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Advisory Bulletin (ADB-04-03)

To: Owners and operators of gas transmission and hazardous liquid pipelines.

Subject: Potential for unauthorized excavations and the installation of acoustic monitoring devices or other data acquisition devices on pipeline facilities.

Purpose: To ensure that pipeline owners and operators are aware of and take actions to prevent or mitigate the dangers associated with unauthorized excavations and the attendant installation of devices by entities seeking to exploit the pipelines for other purposes, and to remind operators and the public of the need to ensure that underground pipeline facilities are adequately located and protected from inadvertent damage prior to excavations.

Advisory: RSPA/OPS urges all owners and operators of gas and hazardous liquid pipelines to vigilantly monitor their right-of-ways for unauthorized excavation and the installation of data acquisition devices by third parties seeking to extract product movement information from the pipelines. This activity can impact pipeline integrity either through damage to the pipeline caused by the excavation activities or damage to the pipe coating caused by the attachment of the devices to the pipeline. The installation of pipeline monitoring devices should only be performed with the express knowledge, consent, and support of the pipeline operators.

• imposed the same requirements for natural gas and hazardous liquid pipelines
• limited the underwater periodic inspection requirement to waters less than 15 feet deep in the Gulf of Mexico and its inlets, and clarified that certain requirements only apply to waters less than 15 feet deep.
• confirmed that the existing regulations at § 192.612(b)(1) and 195.413(b)(1) remain in effect.
• confirmed that adoption of the risk analysis systems provided in the NPRM and further articulated in the TTI report is discretionary.
• incorporated the phrase "underwater natural bottom (as determined by recognized and generally accepted practices)” in place of the term "seabed" in the affected sections, and allowed for the use of recognized and generally accepted practices to determine the underwater natural bottom
• allowed for a performance-based alternative to reburial.
• not including abandoned pipelines in the rule.
• required an operator to notify RSPA/OPS if it cannot obtain required state or Federal permits in time to comply with the regulation.

§ 112.3 Requirement to prepare and implement a Spill, Prevention, Control, and Countermeasure Plan.

1. If your onshore or offshore facility was in operation on or before August 16, 2002, you must maintain your Plan, but must amend it, if necessary to ensure compliance with this part, on or before February 17, 2006, and must implement the amended Plan as soon as possible, but not later than August 18, 2006. If your onshore or offshore facility becomes operational after August 16, 2002, through August 18, 2006, and could reasonably be expected to have a discharge as described in § 112.1(b), you must prepare a Plan on or before August 18, 2006, and fully implement it as soon as possible, but not later than August 18, 2006.
2. If you are the owner or operator of an onshore or offshore facility that becomes operational after August 18, 2006, and could reasonably be expected to have a discharge as described in § 112.1(b), you must prepare and implement a Plan before you begin operations.
3. If you are the owner or operator of an onshore or offshore mobile facility, such as an onshore drilling or workover rig, barge mounted offshore drilling or workover rig, or portable fueling facility, you must prepare, implement, and maintain a facility Plan as required by this section. You must maintain your Plan, but must amend and implement it, if necessary to ensure compliance with this part, on or before August 18, 2006. If your onshore or offshore mobile facility becomes operational after August 18, 2006, and could reasonably be expected to have a discharge as described in § 112.1(b), you must prepare and implement a Plan before you begin operations. This provision does not require that you prepare a new Plan each time you move the facility to a new site. The Plan may be a general Plan. When you move the mobile or portable facility, you must locate and install it using the discharge prevention practices outlined in the Plan for the facility. The Plan is applicable only while the facility is in a fixed (non-transportation) operating mode.