The Minerals Management Service (MMS) regulates some pipelines in the Gulf of Mexico and other OCS waters. The MMS recently published a summary of the fines paid in the year 2000 for violations of their regulations. In total, 66 fines were paid, totalling $1,780,721, for an average fine of $26,980. Some of the pipeline fines include:

• The SDV on the bi-directional pipeline was bypassed – $22,000
• The PSHL protecting the departing oil pipeline was bypassed – $5,000
• Pipeline leak detection system was not operated and maintained properly – $48,000

The entire report is available on RCP’s website here.

The Technical Pipeline Safety Standards Committee Meeting scheduled for Thursday, September 13, 2001, at the Dulles Marriot is cancelled. OPS hopes to reschedule this meeting in the near future.

On June 17, 1999, the EPA issued the national emission standards for hazardous air pollutants from oil and natural gas production facilities and the national emission standards for hazardous air pollutants from natural gas transmission and storage facilities (64 FR 32610). On June 29, 2001, EPA issued technical corrections to clarify intent and correct errors in these national emission standards for hazardous air pollutants (NESHAP) (66 FR 34548). On September 27, 2001, the EPA corrected an error in the June 29, 2001 technical corrections for the Natural Gas Transmission and Storage Facilities NESHAP. This correction was made to reinstate a portion of the first sentence in §63.1270(a) that was mistakenly deleted during the editing process for the June 29, 2001 technical corrections. Reinstatement of this language will make it clear that the natural gas transmission and storage facilities NESHAP only applies to natural gas transmission and storage facilities that are major sources of HAP, and that transmission and storage systems are subject to the rule up to a final end user only when a local distribution company is not present.

40 CFR Section 63.1270 is amended by revising the first sentence of paragraph (a) introductory text to read as follows:

§63.1270 Applicability and designation of affected source.

(a) This subpart applies to owners and operators of natural gas transmission and storage facilities that transport or store natural gas prior to entering the pipeline to a local distribution company or to a final end user (if there is no local distribution company), and that are major sources of hazardous air pollutants (HAP) emissions as defined in §63.1271. * * *

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.

The Integrity Management Program workshop planned for October 10-11, 2002, has been postponed indefinitely. OPS is continuing their work on a new OPS Integrity Management Program website, and plans to use the website to communicate information about implementation of the hazardous liquid integrity management rules. OPS will broadcast an announcement on the debut of the new IMP website shortly. Please direct related questions either to Beth Callsen (202.366.4572) or to Jeff Wiese (202.366.2036), or jeff.wiese@rspa.dot.gov.

As expected, the OPS / RSPA has conformed their pipeline facility drug and alcohol testing regulations with DOT’s ‘‘Procedures for Transportation Workplace Drug and Alcohol Testing Programs.’’ In addition, they have changed the format of the regulations to make them easier to apply and understand. The purpose of these changes is to make the regulations clearer and consistent with DOT’s drug and alcohol testing policies. This Final Rule takes effect September 11, 2001. This action is consistent with the Notice of Proposed Rulemaking issued April 30, 2001 (66 FR 21506) (reference RCP's May 2001 newsletter and links for additional background information). The revised drug and alcohol testing regulation can be downloaded from RCP's 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.