This is a free newsletter from Regulatory Compliance Partners (RCP) that is mailed to anyone with an interest in recent happenings within the Department of Transportation Office of Pipeline Safety . If you have an issue or topic that you would like to see discussed, send it to dcdorhauer@your-rcp.com, and we will address it in an upcoming issue. Be sure to check out the RCP Web page for past issues of this newsletter and other pertinent DOT OPS information.

Numerous changes are being required after October, 2000 with the addition of the Breakout Tank rules. Some of these changes include:

• New design and cost requirements
• New requirements for the repair, alteration, and reconstruction of above-ground breakout tanks already in service.
• New maintenance and operation requirements for these tanks.

Protection must be provided against ignitions from static electricity, lightning, and stray currents. This protection must be in accordance with API Recommended Practice 2003. However, this is not required if the operator notes in the Operations and Maintenance Manual why such protection is not necessary for the safety of a particular breakout tank.

Another potential addition to the Operations and Maintenance Manual is the identification of the hazards associated with access/egress onto floating roofs of in-service breakout tanks. These hazards as summarized in API Publication 2026 fit into the following categories:

• Oxygen Content Hazards
• Flammable Vapor Hazards
• Toxic Vapor and Gas Hazards
• Vapor Exposures
• Fire Hazards, and
• Physical Hazards

These hazards along with safety practices and procedures must be reviewed, and incorporated into the Operations and Maintenance Manual.

OTHER NEWS:
The Office of Pipeline Safety issued an advisory bulletin on July 16, 1999 , in the Federal Register (64 Fed. Reg. 38501 ), to notify owners and operators of hazardous liquid and natural gas pipelines of potential operational limitations associated with Supervisory Control and Data Acquisition (SCADA) systems and the possibility of those problems leading to, or aggravating, pipeline releases.

OPS and API are working together on a pilot program to identify potential Unusual Sensitive Areas. The final results will be evaluated by other government agencies, environmental groups, and academia. The test will be conducted in Louisiana, Texas and California and will determine if the model can be used to identify and locate unusually sensitive drinking water and ecological resources using data available from governmental and environmental agencies. The results of this pilot will be published after the test and analysis are complete.

REMEMBER:
All DOT Pipeline activites are not periodic and can not be scheduled ahead of time. Operators must be ready to identify possible safety-related conditions and follow-up as necessary. Other activites that must be performed as needed are:

• Inspect cut pipe
• Inspect uncovered pipe
• Report accidents
• Investigate accidents
• Correct abnormal operating conditions
• Train new employees
• Drug/Alcohol test for reasonable cause

Contact Regulatory Compliance Partners for assistance with any OPS compliance issue. Our experts will respond to your concern promptly, ensuring that you will stay in compliance with any and all regulations you face.