On December 14, 1999, the DOT announced their adoption of a safety performance standard for the repair of corroded or damaged steel pipe in gas or hazardous liquid pipelines. Because present safety standards specify particular methods of repair, operators must get approval from government regulators to use innovative repair technologies. The performance standard is likely to encourage technological innovations and reduce repair costs without reducing safety. This final rule takes effect January 13, 2000. After that time, operators will have more flexibility to use alternative repair methods other than simply replacing the damaged sections of the pipeline. This could yield significant savings in repair costs, with much less pipeline downtime. The entire final rule can be accessed from our website at http://www.your-rcp.com/newsletters/12-14-99 alternative pipeline repair final rule1.
This proposed rule defines drinking water and ecological areas that are unusually sensitive to environmental damage if there is a hazardous liquid pipeline release. RSPA refers to these areas as unusually sensitive areas (USAs). RSPA is working on a pilot test that implements the proposed definition and identifies USAs in three states: Texas, Louisiana, and California. Other government agencies, environmental groups, and academia will evaluate the final results of this pilot test. RSPA will publish the results of the pilot test and technical analysis once they are complete. This proposed rule would not require specific action by pipeline operators. However, this proposed definition would be used as criteria in evaluating requirements by certain existing and future regulations.
RSPA will use the definition for identifying USAs in current and future regulations. Any regulatory application of this definition will be aimed at ensuring that operators implement appropriate protective measures for pipelines in USAs.
Regulations where operators may have to identify USAs include:
- Risk-based Alternative to Pressure Testing Older Hazardous Liquid and Carbon Dioxide Pipelines (63 FR 59475; November 4, 1998),
- Response Plans for Onshore Oil Pipelines (62 FR 67292; December 24, 1997),
- Hazardous Liquid Pipelines Operated at 20% or Less of Specified Minimum Yield Strength (49 CFR Part 195),
- Emergency Flow Restricting Devices, (Docket PS-133),
- Increased Inspection Requirements, (Docket PS-141) and
- Pipeline Safety: Enhanced Safety and Environmental Protection for Gas Transmission and Hazardous Liquid Pipelines in High Consequence Areas, (64 FR 56725; October 21, 1999)
Send written comments on this proposed definition to DOT / RSPA by June 27, 2000.
The Office of Pipeline Safety (OPS) has extended to January 17, 2000, the comment period on pipeline system integrity programs in high-consequence areas. OPS requests comments that address how to provide additional safety and environmental protection for gas transmission pipelines and hazardous liquid pipelines in high-consequence areas through regulated integrity management programs.
On November 18-19, 1999, the Office of Pipeline Safety held a public meeting to discuss the need for additional safety and environmental regulations for pipelines in high-consequence areas (i.e., areas where a pipeline failure could have serious consequences for the public or the environment). At the meeting, OPS announced that written comments on pipeline system integrity management issues would be accepted through December 20, 1999. The questions raised at the public meeting and subsequent discussions with the pipeline industry and regulators have shown that more time is needed to prepare and file comments. After the public meeting, OPS began discussing a conceptual model for ensuring extra protection in high-consequence areas. This model, along with additional information on the public meeting and on pipeline system integrity management issues for high-consequence areas, is posted on OPS’s pipeline system integrity management Internet site. OPS has also set up an electronic discussion forum so that they can get a free exchange of ideas on how to implement a pipeline system integrity management process into the pipeline safety regulations. This forum will be open until at least January 17, 2000. The transcript of the November 18-19, 1999, public meeting and public comments concerning issues raised at the meeting are available in the docket, which is accessible at the Dockets Facility or through the OPS pipeline system integrity management Internet site at http://ops.dot.gov/imp.htm.
No later than January 17, 2000, comments can be submitted over the Internet to the OPS integrity management site at http://ops.dot.gov/imp.htm. You may also submit written comments by mail or delivery directly to the Dockets Facility, U.S. Department of Transportation, Room PL-401, 400 Seventh Street, SW, Washington, DC 20590-0001. Comments may be submitted directly to the docket at the following Internet Web address: http://dms.dot gov. Click on “Help & Information” for instructions on how to file a document electronically. All comments should identify the docket and notice numbers stated in the heading of this notice. Anyone desiring confirmation of mailed comments must include a self-addressed stamped postcard.
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:
- Electronic submittal of the data through the new system satisfies the state police reporting requirement. No hardcopy must be sent if the form is electronically submitted.
- Only one person per facility will be authorized to submit the final “certified” form. No signature is required for electronic submittals.
- Hardcopies must still be sent to the LEPC and fire department. The program will print a suitable document for submittal.
- The program creates a form for assessing the fee associated with the submittal. This must be printed out and mailed with a check to the State Police. The system will eventually allow for credit card payments.
- Data can be entered into the system at any time. It can also be edited at any time. The “official” report only occurs when the person authorized to submit the data actually does so.
- Data access will be limited to the following groups for each facility:
- Company representatives
- Consultants (is authorized by the company)
- State Police
- Parish LEPC
- Neighboring LEPC if facility is within one mile of parish boundary
- Local fire departments
Related information can be found at:
Right-to-Know Website: http://www.dps.state.la.us/lsp/rtkcover.html
Right-to-Know “e-filing” Address: http://www.dps.state.la.us.lcnweb.nsf
State Police Website: http://www.dps.state.la.us/lsp/welcome.html
Right-to-Know Response e-mail: rtktier2@dps.state.la.us
RCP is planning DOT seminars in April and June of 2000 in Louisiana and Texas. These seminars will include a review of the DOT Pipeline regulations, with special emphasis on new requirements associated with Operator Qualification and Breakout Tanks. Watch this newsletter or check our website for details.
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
Heather Roark
Jessica Foley
