The February 1, 2000 Federal Register contained a correcting amendment to a final rule published April 2, 1999. The final rule incorporates by reference consensus standards for aboveground steel storage tanks into the hazardous liquid pipeline safety regulations. This document makes two minor corrections to the final rule. First, it adds an industry publication, American Petroleum Institute (API) 1130 to the list of incorporated references. Second, it corrects the reference to the API Standard 653 to include Addendum 2. The Federal Register publication can be found on the RCP Web-site at

http://www.your-rcp.com/downloads/Misc/65 FR 4770 2-1-00.pdf

(requires Adobe Acrobat to view)

Is all of your Tier II information getting you down? Too many things to do, and not enough time to become an expert on this too? RCP can prepare your Tier II reports and handle the electronic submittals for you. Give Tina a call at 225-755-7760.

RCP is currently working to develop more precise methods to estimate the worst case discharge (WCD) for long oil pipelines. The default method is to assume the entire volume of oil in the pipeline between block valves is lost during a worst case discharge spill. However, numerous factors can have a significant impact on the volume of oil that could actually leak from a damaged pipeline – including pipeline diameter, pipe elevation profile, oil compressibility, and pipeline wall thickness versus operating pressure. If you would like to participate in development of this WCD calculation methodology, please contact Bill Byrd at wrbyrd@your-rcp.com.

Once again this month, we will evaluate a task with the 4-part test as required by the Operator Qualification Rule. As we have discussed in previous issues, it is not always an easy decision when deciding whether or not a task is covered.

Is placing and maintaining line markers a covered task?

1. Is it performed on a pipeline facility? The definition of a pipeline facility includes the pipeline right-of-way. Since these markers are placed in the right-of-way, this task is indeed performed on a pipeline facility.
2. Is it an Operations and Maintenance task? This task is required under Subpart F of 49 CFR Part 195 Operations and Maintenance.
3. Is it performed as a requirement of 49 CFR Part 192 or 195? This task is performed to comply with 49 CFR Part 195.410 (a) & (c)
4. Does it affect the operation or integrity of the pipeline? Although the actual placement and maintenance of the markers themselves does not affect the operation or integrity of the pipeline, without the markers the pipeline integrity of the pipeline is in danger from third parties.

What do you think about these questions? Please email your comments on this or other tasks that you would like to have included in future newsletters to tdhollowell@your-rcp.com

The U.S. DOT Office of Pipeline Safety (OPS) administers the national regulatory program to assure the safe and environmentally sound transportation of natural gas, liquefied natural gas and hazardous liquids by pipeline. The Accountable Pipeline Safety and Partnership Act of 1996 requires that OPS adopt rules requiring interstate gas pipeline operators to provide maps of their facilities to the governing body of each municipality in which the pipeline is located. OPS is also required to adopt rules requiring pipeline operators to identify facilities located in unusually sensitive areas and high density population areas, to maintain maps and records detailing that information, and to provide maps to federal and state officials upon request. A joint government-industry pipeline mapping quality team (MQAT I) developed a set of strategies concerning how the OPS could develop reasonable pipeline location information without creating an undue burden on the pipeline industry. The findings of MQAT I are described in, "Strategies for Creating a National Pipeline Mapping System". The second joint Government/Industry Pipeline Mapping Quality Action Team (MQATII) developed standards for the states and the national repository as well as Pipeline and Liquefied Natural Gas Operator Submission standards. MQATII drafted these standards and incorporated appropriate recommendations outside those developed by the action team. Check out the National Pipeline Mapping System at http://www.npms.rspa.dot.gov/default.htm.

Pending Audits? Has the DOT notified you of a pending audit? RCP can provide confidential internal auditing to help ensure that your facilities are up to the agency's latest standards.

On January 14, 2000, the EPA gave express notice of a regulatory interpretation that "slotted guidepoles at certain petroleum storage vessels and tanks may not comply with regulatory requirements. Slotted guidepoles are relatively simple devices for sampling the contents of a floating roof storage tank. Unless they are controlled, the slots, hollow core and the space between the guidepole and the tank's roof are observable emission pathways that violate the "no visible gap" prohibition in 40 CFR part 60, subparts Ka and Kb.

Based on these determinations, EPA Region IX brought enforcement actions against 5 California refineries that had tanks with slotted guidepoles and later issued a letter to the Western States Petroleum Association in which it provided a detailed analysis of the issue, determining that slotted guidepoles are subject to the no visible gap requirement. These enforcement matters were settled by the facilities installing controls (e.g., floats and wipers) at 20 NSPS Subpart Ka/Kb tanks and 27 non-NSPS tanks.

Also on January 14, 2000, the EPA proposed a "Storage Tank Emission Reduction Partnership Program". In the interests of promoting fast, efficient and widespread emission reductions, EPA intends to offer and enter into agreements with companies that installed or will install controls to reduce slotted guidepole emissions at their NSPS Subpart Ka/Kb tanks. As under EPA's policy concerning voluntary disclosure, this opportunity will be available only to owners/operators of affected NSPS Subpart Ka/Kb facilities that are not currently the subject of an enforcement action based upon their use of slotted guidepoles.

RSPA will hold a public meeting on Thursday, February 17, 2000, from 9:00 a.m. to 4:30 p.m to continue the efforts to prevent damage to underground facilities, as identified in last year's Common Ground Study. RSPA is facilitating the establishment of an organization to advance underground facility damage prevention. RSPA has established four teams: by-laws, finance, membership, and nominating. The purpose of this meeting is to provide a forum for these teams and interested public to begin the development of this damage prevention organization. ADDRESSES: The public meeting will be held at the Sheraton International Hotel at BWI, 7032 Elm Road BWI Airport, MD. FOR FURTHER INFORMATION CONTACT: Eben M. Wyman, (202) 366-0918, or by e-mail at eben.wyman@rspa.dot.gov.

Need to permit a new facility? RCP's expert staff can handle the entire permitting process. We have decades of experience with all types of permitting and authorizations, and have professional engineering registrations throughout the Gulf Coast.

The Louisiana State Police has unveiled a new electronic reporting format for the annual Tier Two inventory report submittal. The system can be accessed via internet access with no additional software requirements at http://www.pds.state.la.us/lanweb.nsf. Facility and user ID numbers and passwords can be requested at the above site. The Id and password will be sent to you by the "Right-to-Know" Unit of the Louisiana State Police via US mail for you to begin the filing process. The electronic filing is not required, but the State Police and the EPA state that they will not take enforcement action against facilities planning to submit the information electronically for filing after March 1, 2000. However, the complete inventory information must be available upon request by March 1, 2000 and must to submitted by May 1, 2000. This extension only applies to facilities filing ELECTRONICALLY. Please note however, that the EPA does not have authority to extend the deadline. Their promise is only to not take enforcement action. If challenged by some group, it is not clear what the EPA would do.

Some points to remember about the electronic data submittal: