposing to clarify application of RSPA's safety standards for operation, maintenance, and fire protection of liquefied natural gas (LNG) facilities to certain existing facilities. In addition, DOT proposes to revise standards that contain incorrect cross-references, clarify training standards, and require annual reviews of plans and procedures. DOT also proposes to update present references to the National Fire Protection Association (NFPA) 59A standard to the 2001 edition of that standard. These actions are needed to remove ambiguities, assure that plans and procedures are up-to-date, and modernize present references to NFPA 59A. The changes would improve the clarity and effectiveness of RSPA's LNG facility safety standards. The entire proposal can be downloaded from RCP's website here through the DOT Gateway.

Persons interested in submitting written comments on the rules proposed in this notice must do so by June 30, 2003 (Docket No. RSPA-03-14456; Notice 1). Late filed comments will be considered so far as practicable. FOR FURTHER INFORMATION CONTACT: L. M. Furrow by phone at 202-366-4559, by fax at 202-366-4566, by mail at U.S. Department of Transportation, 400 Seventh Street, SW., Washington, DC, 20590, or by e-mail at buck.furrow@rspa.dot.gov.


Meetings of the Pipeline Safety Advisory Committees - Notice Top
The Research and Special Programs Administration's (RSPA) Office of Pipeline Safety (OPS) will convene a meeting of the Technical Pipeline Safety Standards Committee (TPSSC) to discuss and vote on the Notice of Proposed Rulemaking, "Pipeline Integrity Management for Gas Transmission Pipelines in High Consequence Areas" ( 67 FR 4278 ) and on the associated risk assessment. In addition, RSPA/OPS will brief the TPSSC on the draft Cost-Benefit Study of Excess Flow Valve Installation on Gas Service Lines completed by RSPA's Volpe National Transportation Systems Center. Other briefings and votes may include proposals on periodic underwater inspection and on clarifications and updates to the liquefied natural gas facilities section of the pipeline safety regulations.

The meetings will be held at Loews L'Enfant Plaza Hotel, 480 L'Enfant Plaza, SW., Ballroom A-Lobby Level, Washington, DC on Wednesday, May 28 from 1:30 p.m. to 5 p.m.; and Thursday, May 29 from 9 to 5 p.m. Friday, May 30 is reserved should additional business need to be conducted. (Editor's note: the federal register notice contains a typo concerning these dates.)

Members of the public may attend the meetings, and an opportunity will be provided for the public to make short statements on the topics under discussion. Anyone wishing to make an oral statement should notify Jean Milam, (202) 493-0967, not later than May 19, 2003, on the topic of the statement and the length of the presentation. The presiding officer at each meeting may deny any request to present an oral statement and may limit the time of any presentation. You may also submit written comments to the Dockets Facility [Docket No. RSPA-98-4470].


RCP's Fantastic 1-Page Version of New SPCC Regulation
RCP has developed a 1-page version (in tiny type) of the new SPCC regulations, as revised January 9, 2003. To receive a complimentary copy, Click Here.



National Pipeline Mapping System (NPMS) - Meeting Notice Top
The Research and Special Programs Administration's (RSPA) Office of Pipeline Safety (OPS) will conduct a public meeting on Wednesday, May 28, 2003, from 9 a.m. to 12 p.m.at Loews L'Enfant Plaza Hotel, 480 L'Enfant Plaza, SW., Ballroom A, Lobby Level, Washington, DC to discuss possible improvements in data submissions to the National Pipeline Mapping System (NPMS). Possible improvements are more detailed pipeline attributes, more accurate pipeline locational data, and delineation of natural gas transmission high consequence areas. The potential for collecting annual report data through data submitted to the NPMS will also be discussed.

The public may attend the meeting, and an opportunity will be provided for the public to make short statements on the topics under discussion. Anyone wishing to make an oral statement should notify Jean Milam, (202) 493-0967, not later than May 19, 2003, on the topic of the statement and the length of the presentation. The presiding officer at each meeting may deny any request to present an oral statement and may limit the time of any presentation. You may also submit written comments to the Dockets Facility [Docket No. RSPA-97-2426].

FOR FURTHER INFORMATION CONTACT: Steve Fischer, OPS, (202) 366-6267 or Richard Huriaux, OPS, (202) 366-4565, regarding the subject matter of this notice. Additional information about the NPMS and the "National Pipeline Mapping System Standards for Pipeline and Liquefied Natural Gas Operator Submissions" can be found at www.npms.rspa.dot.gov.


Interested in Web-Based Compliance Management Systems?
RCP has the latest technology to help manage all of your permits, inspections, procedures, and data requirements and neatly organize them into one overall compliance assurance system. This includes regulatory tasking, data management, and exception reporting. Because it is web-based, there are no IT issues to struggle through to get started. An institutional memory is created of the compliance history and ongoing compliance requirements, despite operator or personnel turnover.  Click Here



Acquiring a pipeline?
RCP can provide due diligence audits to help you ensure that potential compliance issues have been addressed before the sale is final.  Click Here




If you have a regulatory-issue meeting planned, let us know, and we'll announce it in both our Vessel and Facility Newsletter and our DOT Pipeline Newsletter.

Yours,
W. R. (Bill) Byrd, PE
President
RCP Inc.
888-727-9937
wrbyrd@your-rcp.com
www.your-rcp.com
RCP - Your Regulatory Compliance Partner!



Visit Regulatory Compliance Partners on the Web at
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