DOT Pipeline Compliance News

July 2004 Issue

In This Issue

DOT Pipeline Compliance / Integrity Assessment Workshop September 28 – 30, 2004 – Houston

RCP will conduct a 3-day workshop on DOT Pipeline Regulations on September 28 – 30 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 integrity management initiatives and national standards (ASME, NACE, API) for liquid & gas pipelines including ECDA/ICDA, SCCDA, and ILI standard development.   Day 3 will review a variety of regulatory requirements associated with integrity assessments, including permitting, waste management, remediation/repair, excavation, hydro testing, and ILI.   This workshop is suitable for all levels of pipeline regulatory and integrity management expertise.   We have conducted several of these seminars in the past, and have received excellent feedback.   We expect this workshop to fill up rapidly.   Early registration and group discounts are available.   We will publish the final course content and registration information in next month’s newsletter.   For more information, you may visit our website or call Maria at 1-888-727-9937.

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.

DOT Profile – David D. Wint – RCP’s Newest Project Manager-Integrity Management

“Direct Assessment is relatively new bringing together both the old and the latest technology that is instrumental in Pipeline Integrity Management and dramatically impacts other pipeline operation programs”, says David Wint, RCP’s newest Integrity Management Project Manager.

With over 20 years in the pipeline industry, David adds tremendous value to RCP. He specializes in the development of pipeline Corrosion Control and Integrity Management Programs for both natural gas and liquid pipelines. David has experience in managing over 9,000 miles of pipeline utilizing risk ranking, remediation, in-line inspection, and construction. His expertise in integrity assessment brings significant impact to RCP’s Pipeline Integrity Management Programs, which assists our clients in evaluating and determining operating liability and annual operating costs of pipelines to maintain regulatory compliance.

For more information regarding RCP’s Pipeline Integrity Management Programs utilizing Direct Assessment, please contact Laura Wager.

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.

API Petitions DOT/OPS: Integrity Management Rule Changes

The American Petroleum Institute (API) and the Association of Oil Pipeline (AOPL) have submitted two petitions to DOT/OPS to amend Title 49 CFR Part 195.452. While most API member companies are primarily engaged in the transportation of hazardous liquids, some of the members do operate small amounts of gas pipelines that are subject to the Part 192 Subpart O Pipeline Integrity Management Rule.   Acceptance of the petition would allow operators to incorporate their gas pipelines into their hazardous liquid pipeline integrity management program under Part 195.452.

A second request was made requesting clarification and modification to Title 49 Part 195.452 to allow engineering judgment and flexibility under the “Special requirements for scheduling repairs”.   The proposed change would be similar to that of the published natural gas integrity rule and ASME B31.8S. Acceptance of the entire petition would allow hazardous liquid operators to redefine the following:

  • Expanding immediate repairs to include any dent with an indication of cracking rather than just top side dents with cracking.
  • Remove 3% dents from the 60-day condition category.
  • Create a 365-day condition category.
  • Creating a monitoring conditions category, which in addition to including the 180-day conditions, consists of the “other conditions” category under the rule as published?

If you would like to receive a copy of the petitions, please contact Laura Wager.

Need A Security Plan or Audit?

We have the expertise to develop a security plan and perform risk assessments for pipeline and terminal facilities to meet recent DOT Hazmat Transportation & Pipeline regulations. We can also assist you in USCG security plans for dock facilities and vessels. Please contact Jessica Roger for more information.

OPS Issues NPRM for Public Education Programs for Hazardous Liquid and Gas Pipeline Operators

The Research and Special Programs Administration’s (RSPA) Office of Pipeline Safety (OPS) proposes to require all gas and hazardous liquid pipeline operators to develop and implement public education programs based on the provisions of the American Petroleum Institute’s (API) Recommended Practice (RP) 1162, Public Awareness Programs for Pipeline Operators. API RP 1162 provides guidance on development, implementation, and evaluation of pipeline operator “public awareness” programs. Note that “public education programs,” as used in this proposal, and “public awareness programs,” as used in API RP 1162, are considered to be the same and are used interchangeably for the purposes of this proposed rule.

This proposed rule applies to all pipelines regulated under 49 CFR parts 192 and 195, including:

  • Interstate and intrastate hazardous liquid transmission pipelines.
  • Interstate and intrastate natural gas transmission pipelines.
  • Natural gas distribution pipelines.
  • Oil and gas gathering lines.

Each operator is required to establish and periodically update a written public education program covering all program elements. Baseline and supplemental program requirements for different pipeline operator types are summarized in a set of tables in API RP 1162 that may be found at:   If an operator’s current public education program does not comply with API RP 1162, the operator would be required to modify the program to come into compliance. Information on API RP 1162, including a link to the document, may be found at:

Interested persons are invited to submit written comments by August 23, 2004 (DOT DMS Docket Number RSPA-03-15852). If you would like copies of these petitions, e-mail Laura Wager or call (713) 655-8080.

Need to update your Public Awareness Program?

RCP can help develop your updated plan to meet API RP 1162 standards, and provide turnkey implementation, mail-outs, evaluations, and tracking of your program. For more information call or Click Here.

Passage of Internal Inspection Devices – Gas Pipelines

Years ago, the Research and Special Programs Administration (RSPA) published a regulation requiring that new gas transmission lines and sections of existing transmission lines in which pipe or components are replaced be designed and constructed to accommodate the passage of instrumented internal inspection devices.   On January 30, 1995 (60 FR 7133; Feb. 7, 1995), RSPA stayed enforcement on some facilities and invited comments on proposed changes to the regulation.   The review process is now complete.   This final rule modifies § 192.150 and removes the need to continue in force the suspension of enforcement.   Therefore, the suspension of enforcement is withdrawn as of July 28, 2004 (the effective date of this Final Rule).

For existing onshore gas transmission lines, this action restricts the regulation to replacements of pipe or components.   Note that this is different than the original rule, which required entire line sections to be modified to accommodate smart pigs.

For offshore gas transmission lines, the regulation is restricted to certain new lines that run between platforms or from platforms to shore (for purposes of this rule, new offshore transmission lines are those on which construction begins after December 28, 2005).   New offshore transmission lines 10″ inches or more in outside diameter that run from platform to platform or platform to shore will have to be designed and constructed to accommodate the passage of smart pigs.   This requirement will not apply, however, if platform space or configuration is not compatible with launching or retrieving smart pigs.   Nor will it apply if the design includes one or more taps for lateral connections and the operator can demonstrate, based on investigation or experience, that use of a tap that does not obstruct the passage of instrumented internal inspection devices is not reasonably practical under the design circumstances.   The exemption of other offshore lines based on certain maintenance practices is withdrawn.

Note that none of these exemptions, suspensions of enforcement, or rule modifications apply to hazardous liquid pipelines.

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

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

NACE International’s Pipeline Integrity Direct Assessment Seminar

NACE International presented a Pipeline Integrity Direct Assessment Seminar in Houston, TX on June 23-25.   The seminar addressed external corrosion direct assessment, internal corrosion direct assessment and stress corrosion cracking.   It provided a detailed description of the four-step process and the tools available to implement direct assessment.

NACE Task Groups are currently in the process of developing the following Standards to accommodate the DOT/OPS Direct Assessment Requirements.
  NACE TG293 – Internal Corrosion Direct Assessment on Dry Gas Pipeline Systems (final draft revision).
  NACE TG305 – Internal Corrosion Direct Assessment on Wet Gas Pipeline Systems (early development).
  NACE TG315 – Internal Corrosion Direct Assessment on Liquid Pipeline Systems (early development).
  NACE TG273 – Stress Corrosion Cracking Direct Assessment (final draft revision).

API Standard 1163 that addresses In-Line Inspections of Pipeline Systems is currently under review with an expected distribution release by the end of year 2004.

API Standard 1110 for the Hydrostatic Pressure Testing of Pipelines is currently being revised to address various pipeline integrity threats.   The anticipated distribution release date is unknown.

Pipeline De-Watering Bulletin

OSHA and OPS have jointly developed an advisory bulletin to increase awareness of the hazards involved in pipeline de-watering and to encourage employers and workers to refocus their energies on ensuring proper procedures are followed during the process.   De-watering of pipelines is a process conducted following the construction of the pipelines.   The bulletin was designed to highlight potential hazards associated with the operations and to focus on work practices that will reduce the potential for unexpected separation of temporary de-watering pipes.   The bulletin provides detailed background information on the procedures involved in ensuring the integrity of installed pipelines and reemphasizes OPS regulations on pipeline safety.   A section of the bulletin is dedicated to descriptions of hazards focusing on insufficient anchoring, worn couplings, excessive air pressure, and lack of training.   A separate list of references and resources are also provided for more information.   The bulletin is available at:

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.

DOT Implements Changes to 46 CFR 310, Merchant Marine Training

The Department of Transportation Maritime Administration is publishing an interim final rule on Merchant Marine Training (46 CFR 310), effective July 8, 2004.   In their summary of the rule, the Maritime Administration states that these changes will update “the Maritime Education and Training regulations to conform with … the National Defense Authorization Act for Fiscal Year 2004 (and) makes non-substantive technical changes to part 310.”

Among the changes to the rule are several important provisions, including:

  • An increase in the student incentive payment amount to $4000 per annum;
  • Separation of an individual from the School no longer releases an individual from his or her service obligations;
  • Changes in the license maintenance requirements following graduation, so that a graduate can satisfy this requirement by maintaining a more restricted Coast Guard license rather than a continuity license;
  • Failure to fulfill service obligations leading to the possibility of active duty in the Armed Forces.

The DOT is considering comments through August 9, 2004.   Further information can be obtained through Jay Gordon, Maritime Administration, 400 7th St., SW., Washington, DC 20590; telephone: (202) 366-5173; or e-mail:

The Use of N11 Codes and Other Abbreviated Dialing Arrangements – Notice of Proposed Rulemaking

The Federal Communications Commission seeks comment on various abbreviated dialing arrangements that could be used by state “One Call” notification systems in compliance with the Pipeline Safety Improvement Act of 2002 (the Pipeline Safety Act).   The FCC seeks comment on whether an N11 code, a code using a leading star or number sign, or another three-digit number should be assigned to comply with the Pipeline Safety Act.   They also seek comments on implementation issues such as the integration of existing One-Call Center numbers, an appropriate implementation timeframe for each proposed abbreviated dialing arrangement, and whether they should delegate authority to the state commissions to address implementation issues.   The complete Federal Register Notice can be downloaded from RCP’s website here through the DOT Gateway.

Comments may be filed using the Commission’s Electronic Comment Filing System (ECFS) at FCC number 04-111 or by filing paper copies.   Paper copies should be sent to the Commission’s Secretary, Marlene H. Dortch, Office of the Secretary, Federal Communications Commission, 445 12th Street, SW., Washington, DC 20554.   See Supplementary Information section of the Federal Register article. Comments are due on or before July 8, 2004. Reply comments are due on or before July 23, 2004.

For more information, contact Regina Brown, Attorney, Wireline Competition Bureau, Telecommunications Access Policy Division, (202) 418-7400, TTY (202) 418-0484.

Pending Audits?

Has the DOT notified you of a pending audit? RCP can provide confidential internal auditing to help ensure that your facilities are up to the agency’s latest standards.
Click Here.

NESHAP for stationary reciprocating internal combustion engines (RICE)

The EPA has promulgated national emission standards for hazardous air pollutants (NESHAP) for stationary reciprocating internal combustion engines (RICE) with a site-rating of more than 500 brake horsepower (HP).   The EPA proposed the NESHAP for stationary RICE on December 19, 2002, and received 64 comment letters on the proposal.   A background information document (BID) (“National Emission Standards for Stationary Reciprocating Internal Combustion Engines, Summary of Public Comments and Responses,”) containing EPA’s responses to each public comment is available in Docket ID Nos. OAR-2002-0059 and A-95-35.   RICE are major sources of hazardous air pollutants (HAP) emissions such as formaldehyde, acrolein, methanol, and acetaldehyde.   This NESHAP will implement section 112(d) of the Clean Air Act (CAA) by requiring all major sources to meet HAP emission standards reflecting the application of the maximum achievable control technology (MACT) for RICE.

Approximately 40 percent of stationary RICE are located at major sources and thus, subject to the final rule.   The final rule will protect public health by reducing exposure to air pollution, by reducing total national HAP emissions by an estimated 5,600 tons per year (tpy) in the 5th year after the rule is promulgated.   The emissions reductions achieved by these standards will provide protection to the public and achieve a primary goal of the CAA.   The final rule is effective August 16, 2004.

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

Regulation Updates to 49 CFR Parts 191, 192, 195, and 199

As part of an effort to periodically update the pipeline safety regulations RSPA has issued a final rule to incorporate most of the recent editions of the voluntary consensus standards and specifications referenced in the Federal pipeline safety regulations.

These changes allow pipeline operators to utilize the most current technology, materials, and industry practices in the design, construction, and operation of their pipelines.  This rule also increases the design pressure limitation for new thermoplastic pipe, allows the use of plastic pipe for certain bridge applications, increases the time period for revision of maximum allowable operating pressure after a change in class location, clarifies welding requirements, and makes various other editorial clarifications and corrections.  This final rule does not require pipeline operators to undertake any significant new pipeline safety initiatives.  For a list of these regulation changes, e-mail Laura Wager or call at 1-888-727-9937.

For more information, contact Gopala K. Vinjamuri by telephone at (202) 366-4503, by fax at (202) 366-4566, by e-mail at, or by mail at U.S. Department of Transportation, RSPA/Office of Pipeline Safety, Room 7128, 400 Seventh Street, SW, Washington, DC 20590-0001.

ISPS Code Compliance Deadline, July 1, 2004

Ports and shipping lines must meet a July 1st deadline for compliance with the International Ship and Port Facility Security Code.  The ISPS Code is a comprehensive, mandatory security regime for international shipping and port operations.  To comply with the regulations, all ships will be subject to a verification and certification audit.  This includes ship security assessments, ship[ security plans, ship security officers, company security officers and certain onboard equipment.  For port faculties, the requirements include port facility assessments and plans, port facility security officers and certain security equipment.  Both ships and port facilities must monitor and control access, monitor the activities of people and cargo, and assure that security communications are readily available.

After July 1st, all vessels must have the ISPS certification or they will not be allowed into any US port.   According to the International Maritime Organization, which is overseeing the regulations, fewer than 20 percent of the world’s ships and 10 percent of global ports had certified that they have made the changes called for by the new rules.  The agency says there are no provisions to grant extensions for countries or shipping companies that need more time.  The penalty for those that don’t comply could be harsh: ranging from a ban on specific ships entering U.S. ports to an all-out trade embargo for a country whose ports don’t meet security standards.  For more information on the ISPS code visit the International Maritime Organization website at:

Development of Class Location Change Waiver Criteria

OPS has announced the criteria that they will use in considering waiver applications submitted by operators of natural gas pipeline segments that have experienced a change in class location. A class location change results from new construction in the vicinity of a pipeline segment and, in the absence of a waiver, triggers a requirement that the maximum allowable operating pressure be confirmed or revised. The criteria matrix provides information and guidance to pipeline operators concerning the specific pipe design and operating parameters within which OPS is likely to consider a class location waiver application to be consistent with pipeline safety. If granted, a class location waiver would allow a pipeline operator to perform alternative risk control activities based on the principles and requirements of the Integrity Management Program in lieu of pipe replacement or pressure reduction.

Class location waiver requests will be processed through the normal case-by-case waiver approval process. Under 49 U.S.C. 60118, OPS may grant a waiver of any regulatory requirement if granting the waiver is “not inconsistent with pipeline safety.” Therefore, each operator submitting a waiver request has the burden of demonstrating that the proposed waiver would not be inconsistent with pipeline safety with respect to the particular pipe in the affected area. Each waiver request is also subject to public notice and comment.   Operators of intrastate pipelines are required to submit waiver requests at the state level.

Shameless commerce announcement: This is an ideal time to review the class locations of all your gas pipeline systems. The professionals at RCP would be glad to assist you with analysis of your pipeline segments and preparation of any waiver requests that are needed. We can handle your aerial photography, mapping, and engineering analysis needs (yes, we are a professional engineering corporation, in addition to being regulatory experts). Contact Laura Wager for additional information, and for a complete copy of the OPS waiver criteria.

RCP Services Spotlight – Pipeline Direct Assessment Services

RCP can provide written direct assessment procedures to comply with DOT 195 and 192 Regulatory requirements for stress corrosion cracking, internal corrosion and external corrosion threats.   The procedures are custom written to meet the individual client needs, threats and operating philosophy in accordance to NACE RP 502, ASME B31.8S and other NACE recommended practices that are currently being developed.   The advantage of utilizing direct assessment is the ability to be performed without affecting the operations of the pipeline and does not require any modification to the pipeline.

  • Custom written integrity management plans – RCP has the tools and expertise to develop comprehensive Integrity Management Plans for both liquid and gas pipelines.
  • 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.
  • HCA Identification Analysis – RCP can provide HCA identification analysis for both liquid and gas pipelines to identify pipeline segments that could affect highly populated areas, other populated areas, ecologically sensitive areas, drinking water and navigable waterways that are defined as high consequence areas by DOT 192 and 195.
  • ICDA/ECDA/SCCDA Plans – RCP can develop comprehensive written stress corrosion cracking, internal corrosion and external corrosion plans to perform direct assessments as an alternative to in-line inspections and pressure tests.
  • Risk Modeling – RCP can provide pipeline risk modeling to address the identified threats for each pipeline segment and the risk prioritization of those pipeline segments to create baseline and ongoing integrity assessment plans.
  • Baseline Assessment Plans – RCP can develop baseline assessment plan for those segments that fall under the High Consequence Area definition.
  • Pre-Assessment Evaluations – RCP can provide pre-assessment evaluations for direct assessment of pipelines.
  • Direct Assessment Inspections – RCP can manage and evaluate direct assessment inspections.

Please Click Here if you would like information on RCP’s Direct Assessment Services   You can also receive a copy of our FREE Integrity Management CD which includes a “Bookmarked” PDF file copy of the new Gas Integrity Management Rule and one of our recent conference presentations “ Preparing for a Pipeline Integrity Management Audit – Covering All the Bases”.

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