In the Federal Register of January 16, 2002, DOT/RSPA published a Final Rule extending the regulations on managing the integrity of hazardous liquid and carbon dioxide pipelines that affect high consequence areas to operators with less than 500 miles of regulated pipelines. Inadvertently, the date after which prior integrity assessments may qualify for use was incorrectly…
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Request for public comments and OMB approval concerning Operator Qualification Record keeping Burden
RSPA is requesting public participation in the Office of Management and Budget (OMB) approval process regarding the renewal of an existing RSPA/Office of Pipeline Safety (OPS) collection of information for Operator Qualification of Pipeline Personnel. RSPA/OPS published a notice requesting public comment on April 18, 2002, and only one comment was received. Because this was the only…
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Revised Natural Gas Transmission Pipeline Incident and Annual Report Forms – CORRECTION
In the Federal Register of June 5, 2002, RSPA published a Notice document to owners and operators of natural gas transmission systems, concerning revised forms for incident reporting and annual reporting (see our July, 2002 newsletter for additional information). The Notice document contained the wrong Advisory Bulletin number. The correct number is ADB-02-02, not ADB-02-01. FOR…
Revised EPA SPCC and OPA-90 Rule
The Environmental Protection Agency is amending the Oil Pollution Prevention regulation promulgated under the authority of the Clean Water Act. This rule includes requirements for Spill Prevention, Control, and Countermeasure (SPCC) Plans, and for Facility Response Plans (FRPs). The final rule includes new subparts outlining the requirements for various classes of oil; revises the applicability of the…
Hazardous Liquid Pipeline Operator Annual Report Form: NPRM
This notice of proposed rulemaking (NPRM) would require hazardous liquid pipeline operators to submit an annual report (proposed form RSPA F7000-1.1). The report form asks for information that the Research and Special Programs Administration’s (RSPA) Office of Pipeline Safety (OPS) does not currently collect, such as: breakout tank location and capacity; hazardous liquid pipeline mileage by…
New RCP Office in Baton Rouge
RCP is relocating the Baton Rouge office to a newer, more spacious location effective August 16, 2002. The new address will be: RCP – Your Regulatory Compliance Partner 3975 O’Neal Lane, Suite A Baton Rouge, LA 70816www.your-rcp.com Our main Baton Rouge local phone number will remain the same: 225-755-7760. The toll free number of our Baton…
New Spill Planning Guidance in the Gulf of Mexico
Effective October 1, 2002, the Minerals Management Service (MMS) is revising their guidance (aka Notice to Lessees, or NTL) concerning Oil Spill Response Plans (OSRPs) for the Gulf of Mexico (GOM). The new NTL is number 2002-G09. This NTL provides clarification, guidance, and information to operators of facilities and leases located seaward of the coastline…
Gas HCA Determinations / Class Location Surveys
On August 6, 2002, RSPA published the final rule for Gas Pipeline High Consequence Areas. The upcoming Gas Pipeline Integrity Management rule will use this definition of high consequence areas to determine what pipelines are required to prepare integrity management plans. This raises a few questions for Gas Pipeline Operators. Is your Class Location Survey…
Small Liquid Pipeline Integrity Management Deadlines
Just a reminder for those Hazardous Liquid Pipeline Operators with less than 500 miles of pipelines. The initial compliance deadline for identifying segments that could effect HCA’s is only about 10 weeks away (November 18, 2002). The deadline to have the final written plan in place is February 18, 2003. OPS has given a lot…
OPS issues Comprehensive Integrity Management Inspection Protocals on August 30, 2002.
These long awaited protocals cover more than 170 pages and include extensive lists of specific points and questions inspectors will be checking when auditing your Pipeline Integrity Management Plan. Details are the name of the game for these protocols. For example – Have the risk analysis results and information been documented and incorporated appropriately in…
Revised SPCC Requirements and RCP SPCC Workshops
On July 17th, the EPA published final rule revisions for all SPCC and Facility Response Plans. The final rule: Expands the scope of the rule to conform with the expanded jurisdiction in the amended Clean Water Act Includes new subparts for various classes of oil Revises applicability of the regulation Amends several requirements for completing…
Revised SPCC Requirements and RCP SPCC Workshops
On July 17th, the EPA published final rule revisions for all SPCC and Facility Response Plans. The final rule: Expands the scope of the rule to conform with the expanded jurisdiction in the amended Clean Water Act Includes new subparts for various classes of oil Revises applicability of the regulation Amends several requirements for completing…
Texas GLO Spill Planning Revisions
The Texas General Land Office announces that proposed regulation changes have been published in the Texas Register August 23, 2002 edition. The effected regulations include 31 Texas Administrative Code Chapter 19 concerning facility certification, facility response plan requirements and definitions pertaining to coastal facilities. The proposed changes are expected to significantly lessen facility regulatory requirements…
OSHA Excavations Standard – Regulatory Flexibility Act Review
The Occupational Safety and Health Administration (OSHA) is conducting a review of the Excavations Standard pursuant to Section 610 of the Regulatory Flexibility Act and Section 5 of Executive Order 12866 on Regulatory Planning and Review. The purpose of this review is to determine, while protecting worker safety, whether this standard should be maintained without…
Reports of Abandoned Underwater Pipelines
Underwater pipelines are being abandoned at an increasing rate as older facilities reach the end of their useful life. This trend is expected to continue. RSPA’s/OPS’s regulations for abandonment reporting can be found at Title 49 cfr 192.727 and 195.402. RSPA requests public participation in the Office of Management and Budget (OMB) approval process regarding…
Natural Resource Damage Assessments – Final rule
In the event of a discharge or substantial threat of a discharge of oil (incident), the Oil Pollution Act of 1990 (OPA), 33 U.S.C. 2701 et seq., provides that Federal, State, Indian tribal, and/or foreign natural resource trustees (trustees) assess natural resource damages and develop and implement a plan for the restoration, rehabilitation, replacement, or…
Procedures for Transportation Workplace Drug and Alcohol Testing Programs; Procedures for Non-Evidential Alcohol Screening Devices
The National Highway Traffic Safety Administration (NHTSA) determines which non-evidential alcohol screening devices (ASDs) are suitable for use within DOT regulated industry testing programs. NHTSA has approved an ASD device that operates differently from other ASDs, and the DOT had no Part 40 procedures for its use. This final rule establishes procedures for the use…
Texas Proposed Rule for Public Liaison and Public Awareness
The State of Texas has proposed new regulations concerning community liaison and public awareness for gas and liquid pipelines. Each operator of a gas or liquid pipeline or pipeline facilities or the operator’s designated representative would be required to communicate and conduct liaison activities with fire, police, and other appropriate public emergency response officials in…
Drug and Alcohol Management Information System Reporting Notice of proposed rulemaking
The Department of Transportation’s Office of Drug and Alcohol Policy and Compliance (ODAPC) proposes to revise the Management Information System (MIS) forms currently used within six U.S. Department of Transportation (DOT) operating administrations (OA) for submission of annual drug and alcohol program data. These OAs are: Federal Motor Carrier Safety Administration (FMCSA); Federal Aviation Administration…