DOT Pipeline Compliance News

January 2006 Issue

In This Issue

Register Now for the DOT Pipeline Compliance Workshop

Feb. 22–23, Houston, Texas

Includes updates on Pipeline Integrity Management, SPCC rules, Public Awareness, Operator Qualification (B31Q) and Underwater Inspection & Reburial of Pipelines

RCP will conduct a 2-day workshop on DOT Pipeline Regulations on Feb. 22nd and 23rd in Houston.


  • Day 1: Introduction to DOT/OPS Pipeline Regulations
    • Agency jurisdictions – what does DOT/OPS regulate anyway?
    • Important definitions
    • Important letters of clarification from the agency
    • Recent EPA/DOI memorandums of understanding
    • State and Federal program variations, roles and responsibilities
    • Gas and liquid design, construction, operations, maintenance, and emergency response requirements
    • Spill response planning requirements
    • How to monitor rulemaking activity and stay current with your compliance program
  • Day 2: Special Topics
    • Pipeline Integrity Management
    • Spill Prevention, Control & Countermeasure (SPCC)
    • Public Awareness
    • Operator Qualification – B31Q Update
    • Underwater Inspection & Reburial of Pipelines in the Gulf of Mexico
    • Other State and Federal Regulatory Agenda Items

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.

Standards Proposed to Reduce Corrosion

9 CFR Parts 192 and 195, Docket No. PHMSA-2005-22642

New rules proposed by the PHMSA would help prevent internal pipeline corrosion, one of the leading causes of incidents in gas transmission pipelines for the past five years.

PHMSA – 2005-22642 would add a new section to subpart I—Requirements for Corrosion Control in 49 CFR part 192. The new section, § 192.476, would require an operator to address internal corrosion risk when designing and constructing gas transmission pipelines.

Proposed paragraph (a) provides a performance test for internal corrosion prevention measures in design and construction. The test is whether the design and construction choices include measures to reduce the risk that liquid will collect inside the pipe. The proposed rule would require an operator to use measures that include, at the least, arrangement to avoid collection of liquids and the use of effective liquid removal equipment.

If an operator is unable to avoid low spots, an operator would explain why and identify the alternative measures to reduce the risk. There may be cases in which the design avoids low spots, but during construction the operator finds that it cannot avoid low spots. In this case, the operator would document the ‘‘as built’’ condition and the alternative measures used.

Proposed paragraph (b) provides a performance test for design and construction measures to check any internal corrosion that occurs. The test is whether the design and construction choices include measures to reduce the risk of internal corrosion. The design must allow for use of corrosion detection equipment.

These design and construction requirements would apply to all new construction and to replaced pipe and components.

With one limited exception, application to replaced pipe would be the same as the rule on designing to allow the passage of instrumented internal inspection tools (pigs). PHMSA clarified the meaning of replaced pipe in the final rule published in the Federal Register on June 28, 2004 (69 FR 36024). The exception occurs when replaced pipe changes the physical features of an existing downstream pipeline. Proposed paragraph (c) clarifies that an operator must consider the impact of line changes on internal corrosion risks and plan for these.

Proposed paragraph (c) would not require an operator to rebuild the downstream pipeline to remove low points, but would require an operator to consider whether it should install liquid removal equipment or tools to monitor corrosion. After analysis, an operator may decide O&M; measures would adequately address the impacts of the changes upstream.

Paragraph (d) would require an operator to record the decisions it makes about internal corrosion control when designing and constructing pipelines. The operator would have to explain its reasons for the decisions and justify variance. For example, if an operator did not use equipment to remove liquids in designing a pipeline, the operator would have to explain why the use of the equipment would be impracticable. Recording reasons for decisions fosters better decisionmaking and will provide needed information about safety features of the line in the future.

Anyone interested in filing written comments on the rule proposed in this document must do so by Feb. 13, 2006. Identify the docket number, PHMSA–2005–22642, at the beginning of your comments. You can make comments on the DOT website at or send hardcopy comments to Docket Management System: U.S. Department of Transportation, 400 Seventh Street, SW., Nassif Building, Room PL–401, Washington, DC 20590– 0001.

For more information, contact Barbara Betsock by phone at (202) 366– 4361 or by fax at (202) 366–4566, or by e-mail at

Integrity Management Services

RCP can assist pipeline operators with ongoing compliance management and engineering associated with your IMP. This includes direct assessment strategies, tool and vendor selection, ILI/ECDA report analysis, corrosion control programs, repair strategies, and IMP/risk model updates. For more information on how RCP can support your ongoing IMP needs, Click Here.

Integrity Management Updates

49 CFR Parts 192 and 195, Docket No. PHMSA-04-18938

At the request of the hazardous liquid pipeline industry, PHMSA has proposed revisions to the current Pipeline Safety Regulations for Pipeline Integrity Management in High Consequence Areas (HCAs).

The revisions are to: allow more flexibility in reassessment intervals for hazardous liquid pipelines by adding an eight-month window to the five-year time frame for operators to complete reassessment; and require both hazardous liquid pipeline and gas transmission pipeline operators to notify PHMSA whenever they reduce pipeline pressure to make a repair and to provide reasons for pressure reduction.

Another notification, including reasons for repair delay, would be required when a pressure reduction exceeds 365 days.

Also, PHMSA proposes to correct existing provisions for calculating a pressure reduction when making an immediate repair on a hazardous liquid pipeline. The proposed correction would allow operators to use another operating pressure when a specified formula is not applicable or results in a calculated pressure higher than operating pressure.

Finally, PHMSA seeks the submittal of engineering analyses and technical data. These submittals are to provide the basis for modifying the required time periods for remediating certain conditions found during a hazardous liquid pipeline integrity assessment. PHMSA will use this data to evaluate the scope and scale of repair issues to develop an accurate basis for determining if any additional flexibility is needed in the repair schedules.

The full text of the proposed regulations can be found at

Anyone interested in filing written comments on the rule proposed in this document must do so by Feb. 13, 2006. Identify the docket number, PHMSA–04-18938, at the beginning of your comments. You can make comments on the DOT website at or send hardcopy comments to Docket Management System: U.S. Department of Transportation, 400 Seventh Street, SW., Nassif Building, Room PL–401, Washington, DC 20590– 0001.

For more information, contact Shauna Turnbull by phone at (202) 366– 3731 or via e-mail at . For questions on technical issues, contact Mike Israni at (202) 366–4571 or via e-mail at

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

Operator Qualifications: Materials Available

Materials presented at the public meeting on operator qualification programs on Dec. 15, 2005, are now available [Docket No. PHMSA-2004-19857]. PHMSA is preparing a report to Congress on the status and results of these programs to ensure the qualifications of individuals performing safety tasks on pipelines. Participants at the meeting discussed progress on operator qualification programs to help PHMSA prepare the report to Congress. Participants also discussed the potential for strengthening operator qualification programs. PHMSA requests public comment on these matters. Submit comments on the progress on operator qualification programs by Jan. 20, 2006. Submit comments on the potential for strengthening operator qualification programs by Feb. 10, 2006.

The text of the revised concept paper on operator qualification follows.

A Concept To Address Remaining Operator Qualification (OQ) Issues Revised Following Public Meeting on Dec. 15, 2005

Regulatory — PHMSA is considering three changes to regulations:

  • Training — The OQ regulations now require only that an OQ program include training “as appropriate.” PHMSA is considering providing additional specificity. In addition to including training “as appropriate,” an OQ program would have to include training in particular circumstances. These circumstances are as follows:
    • an individual has never performed an assigned covered task;
    • there has been substantial change to a covered task, such as the use of new equipment or procedures that makes previous training no longer adequate; or
    • an individual has failed to requalify on a covered task after an accident. In addition, an operator would have to ensure training in damage prevention for individuals performing excavation for the operator. Excavation damage remains a major concern in pipeline failures.
  • Reevaluation intervals — The OQ regulations now require an operator to identify the tasks for which reevaluation is required and the intervals for reevaluation. PHMSA is considering requiring an operator to set maximum intervals for reevaluation for every task. These intervals would not exceed five years. Operators may find a shorter absolute maximum interval of three years easier to administer.
  • New construction — PHMSA is considering a change to the pipeline safety standards (not necessarily the OQ regulations) to require an operator to have a process to verify the integrity of new construction. Errors in the construction of a pipeline can result in failures, costly repairs, and increased maintenance costs. The process for verifying integrity of new construction could include:
    • Using accepted quality control practices during construction.
    • Including new construction tasks in OQ programs.
    • Using integrity verification methods such as pressure testing and nondestructive testing.

Non-regulatory — Other clarifications, possibly by advisory bulletin, would enhance an operator’s understanding of the requirements:

  • Emergency response — Clarify the requirement to include emergency response tasks in OQ programs. An operator needs to have qualified personnel available to handle actions necessary to ensure pipeline safety.
  • Abnormal operating conditions — Clarify the need for an operator to identify and periodically review the operator’s list of abnormal operating conditions to aid in compliance.

Need to Update Your Current Operator Qualification Program?

We have the expertise to update your current operator qualification program to satisfy the upcoming regulation change and inspection protocols. Click Here to request more information.

Regulation of Liquid Gathering Pipelines

Buck Furrow of OPS gave a presentation at the Dec. 13, 2005, technical advisory committee meetings concerning regulation of rural crude oil gathering pipelines. The existing hazardous liquid pipeline safety regulations regulate non-rural onshore gathering lines. Hazardous liquid gathering lines are currently defined as pipelines that are 8 5/8″ in diameter or less that transport petroleum from a production facility (note that this definition is very different from the definition of GAS gathering lines, which is the topic of separate rulemakings). OPS is considering changes to this definition to regulate liquid gathering lines based on a combination of size, stress level, and ability to affect a high consequence area. OPS is also considering what type of regulation is appropriate for regulated gathering lines (perhaps a subset of the current pipeline safety regulations). OPS has not yet developed a proposed rulemaking in this area, but has established a docket to contain any comments that are received (#15864).

RCP Services Spotlight – RCP Auditing, Due Diligence and Expert Witness Services

RCP’s approach to audits and assessments is typically either consultative or enforcement oriented depending upon the client’s needs. The consultative approach is typically viewed by clients as a cooperative effort that assesses regulatory compliance status in concert with operational and maintenance issues. This method provides feedback on existing management practices versus industry standards. The consultative approach not only identifies opportunities for regulatory compliance improvement, but also provides recommendations on how existing management practices can effectively achieve and sustain these improvements. An enforcement approach gives the client an idea of how well a facility can manage an agency audit and how likely it would be for an agency inspector to issue a Notice of Violation.

RCP provides comprehensive, confidential regulatory consulting services, including:

  • Quick-Hit Regulatory Compliance Checkups
  • Comprehensive Regulatory Compliance Audits
    • Compliance program gap analysis
    • Recordkeeping evaluation
    • Field inspections
  • Regulatory Agency Jurisdictional Determinations, Interpretations & Audits
    • DOT
      • Integrity Management Program
      • Operator Qualification
      • Operations & Maintenance
      • Public Awareness API RP1162
      • Facility Response Plans
    • U.S. Coast Guard
      • Dock Operations
      • Oil Spill Response Plans
      • Facility Security Plans
    • EPA
      • Spill Prevention Control & Countermeasure Plans
      • Air/Wastewater Permitting
      • Facility Response Plans
      • Risk Management Plans
    • OSHA
      • Process Safety Management
      • Health & Safety Plans
    • FERC
      • NEPA Pre-filing
      • Environmental Compliance and Report Planning
    • State-Specific Regulations
  • Asset Acquisition Due Diligence
    • Phase I Environmental Assessments
    • Permitting & Associated Agency Notifications
    • Compliance Program Development
    • Employee Qualification & Training Program Assessments
    • Asset Integrity Management Liability Assessment
    • Record Keeping, Documentation & Data Room Inspections
  • Expert Witness Service
    • Pipeline Safety
    • Regulatory Interpretation

If you would like information regarding RCP’s Auditing, Due Diligence and Expert Witness Services, e-mail Jessica Roger or call (713) 655-8080.

PHMSA’s Public Awareness Expectations–API RP 1162

Two workshops on Public Awareness for pipeline operators held recently by PHMSA will help ensure operators’ full compliance with the new public awareness program requirements included in API RP 1162. Presentations can be found at

PHMSA believes RP 1162 sharpens the focus for operators to invest in effective communications that include messages that are received and understood by the audience, and that the awareness will lead to behavioral changes. PHMSA representatives noted that the program offers an opportunity for operators to create effective programs as well as spotlighting the need for individual operators to take ownership of awareness programs. PHMSA stressed the importance of creativity in yielding effective and efficient programs that make a difference in pipeline awareness and safety. Following is a recap of clarifications made during the meetings.

Program Overview

Written programs must be completed by June 20, 2006. A one-year extension from this date applies to both propane systems and master meter operators having less than 25 customers. Initial distribution of awareness materials must be completed by June 20, 2007. (This is a new requirement.) Operators’ first evaluation of program effectiveness must be completed by June 20, 2010. A one-year extension from this date applies to both propane systems and master meter operators having less than 25 customers.

Programs must follow the general program recommendations, including baseline and supplemental requirements of RP1162, unless written program justification includes why compliance with the RP is not practicable and not necessary for safety.

Stakeholder Audience Clarification

Operators are not required to address the general public as an audience. RP 1162 identifies the affected public audience, which includes:

  • residents located along the distribution system and adjacent to the transmission pipeline and gathering pipeline right-of-way
  • customers of LDCs and transmission operators
  • places of congregation
  • residents near storage or other major operational facilities.

For detailed definitions, refer to RP 1162’s section 3.1.

Cooperative Efforts

PHMSA pointed to RP 1162’s sections 2.4.6 and 8.4.2 regarding cooperative information exchange or shared public awareness activities. They indicated that while collaboration adds value and leverage to awareness campaigns, operators also should be able to produce documentation that demonstrates operator-specific results. In addition, PHMSA understood that collaborative efforts create challenges for operators to partner for success and that operators may consider nontraditional partners such as One-call Centers and schools along the right-of-way.

Supplemental Enhancements

PHMSA indicated that operators’ written public awareness programs must describe the process operators use to determine whether supplemental enhancements are warranted. In addition, operators must document when and where along its pipeline a more intensive public awareness effort is needed. These pipeline right-of-way areas include high consequences areas; land development activity; third-party damage incidents; and a pipeline’s incident history. Forms of supplemental enhancements include increased frequency of communications; enhanced message content and additional delivery method and/or media; and/or widening the stakeholder audience coverage area beyond the baseline program. Implementation records must document areas along the pipeline route when supplemental elements have been implemented. Refer to RP 1162’s section 6.

Integrity Management Communication Requirements – ASME B31.8S and RP 1162

PHMSA stated that some differences are included in the two rules but operators may develop and implement a single external communication program to address the requirements of both rules. Operators must be able to demonstrate when and how their programs adequately address the requirements of each.

Need to make sure your Public Awareness Program meets API RP 1162 standards?

RCP can conduct a gap analysis of your current program that includes a self assessment of your Public Awareness Programs. This final product will help you to meet API RP 1162 standards. We can provide turnkey implementation, mail-outs, evaluations, and tracking of your program. For more information, call or click here.

Pipeline Safety: Mechanical Damage Technical Workshop

[Docket No. PHMSA-2005-23198]

PHMSA and the National Association of Pipeline Safety Representatives (NAPSR) are hosting a workshop to address pipeline safety issues with mechanical damage. This workshop will provide a forum to share information on mechanical damage among pipeline operators, state agencies, technical experts, and the public. Workshop attendees will discuss and see existing and future technology used to prevent, detect and characterize mechanical damage. Participants will discuss and learn about prevention, detection, and characterization technologies for mechanical damage. This information will aid PHMSA in coordinating actions to address the problems mechanical damage poses in operating natural gas and hazardous liquid pipelines. To facilitate meeting planning, advance registration is strongly encouraged. Please visit the Meeting Registration and Document Commenting web page ( PHMSA will post details about the meeting.

Mechanical damage from third-party intrusion and latent defects caused during pipeline construction remains a leading cause of major pipeline incidents. Mechanical damage defect types are commonly identified as denting, metal loss, metal deformation, and cracking. Several existing technologies are in practice to prevent, detect and characterize damage to pipelines. Regulators, operators, and commercial vendors have varying levels of confidence in these technologies.Several organizations fund or conduct research addressing mechanical damage technology. The development of mutual technology goals will lead to aligning resources, better synergy, and better dissemination of information about new technologies. This will promote pipeline safety across the industry. The workshop aims to identify confidence levels with existing technologies, build research synergy, and gauge the state of our efforts to address mechanical damage.

PHMSA will hold the meeting on Tuesday, Feb. 28, 2006, from 8 a.m. to 4:30 p.m. and Wednesday, March 1, 2006, from 9 a.m. to 4:30 p.m. at the Houston Marriott Westchase, 2900 Briar Park Drive, Houston, Texas 77042. The telephone number for hotel reservations is (713) 978-7400 or (800) 452-5110. PHMSA has reserved a room rate of $92 per night for the first 100 reservations for both Monday, Feb. 27 and Tuesday, Feb. 28. Mention the Department of Transportation/PHMSA or the Mechanical Damage Technical Workshop when speaking with the hotel. The hotel must receive reservations by attendees on or before, Feb. 13, 2006.

NPDES Stormwater Oil and Gas Exemption – Proposed Rule

On Dec. 30, 2005, the EPA Administrator signed a proposed rule that will exempt most stormwater discharges from oil and gas exploration, production, processing, or treatment operations, or transmission facilities, including associated construction activities, from the requirement to obtain NPDES permit coverage. The proposed rule also encourages operators of oil and gas activities or operations to implement and maintain Best Management Practices (BMPs) to minimize the discharge of pollutants during and after construction activities to help ensure protection of surface water quality during storm events. Entities potentially affected by this action include operators of oil and gas exploration, production, processing and treatment, and transmission facilities and associated construction activities at oil and gas sites that generally are defined in the following North American Industrial Classification System (NAICS) codes and titles: 211 – Oil and Gas Extraction, 213111 – Drilling Oil and Gas Wells, 213112 – Support Activities for Oil and Gas Operations, 48611 – Pipeline Transportation of Crude Oil and 48621 – Pipeline Transportation of Natural Gas.

The proposed exemption includes construction of drilling sites, drilling waste management pits, and access roads. EPA also interprets the proposed exemption as being applicable to construction of in-field treatment plants and the transportation infrastructure (e.g., crude oil and natural gas pipelines, natural gas treatment plants and both natural gas pipeline compressor and crude oil pump stations) necessary for the operation of most producing oil and gas fields. Such construction activities would thus be eligible for the CWA section 402(l)(2) exemption from NPDES permitting requirements.

There is no distinction in the proposed rule as to whether the amount of disturbed acreage is less than one acre, between one and five acres, or greater than five acres. Hence, discharges from “large” construction activity (disturbing at least five acres) at oil and gas facilities would be eligible for the exemption from NPDES permitting requirements to the same extent as discharges from small construction activity at such facilities.

EPA is proposing to clarify in 122.26(a)(2)(ii) that a water quality standard violation for sediment alone does not trigger a permitting requirement.

The proposed rulemaking would apply to all States, Federal lands, and Indian Country regardless of whether EPA is the NPDES permitting authority. Discharges that would be exempted from NPDES permit requirements in this proposal would be exempted from such NPDES requirements regardless of whether EPA or a State is the permitting authority. EPA wishes to clarify, however, that this proposal is not intended to interfere with the States’ ability to regulate any discharges through a State’s non-NPDES program. This proposed rulemaking would not curtail the ability of an appropriate environmental management agency (e.g., State, Tribal or local government) from imposing specific discharge conditions on an oil and gas operator that would otherwise be exempted under today’s proposed rule so long as these requirements are imposed pursuant to authority other than an EPA-approved NPDES program. For example, a State or tribe could choose, under its own authorities, to set limits or require that an operator meet certain discharge conditions in sensitive watersheds.

EPA intends to issue a final rulemaking in advance of the June 12, 2006, deadline by which oil and gas construction sites that disturb one to five acres of land are currently scheduled to obtain NPDES permits for their discharges. If finalized as proposed, EPA’s final rulemaking would effectively exempt all field activities or operations associated with oil and gas exploration, production, processing or treatment and transmission construction activities from regulation under the NPDES storm water permitting program, except in accordance with 122.26(a)(2)(ii) and (c)(1)(iii). The proposal will be available for public comment for 45 days after publication in the Federal Register (docket ID No. EPA-HQ-OW-2002-0068).

Coastal Zone Management Act Federal Consistency Regulations: Final Rule

[Docket No. 030604145-4038-02]

The National Oceanic and Atmospheric Administration (NOAA) has revised the federal consistency regulations under the Coastal Zone Management Act of 1972 (CZMA). For nearly 30 years, the CZMA has met the needs of coastal States, Great Lake States and United States Trust Territories and Commonwealths (collectively referred to as “coastal States” or “States”), Federal agencies, industry and the public to balance the protection of coastal resources with coastal development, including energy development. The CZMA requires the States to consider the national interest as stated in the CZMA objectives and give priority consideration to coastal-dependent uses and processes for facilities related to national defense, energy, fisheries, recreation, ports and transportation, when adopting and amending their Coastal Management Programs (CMPs), and when making coastal management decisions. This final rule continues to provide the balance between State-Federal-private interests embodied in the CZMA, while making improvements to the federal consistency regulations by clarifying some sections and providing greater transparency and predictability to the implementation of federal consistency. This final rule fully maintains the authority and ability of coastal States to review proposed federal actions that would have a reasonably foreseeable effect on any land or water use or natural resource of a State’s coastal zone, as provided for in the CZMA and NOAA’s regulations, as revised in 2000.

These rules shall become effective on Feb. 6, 2006. All appeals to the Secretary under 15 CFR part 930, subpart H, filed on or after Feb. 6 shall be processed in accordance with the procedures and time frames adopted in subpart H of this final rule. For appeals to the Secretary under 15 CFR part 930, subpart H, any procedural or threshold issues that occurred prior to Feb. 6 shall be governed by the regulations in 15 CFR part 930, subpart D, E, and/or F that were in effect at the time the procedural or threshold issue occurred. Additional information on federal consistency can be located at OCRM’s federal consistency Web page:

Will your SPCC Plan pass an EPA inspection based on the new SPCC Inspectors’ Guidance document?

RCP can conduct a gap analysis of your current SPCC Plan and provide updates and recommendations based on the new SPCC Guidance for Regional Inspectors that was published Dec. 2, 2005. The new guidance document includes more detail than is in many of the plans in use today. RCP can review and update your plan so that you will be prepared for an Inspection. For more information, call or Click Here.

EPA Proposes Amendments to the SPCC Rule

On Dec. 12, 2005, EPA proposed two separate amendments to the Spill Prevention, Control, and Countermeasure (SPCC) Rule in the Federal Register. The first (FR EPA-HQ-OPA-2005-0001) streamlines the regulatory requirements for qualified facilities and equipment regulated under 40 CFR part 112. The second (FR EPA-HQ-OPA-2005-0003) extends the SPCC compliance dates for all facilities.

EPA is requesting public comments on the proposed rules between now and Feb. 10, 2006, for the proposed streamlined provisions, and between now and Jan. 11, 2006, for the proposed compliance date extension. Submit your comments, identified by Docket ID No. EPA-HQ-OPA-2005-0001 or Docket ID No. EPA-HQ-OPA-2005-0003, through the Federal Rulemaking Portal. To locate a docket, enter the Docket ID (EPA-HQ-OPA-2005-0001 or EPA-HQ-OPA-2005-0003) in the “Keyword” field and click “Submit.”

If you have questions about the proposed amendments please call the Superfund, TRI, EPCRA, RMP and Oil Information hotline at 1-800-424-9346. If the hotline is unable to answer your specific questions, your question will be forwarded to an EPA staff member for a response.

RCP’s Fantastic 1-Page Version of SPCC Regulation

The Feb. 17, 2006, deadline for SPCC Plan revisions is fast approaching. (Although the deadline may be extended, the extension is not yet final). RCP has developed a 1-page version (in tiny type) of the SPCC regulations that includes the guidance document for inspectors that was issued Dec. 2, 2005. To receive a complimentary copy along with a CD of valuable SPCC Reference Materials, Click Here.

EPA Seeks Comment on Proposed NPDES Stormwater Permit for Industrial Activities

EPA is soliciting public comment on its NPDES Stormwater Multi-Sector General Permit for Industrial Activities (MSGP) through Feb. 16, 2006. The proposed permit will replace the MSGP-2000 that expired on Oct. 30, 2005. The proposed permit is available for public comment until Feb. 16. The MSGP covers 29 categories of industrial activity in the five states, territories, and other areas where EPA remains the permitting authority. (Most states are authorized to implement the NPDES program and issue their own stormwater permits.)

For more information on this proposed permit, including information on how to submit written comments, please visit

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