DOT Pipeline Compliance News

February 2003 Special Edition Issue

In This Issue

Special Edition Letter from the Editor

There are two meetings in February that are of general interest to our readers, but were not announced in time for the normal February newsletter.

Also note that a Federal Register announcing one of these meetings was incorrect, as described in the article below. We are also including the announcement about our March 19-20th, 2003 DOT Pipeline Compliance Workshop. The early registration deadline is March 4th, but it is filling up rapidly and early registration is encouraged to ensure available space.

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

The Interstate Natural Gas Association of America (INGAA) Foundation and the American Gas Association (AGA) have jointly organized a two-day workshop on proposed regulations on “Pipeline Integrity Management in High Consequence Areas” to be held on February 20, 2003, from 8 a.m. to 5 p.m., and on February 21, 2003, from 8 a.m. to 12 noon. This workshop is intended to give participants an understanding of the integrity management program requirements being proposed in the rule and the process to comment on the proposed rulemaking. An OPS representative will give an overview of the proposed regulation and answer questions about it. This workshop will be held at the Renaissance Houston Hotel, 6 Greenway Plaza, Houston, Texas, 713-629-1200.

Note that registration is required, and a registration fee must be paid. A notice in the Federal Register on February 7, 2003, stating that the meeting was free and open to all was incorrect.

The preliminary agenda for this AGA/INGAA sponsored workshop on Integrity Management for Natural Gas Pipelines is as follows:

February 20, 2003

  • Pipeline Safety Legislation – An overview of the recently passed legislation and its impact on the proposed integrity management program requirements.
  • Overview of Proposed Regulation – An OPS representative will discuss the intent and structure of the recently published proposed integrity management rule for gas transmission pipelines.
  • HCA Identification – An industry panel will discuss the high consequence area definition and the proposed refinement of that definition in the proposed integrity management rule.
  • Risk Assessment – An industry panel will discuss the risk assessment process detailed in the proposed rulemaking and compare it to present practices.
  • Plan Development – An industry panel will discuss the plan development as envisioned in the proposed rule and compare it to present practices.
  • IMP Implementation & Data Integration – Issues surrounding data integration and implementing the administrative process in a company will be discussed by an industry group.

February 21, 2003

  • Mitigation & Repair – An industry panel will discuss the proposed requirements for mitigation and remediation.
  • Performance Metrics – An industry panel will discuss performance measures for an integrity management program.
  • Open Forum and O&A; – The audience will be able to query all the panelists and state their opinions during this session. Because this involves an open rulemaking, RSPA/OPS will include detailed notes of this workshop in the docket for the proposed rule. However, participants wishing to comment on the proposed rule should comment directly in the docket rather than rely on the notes of the workshop.

FOR FURTHER INFORMATION CONTACT: Contact Mike Israni by phone at (202) 366-4571, by e-mail at For other details on this workshop contact Linda A. Thomas of INGAA at 202-216-5925.

Operator Qualification: Public Meeting

The Research and Special Programs Administration’s (RSPA) Office of Pipeline Safety (OPS) will conduct a public meeting from 9 a.m. to 4 p.m. on February 25, 26, and 27, 2003, to discuss progress in implementing the operator qualification (OQ) rule for gas and hazardous liquid pipelines. OPS will continue to develop the protocols and guidance materials, and provide an opportunity for public comment. A panel of experts will address technical issues associated with protocols and related materials. The program will address the 13 issues generated by the first public meeting held in January 2003, and will be open for technical input. This will include presentations on definitions of terms discussed at the last meeting. Persons wishing to make a presentation or statement at the meeting should notify Janice Morgan, (202) 366-2392, no later than February 19, 2003.

The public meeting will be held at the Hyatt Regency Houston Airport Hotel, 15747 John F. Kennedy Blvd., Houston, TX 77032 (Tel: 800-233-1234); Fax: 281-590-8461; Web: This meeting is free and open to the public. You may register electronically for this meeting at: The deadline for making a hotel reservation is February 17, 2003. Although RSPA encourages persons wishing to comment on operator qualification and inspection protocols to participate in the public meeting, written comments will be accepted. All written comments should identify the docket number RSPA-03-14448; Notice 2. A record of the previous public meeting on Qualification of Pipeline Personnel that was held in San Antonio, TX, is available in this docket (RSPA-03-14448).

You may contact Richard Sanders at (405) 954-7214 or (405) 954-7219, regarding the agenda of this public meeting. The meeting will focus on areas considered high priority and discussion on compliance issues from Federal and State pipeline safety personnel. These issues, as identified at a previous public meeting on January 22, 2003, in San Antonio, TX, are as follows:

  1. Scope of operator qualification;
  2. Evaluation of knowledge, skills, and physical ability;
  3. Re-evaluation intervals;
  4. Maintenance versus new construction;
  5. Treatment of emergency response;
  6. Additional covered tasks;
  7. Extent of documentation;
  8. Abnormal operating conditions;
  9. Treatment of training;
  10. Criteria for small operators;
  11. Direction and observation of non-qualified people;
  12. Noteworthy practices;
  13. Persons contributing to an incident or accident. All persons attending the meeting will have an opportunity to comment on operator qualification compliance issues and to question the expert panel on the new operator qualification compliance protocols.

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DOT Pipeline Compliance Workshop – March 19-20, 2003 – Houston Includes update on the new Pipeline Safety Improvement Act of 2002 signed into law on Dec 17, 2002

RCP will conduct a 2-day workshop on DOT Pipeline Regulations on March 19th and 20th in Houston. Day 1 of this workshop will present an overview of all the current DOT regulations for pipeline operators. Day 2 will review recent regulatory initiatives such as pipeline integrity management, hazardous liquid corrosion control requirements, high consequence area (HCA) analysis and operator qualification. Day 2 will also include a review of the new Pipeline Safety Improvement Act of 2002, which includes several important self-implementing requirements that will affect pipeline operators. This workshop is suitable for personnel who need a general introduction to DOT pipeline regulatory requirements, or who need an update on recent and proposed DOT Pipeline regulatory initiatives. We have conducted this type of seminar several times, and have received excellent feedback each time. We expect this workshop to fill up rapidly. Early registration and group discounts are available. Additional information is available on our website here.

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