On June 27, 2001, RSPA published a request for comments concerning gas pipeline integrity management program requirements. RSPA has previously published the final pipeline integrity management rule for large liquid pipeline operators, and has already proposed the rule for small liquid pipeline operators. However, discussions concerning the appropriate pipeline integrity management requirements for gas transmission pipelines are still in progress. The June 27 document gives a very good description of the unique challenges and special considerations that must be incorporated into a final rule for gas transmission pipeline integrity management programs, such as:

• gas is not easily stored, and some communities are served by only one gas transmission pipeline. Thus, downtime due to integrity management tests could have serious supply (and possibly price) repercussions.
• many gas pipelines are not currently capable of accommodating smart pigs, so other forms of assessment may be more appropriate.
• failures of gas pipelines can result in serious fires, with resulting personnel and property damage, but do not tend to have severe environmental consequences. Thus, the definitions of High Consequence Areas should be different than for liquid pipelines.

To facilitate the discussion process, an electronic public discussion forum on gas pipeline integrity management issues has been developed on the office of Pipeline Safety’s internet home page at http://ops.dot.gov/forum. Interested persons are invited to submit written comments by August 13, 2001, Docket No. RSPA-00-7666. The full notice is available on RSPA’s website at http://assn.cycla.com/opsforum/docs/GasIMP_FR_Notice_mi_06_14_01.pdf.

RCP’s staff includes professional engineers who are experienced in the development of pipeline integrity management programs and who can provide assistance to companies that are developing their own pipeline integrity programs, such as:

• Training integrity assessment team members on the applicable regulations and the assessment process.
• Selecting an appropriate assessment and ranking methdology.
• Structuring the assessment process and in tracking the necessary data, including selection of an appropriate software tool if needed.
• Identifying High Consequence Areas and impact areas of potential pipeline failures.
• Comparing and reconciling the input from various groups across an organization, to ensure that the company-wide assessment data is consistent between each operating organization.
• Identifying and reviewing resource information (industry studies, engineering standards and recommended practices, historical failure and incident data, etc.) of relevance to the operator’s pipelines.

Contact Mr. Ron McCoy, PE, at 713-655-8080 if you would like to discuss these services in more detail.

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. Some companies have chosen to send their entire risk assessment team to this seminar, as a way of kicking off their internal risk assessment process. 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 Office of Energy Projects will hold the fifth in a series of public meetings for the purpose of exploring and enhancing strategies for constructive public participation in the earliest stages of natural gas facility planning. This seminar will be held on Thursday, July 19, 2001, at the Holiday Inn, 300 Woodbury Avenue, Portsmouth, New Hampshire 03801, phone number 1-603-431-8000, website www.hiportsmouth.com. The meeting is scheduled to start at 9:00 a.m. and finish at 2:45 p.m. This seminar will be a new experience because FERC will present and discuss the draft Outreach Action Options for Industry, Agencies, Citizens, and FERC staff which they have developed based on the first four seminars. The draft Outreach Action Options are a compilation of the ideas, or “tools”, the FERC staff has designed to provide each stakeholder group with practical strategies for reaching consensus and developing win-win solutions.

The staff of the Commission’s Office of Energy projects will give a briefing on the draft plans. Then, participants will be given an opportunity to provide feedback on the plans to help ensure that they address the necessary issues. FERC is inviting interstate natural gas companies; Federal, state and local agencies; landowners and non-governmental organizations to join as they continue to develop new strategies in participatory project design. Interactive breakout sessions will be held with representatives from each stakeholder group to review and comment on the draft Outreach Action Options. Then, each breakout group will have an opportunity to share its results with the overall seminar group in an interactive “brainstorming” session.

The objectives of the seminar are:

1. Present and discuss the draft Outreach Action Options;
2. Collect constructive comments and make constructive revisions to the plans;
3. Explore other ideas for improving the FERC’s environmental review process.

If you plan to attend, please email gasoutreach@ferc.fed.us by July 6, 2001. Or, you can respond via facsimile to Pennie Lewis-Partee at 202-208-0353. Please include in the response the names, addresses, and telephone numbers of all attendees from your organization. FERC will send an acknowledgment of your request. The draft Outreach Action Options will be posted on the FERC website www.ferc.gov and will be mailed to all past seminar participants and to all registrants for this seminar. Interested persons will then have an opportunity to review the draft Outreach Action Options and offer comments. Comments should be sent via e-mail to: gasoutreach-feedback@ferc.fed.us@ferc.fed.us and should be sent by August 3, 2001.

If you have any questions, you may contact any of the staff listed below:

Richard Hoffmann 202/208-0066
Lauren O’Donnell 202/208-0325
Jeff Shenot 202/219-2178
Howard Wheeler 202/208-2299

OPS recently posted their December, 2000, report to congress concerning the Pipeline Risk Management Demonstration Program. It reads in part:

Building on the experience gained to date, the primary foci of the remainder of the program will be:

• Monitoring and auditing the approved demonstration projects. This activity will: a) ensure that the programs are producing the expected benefits; b) continue to improve the industry and regulator understanding of the critical elements of process-oriented safety and environmental programs; c) develop improved approaches to conducting safety and risk management system audits; and d) continue to develop appropriate performance measures.
• Enhanced Public Information and Communication. This activity will continue to expand the amount and types of risk-related information available to local safety officials and other concerned citizens.
• Application of lessons learned in the Risk Management Program to the current regulatory process. This activity will allow OPS to make informed decisions about the future use of risk management in the pipeline safety program, including input to the risk-based criteria and essential process elements of the Integrity Management rule.

The full report can be accessed on OPS’s website at http://ops.dot.gov/ReportToCongress042501.htm.