DOT Pipeline Compliance News

July 2002 Issue

In This Issue

Pipeline Safety: Gas and Hazardous Liquid Pipeline Mapping

The Research and Special Programs Administration’s (RSPA) Office of Pipeline Safety (OPS) issued an advisory to gas distribution, gas transmission, and hazardous liquid pipeline systems. Owners and operators should review their information and mapping systems to ensure that the operator has clear, accurate, and useable information on the location and characteristics of all pipes, valves, regulators, and other pipeline elements for use in emergency response, pipe location and marking, and pre-construction planning. This includes ensuring that construction records, maps, and operating history are readily available to appropriate operating, maintenance, and emergency response personnel. The Advisory Bulletin is reproduced below. The full text of RSPA’s announcement can be downloaded from RCP’s website by clicking here.

Advisory Bulletin (ADB-02-03)

To: Owners and Operators of Gas Distribution Systems.

Subject: Gas and Hazardous Liquid Pipeline Mapping.

Purpose: To advise owners and operators of gas distribution, gas transmission, and hazardous liquid pipeline systems of the need to maintain and review construction records, maps, and operating history, and to make this information available to operating, maintenance, and emergency response personnel.

Advisory: Owners and operators of gas distribution, gas transmission, and hazardous liquid pipeline systems should ensure that accurate construction records, maps, and operating history are available to appropriate operating, maintenance, and emergency response personnel. The maps or associated records should provide the following information:

(1) Location and identification of pipeline facilities, including key features needed in emergency response.

(2) Crossings of roads, railroads, rivers, buried utilities, and pipelines.

(3) The maximum operating pressure of each pipeline.

(4) The diameter, grade, type, and nominal wall thickness of pipe.

RSPA urges every pipeline operator to (1) accurately locate and clearly mark on company maps and records key pipeline features and other information needed for effective emergency response; (2) keep these maps and records up-to-date as pipeline construction and modifications take place; (3) ensure that ‡its personnel are knowledgeable about the location of abandoned pipelines and to keep data on their location in order to further eliminate confusion with active pipelines during construction or emergency response activities; and (4) communicate pipeline information and maps to appropriate operating, maintenance, and emergency response personnel. Operators are also encouraged to collaborate with the Common Ground Alliance and the Federal and State pipeline safety programs to improve all phases of underground facility damage prevention, including improved mapping standards; and to work toward developing and using, to the maximum feasible extent, consistent mapping symbols and notational system

Draft Regulatory Evaluation of Gas Pipeline Integrity Management Rule

RSPA has posted the draft regulatory evaluation of their proposed Gas Pipeline Integrity Management rule on their website here. RSPA has indicated that they plan to have the final rule adopted sometime this year. The draft regulatory evaluation is a rather lengthy document to view in a web browser. RCP has prepared a formatted and bookmarked version in Adobe Acrobat, which is posted on our website here.

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

Meeting of the Gas Pipeline Safety Advisory Committee

A meeting of the Technical Pipeline Safety Standards Committee (TPSSC), the gas pipeline advisory committee, will be held on Thursday, July 18, 2002, from 9 a.m. to 6 p.m. in Washington, DC. The TPSSC will be advising the Office of Pipeline Safety (OPS) and voting on the proposed definition of High Consequence Areas (HCA) for Gas Transmission Operators which was published on January 9, 2002 (67FR 1108). This definition will be referenced in an upcoming proposed rule on Pipeline Integrity Management in HCAs (Gas Transmission Pipeline Operators). OPS will brief the TPSSC on integrity management concepts for gas pipelines and on the comments received in response to previous notices. In addition, OPS will present the draft cost-benefit analysis prepared for the upcoming proposed rule on integrity management programs for gas transmission pipelines. Because of the importance of this rule, OPS is providing the regulatory evaluation for peer review by the TPSSC before the proposed rule has been finalized.

Members of the public may attend the meetings at the Department of Transportation, Nassif Building, 400 Seventh Street, SW., Washington, DC 20590. The exact location and room number for this meeting will be posted on the OPS web page approximately 15 days before the meeting date at An opportunity will be provided for the public to make short statements on the topics under discussion. Anyone wishing to make an oral statement should notify Juan Carlos Martinez, (202) 366-1933, not later than July 12, 2002, on the topic of the statement and the length of your presentation. The presiding officer at each meeting may deny any request to present an oral statement and may limit the time of any presentation.

FOR FURTHER INFORMATION CONTACT: Cheryl Whetsel, OPS, (202) 366-4431 or Richard Huriaux, OPS, (202) 366-4565, regarding the subject matter of this notice.

The upcoming proposed integrity management rule for gas transmission pipelines (docket RSPA-00-7666) maintains the duty of a gas pipeline to comply with the current pipeline safety regulations, but creates a protective umbrella of more comprehensive assessment, repair, prevention, and mitigative actions in those areas (high consequence areas) where a failure would do the greatest damage. This assessment process will produce better information about problems that may have been missed and creates checks and balances to assure that the best use is made of available information to correct newly found problems.

Key concepts OPS is considering for the proposed gas integrity management rule include:

1. Expansion of the areas where added protection is required based on history of recent accidents in which a large impact area was experienced.

2. Improvement of protection though better inspection and management technology.

3. Establishment of stronger repair requirements.

4. Integration of various kinds of information to provide a clearer picture of threats.

5. Requirement to address each threat to integrity.

In addition to requirements for cost-benefit analysis of proposed pipeline safety standards, Federal law (49 U.S.C. 60115(c)) requires that OPS submit cost-benefit results and risk assessment information to one of two advisory committees established to support OPS on technical and policy issues. A key responsibility of the TPSSC is to provide peer review and evaluation of OPS’ cost-benefit analyses for proposed gas pipeline standards. The TPSSC must: (1) Evaluate the merit of the data and methods used within the analyses, and (2) when appropriate, provide recommendations relating to the cost-benefit analyses.

OPS will consider the advice of the TPSSC and its peer review of the draft regulatory evaluation in crafting the proposed rule to require gas transmission pipelines to institute integrity management programs. The proposed rule will be submitted to the TPSSC for comment after it is published. Any comments by the TPSSC will be carefully considered before a final rule is issued.

Confident that you are in compliance?

RCP has the tools and experience to create Comprehensive Compliance Assurance Systems for your particular operations.  Click Here

Upcoming RCP Seminars

RCP will conduct a 1 day workshop on Pipeline Integrity Management on July 22, 2002, in Houston. This one day workshop is an excellent introduction to the Pipeline Integrity Management regulations, and has been scheduled for the day prior to OPS’s PIM workshop in Houston (note that the OPS workshop will assume that the attendees already have a good understanding of OPS’s PIM regulations). This workshop presents a detailed analysis of the recent federal Pipeline Integrity Management regulation and the management programs / elements that it requires. The latest PIM inspection checklist will also be distributed and discussed. We will also review recent state initiatives and other proposed rules on pipeline integrity management. We received very positive feedback from the other Pipeline Integrity Management workshops that we have conducted, and expect this session to fill up rapidly. Some companies have chosen to send their entire risk assessment team to this seminar, as a way of kicking off their internal risk assessment process. Additional information is available on our website here.

OPS workshop on Pipeline Integrity Management

OPS will conduct a workshop on Pipeline Integrity Management on July 23, 2002, from 8 a.m. to 5 p.m., and July 24, 2002, from 8 a.m. to noon, at the J.W. Marriott Hotel, 5150 Westheimer Road, Houston, Texas 77056 (tel: 713-961-1500 fax: 713-961-5045). The purpose of this workshop is to assist operators in learning where improvement in integrity management is needed, and what means are available to achieve these improvements. On day 1, OPS will present its findings from the “quick hit” inspections conducted from February through April 20. This will include OPS’s assessment of operators’ progress in identifying pipeline segments that could affect high consequence areas (HCAs). OPS will also comment on its plans for conducting the Comprehensive Integrity Management Program Inspections, set to begin in August 2002. On day 2, OPS will provide a forum for the pipeline industry to share and discuss noteworthy integrity management practices that achieve compliance with the rule. Emphasis will be in areas in which OPS believes improvement is needed. No later than June 10, 2002, rooms may be reserved within a block identified as “USDOT/IMP Meeting Block”. For event planning purposes, please register via the instructions given at The website provides links to other useful information (including a meeting agenda, once available) and enables viewers to submit questions to OPS about the workshop. The full notice can be downloaded from RCP’s website here.

Acquiring a pipeline?

RCP can provide due diligence audits to help you ensure that potential compliance issues have been addressed before the sale is final. Click Here.

Effluent Limitation Guidelines and New Source Performance Standards for the Construction and Development Category; Proposed Rule

EPA is proposing a range of options to address storm water discharges from construction sites. As one option, EPA is proposing technology-based effluent limitation guidelines and standards (ELGs) for storm water discharges from construction sites required to obtain National Pollutant Discharge Elimination System (NPDES) permits. As another option, EPA is proposing not to establish ELGs for storm water discharges from those sites, but to allow technology-based permit requirements to continue to be established based upon the best professional judgment of the permit authority A third option would establish inspection and certification requirements that would be incorporated into the storm water permits issued by EPA and States, with other permit requirements based on the best professional judgment of the permit authority. This proposal, if implemented, is expected to significantly reduce the amount of sediment discharged from construction sites. The deposition of sediment from construction site runoff has contributed to the loss of capacity in small streams, lakes, and reservoirs, leading to the necessity for mitigation efforts such as dredging or replacement. EPA also requests comment and information on several variations on these options and several other significant aspects of the proposal, such as technologies, costs, and economics.

EPA must receive comments on the proposal by October 22, 2002 (docket No. W-02-06). EPA will conduct public meetings for this proposed rule on July 9, 2002; July 23, 2002; July 30, 2002 and additional dates to be announced later. EPA will announce the remaining meetings in a subsequent Federal Register document and on its website here. No registration is required for these meetings. Seating will be provided on a first-come, first-served basis.

  • Tuesday, July 9, 2002, 9 a.m.-noon, Hyatt Regency Hotel–San Francisco Airport, 1333 Bayshore Highway, Burlingame, CA, Phone 650-347-1234.
  • Tuesday, July 23, 2002, 9 a.m.-noon, Wyndham Garden Hotel–Dallas Park Central, 8051 LBJ Freeway (I-635), Dallas, TX, Phone 972-680-3000.
  • Tuesday, July 30, 2002, 9 a.m.-noon, Holiday Inn Chicago–Elmhurst, 624 N. York Rd., Elmhurst, IL, Phone 630-279-1100.

Air Permit Needs?

Are you planning to expand or acquire? Air permit applications can be complex and consuming. RCP has the expertise to navigate through the application process, develop compliance assurance systems, and submit reports. Click Here

Revised Natural Gas Transmission Pipeline Incident and Annual Report Forms

RSPA/OPS has revised the incident and annual report forms for natural gas transmission pipelines to improve the usefulness of the reported data. The failure cause categories have been expanded from five to 25 on the incident report. The annual report form includes two new sections: (1) Mileage by decade of installation and (2) mileage by class location. The complete notice can be downloaded from RCP’s website here.

As of January 1, 2002, all incidents meeting the reporting criteria in 49 CFR 191.15 are to be reported using the revised form RSPA F 7100.2 Incident Report for Gas Transmission and Gathering Systems. RSPA/OPS reminds owners and operators to file supplemental written reports (on RSPA Form F7100.2) if additional information on an incident later becomes available. Owners and operators are reminded that all relevant costs must be included in the estimated property damage total on the initial written incident or accident report as well as on supplemental reports. This includes (but is not limited to) costs of: Property damage to the operator’s facilities and to property of others; commodity/product not recovered; facility repair and replacement; gas distribution service restoration and relighting; leak locating; right-of-way clean-up, and environmental clean-up and damage. Facility repair, replacement, or change that is not necessitated by the incident should not be included.

Beginning March 15, 2002, the annual reports required by 49 CFR 191.17 are to be filed using the revised form RSPA F 7100.2-1 Annual Report for Gas Transmission and Gathering Systems. RSPA/OPS understands that operators may need some time to adjust information collection systems and research the new information requested for the annual report filing. If exact information is unavailable, requests for extensions of the filing date may be made to OPS’ Information Resources Manager at (202) 366-4569. Pipeline owners and operators may estimate mileage by decade and mileage by class location.

Forms and instructions are downloadable from the OPS home page at (in the “FORMS” section under “ONLINE LIBRARY”). RSPA/OPS is also implementing electronic reporting for natural gas transmission pipeline incidents by January 1, 2002, and for annual reports by January 15, 2002, for the annual report due March 15, 2002. Details are available on the OPS home page.

FOR FURTHER INFORMATION CONTACT: Roger Little, (202) 366-4569, or by e-mail,

TNRCC Changing Name to Texas Commission on Environmental Quality

Beginning September 1, 2002, the TNRCC will formally change its name and begin doing business as the Texas Commission on Environmental Quality, or the TCEQ.

The name change is required by our Sunset legislation, House Bill 2912. The Texas Legislature felt that the new name is shorter and gives people a better sense of the agency’s purpose. Plus, it’s more consistent with what other states are calling their environmental agencies.

The agency name change does NOT affect any previous permits, registrations, or any other paperwork or transactions between the public and the TNRCC prior to Sept. 1, 2002. It also does not affect any signage or other postings required of businesses by this agency. All the powers, duties, rights, and obligations of the Texas Natural Resource Conservation Commission are the powers, duties, rights and obligations of the Texas Commission on Environmental Quality.

Many of our forms, documents, and Web pages will continue to refer to the TNRCC for a while as we phase in our name change.

If you have any questions, please contact us at

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