The DOT / OPS has finalized their new reporting requirements for hazardous liquid pipeline accidents. The rule lowers the current release reporting threshold of 50 barrels to a new threshold of 5 gallons, and makes changes to the accident report form. The changes are necessary because the existing reporting threshold and report form do not yield sufficient information for effective safety analysis. This final rule also changes the "bodily harm" criteria for accident reporting to conform to the gas pipeline reporting requirements. This change is necessary to harmonize reporting by hazardous liquid and gas pipeline operators. This rule is effective January 1, 2002! (editor's note: any spills since the first of 2002 should be re-evaluated using the new reporting criteria. However, since the rule was published January 8, 2002, we assume that reporting violations for the first 8 days of the year will not be levied using the new criteria. Also note that your O&M; manual will need to be revised to incorporate the new reporting criteria.)

FOR FURTHER INFORMATION CONTACT: Roger Little by phone at (202) 366-4569, by e-mail at roger.little@rspa.dot.gov, or by mail at the U.S. Department of Transportation (DOT), Research and Special Programs Administration (RSPA), Office of Pipeline Safety (OPS), Room 7128, 400 7th Street, SW., Washington, DC 20590. The final rule, including the revised reporting form and instructions, can be downloaded from RCP's website here.

At the request of Rep. John Dingell, D-Mich, the General Accounting Office will conduct a new investigation of the Office of Pipeline Safety and "the adequacy of its regulation" of the nation's network of natural gas and hazardous liquid pipelines. This is the second time in recent years that the office, which is Congress' investigative arm, has examined the pipeline agency at Dingell's request. The latest report, dated September 2001 and entitled "PIPELINE SAFETY – Progress Made, but Significant Requirements and Recommendations Not Yet Complete", can be downloaded from RCP's website here.

Electronic Reporting Process and New Inspection Forms 2000

Electronic Reporting Process:

OPS intends to begin electronic reporting of Incident and Annual reports, beginning Jan 1, 2002. They will have online reporting for the revised Transmission Incident report and electronic reporting for the Transmission Annual report. Information can be found at http://ops.dot.gov/electronic_reporting.htm. Continue to file all other reports using the existing hard copy method.

New Inspection Forms:

OPS has updated some of their inspection forms. Most have a revision date of July, 2001. The latest inspection forms can be downloaded from OPS's website at http://ops.dot.gov/forms.htm

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.

As mentioned in our September, 2001 newsletter, the DOT is planning to conduct "quick hit" audits of large liquid pipeline operators in early 2002 to ensure that their Pipeline Integrity Management program is on-track. Our December 2000 newsletter contained a link to the quick hit audit guidelines on the IMP website at http://primis.rspa.dot.gov/iim/protocol.htm. These guidelines have been updated and re-posted at this site. If you downloaded the earlier version, you should return to this site to get the latest edition. Remember that this is a situation where first impressions matter. If your company fares poorly (or below the average of other companies that were audited), you will face an in-depth audit earlier than the rest.

The DOT has updated the user fees to be assessed for natural gas transmission, hazardous liquid and liquefied natural gas (LNG) facilities. Detailed information can be found at http://ops.dot.gov/userfee/FY2002feeAssess.htm. Note that user fees (and other payments to DOT) can now be paid on-line.

Notice of Final NPDES General Permit – Western Portion of the OCS of the Gulf of Mexico (GMG290000) EPA Region 6 issued a modification of the National Pollutant Discharge Elimination System (NPDES) general permit for the Western Portion of the Outer Continental Shelf of the Gulf of Mexico (No. GMG290000) for discharges from new sources, existing sources, and new dischargers in the Offshore Subcategory of the Oil and Gas Extraction Point Source Category (40 CFR part 435, Subpart A). The modified permit will become effective February 19, 2002. The existing permit published in the Federal Register, at 64 FR 19156 on April 19, 1999, authorizes discharges from exploration, development, and production facilities located in and discharging to Federal waters of the Gulf of Mexico seaward of the outer boundary of the territorial seas offshore of Louisiana and Texas. This action adds the authorization to discharge of drill cuttings generated using synthetic and other non-aqueous based drilling fluids and hydrostatic test water from pressure testing of existing pipelines.

FOR FURTHER INFORMATION CONTACT: Ms. Diane Smith, EPA Region 6, 1445 Ross Avenue, Dallas, Texas 75202, Telephone: (214) 665 7191, or via EMAIL to the following address: smith.diane@epa.gov. The full notice can be downloaded from RCP's website at here.

On December 28, 2001, the DOT / OPS issued a final rule concerning corrosion control standards for hazardous liquid and carbon dioxide pipelines (see our January, 2001 newsletter regarding the proposed rule). The changes are intended to improve the clarity and effectiveness of the present standards, and reduce the potential for pipeline accidents due to corrosion. This final rule takes effect January 28, 2002. 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. The final rule is available on RCP's website here.

RCP will conduct a 2 day workshop on Pipeline Integrity Management on February 27-28, 2002 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 28th we will discuss various methods of actually conducting a risk assessment for pipeline segments, and will work though several hands-on examples. Copies of API Standard 1160: Managing System Integrity for Hazardous Liquid Pipelines and NACE Publication 35100: In-Line Nondestructive Inspection of Pipelines will be made available and used during the workshop. We received very positive feedback from the Pipeline Integrity Management workshops that we conducted in 2001, and expect this session to fill up rapidly. Additional information is available on our website here.

Help Wanted

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.