DOT Pipeline Compliance News

April 2003 Special Edition Issue

In This Issue

Note from the Editor

NOTE: This special edition newsletter is being sent to alert you to two recently announced meetings and deadline extension which are of broad interest to the pipeline industry. The meetings will occur before our regular monthly newsletter will be published.

Pipeline Integrity Management in High Consequence Areas (Gas Transmission Pipelines) – Notice of public meeting

OPS will conduct a meeting the proposed gas pipeline integrity management rule on Friday, April 25, 2003, from 8 a.m. to 4 p.m. at the Marriott at Washington Dulles Airport, 4520 Aviation Drive, Dulles, VA 20166. Tel: 703-471-9500; Web site: The meeting is open to all. There is no cost to attend. You may register electronically for this meeting at: Please make your reservations as soon as possible as hotel rooms are limited. For other details on this meeting contact Juan Carlos at 202-366-1933.

At this meeting OPS intends to present the following issues for comment and to question further those offering comments to assure that they completely understand each issue. The preliminary agenda for the April meeting includes the following questions for discussion:


Low Stress Pipelines
Should assessment requirements for low-stress pipeline (i.e., operating at less than 30 percent SMYS) allow use of confirmatory direct assessment (CDA) for all assessments (baseline and reassessments)?

Pressure Testing
Should the requirement to pressure test pipelines to verify integrity against material and construction defects be limited to pipeline segments for which information suggests a potential vulnerability to such defects? If so, what information should be relied upon?

Direct Assessment Equivalency Should the assessment intervals for direct assessment be revised to be the same as those applicable to in-line inspection or pressure testing? Are there opportunities to quickly schedule and assess research demonstrations to provide additional data on which to base judgments about validity?

Plastic Transmission Lines
What assessment requirements should be applicable to plastic transmission pipelines?


Dents and Gouges
Should a repair criteria for constraint dents on the bottom of the pipe be different from that allowed for dents located on the top? Should the presence of stress risers, cracking or metal loss affect this decision?

Preventive and Mitigation Measures

Third Party Damage
Should additional third-party damage prevention methods be utilized instead of explicit assessments for third-party damage? What methods should be used in conjunction with other assessment methods to detect delayed third party damage?

Segments Outside HCAs
How can the requirements be clarified for the situations when an operator should look beyond the segment in a high consequence area, when segments outside the HCA are likely to have similar integrity concerns as those found inside an HCA?

Performance Measures
Should we require monthly electronic reporting of performance measures?


High Consequence Area-Bifurcation Option
Should a rule allow two options: following the definition of high consequence areas defined by final rule on August 6, 2002; ( 67 FR 50824 ) or using potential impact circles along the entire length of the pipeline? Under either option, an operator would calculate the potential impact circles for each segment, but the use of those circles would differ depending on the option. If the operator used the class location component of the high consequence area definition, the operator would treat entire class 3 and 4 areas as high consequence areas and use the potential impact circles to determine population density beyond 660 feet using specified number of buildings intended for human occupancy. Under the potential impact circle option, operators would use the circles to identify areas where the density of buildings intended for human occupancy exceeds a specified number and then focus the integrity assessments, repairs and other protections in these areas.

Requirements for how an operator treats identified sites that are defined in the high consequence area would not change under either option.

Population Threshold
Should the criterion for determining the population density component of a high consequence area be based on 10 or 20 buildings intended for human occupancy within the impact circle?

Impact Radius Safety Margin
Should additional safety margin be applied to the potential impact circle radius calculated using the C-FER equation?

Should a rule allow an operator to use data regarding the number of buildings within 660 feet of the pipeline (available now to operators because of the existing definition of class locations) to infer (extrapolate) the building density in potential impact circles larger than 660 feet? Should this be limited to an interim period of five years to allow operators to collect additional data on buildings beyond 660 feet?

Integrity Management Plan Up-to-Date?

RCP has the tools and expertise to develop comprehensive Integrity Management Plans for both liquid and gas pipelines. Click Here if you would like information on RCP’s Integrity Management Services and receive a copy of our FREE Integrity Management CD.

Operator Qualification Public Meeting

The Office of Pipeline Safety (OPS) will conduct a public meeting on Wednesday, April 23, 2003, beginning at 8:30 a.m., ending at 4 p.m. to discuss progress in implementing the operator qualification (OQ) rule for gas and hazardous liquid pipelines. The meeting will focus on development of the 13 OQ issues identified at previous public meetings on February 25, 2003, in Houston, TX, and March 25, 2003, in Mesa, AZ. Discussion will include protocols and explanation of changes, supplementary guidance, definitions of terms, and development of a national consensus standard. Persons wishing to make a presentation or statement at the meeting should notify Janice Morgan, (202) 366-2392, no later than April 14, 2003. A record of previous public meetings on Qualification of Pipeline Personnel that were held in San Antonio, TX; Houston, TX; and Phoenix, AZ, are available in this docket (RSPA-03-14448).

This meeting is free and open to the public. You may register electronically for this meeting at: The public meeting will be held at the Double Tree Hotel Atlanta-Buckhead, 3342 Peachtree Road, Atlanta, GA 30326 (telephone: 404/231-1234, fax: 404/231-5236, Web: The deadline for making a hotel reservation is April 11, 2003, (refer to the U.S Department of Transportation (DOT) (Operation Qualification Group block for government rates). You may contact Richard Sanders at (405) 954-7214 or (405) 954-7219, regarding the agenda of this public meeting.

O&M Manual Up-To-Date?

RCP has the tools and expertise to develop comprehensive procedures that you need to protect your people, facilities, and environment. Click Here

SPCC Deadline Extended by EPA

EPA is extending, by eighteen months, the compliance dates in §112.3(a) and (b).

Thus, an onshore or offshore facility that:

  1. was in operation on or before August 16, 2002 must maintain its existing Plan, but must amend it, if necessary, to ensure compliance, on or before August 17, 2004, and must implement the amended Plan as soon as possible, but not later than February 18, 2005.
  2. becomes operational after August 16, 2002 through February 18,2005, and could reasonably be expected to have a discharge as described in 40 C FR 112.1(b), must prepare a Plan on or before February 18, 2005, and fully implement it as soon as possible, but not later than February 18, 2005.
  3. becomes operational after February 18, 2005, and could reasonably be expected to have a discharge as described in 40 CFR 112.1(b), must prepare and implement a Plan BEFORE it begins operations.

The SPCC extension rule was signed by the EPA Administrator on April 10, 2003 and will become effective on the date of publication in the Federal Register. The expected date of publication is April 17, 2003.

DISCLAIMER: This version is not the official Federal Register version. Should there be any discrepancies between this document and the Federal Register version, the Federal Register version governs.

RCP’s Fantastic 1-Page Version of New SPCC Regulation

The deadline for SPCC Plan revisions is fast approaching, February 17, 2006! RCP has developed a 1-page version (in tiny type) of the new SPCC regulations, to be revised as per the April 17, 2003 rule modification. To receive a complimentary copy along with a CD of valuable SPCC Reference Materials Click Here to request additional information.

Bill Byrd signature
W. R. (Bill) Byrd, PE
RCP Inc.