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In This Issue

  1. DOT Pipeline Compliance / Integrity Assessment Workshop September 28 – 30, 2004 – Houston Early Registration-on or before September 6, 2004.
  2. Marketing Snoops on your pipeline?
  3. Acquiring a pipeline?
  4. Pipeline Safety: Periodic Underwater Inspections
  5. Pending Audits?
  6. EPA SPCC Plan Extension
  7. RCP’s Fantastic 1-Page Version of New SPCC Regulation
  8. RCP President to speak at the GITA conference
  9. OSHA Whistleblower Webpage
  10. Integrity Management Plan Up-to-Date?
  11. MOU on Pipeline Repair Permitting Streamlining
  12. DOT/OPS adopts API Standard 1104 Nineteenth Edition
  13. RCP Services Spotlight – Litigation Support / Expert Witness Services

EPA SPCC Plan Extension

The EPA has granted an 18 month extension to the new SPCC plan requirements. The actual text of the rule extension / modification is given below.

§ 112.3 Requirement to prepare and implement a Spill, Prevention, Control, and Countermeasure Plan.

  1. If your onshore or offshore facility was in operation on or before August 16, 2002, you must maintain your Plan, but must amend it, if necessary to ensure compliance with this part, on or before February 17, 2006, and must implement the amended Plan as soon as possible, but not later than August 18, 2006. If your onshore or offshore facility becomes operational after August 16, 2002, through August 18, 2006, and could reasonably be expected to have a discharge as described in § 112.1(b), you must prepare a Plan on or before August 18, 2006, and fully implement it as soon as possible, but not later than August 18, 2006.
  2. If you are the owner or operator of an onshore or offshore facility that becomes operational after August 18, 2006, and could reasonably be expected to have a discharge as described in § 112.1(b), you must prepare and implement a Plan before you begin operations.
  3. If you are the owner or operator of an onshore or offshore mobile facility, such as an onshore drilling or workover rig, barge mounted offshore drilling or workover rig, or portable fueling facility, you must prepare, implement, and maintain a facility Plan as required by this section. You must maintain your Plan, but must amend and implement it, if necessary to ensure compliance with this part, on or before August 18, 2006. If your onshore or offshore mobile facility becomes operational after August 18, 2006, and could reasonably be expected to have a discharge as described in § 112.1(b), you must prepare and implement a Plan before you begin operations. This provision does not require that you prepare a new Plan each time you move the facility to a new site. The Plan may be a general Plan. When you move the mobile or portable facility, you must locate and install it using the discharge prevention practices outlined in the Plan for the facility. The Plan is applicable only while the facility is in a fixed (non-transportation) operating mode.