On August 2, 2000, RSPA published its intention to revise forms RSPA F 7100.2-Incident Report For Gas Transmission and Gathering Systems and RSPA F 7100.2-1-Annual Report For Gas Transmission and Gathering Systems. RSPA is giving the public an additional 30 days to comment on the proposed changes in the natural gas transmission forms and the information collection burden for both the revised natural gas transmission forms and the existing natural gas distribution forms. The natural gas distribution incident and annual report forms are not being revised at this time. Copies of this proposed information collection and the revised forms can be reviewed in this docket at http://dms.dot.gov, docket RSPA-98-4957.

Comments on this notice must be received on or before June 7, 2001. Comments are invited on: (a) The need for the proposed collection of information for the proper performance of the functions of the agency, including whether the information will have practical utility; (b) the accuracy of the agency's estimate of the burden of the proposed collection of information including the validity of the methodology and assumptions used; (c) ways to enhance the quality, utility and clarity of the information to be collected; and (d) ways to minimize the burden of the collection of information on those who are to respond, including the use of appropriate automated, electronic, mechanical, or other technological collection techniques. For further information contact: Roger Little at roger.little@rspa.dot.gov.

The Office of Pipeline Safety (OPS) issued an advisory to owners and operators of gas distribution systems, that they should ensure that their emergency plans and procedures require employees who respond to gas leaks to consider the possibility of multiple leaks, to check for gas accumulation in nearby buildings, and, if necessary, to take steps to promptly stop the flow of gas. These procedures should be communicated to both employee and contractor personnel who are responsible for emergency response to pipeline incidents. On January 22, 1999, while excavating a trench behind a building in the downtown area of Bridgeport, Alabama, a backhoe operator damaged a natural gas service line. This resulted in two leaks on the natural gas service line, which was operating at a pressure of 35 pounds per square inch (psig). One leak occurred where the backhoe bucket contacted the gas service line and pulled it aboveground. Although the second leak was not visible, the ensuing investigation revealed that the natural gas service line was separated at an underground joint near the gas meter, and close to a building. As a result, natural gas migrated into the building. The gas ignited, destroying three downtown buildings in a two square block area. The incident resulted in four fatalities and five injuries.

The National Transportation Safety Board (NTSB) investigated this incident and determined that the probable cause of the accident was (1) the failure of the construction contractor to establish and follow safe procedures for excavation activities, resulting in damage to the 3/4-inch steel natural gas service line and (2) the failure of the operator to provide appropriate emergency response to the subsequent natural gas leak. The operator's written emergency procedures in effect at the time of the accident instructed service personnel to "…evaluate the extent of the emergency, request assistance as needed, and to inform the manager if necessary." However, the procedures did not instruct employees responding to a reported leak to consider the possibility of multiple leaks, check for gas accumulation in nearby buildings, and, if necessary, take steps to promptly stop the flow of gas.

RCP will repeat our 2 day workshop on Pipeline Integrity Management on July 17 and 18th in Houston. This workshop presents a detailed analysis of the recent federal Pipeline Integrity Management regulation and the management programs / elements that it requires. We will also review recent state initiatives / proposed rules on pipeline integrity management. On the 18th we will discuss various methods of actually conducting a risk assessment for pipeline segments, and will work though several hands-on examples. We received very positive feedback from the Pipeline Integrity Management workshop that we conducted in March, and expect the July session to fill up rapidly. Additional information is available on our website HERE.

RCP will conduct a 2 day workshop on DOT Pipeline Regulations on September 18th and 19th in Houston. This workshop will present an overview of all the current DOT regulations for pipeline operators, including recent regulatory initiatives such as operator qualification and pipeline integrity management. It will be followed by a half day workshop on September 20th dedicated to OPA-90 oil spill response planning for DOT pipelines. Both of these workshops are suitable for personnel who need a general introduction to DOT pipeline regulatory requirements. Additional information is available on our website HERE.

The final drug and alcohol testing rule (published on December 19, 2000; effective August 1, 2001) provides for new reporting forms and allows electronic reporting of some test results (reference RCP's January 2001 newsletter on this subject). On May 23, 2001, the Department of Transportation gave its approval for HHS certified drug testing labs to begin using the new electronic reporting process and new reporting forms now, before the August 1 effective date. This should ease the transition to the new reporting process. The notice can be downloaded from RCP's website HERE.

"Get the Dirt," a damage prevention awareness video produced by the Dig Safely Team, is available for $1.20 each, plus shipping handling. The team, a subcommittee of the Common Ground Alliance, is encouraging pipeline companies to get a copy of the video into the hands of everyone who digs. The order form can be download from the Dig Safely website at http://www.digsafely.com. Also check out the Dig Safely website for other materials and promotional items.

Pending Audits?

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.

Compliance Management Programs – additional thoughts.

Our "reader question of the month" in May prompted these additional comments from Richard Flint:

1. Ensure that the Company attorney(s) understand and support the program; especially that the program is not a one-time project to be shelved after a year or two when something more exciting comes along. Non-support by the Legal department can be fatal.
2. Ensure that Management understands the unique nature of a compliance program and is willing to fund it every year. Also, since new regulations may require resources to be expended for programs not included in the current budget, and revised regulations may cause previously authorized funds to be inadequate, some flexibility is needed to permit the development/implementation of required programs within the mandated time frames.

Thank you, Mr. Flint, for these sage thoughts. The importance of management support and buy-in, as evidenced by sufficient management attention, manpower, and funding, is critical to the success of a compliance management program.

Know someone with regulatory expertise who is interested in full or part time work? Our recruiting coordinator would be glad to get their resume! Have them sent to chandra@your-rcp.com, or FAX to 713-655-8083.

Visit Regulatory Compliance Partners on the Web at

or call us at 1-888-RCP-X-YES to see what we can do for you.