DOT Pipeline Compliance News

December 2003 Issue

In This Issue

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Advisory bulletin: Self-Assessment of Pipeline Operator Public Education Programs

RSPA’s Office of Pipeline Safety (RSPA/OPS) has issued as advisory bulletin to owners and operators of hazardous liquid pipelines, gas transmission pipelines, gas distribution pipeline systems and gathering pipeline systems regulated under the Federal pipeline safety regulations at 49 CFR Parts 192 and 195. In an advisory bulletin issued September 5, 2003 ( 68 FR 52816 ) RSPA/OPS noted that the Pipeline Safety Improvement Act of 2002 (PSIA) requires each owner or operator of a gas or hazardous liquid pipeline system to implement a continuous public education program on the use of one-call notification systems and other damage prevention activities, the indications of and hazards of an unintended release of product from a pipeline, the public safety steps required after a release, and how to report pipeline product releases. This advisory reminds pipeline operators that they must complete and submit self-assessments of their public education programs to RSPA/OPS for receipt no later than December 17, 2003, to meet the deadline established in the PSIA.

Advisory Bulletin (ADB-03-08)

To: Owners and Operators of Hazardous Liquid, Gas Transmission, Gas Distribution, and Gathering Pipeline Systems.

Subject: Self-Assessment of Pipeline Operator Public Education Programs.

Purpose: To remind owners and operators of gas and hazardous liquid pipeline systems of the requirements for effective public education programs and of the requirement to complete and submit self-assessments of those programs to RSPA/OPS no later than December 17, 2003.

Advisory: The Pipeline Safety Improvement Act of 2002 (PSIA) requires that each owner or operator of a gas or hazardous liquid pipeline system must implement a continuous public education program. The PSIA requires that by December 17, 2003, each owner or operator must review its existing public education program for effectiveness and modify the program as necessary by that date.

Although submission of the public education program is not required at this time, RSPA/OPS advises each operator to document their compliance with the PSIA by completing a formal self-assessment of its public education program and by comparing this program against the guidelines established in the recently-issued, industry consensus standard, API RP 1162, Public Awareness Programs for Pipeline Operators, and has developed a self-assessment form for that purpose. The self-assessment forms can be completed and submitted online at primis.rspa.dot.gov/edu/rp1162.htm. Self-assessment forms may also be downloaded from the same Web address and submitted to RSPA/OPS via E-mail, fax, or other delivery method.

Operators must submit their self-assessments to RSPA/OPS for receipt no later than December 17, 2003:

• Completed electronic forms may be submitted to RSPA/OPS as E-mail attachments at: RP1162SA@rspa.dot.gov.
• Hard-copy forms can be completed and sent to RSPA/OPS via fax, U.S. mail, or other delivery methods, but must be received by RSPA/OPS no later than December 17, 2003. Delivery of documents should be confirmed. Forms submitted by mail or other delivery methods should be sent to: Attn: Juan Carlos Martinez, Room 7128, U.S. Department of Transportation, Research and Special Programs Administration, Office of Pipeline Safety, 400 7th Street, SW., Washington, DC 20590.

Faxes should be sent to: Juan Carlos Martinez, fax # 202-366-4566. (Operators may call 202-366-1933 for confirmation of fax receipt).
Operators are encouraged to also provide copies of their self-assessments to the appropriate state pipeline safety agencies.

FOR FURTHER INFORMATION CONTACT: Juan Carlos Martinez, (202) 366-1933; or by e-mail, juan.martinez@rspa.dot.gov. The entire document can be viewed at the OPS home page at dms.dot.gov.

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Corrosion Threat to Newly Constructed Pipelines: Advisory Bulletin (ADB-03-06)

The OPS has recently issued an advisory bulletin to advise owners and operators of natural gas transmission and hazardous liquid pipelines to consider external corrosion as a possible safety risk to newly constructed pipelines and to identify and remediate the detrimental effects of stray currents during and after construction. This action follows the discovery of substantial external corrosion on a newly constructed gas transmission pipeline. The pipeline had been in service a little over two years when this unexpected corrosion was revealed by a high-resolution, inline inspection tool. The pipe wall pitting was consistent with that caused by underground stray electrical current before a cathodic protection system is installed. In some isolated areas, the pipeline exhibited more than 50% wall loss. Corrosion due to stray current is most often found on pipelines that cross other underground structures (such as other pipelines) or that follow overhead electric transmission lines.

Advisory: Each operator of a natural gas transmission or hazardous liquid pipeline should determine whether new steel pipelines are susceptible to detrimental effects from stray electrical currents. Based on this evaluation, an operator should carefully monitor and take action to mitigate detrimental effects. The operator should give special attention to a new pipeline’s physical location, particularly a location that may subject the new pipeline to stray currents from other underground facilities, including other pipelines, and induced currents from electrical transmission lines, whether aboveground or underground. Operators are strongly encouraged to review their corrosion control programs and to have qualified corrosion personnel present during construction to identify, mitigate, and monitor any detrimental stray currents that might damage new pipelines.

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Gas Pipeline Advisory Bulletin: Start of Baseline Assessment

The following is the text from a November 10, 2003 advisory bulletin from OPS:

Advisory Bulletin (ADB-03-07)

To: Operators of gas transmission pipelines.

Subject: The requirement in 49 U.S.C. 60109 (c) that each operator begin the baseline integrity assessment of segments in high consequence areas no later than June 17, 2004.

Purpose: To provide guidance to operators on what steps RSPA/OPS considers acceptable to begin the baseline integrity assessment process to meet the intent of the statute.

Advisory: RSPA/OPS will accept the following steps as having begun the baseline assessment process required by 49 U.S.C. 60109 (c).

Prior to June 17, 2004, each operator must have begun to-

• Identify segments that are located in high consequence areas;
• Integrate available data on those identified segments;
• Prioritize the highest risk segments from available data on those identified segments; and
• Select the assessment method best suited to assess (pressure-test, internal inspection devices, direct assessment, or alternative method) each high risk segment.

By June 17, 2004, each operator must have begun its preparation to conduct a baseline assessment on at least one high risk segment that the operator has already identified. Preparing to conduct a baseline assessment means that-

• An operator has scheduled for assessment the segments identified prior to June 17, 2004; and
• An operator has started to contract or has entered into a contract with a tool vendor to assess the identified segments; or
• An operator has started to assess the first scheduled segment.

RSPA/OPS also considers that any of the following actions as meeting the intent of the statute that an operator have begun the baseline integrity assessment process by June 17, 2004. The following actions are not the only actions that RSPA/OPS will accept.

• An operator has installed launchers or receivers for internal inspection devices;
• An operator has set up a segment for a pressure test; or
• An operator has completed the pre-assessment step for Direct Assessment.

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Integrity Management Plan Up-to-Date?

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Pipeline Surge Tanks are DOT Regulated

Just in case you weren’t sure, in 49 CFR 195.2 the Office of Pipeline Safety makes it clear that any “tank used to relieve surges in a hazardous liquid pipeline system” is considered a breakout tank and therefore falls under DOT jurisdiction. This is the case even if EPA also regulates the tank, such as at a refinery. So, if a regulated pipeline uses your tank for operational pressure relief surges, you have a breakout tank.
In addition to the applicable general pipeline safety requirements, breakout tank requirements include

• Design and construction (195.132)
• Repair, alteration and reconstruction (195.205)
• Impoundment, protection against entry, normal/emergency venting or pressure/vacuum relief (195.264)
• Pressure testing (195.307)
• Protection against ignitions and safe access/egress involving floating roofs (195.405)
• Overpressure safety devices and overfill protection systems (195.428)
• Inspection (195.432)

Not sure if your plant tanks are regulated? RCP can do a jurisdictional determination and help ensure that your breakout tanks are in full compliance with DOT requirements as needed.

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Passage of Internal Inspection Devices – Request for information

RSPA published regulations on Apr. 12, 1994 (59 FR 17281) requiring that, except where impracticable, operators of gas and hazardous liquid pipelines must design and construct certain pipelines to accommodate the passage of instrumented internal inspection devices, or smart pigs. In response to petitions for reconsideration from the American Gas Association and the Interstate Natural Gas Association of America (INGAA), RSPA proposed to modify provisions of � 192.150 that apply to offshore transmission lines and that require removal of smart pig obstructions from transmission line sections (59 FR 49896; Sept. 30, 1994). In addition, pending completion of the rulemaking, RSPA suspended enforcement of � 192.150 on offshore transmission lines and on onshore transmission line sections except replacement parts (60 FR 7133; Feb. 7, 1995).

One of the issues raised by INGAA’s petition and by comments on the proposed modification of � 192.150 concerns the applicability of � 192.150 to new offshore transmission lines 10 inches or larger. INGAA and industry commenters strongly suggested the rule should exempt all offshore transmission lines. The reasons were increased design and construction costs and lack of benefits. In addition, the Technical Pipeline Safety Standard Committee, RSPA’s advisory committee on proposed gas pipeline safety standards, supported industry’s view at a meeting in Washington D.C. on May 2, 1995.

In contrast, operators of hazardous liquid pipelines did not object to the similar pig-passage rule in � 195.120 that applies to offshore pipelines 10 inches or larger. And the Marine Board, in a 1994 study jointly sponsored by RSPA and the Minerals Management Service, “Improving the Safety of Marine Pipelines,” recommended that “[n]ew medium-to large-diameter pipelines running from platform to platform or platform to shore should be designed to accommodate smart pigs whenever reasonably practical.” (The study is available at books.nap.edu/books/0309050472/html/.)

In light of this background and the considerable time since persons submitted written comments on the proposed changes to � 192.150, RSPA has the following questions:

• Do operators of offshore gas transmission lines still object to applying � 192.150 to new offshore transmission lines 10 inches or larger?
• If the answer is yes, given that new hazardous liquid pipelines 10 inches or larger are meeting � 195.120, what differences are there between gas and liquid pipeline design and construction practices that would justify exempting new offshore gas transmission lines 10 inches or larger from � 192.150?
• Regarding the Marine Board’s recommendation, when would it not be “reasonably practical” to design new gas transmission lines 10 inches or larger running between platforms or platforms and shore to accommodate the passage of smart pigs?

To file written responses electronically, after logging on to dms.dot.gov, click on “Comment/Submissions” [Docket No. RSPA-03-16330]. You can also read all responses in the docket at dms.dot.gov. The previous record of this proceeding is in Docket No. PS-126. You can read comments and other material in this docket at the Nassif Building, U.S. Department of Transportation, Room 7128, 400 Seventh Street, SW, Washington, DC 20590-0001. For access to this docket, please call Jenny Donohue at (202) 366-4046.

FOR FURTHER INFORMATION CONTACT: L. M. Furrow by phone at 202-366-4559, by fax at 202-366-4566, by mail at U.S. Department of Transportation, 400 Seventh Street, SW, Washington, DC, 20590, or by e-mail at buck.furrow@rspa.dot.gov.

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O&M Manual Up-To-Date?

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Gas and Hazardous Liquid Gathering Lines: Notice of Public Meeting and Request for Comments

OPS has announced another public meeting to discuss the regulation of gas and hazardous liquid gathering lines (see our November 2003 newsletter for additional detail). Congress has directed RSPA to define “gathering line” for gas and hazardous liquid pipeline transportation and, if appropriate, define as “regulated gathering line” those rural gathering lines that, because of specific physical characteristics, should be regulated. The gas pipeline regulations do not clearly distinguish gathering lines from production facilities and transmission lines. This lack of clarity has caused many disputes between government and industry over whether the regulations cover particular pipelines. The definition of liquid gathering lines has not been as unclear, but it is also being re-evaluated.

The public meeting will occur Tuesday, December 16, 2003, from 8:30 am to 4:30 pm, and Wednesday, December 17, 2003, from 8:30 am to 4:30 p.m. at the Anchorage Marriott Downtown, 820 W. 7th Ave., Anchorage, AK 99506 phone: (907) 279-8000. You may participate in the meeting by making oral or written comments about any of the topics discussed in this notice. OPS will consider all public comments in developing future proposals on gathering lines. The deadline for submitting written comments is January 17, 2004 [Docket No. RSPA-98-4868 (gas); and RSPA-03-15864 (liquid)].

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RCP Services Spotlight – Pipeline Acquisition Due Diligence & Program Support

RCP has provided expert support for various pipeline acquisitions. The types of services we have recently provided include the following:

• Environmental Site Assessments (Phase I and Phase II) – An Environmental Site Assessment (ESA) is an evaluation of a property and all structures on the property to determine the likelihood of a recognized environmental condition.

• Pipeline Risk / Liability Assessments – RCP will evaluate the pipeline’s operating and maintenance history, its environment, and other factors to identify any unusual risks or liabilities. This can include, for example, problems identified during previous in-line inspections which have never been corrected.

• Regulatory Compliance Review – RCP can conduct a comprehensive permit and authorizations audit for all state and federal agencies (air, water, waste, etc.). For pipelines, this includes a review of the existing O&M; Manuals, Operator Qualification Program, and Integrity Management Program to evaluate compliance with existing regulations.

• Compliance Program Development – RCP can assist you with the integration of these assets into your existing regulatory compliance programs. This may include consolidating programs or in some cases creating new manuals and programs for the new pipeline system.

Please Click Here if you would like information on RCP’s Pipeline Acquisition Support Services.

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