Integrity Management Communication Team Telephone Conference Meeting:

Integrity Management Communication Team held a meeting on August 28 at 1:30 p.m. The Team discussed the content and delivery of pipeline information to be conveyed to local officials and members of the public in or near high consequence areas. The meeting was held at the Department of Transportation, Nassif Building, 400 Seventh Street, S.W., Room 7128, Washington, D.C. 20590.

In connection with the proposed rule on Pipeline Integrity Management in High Consequence Areas, OPS plans to propose related rules governing operator communications with local public officials and agencies. To assist in this effort, the OPS Technical Advisory Committees created an Integrity Management Communications Subcommittee to focus on communications issues and to report back to the full Advisory Committee. OPS expanded this Subcommittee to form a team with equal representation from the public, government agencies, and the pipeline industry, and to consolidate several related efforts.

The Team provided feedback, insight, and information to the Advisory Committee on the content and delivery of information conveyed to local officials and public about pipeline operations, systems, and the risks they pose in or near high consequence areas. The Advisory Committee provided pipeline communication recommendations to OPS for consideration in drafting the Integrity Management Communications rulemaking. The Team assisted OPS in finalizing a primer to educate local officials on pipelines and their operations.

On August 22, 2000, the EPA published a proposed consent decree with Jayhawk Pipeline for alleged violations of the Clean Water Act. Under the proposed Decree, Jayhawk shall pay the United States $352,500 in civil penalties for the 16 discharges alleged in the Complaint, and 12 additional discharges itemized in Appendix D to the proposed Decree. Additionally, the proposed Decree requires Jayhawk to:

1. Purge and permanently remove from service portions of its gathering line system
2. Install a cathodic protection system on all gathering lines which remain in service in accordance with specified industry standards. The system will include periodic close interval and pipe-to-soil surveys and a commitment to perform corrective measures.
3. Perform periodic on the ground surveys of all remaining gathering lines in order to identify "Covered Water Bodies" within 500 feet of Jayhawk's remaining lines, and to ensure that the gathering lines meet specified standards for sufficiency of cover. Jayhawk will perform required corrective measures.
4. Hydrostatically test all remaining gathering lines located within 500 feet of a Covered Water Body, in order to ensure that the gathering line meets industry standards for structural integrity.
5. Company (sic) with an operation and maintenance manual for its gathering system which complies with federal standards set for trunk lines. Similarly, Jayhawk shall comply with federal standards for employee training set for trunk lines on its gathering system.

Editor's note: while we have not examined the case, it appears that the EPA is imposing DOT / OPS style regulations on pipeline systems that would otherwise be exempted from these requirements, and is imposing additional requirements that DOT / OPS does not require for any pipeline.

Acquiring a pipeline?

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On August 24, 2000, the Chairman of the National Transportation Safety Board, Mr. Jim Hall, released a statement after his visit to the site of the El Paso Natural Gas Company pipeline rupture last weekend near Carlsbad, New Mexico that killed 11 people. It reads in part:

"National Transportation Safety Board investigators thus far have determined that the section of pipe that failed during this accident was originally installed in 1952. It is unfortunate that this pipe had never been inspected with an internal inspection tool or hydrostatically tested in all that time. There are no federal regulations requiring such tests. Although this section of pipeline as configured could not accommodate an internal inspection tool, it could have been pressure tested or examined by other means. The NTSB has been urging mandatory testing requirements such as internal inspections and pressure tests since 1987. No American would want to use any transportation vehicle that would not be properly inspected for 48 years, nor should we have pipelines travelling though any of our communities in this condition."

The full text of this and other NTSB press releases is available at http://www.ntsb.gov/pressrel/pressrel.htm.

The Office of Pipeline Safety has posted an advisory bulletin to Owners and Operators of Gas Transmission Pipelines concerning Internal Corrosion in Gas Transmission Pipelines. The bulletin advises owners and operators of natural gas transmission pipelines of the need to review their internal corrosion monitoring programs and operations. This action follows a review of incidents involving internal corrosion, some of which resulted in loss of life, injuries, and significant property damage. OPS' preliminary investigation of a recent gas transmission pipeline incident found internal wall thinning on damaged pipe associated with the incident. The wall thinning is consistent with that caused by internal corrosion. Gas transmission owners and operators should:

• Review procedures for testing to determine the existence or severity of internal corrosion associated with their pipelines. Some methods for monitoring internal corrosion are weight loss coupons, radiography, water chemistry tests, in-line inspection tools, and electrical, galvanic, resistance and hydrogen probes.
• Give special attention to specific conditions, including flow characteristics, pipeline location (especially drips, deadlegs, and sags which are on line segments that are not cleaned by pigging or other methods, fittings and/or "stabbed" connections which could affect gas flow, operating temperature and pressure, water content, carbon dioxide and hydrogen sulfide content, carbon dioxide partial pressure, presence of oxygen and/or bacteria, and sediment deposits.
• Review conditions in pipeline segments downstream of gas production and storage fields.
• Review conditions in pipeline segments with low spots, sharp bends, sudden diameter changes, and fittings that restrict flow or velocity, and segments in unusual terrain. These features can contribute to the formation of internal corrosion by allowing condensates to settle out of the gas stream.

The full advisory bulletin is available on the OPS website at http://ops.dot.gov/advisory082500rev2.htm.

In case you were wondering, the Texas Railroad Commission / Pipeline Safety Section reports the following level of activity for June, 2000:

• No. of distribution safety evaluations – 77 (175 in May!)
• No. of transmission safety evaluations – 63
• No. of liquid safety evaluations – 33 (85 in May!)
• No. of leak/calls – 29
• No. of accident investigations – 2
• No. of special investigations – 27

If they haven't evaluated your intra-state pipeline recently, looks like they will get to it soon!

Pipeline Safety: Meeting of the Integrity Management Communication Team:

(AGENCY: Research and Special Programs Administration, DOT – Communication Team Meeting)

The Integrity Management Communication Team met to discuss the content and delivery of pipeline information to be conveyed to local officials and members of the public in or near high consequence areas. The meeting was held on September 12, 2000, at the Department of Transportation, Nassif Building, 400 Seventh Street, SW, Room 6200 Washington, DC 20590.

The topics discussed at this meeting included discussions of the following: Information that is needed by various groups: landowners/tenants along pipeline rights-of-way; local and regional emergency response officials; excavators and the general public; review of existing materials used by pipeline operators for public education; results from a public awareness survey conducted by the American Petroleum Institute and focus groups sponsored by the Interstate Natural Gas Association of America; Office of Pipeline Safety website materials; information currently available under the Freedom of Information Act; and pending pipeline legislative proposals for community right-to-know.

The full announcement is available in pdf format: (65-54338)

Pending Audits?